Draft Planning Policy Statement: Eco-towns (DCLG 2008)
Submission from ALGAO:England
Housing and Growth Programmes
Department for Communities and Local Government
2/H9 Eland House
London, SW1E 5DU
The Association of Local Government Archaeological Officers for England (ALGAO:England) is the national body representing local government archaeology services at County, District, Metropolitan, Unitary and National Park level in England. ALGAO:England co-ordinates the views of its member authorities (93 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.
This response is from the Association as a whole, but individual responses may be received from members who cover the specific proposed Ecotown sites, probably through their respective local authorities.
We welcome this opportunity to comment on the Draft Planning Policy Statement for Eco-towns, which we recognise has a valuable part to play in providing a sustainable form of housing, that will minimise harm to the natural environment whilst delivering valuable housing capacity and new communities.
The historic environment is ubiquitous throughout this country, as it is past peoples who have shaped our landscapes, occupied and managed the land and created its characteristics that can be seen today. This is marked by earthworks, field boundaries and banks and ditches, as well as by specific settlement evidence, such as past farmsteads and special monuments, and historic parks and gardens, ranging through to industrial and military features. These are demonstrative of past communities, and how they previously used and changed the land, and can speak to the proposed new communities, to provide a very real sense of place. Within them may be sites and features, both above and below ground, of great intrinsic archaeological and historic interest.
We appreciate the many factors that must be balanced in the creation of new communities, particularly in the context of sustainability and climate change. However we believe that this policy statement fundamentally undervalues, and fails to appreciate, the historic character of the landscape in which the proposed Ecotowns might fit, and the role they have to play in shaping sustainable development. It is notable that Part 1: para. 3.2 does not select either PPGs 15 or 16 as being of particular relevance to Ecotown planning.
This is evident in Part 1: para. 26, Landscape and the Historic Environment, where, in response to the Sustainability Assessment that clearly advocated decision-making based on a sound evidence base of historic environment characterisation, this important factor in both understanding and fundamental master-planning was discounted as simply a factor to be dealt with in the planning decision-making process. This is in clear contrast to the weight placed on Bio-diversity in the PPS, paras 4.20 and 4.21, which recognised the importance of internationally designated sites, as well as SSSIs, and other local designation. Whilst we would not disagree with this, we would point out that the Historic Environment has designation of similar status, including that of World Heritage Sites, Scheduled Monuments, Listed Buildings, and Registered Parks and Gardens. The European Landscape Convention highlights the need to define and assess landscapes, to understand and thus shape continuing landscape change. The thrust of PPGs 15 and 16 is to establish the importance of historic assets from the start and thus to plan to mitigate the impact on them.
We therefore advocate that, in planning for an Ecotown, comparable strategies to conserve and enhance landscapes and the historic environment should be devised. Developers be guided to seek advice from English Heritage and the relevant local historic environment advisory services, on both designated and undesignated assets, at an early stage in the consideration of such developments. In particular, the Historic Environment should be an essential factor in the preparation of Masterplans.
The proposal to deliver generous green space in Ecotowns (para. 4.18) provides ideal circumstances to preserve significant archaeological sites (whether visible above ground or buried). Such allocation of open space needs to be at an early Masterplanning stage, and thus an understanding of historic assets needs to be gained at an early stage. This understanding can feed into the creation of new communities, their understanding of place, and thus contribute to community cohesion.
Our members would be glad to provide advice, particularly on the archaeological potential of Ecotown sites, and to provide the background information contained in local Sites and Monuments, or Historic Environment, Records to contribute to understanding the historic context in which Ecotowns will evolve.
Q1 Does the draft PPS provide sufficient guidance on the consideration of eco-towns through the plan making process?
No - the approach as laid out in the PPS is fairly scattergun, with some variables discussed (e.g. biodiversity) and others not (e.g. historic environment). The PPS is particularly weak on the historic environment. To be consistent with other PPG guidance, this PPS should advocate the early consideration of the historic environment, the importance of pre-application consultation and evaluation, and that mitigation should favour preservation of nationally and internationally important historic assets, as well as locally valued assets.
Q4.1 No. There is insufficient emphasis on the assessment of impacts. The principles set out in EIA regulations should be followed.
Q4.2 Experience shows that, as advocated in PPG 16, early consideration of the archaeological potential of development sites can save significant costs, particularly from unexpected discoveries at a late stage. This extends to getting Masterplanning right, from the start.
Q5 The Sustainability Appraisal advocates the need for historic environment characterisation to inform understanding of the landscapes in which the proposed Ecotowns will fit, and therefore the Masterplanning of these new communities. We would strongly support this, and wish to see it applied to the individual sites proposed in Q.6, most of which contain known historic assets.
Convenor ALGAO:England Planning & Legislation Committee
16 February 2009