The Chancellor George Osborne and Business Secretary Sajid Javid last week launched the Government’s new productivity plan. The document, entitled ‘Fixing the Foundations: Creating a more prosperous nation’ contains radical new plans to alter the way permitted development for brownfield land could work.
The plan builds on a previous government promise to create a register of brownfield sites which developers could use to easily find sites suitable for new housing. While the Chancellor’s plan is silent on archaeology the proposals could undermine archaeological protections, as they would potentially remove opportunities for sites to be assessed for surviving archaeological evidence as part of the process of applying for planning permission.
Brownfield land often contains highly significant archaeological deposits which would be bereft of protections should the mechanism of permission be removed. The government should be reminded that the recent discovery of King Richard III’s remains was made on a brownfield site, and in 1989 it was the discovery of the remains of Shakespeare’s Rose Theatre on a brownfield site in Southwark which was the case which finally led to the creation of a system for archaeological protections to be made a comprehensive part of the planning system. Any system that would undermine this protection should be judged not fit for purpose and would be against the principles of sustainable development as outlined in the National Planning Policy Framework.
At the current time there are few details on how the proposal would work in reality. The CBA notes that there are caveats within the plan which will be vital in determining how archaeology protections will be preserved under the proposed plans. For instance:
- Only land held within the national register, which is yet to be established, will be eligible for permitted development. How land is assessed for archaeology prior to inclusion in the register is likely to be significant to interpreting how it will affect protections.
- The proposal is for ‘automatic permission in principle’ and would be subject to achieving approval of a ‘limited number of technical details’ – a caveat under which archaeological assessment of the land in question could be included.
The CBA are in favour of reducing the burden of bureaucracy and removing ‘unnecessary planning obstacles’. However the principle of retaining necessary safeguard must be carefully guarded in order to ensure that sustainability is not undermined. This is particularly so where changes are based upon false assumptions that archaeology is a brake on development.
The CBA strongly assert that archaeology is not, in fact, a brake on growth, but rather is a tool which decreases risk for developers by enabling them to prevent unforeseen delays and costs in development which can arise if archaeology is discovered after construction begins. Of course, archaeology also contributes to public benefits such as increased tourism, sense of place, and enhances our knowledge and understanding of our past. Early assessment of the archaeological potential of land within the planning process is beneficial for productivity and must therefore be retained.
The CBA will be discussing the matter with partners in the sector including Historic England and the Heritage Alliance to ensure that appropriate advice is supplied to government on this issue. The CBA will also be writing to the Government in order to set out the potential threats upon archaeology which are implicit in the plans and will aim to ensure that current levels of heritage protection are sustained.