NEW DRAFT GOOD PRACTICE ADVICE FROM ENGLISH HERITAGE

English Heritage have recently produced new draft Good Practice Advice, when finalised this will be highly influential to how local planning authorities deal with proposed changes in Conservation Areas and Listed Buildings. Our Town Planning Advisor looks at the role of this Advice, and considers the likely impact on those wanting to install replacement double glazing?

He challenges whether the draft Advice really does what it needs to do to take onboard the changes introduced in the National Planning Policy Framework and whether it adequately addresses new innovations in design and manufacturer of construction products such as double glazing to offer improved visual appearance and energy performance to meet the ‘carbon challenge’?

The changing nature and role of government guidance
The Coalition Government has introduced many changes to streamline and reform the planning system; the shorter National Planning Policy Framework (NPPF) replaced a whole raft of government endorsed planning policy and guidance that was critical in guiding how local authorities dealt with planning applications.

One of these policy documents was ‘PPS5 Planning for the Historic Environment’, which was in turn supported by a detailed ‘Historic Environment Planning Practice Guide.’

The shorter NPPF and removal of government authored detailed supporting technical advice has arguably left local planning authorities and developers a freer hand, but it has also created a vacuum of authoritative up-to-date detailed advice. This allows greater inconsistency between local authorities and some have clung onto old ‘discontinued’ guidance and attitudes this all means they become increasingly out of date with the latest innovations in new construction products and techniques.

Different specialist organisations are now producing a range of specialist advice to influence and fill this void.

Filling the information gap
The advice offered by English Heritage will highly influential, but nevertheless, it does reflect a particular point of view, for example, about how a proper balance is struck between the need to protect heritage and to allow homes to be affordably adapted to meet the climate challenge.

Such issues are central to the ‘presumption in favour of sustainable development’ introduced by the NPPF. So while the new English Heritage Good Practice Advice may be presented as a replacement for the previous government Practice Guide, will it be properly balanced?

The roles of English Heritage and local planning authorities
English Heritage has a statutory role to promote the conservation and enjoyment of our heritage – in particular for the most important and biggest sites and buildings of interest. Their published advice is influential on the local planning authorities responsible for most Conservation Buildings and Listed Buildings.

Draft Good Practice and Technical Advice – Notes 1 to 3
English Heritage recently conducted consultation Good Practice and Technical Advice in Planning documents. Note 2 Decision–taking in the Historic Environment’ offers advice to local planning authorities on how planning applications are dealt with.

It is anticipated that these will be finalised and published in the Autumn at the same time the joint government / English Heritage prepared Practice Guide is withdrawn. We’re also told these Notes will also be followed by further ‘Technical Guidance’ on a range of topics.

My response made to the consultation documents

As an independent Charter Town Planner working in the field, I responded to the documents with a number of concerns. Overall I was concerned that some important matters appear to have been missed, and at points the advice appears inconsistent with the wording with that of the NPPF. In particular:

What’s missing…
Despite the title, that the Note does not address the “Management of Change” (replacing Part 6 of the previous PPS5 Practice Guide) – this is left to future ‘Technical Guidance’. This part of the advice could include critical detail on attitudes to replacement double glazing versus, say, secondary glazing.

A key issue will be whether it reflects at understanding of the latest innovations in design and slim section PVC-u frames.

The role and responsibilities of English Heritage when offering advice…
English Heritage can have an important influence on those who have not adequately moved-on their mindset from building technologies and materials that have now been vastly improved upon; dating back to the chunky PVC of the late 1990s/early 2000s when much local planning policy was prepared. English Heritage enjoy a privileged and responsible position and should ensure:

(a) Their advice is consistent with the central tenant of the government’s NPPF, that all planning decisions apply the ‘presumption in favour of sustainable development’;
(b) They keep up to date advice in step with latest innovations in construction technology and design;
(c) They help achieve a shift that both addresses the climate challenge with better energy performance and insulation in all buildings; and
(d) They engage with the construction materials industry including the manufacturers of replacement double glazing.

Having considered the documents I find critical failings in all four of these respects.

I consider the draft Advice fails to provide rounded balance or to embrace the changes in the NPPF, and I am concerned at how it reserves the all important detailed advice on the future management of change in historic environment to future Technical Guidance.

We now await the Advice in its final form, and should press at every opportunity to influence the promised Technical Guidance. The detail of this will be critical to encouraging local planning authorities to properly evaluate the benefits of good quality replacement windows.

These views are those of
Michael Thornton MRTPI
Merit Thornton Planning Ltd

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