FAME note the government’s plans to support growth and deliver new infrastructure through further proposed reform of the planning system and are concerned over the potential negative impact these could have for the protection of the UK’s archaeological heritage.
Current planning policy places an emphasis on sustainable development, balancing the needs of economic growth with, remedy among other things, the interests of local communities and their interest in protecting and investigating historic and archaeological remains. This balance is achieved through a partnership between local authorities, developers and archaeologists whereby early stage surveys are undertaken to understand impact and so support sensitive design and successful planning applications. Such an approach is part of responsible due diligence whereby essential baseline information helps to identify risks for developers in their management of geotechnical, land quality, ecological or archaeological issues. Where development is likely to harm archaeological remains the potential for this harm is reduced or removed through the use, by local authorities, of pre-commencement planning conditions to manage the protection or recording of those remains.
This partnership and this process has been developed over the past 25 years to ensure that homes and infrastructure get built, to help reduce the budget and programme risk to developers, as well as reducing the risk that the UK’s unique archaeological heritage might be damaged or lost. This is accomplished in large measure by FAME members who deliver substantial public benefit with minimal cost to the taxpayer, whilst also providing employment and contracts for local businesses.
The government proposes to reform the use of pre-commencement planning conditions to address the following objectives:
- To ensure that pre-commencement planning conditions are only imposed by local planning authorities where they are absolutely necessary.
- To reduce excessive pre-commencement planning conditions that can slow down or stop the construction of homes after they have been given planning permission.
- To tackle the overuse, and in some cases, misuse of certain planning conditions, and thereby ensure that development, including new housing, can get underway without unnecessary delay.
FAME would be opposed to any implementation of this agenda where it weakened or reduced the effectiveness of the current policy to deliver a sustainable balance of economic and heritage conservation goals, and where it instead created risks for local communities, developers and archaeological remains. Our position is that in respect of archaeology, the current policy, which has been established over the past 25 years specifically to assist development and reduce public expenditure, works well.
- A proper implementation of the current system already ensures that pre-commencement conditions for archaeological work are relatively rare and are already only imposed where absolutely necessary.
- The current process allows for cost-effective early stage surveys to ensure developers can select sites where there will be no or minimal requirement for conditions, no delay, and certainly no stopping of development.
- Where they are needed, conditions are already designed to mesh effectively with construction programmes with the express objective of reducing risks and delay.
FAME will be scrutinising the detail of the proposals when they are available, and working with our partners in The Archaeology Forum, the heritage sector and more widely with those concerned with the protection of the natural landscape and habitats. Together we will work to ensure the government has the information it needs to fully understand the potentially dangerous, albeit unintended, consequences of its proposed policy changes, and is in the best position to implement change that will both encourage growth and protect our valuable archaeological heritage.