On Friday 23 September, the UK Government published its ‘mini-budget’. The proposals included in this ‘fiscal event’ have added to a complex landscape of policy reform under Liz Truss’ new-look Government.
These various policies (mostly relevant only in England) are interlinked and subject to a high degree of uncertainty in the short term. This e-bulletin sets out how CIfA is engaging with all relevant issues, and what you need to know about the policies.
CIfA is following the situation surrounding all aspects of these policies closely, as well as talking to advisors within CIfA’s membership, and with other organisations in the historic environment sector.
The full understanding and impact of these various policy areas on the historic environment will not be known in the short term, but we will be pursuing answers with Civil Servants in DLUHC and DCMS over the coming weeks and months.
CIfA is part of the Better Planning Coalition, a collection of 29 organisations which includes the RSPB, National Trust, Woodland Trust, Wildlife Trusts, Shelter, Sustrans, TCPA and Wildlife and Countryside Link. CIfA will be taking part in joint advocacy with the Better Planning Coalition where appropriate, in the coming weeks, including at a reception with Parliamentarians hosted by the Coalition in Westminster, in November. CIfA will also be contributing to joint advocacy with the Heritage Alliance.
As part of the Growth Plan, announced on 23 September, the Government outlined proposals for new ‘Innovation Zones’, which would be specific sites where a “variety of tax, regulatory innovations and flexibilities, and planning simplifications will apply within those site’s boundaries”.
These sites are designed to speed up planned development and simplify new opportunities, reducing “many of the burdensome requirements which has made the planning of large sites slower and more complex than it should be, to enable developers to bring forward good quality development which responds to the market”.
DLUHC have stated that;
“Key planning policies to ensure developments are well designed, maintain national policy on the Green Belt, protect our heritage, and address flood risk, highway and other public safety matters - along with building regulations - will continue to apply.”
However, it is not clear how this will be assured as they seek to
“remove burdensome EU requirements which create paperwork and stall development but do not necessarily protect the environment; focus developer contributions on essential infrastructure requirements; reduce lengthy consultation with statutory bodies; and relax key national and local policy requirements.”
These ‘burdensome’ requirements include Environmental Impact Assessment (EIA), which the Government has been promising to reform EIA for some time, with proposals in the Levelling-up and Regeneration Bill already proposing revised ‘Environmental Outcome Reports’ (EOR) to replace it. Forthcoming discussion of what EOR will entail is expected in the future. The new plans to bypass EIA in Investment Zones will require a different conversation, and we will expect to look very closely at details when they emerge, alongside partners in the natural environment.
It should be stated that natural environment regulations, like the Habitats and Birds Directives, are explicitly threatened by the proposed policy, and as such natural environment bodies have responded angrily to the announcement over the past weeks. The Historic Environment is not similarly targeted by the reforms on paper.
However, in the past we have seen problems arise when Government has sought to ‘radically streamline’ planning applications. This type of harmful deregulation was a core aspect of CIfA’s concern with the ‘Development Areas’ proposed in the Planning White Paper. The potential concern is similar for Investment Zones; that removing many of the steps associated with traditional planning application, the expected process of archaeological assessment could be disrupted and become less effective.
CIfA has extensive evidence from the Planning Case Studies project that shows how any why these processes of archaeological assessment and management work, and we will be raising this evidence and asking to discuss issues with Government in the coming weeks.
Levelling-up and Regeneration Bill
We expect work on the Levelling-up Bill to continue, and the Commons Bill Committee scrutinising the draft legislation has sittings through October and into November. However, we do not yet know what else may get added to the Bill by Government.
As far as CIfA is aware, there has been no opposition voiced to the provision to make HERs a statutory requirement in the Bill. However, it is possible that the Bill’s passage through parliament becomes strained if political disagreement ensues over other parts of the Bill.
CIfA will be contributing to briefings for Parliamentarians ahead of the Bill being discussed in the Lords. A date for this is not yet known.
Environmental Land Management
Also in the news around the ‘mini-budget’ was the rumour that Government was rethinking its approach to the post-Brexit agri-environment schemes that have been being developed by DEFRA for the past five years. The proposed approach would have given more money to farmers in return for the delivery of environmental benefits, and less flat payment for acreage.
Some work had already been done to update options for historic environment works within the emerging ELM scheme, but even prior to the Government’s most recent announcement, heritage had been de-prioritised within the scheme.
Recent news that the whole process is now at least paused for reflection is concerning, and CIfA will be working with colleagues through the Heritage Alliance Rural Heritage Advocacy Group to influence any review and to revive interest in ensuring that historic features are recognised as relevant assets in agricultural land management.
Other planning changes
The Chancellor’s Growth Plan and Investment Zone announcement also included promises of more planning reform to come in the future. It is not clear what this may be hinting at, but it was already expected that a vision statement for revisions to the National Planning Policy Framework would be published in the summer, and this was delayed due to the leadership changes. It is unclear when this review process will proceed and whether the proposals will be the same.