NPPF 2 - Changes to Heritage Policy

The proposed draft revised NPPF released earlier this year conserved, for the most part, the heritage policy from the previous version of the NPPF. These preservations have by and large been carried through to the final NPPF released on 24 July 2018 along with some additional welcome amendments.

One of the key amendments is that LPAs are now expected to 'maintain or have access to a historic environment record' (para 187). The guidance states that this should be used to 'assess the significance of heritage assets' and 'predict the likelihood that current unidentified heritage assets […] will be discovered in the future'. Previous wording only required that 'LPAs should have up-to-date evidence about the historic environment in their area and use it to assess the significance of heritage assets and the contribution they make to their environment' (para 169, previous NPPF).

In addition there are changes to the way in which the impact of development on the significance of the designated heritage asset is assessed. The NPPF now confirms that 'when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be).' This method seems to be following case law which has developed over the past few years.

Finally, where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, ‘this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use’. This particular wording was not included in the draft revised NPPF but has been re-introduced from the original NPPF.

In summary, the final NPPF both conserves and enhances the NPPF policy guidance for heritage assets. A key question is whether the changes relating to heritage policy raise any cause for concern? In short, no. As the heritage policy has remained largely unamended from the previous version of the NPPF it will be business as usual for the most part. However, the recent update may serve as a reminder to Local Councils to ensure that they have sufficient evidence recorded about the historic environment and heritage assets in their area and to ensure that this is publicly documented to the required standard. Above all, Local Councils should be careful to consider the importance of the asset in question when determining the impact of a proposed development against heritage policy.