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Red Tape Challenge: Planning Administration

Red Tape Challenge
Cabinet Office

By email

6th March 2013

Dear Sir / Madam,

Red Tape Challenge: Planning Administration

Thank you for the opportunity to comment as part of the Red Tape Challenge. I am responding of behalf of the Association of Local Government Archaeological Officers: England.

The Association of Local Government Archaeological Officers (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 (92 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, and our stated aims are to:

  • Provide a strong voice for local authority historic environment services and promote these to strengthen and develop their role within local government in delivering local and national government policy
  • Ensure local government historic environment services are included within policy (national and local) for culture and education
  • Ensure that policy aims to improve the sustainable management of the historic environment
  • Promote the development of high standards in the historic environment profession

Planning Administration

ALGAO:England would support the response to this consultation made by the Institute for archaeologists (IfA) on 27th February. We agree with IfA that fit for purpose secondary legislation plays a crucial part in facilitating the efficient operation of the planning regime, in particular with regard to the management and protection of undesignated heritage assets (which represent more than 95% of the historic environment and for which the planning regime is the only means of consideration and protection).

We also agree with IfA that there is clearly scope to streamline and consolidate secondary legislation in the following respects:

  • statutory instruments that have been largely or wholly superseded or have lapsed (see appendix 1). These instruments could be revoked in their entirety or with minor savings
  • statutory instruments that have little or no relevance to the historic environment. We would not object to the revision or revocation of these instruments on historic environment grounds, but there may be other grounds for retaining such provisions (see appendix 2)
  • statutory instruments whose retention is important for the historic environment, albeit in some cases this may be in a consolidated and/or streamlined form (see appendix 3).

We would agree with IfA that the piecemeal way in which statutory instruments have hitherto been revised and updated (whereby the amending statutory instrument requires to be read with the original instrument and any intermediate revisions) is unsatisfactory. For instance, it is difficult, if not impossible, easily to grasp the current nature and extent of permitted development rules in the absence of a single, consolidated document. There is considerable scope for consolidation in this and other areas and future, amending instruments should consolidate the previous provisions.

I hope this response is of assistance but please don’t hesitate to contact me if we can be of further help

Yours faithfully

Fiona Macdonald Chair, ALGAO:England

c/o Berkshire Archaeology Central Library Abbey Square Reading RG1 3BQ

Email: fiona [dot] macdonald [at] reading [dot] gov [dot] uk