Improving Engagement by Statutory and non-Statutory Consultees (DCLG 2010)
Submission from ALGAO:England/Planning & Legislation Committee
ALGAO is the national body representing local government archaeology services at County, District, Metropolitan, Unitary and National Park authority level. These provide advice to nearly all the District, Unitary and other local government bodies in the country. ALGAO: England co-ordinates the views of its member authorities (106 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association (LGA) on archaeological matters. The range of interests of our members embraces all aspects of the historic environment, including archaeology, buildings and the historic landscape.
The historic environment is vulnerable to change, once destroyed archaeological evidence is lost for ever. Mitigation strategies can be developed for historic assets that are under threat, the broad approach is set out in PPG15: Planning and the Historic Environment (1994); and PPG 16: Planning and Archaeology (1990) – which are to be updated in PPS 15 and its supporting Guidance. Where preservation in situ cannot be achieved, recording of archaeology by excavation or building analysis is possible. The historic environment can make a positive contribution to planning for new development and new communities, and promoting a sense of place, but needs to be assessed and integrated into the planning process from the start of the decision-making process.
Part 2: Questions
Q1 Do you agree with the policy principles guiding the statutory and non-statutory consultation process? Q2 Does the draft policy statement provide a suitable policy framework for statutory and non-statutory consultation? Q3 Are any of the proposed policies too prescriptive? Q4 Are there any important policy omissions?
We strongly support much of these proposals and believe they have correctly identified the issues to improve consultations and the responses to them. Many of our members are placed with County Councils, and provide advice, pursuant to PPGs 16 and 15 (and the consultation draft PPS15) to local planning authorities. We therefore have an active interest in ensuring that the consultation process works effectively.
CON 2, para 14, these criteria have rightly been identified as essential to ensure effective consultation – and thus prompt response. Systematic working by local authorities is essential in this regard, and effective administration to support and implement procedures (both in local authorities and the consultee organisations) a vital component in effective consultation.
CON 4, para 19, we concur with the desirability of pre-application consultation, and encourage it in the case of archaeology (following the intention of PPG 16) and the wider Historic Environment in particular, and promote the practice to prospective developers.
In terms of Historic Environment issues early engagement can be very beneficial both in terms of facilitating development and conservation of the historic environment. Whilst the Historic Environment does not get a specific mention in the consultation draft, however, the aim for improving early consultation will have a positive impact on our work. With charges now being made by most Local Authorities for pre-application meetings there has been a reduction in the number of people willing to do this. This document will encourage people to put more effort into the engagement process, and it will be essential for historic environment issues to be part of that process. In that regard it may well be beneficial for English Heritage to promote the use of Heritage statements in their guidance on the new PPS 15 as that should encourage early engagement with historic environment issues.
CON 9, para 34, we suggest dropping the qualification `statutory’ as some other consultees may also advise the imposition of conditions.
Q14 Use of e-planning
E-planning offers a number of opportunities to speed up planning consultation. Improvements are however needed in the standards of delivery and their implementation. We would particularly raise the need to label files in the supporting documentation to planning applications. This is especially necessary for major applications which may be presented as a series of .pdf files. We have come across up to 50 documents with no labels whatsoever so that finding the relevant sections has been frustrating and time-consuming. It is also important to retain the planning documents, as well as the planning conditions, for a period after the application has been granted, so that advisors to the LPA, and local communities, can be certain that relevant issues have been covered during the construction period.
Robert Whytehead Convenor
ALGAO Planning and Legislation Committee