The Setting of Heritage Assets: English Heritage Guidance
Date: November 2010
Debbie Williams English Heritage 37 Tanner Row York YO1 6WP
Dear Ms Williams
The Setting of Heritage Assets: English Heritage Guidance (consultation draft)
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 services 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 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.
ALGAO welcomes the proposed guidance on setting which should help our members, local planning authorities, developers, their consultants and the Planning Inspectorate handle development proposals affecting the setting of heritage assets with greater clarity, confidence and consistency than hitherto. We do however have some detailed comments in response to the consultation questions which we hope you will find useful in finalizing the guidance (see italics below):
(1a) Do you consider that this English Heritage guidance on Setting
conforms to the Government’s policies and guidance in the PPS and
Practice Guide? Generally yes, but there needs to be more clarity over how and to what extent setting can relate to the intellectual experience of buried archaeological remains. For example, paragraph 50(e) refers to changes in water quality etc in the surroundings of an archaeological site affecting its significance – whilst a valid point in its own right the effect on the experience of the site is only likely to be felt in the context of some future archaeological investigation.
(1b) If not, can you explain how it diverges? n/a (1c) Do you consider that it will assist implementation of the Government’s new policies and guidance? Yes, we believe the guidance should lead to a more consistent understanding and approach to setting issues thus reducing the risk of professionals presenting fundamentally different interpretations of the concept with the consequent need on occasion for planning appeals to engage in forensic examination of basic principles before considering their case-specific interpretation.
2. The English Heritage setting guidance applies the heritage values approach advocated in Conservation Principles, Policy and Guidance to the consideration of setting.
(2a) Do you think this approach is helpful and that it is successfully achieved within the draft guidance? Yes, however we are concerned that that it is suggested (on page 2) that the intention is to provide for ‘objective’ assessments of setting issues. We question whether it is sensible to use the term in relation to the experience of place, surely an inherently subjective matter? To continue this line of argument we suggest that the guidance gives insufficient attention to identifying the ‘receptors’ (i.e. people/communities) whose experience could be harmed (or enhanced) and, where appropriate, seeking their opinions. Such an approach would accord with the concept of ‘communal values’ espoused in Conservation Principles and policy HE7.3 of PPS5 relating to community consultation. For example it would be possible to consider whether a site had (or could potentially have) a role in recreation or tourism.
As noted above, the application of the term ‘setting’ to buried archaeological sites and battlefields needs further consideration with worked examples showing how a proposed change might affect the experience of place.
(2b) If not, what alternative approaches would you suggest? n/a
3. The English Heritage setting guidance is intended to cover a wide range of circumstances, from large scale infrastructure projects to more common types of development and for initiatives such as conservation area management plans. We have drafted our guidance to cover the generality of setting issues applying to such circumstances. We have avoided additional technical guidance specific to particular types of development such as tall buildings and wind turbines, as this is included in the specific guidance we offer on these development types.
(3a) Do you agree with this approach and, if so, have we struck the right balance to ensure our draft guidance applies to the majority of circumstances? Broadly speaking yes, although there are several areas which would benefit from further examples (see 3b).
(3b) Are there additional issues that you consider should be included in specific guidance on particular kinds of development? It would be useful to add examples relating to smaller scale development, incremental impact, undesignated assets and ‘invisible’ assets. The single paragraph on enhancement could be strengthened, for example by reference to green infrastructure strategies and examples. In practice some developments offer a mix of harm and enhancement (the latter sometimes perceived as offsetting ‘sweeteners’) – for example new housing near an historic site might harm the setting but also improve access to the asset - guidance on such cases would be helpful.
4. In Section 3 (paragraphs 42 to 62) of the draft guidance we set out, as an assessment framework, issues that we consider may need to be taken into account in assessing the impact on the significance of a heritage asset of changes within its setting. (4a) Do you agree that these are the correct factors to consider? Generally yes, although more prominence could be given to considering the character of the proposed change in relation to the character of the asset itself and its surroundings. Thus for example a disused airfield or military base of high historic interest might have more capacity to absorb certain types of major built development within it than most other types of heritage asset. This would also be an important consideration in relation to design.
We were disappointed that there was no mention of Historic Environment Records in paragraphs 44-46 as a source of information for understanding setting. Developed HERs contain historic landscape and urban characterisation studies as well as reference to conservation areas and other research such as conservation plans, local and academic studies which would be relevant to consideration of setting. There are of course other relevant sources which could be summarised in a new appendix. Mention should also be made of considering setting in heritage statements and desk-based assessments undertaken in connection with PPS5.
(4b) If not, can you suggest which factors should not be considered or which additional factors should be? With respect to archaeological monuments where the historic use has long ago ceased and now lie in tranquil surroundings, it would normally be undesirable to pursue a line of argument which stressed the activity and noise of past uses as a justification for intrusive development (e.g. an upland mining site in a National Park). We therefore suggest that paragraph 50d needs rewording and also the addition of a paragraph covering ‘monuments’ preserved for their own sake as memories of the past not in active use, other than perhaps for recreation or tourism. Some mention of the relevance of protected landscape designations would also be desirable. (4c) Do you agree that the questions posed in paragraph 49 are a helpful way of structuring the assessment framework? Yes.
5. In paragraphs 55 to 58 of the draft guidance we discuss the issue of cumulative impacts in relation to setting. (5a) Do you have views on the practicality of the approach suggested in paragraph 58? We would particularly welcome views from Local Planning Authorities. We believe this approach should be encouraged. Furthermore, we suggest that significant cumulative impacts on setting should be considered within SEA of Development Plans.
6. In Appendix 1 of our guidance (paragraphs 63-74), we provide illustrated examples of how setting can contribute to the heritage values and significance of a heritage asset, structured around a range of questions. These are not intended to provide examples of good or bad development within the setting of an historic asset, but rather to illustrate how an analytical approach to setting can provide better understanding. (6a) Do you think this approach is helpful? Yes (6b) Do you have comments on the appropriateness and usefulness of any particular example? As noted above, it would be useful to add examples relating to smaller scale development, incremental impact, undesignated assets and ‘invisible’ assets. Also more emphasis would be desirable on how development can be located and designed in a manner which does conserve or enhance setting.
I trust you will find these comments helpful.
Alexander (Sandy) Kidd
Buckinghamshire County Council