In recent years, archaeologists have benefited greatly from a planning regime that requires developers to undertake an environmental impact assessment as part of the consent process. Archaeological, conservation, and planning officers working in local government (known in planning jargon as the ‘curators’) have the power to require developers to protect significant heritage assets, or pay for their excavation and recording if that is not possible.
Some local authorities have been better than others in exercising these curatorial responsibilities, but the system is generally accepted by all concerned. The central governments of the four UK nations have set a good example, with substantial investment in archaeology ahead of power station, pipeline, railway, road, and airport construction. You might not agree with the decision to build HS2, but nobody can say the Westminster government has stinted on the archaeology.
Change is in the air, however, and the profession is nervous. In August 2020, Westminster published a consultation paper called ‘Planning for the Future’, which, according to the Prime Minister, proposes ‘radical reform unlike anything we have seen since the Second World War’. This sets out new rules for the Local Development Plans (LDPs) that local authorities in England are required to draw up as a guide to planning decisions.
In the future, LDPs will identify land under three categories: ‘growth’ areas where outline planning consent is assumed to have been granted; ‘renewal’ areas suitable for specific kinds of development (the White Paper suggests ‘gentle densification’); and ‘protected’ areas where development will be subject to the current raft of planning controls. It is expected that the majority of the land identified by LDPs will be in the growth category and that these will be large tracts of land, able to accommodate predicted housing needs for decades to come.
The White Paper stresses that LDPs should be produced to a standard template, mainly consisting of lines on a map, with text limited to setting out ‘site- or area-specific parameters and opportunities’. Decisions will be ‘rules based’ rather than at the discretion of the planning committee, and they will no longer include a ‘long list of “policies” of varying specificity’.
A ‘fast-track for beauty’
In an interesting twist, plans will also ‘ask for beauty and be far more ambitious for the places we create, expecting new development to be beautiful, and to create a “net gain” not just “no net harm”,’ with a greater focus on ‘place-making’ and ‘the creation of beautiful places’ within the National Planning Policy Framework. This will ‘make it easier for those who want to build beautifully through the introduction of a fast-track for beauty through changes to national policy and legislation, to automatically permit proposals for high-quality developments where they reflect local character and preferences.’
‘Beauty’ will be achieved through ‘the establishment of a new body to support the delivery of design codes in every part of the country’. Design codes are ‘to be prepared locally and to be based on genuine community involvement rather than meaningless consultation, so that local residents have a genuine say in the design of new development, and ensure that codes have real “bite” by making them more binding on planning decisions.’ In addition, every local planning authority is to appoint a ‘chief officer for design and place-making, to help ensure there is the capacity and capability locally to raise design standards and the quality of development’.
The White Paper thus has a very considerable tension at its heart. One the one hand, there is the Cummings- esque desire for a rules-based system, for ‘streamlined decision-making’ and for a ‘radical, digital-first approach to modernise [sic] the planning process’. On the other there is the Simon Jenkins and Fiona Reynolds agenda: the former Chair and Director-General of the National Trust have campaigned constantly for ‘beauty’ to be put at the heart of the planning system, in place of economic goals. But ‘beauty’ is hardly a well-defined concept: modernists and traditionalists have been at blows over this for decades. It is certainly not susceptible to rules that can be analysed by government algorithm. Sherds predicts endless arguments about what constitutes beauty or local character and numerous legal challenges questioning whether any particular development meets beauty criteria (lawyers will be the winners every time).
The devil in the detail
The White Paper contains numerous references to environmental and heritage assets and promises to maintain existing levels of heritage protection. So why are professionals concerned? First, it is by no means clear that these protections will apply to the ‘growth’ and ‘renewal’ zones. Equally, it is not clear whether ‘existing levels of heritage protection’ refer exclusively to formally designated assets. As every archaeologist knows, listed buildings and scheduled monuments represent the tip of the heritage iceberg, which is why we need a detailed assessment of a site’s potential heritage significance rather than a blanket presumption that the lack of a formal designation means the land has no ‘archaeological contaminant’ (as it was once described by a hostile local authority chair).
Second, the focus on ‘clear rules rather than general policies’ removes the discretion that curators and planning committees currently have to consider the impact of developments on a case-by-case basis: one size definitely does not fit all when it comes to England’s richly varied historic landscape.
And third, at a time when local authority budgets are under huge strain, it is feared that the proposed apparatus for raising design standards will take resources and attention away from conservation and archaeological services, which have already suffered a 35 per cent decline since 2006. Buckinghamshire Council, for example, supports in principle the suggestion that each local authority should have a place-making officer, but asks how this new burden on local authorities is to be resourced.
There is also very real concern that design codes could stifle architectural innovation and result in pastiche vernacular or historicism (imitating the styles of past eras). As Buckinghamshire again points out, it will be an ‘uphill struggle’ to persuade housebuilders to reflect local design preferences, given that their business model is so heavily tied to the use of standard house-types. Will they simply slap a thin veneer of local stone or roughcast plaster on what are essentially breeze-block structures with plastic windows on overcrowded and garden-free housing estates?
A hint of arguments to come is found in the Barratt Homes response to the White Paper, which says ‘it is important that house builders are involved in the process of producing design codes’ and ‘house builders and developers are generally best placed to determine the most appropriate design approach and product for a site and taking account of constraints, opportunities, and customer aspirations’. Such statements conflict with the idea of democratic local input, but then so does the White Paper’s ominous reference to a ‘National Model Design Code’.
Greenfield or brownfield?
Finally, the White Paper reads as if the only development opportunities of the future will occur on greenfield sites, and this is already fuelling speculative increases in land value in prime parts of England, as well as raising concern for green-belt protection. Only passing reference is made to the COVID-19 pandemic and the lasting impact of working from home and online shopping. There is no acknowledgement that the place-making agenda is about to change fundamentally, because very large numbers of shops, office blocks, and retail parks are going to be redundant from now on. Making good use of these brownfield sites could easily solve the housing problems that the White Paper explicitly sets out to tackle, and ignoring this makes the White Paper backward-looking and seriously lacking in engagement with the real issues.
In fact, the whole White Paper reads like a hastily dictated exercise in hyperbole. It is fervid, repetitive, ungrammatical, and ill-thought-out. Dashed off it might be, but the statement that ‘we want to make rapid progress toward this new planning system’ suggests a top-down approach and decisions already made rather than a genuine consultation. If so, the White Paper has the potential to do a lot of harm when what is needed is a frank and honest look at what is good in the planning system and what needs to change.