English Heritage, working closely with a drafting group from the Historic Environment Forum (including representatives of IfA), has produced draft Historic Environment Good Practice Advice Notes 1-3 for consultation. These notes cover the historic environment in local plans, decision-taking in the historic environment and the setting of heritage assets. They are intended to assist local planning authorities, planning and other consultants, owners, applicants and other interested parties in implementing historic environment policy in the National Planning Policy Framework and the related guidance given in the recently-published Planning Practice Guidance.
IfA, in its response to this consultation, particularly welcomed
- the clear articulation in the Notes of the respective responsibilities of local planning authorities and applicants in relation to heritage assets with archaeological interest
- their recognition of IfA standards as the accepted industry benchmark of good, proportionate practice designed to secure the best outcomes for both developers and the public
- the inclusion of modern, fit-for-purpose model conditions relating to archaeology in Good Practice Advice Note 2.
Nonetheless, some concerns do remain as to the detail of the Notes, particularly with regard to the introduction in Good Practice Advice Note 2 of the concept of ‘limited harm’ to the significance of heritage assets. There is real concern that the concept of ‘limited harm’ will in practice be interpreted so as to avoid taking steps to advance our understanding of the past (such as recording) in any but the most severe cases approaching total loss.
A full copy of the IfA response can be found here. If you would like to know more about IfA’s involvement in the development of this good practice advice please feel free to contact Tim Howard at tim.howard [at] archaeologists.net
