of 5,000 signatures
To The Secretaries of State for: Communities and Local Government; Environment, Food and Rural Affairs; and Digital, Culture, Media and Sport; Leaders of Local and Regional Authorities; and City Mayors
An Open Letter authored by drp archaeology and Minerva Archaeology on ensuring the protection of archaeology for future generations within Planning for the Future
We, the undersigned, are calling on the Westminster Government, Regional and Local Authorities and city mayors to ensure the protection and enhancement of the archaeological heritage, and thus the historic environment and heritage in England, for future generations, and to recognise their inherent role in contributing to inclusive communities, placemaking, identity making and education across the country. These considerations have a vital role to play in sustainable development and each of its three core domains of economy, society and environment. This government must not only ensure that existing protections remain in place but also seek to be progressive in enhancing its significance within planning.
There is considerable concern in the archaeology and heritage sector that the recently published Planning for the Future White Paper places a significant potential threat to the protection and enhancement of the historic and natural environments through its:
• Lack of direct reference to archaeology;
• Promotion of decision making by algorithm;
• Potential to reduce opportunities for archaeological investigation, or limit it to mitigation only;
• Reduction of the historic environment to arbitrary circles on maps;
• Movement from a discretionary system of planning to a blanket rules-based system;
• Indications that government could remove historic environment matters from Environmental Impact Assessments;
• Sidestepping of predetermination requirements for archaeological desk based assessments and heritage statements;
• Scrapping of Section 106 Agreements; and
• Complete lack of acknowledgement of non-designated heritage assets.
Some of England’s most significant heritage is already at risk, with Historic England’s Heritage at Risk Register publishing 5,097 entries in 2020 alone that have been lost ‘as a result of neglect, decay or inappropriate development’.
The clear emphasis on housing as a national priority, which this paper attempts to address, is welcomed. However, its bias towards reducing perceived environmental regulatory barrier in order to achieve this outcome is both misplaced and negligent. It is therefore vital that as part of an integrated sustainable development approach, as promoted in the Planning for the Future White Paper, that government acknowledges the value and significance of the historic and natural environments.
We recognise that the White Paper provides opportunities for the archaeology community that should be explored and if necessary promoted. Its promotion of national integrated digitisation, Climate Change responsibility, simplification of economic funding streams and its overarching goal for the creation of “beautiful places” where people want to live are just some of the areas where archaeology could be proactive.
The haste in which these wide-ranging reforms are being promoted may lead to irreversible damage to the historic environment. Now more than ever, we need to ensure that reactive policies after an unprecedented series of events in 2020 do not inadvertently destroy our heritage.
Our proposals needed to protect and enhance our historic environment
We call on the Westminster Government, Regional and Local Authorities, and mayors, to:
• Acknowledge the importance of historic environment evidence and data produced and assessed in advance of determination for providing certainty, clarity and risk reduction for development, while acknowledging the need for national, regional and local consistency in the approach for achieving and thus improving efficiency. Such a policy will reduce the risk of both cost and delay to development.
• Ensure the historic environment, as with the natural environment, is promoted to primary national legislation with the creation of a Heritage Act as already observed in the devolved nations in order to ensure heritage is at the core of sustainable development.
• Honour existing internationally signed conservation conventions including the Paris Convention (1954), World Heritage Convention (1972), Granada Convention (1985), Valetta Treaty (1992) and Florence Convention (2000).
• Ensure, regardless of the proposed new zones of Growth, Renewal and Protection, that archaeology will continue to play a vital role during both the assessment of and mitigation for development within all three areas.
• Ensure that zones designated for Protection include not only all existing statutory protected heritage assets (World Heritage Sites, Scheduled Monuments, Conservation Areas, Listed Buildings) but are extended to include Registered Parks and Gardens, Registered Battlefields, Ancient Woodland, existing Areas of Archaeological Importance as defined in the Ancient Monuments and Archaeological Areas Act 1979 (Part II) as well as Local Authority Areas of Archaeological Significance.
• Reappraise the Areas of Archaeological Importance. As of 2004 only five historic urban centres held this designation: i.e. Canterbury, Exeter, Chester, Hereford and York.
• Ensure that planning by algorithm does not result in planning by automation thus removing expert Local Planning Authority archaeological advice in person from the equation.
• Ensure, in line with the proposal for a fully nationally integrated, publicly accessible and user-friendly digital platform, that our proposal is followed for the wholesale national digitisation of the Historic Environment Record, accessible on a standardised platform with a publicly user-friendly interface and interpretation of the metadata generated from archaeology work.
• Make this data accessible from any smart device and available in all public libraries which will be both state-funded and administered. This will ensure the results of our public legitimated archaeological work are fully demonstrated and accessible to the public.
• Recognise the role archaeology research can offer Climate Change mitigation and adaptation strategies for consideration in land use planning reform.
• Acknowledge the contribution that archaeology can bring to the carbon reduction agenda, as recently acknowledged by the United Nations seventy-fifth General Assembly on Cultural Rights (2020) and the International Panel on Climate Change (IPCC) publication A primer for archaeologists (2020).
• Acknowledge existing buildings, particularly historic buildings, as part of our solution towards a net zero agenda and support their maintenance through removing VAT on repairs and other fiscal incentives.
• Ensure that Design Codes include alternative pathways to improved eco-friendly construction techniques, which currently contribute to approximately 33of GHG and damage below ground heritage assets.
Environmental Impact Assessments/Desk Based Assessments/Heritage Statements
• Acknowledge that the historic and natural environments are not isolated domains but part of an overarching environmental ecosystem that rely on one another and that to remove historic environment assessments from this process will be detrimental to the objective of planning reform to achieve place-making, identity-making and beautiful places.
• Recognise that archaeological excavation is a destructive process and that all effort should be made to reduce this destruction through prior risk assessment, ultimately saving delays and costs to developers.
• Acknowledge that such assessments could be digitised and standardised nationally with accessible data through a nationally digitised HER. This would ensure efficiency and standardisation, providing greater clarity for development and archaeology.
New Infrastructure Levy
• Acknowledge the Polluter Pays Principle as a fair and just means for compensating for the destruction of irreplaceable heritage.
• Recognise that “Cultural Infrastructure” is as much a part of “Infrastructure” as “Physical Infrastructure”.
• Ensure therefore that adequate funds are collected and distributed for the explicit purpose of protecting, conserving and enhancing our historic environment and cultural infrastructure, through statutory developer contributions.
• Further, in line with the ambitions of the Planning for the Future White Paper, recognise that the current system of funding archaeological investigation in planning through competitive tendering creates an imbalance between the requirements of economics and the environment leading to inefficient planning and blurred focus.
• In support of a new planning system, the new Infrastructure Levy should seek to directly fund all planning-led archaeological investigation.
• Acknowledge that planning reform should and could do more to allow for public participation and local democracy in issues related to the historic environment, both at the plan-making stage and decision-taking stage. Providing greater emphasis on the local historic environments through archaeology will help to create identity and community.
Minerva Archaeology Ltd
Midland Archaeological Services
North Hertfordshire Archaeological Society