PLANNING AND WORLD HERITAGE

POSITION STATEMENT

OCTOBER 2018

Picture courtesy of Historic Royal Palaces

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CONTENTS

Page

1. Background 2 2. Planning Issues A. National planning policies 4

B. Heritage Impact Assessments 8 C. Settings and buffer zones 9 D. Local plan policies 10 E. Development management 11 F. Monitoring 12 G. Engagement of World Heritage Site managers and steering groups

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H. A Planning guide/training 13 3. The role of UNESCO-related advisory bodies in the UK’s planning systems

A. UNESCO and its advisors – roles, responsibilities and accountability

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B. The reactive monitoring process 14 C. Timescales and delegation 15 D. Plain language 16 E. The protection of sites and the public benefit of development 16

4. Central government and devolved administrations

A. Responsibilities 18 B. Timing and transparency issues 19 C. National infrastructure projects 19 D. Crown estates and licensing for offshore windfarms 20

E. Resources 20 5. Local authority issues A. The need for a better

appreciation of the significance of World Heritage Sites

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B. Training 22 C. Resources 23

6. Issues relating to World Heritage Site steering groups and managers

A. Clarification of how World Heritage Site steering groups and managers should be involved in the planning system

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B. Good practice on involvement in the planning system 25

C. The use of management plans 26 D. Good practice guide on councillor support 26

E. Resource issues 26 Appendix A - Abbreviations 28 Appendix B – Actions and responsibilities

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1. BACKGROUND 1.1 As a State Party to the World Heritage Convention, the United Kingdom is required to protect, preserve, present and transmit to future generations its World Heritage Sites (WHSs). It does this primarily through its planning systems. The systems set planning policy contexts and manage development proposals. They are complex. Planning policy is determined by several levels of government from national to local. Development management is done mainly at local level, but sometimes centrally. Many bodies and organisations, as well as the public, are involved in the democratic decision-making processes. For WHSs, advisory bodies to the United Nations Educational, Scientific and Cultural Organisation (UNESCO) may also become involved, adding to the complexity. 1.2 On 8th March 2017, World Heritage UK (WH:UK) arranged a workshop “Planning for World Heritage Sites – Dovetail or Disconnect”. The aim of the workshop was to equip WHSs practitioners with a better understanding of the UK’s planning systems and to explore with them how well the systems support the protection and conservation of the sites. The final part of the day gave attendees the opportunity to suggest how the systems and their operation might be improved. 1.3 The workshop was entitled ‘Dovetail or Disconnect’ to recognise the dependence of the protection of UK WHSs on the planning system. It was also recognised however that the inter-relationship of the UK planning system and the UNESCO Operating Guidelines was not without problems. In the last decade, the UK has been the subject of numerous UNESCO ‘reactive missions’, such as those visiting Sites such as the City of Bath, the Old and New Towns of Edinburgh, Liverpool – Maritime Mercantile City, the Palace of Westminster and Westminster Abbey including Saint Margaret’s Church, Cornwall and West Devon Mining Landscape, the Giant’s Causeway and Causeway Coast and Stonehenge, Avebury and Associated Sites. It was a development (planning) issue at the heart of each of these missions. This is a clear indication that all is not well. 1.4 This document draws together the findings of the day and subsequent reflections. In particular, it: • sets out WH:UK’s views on a number of issues regarding the effectiveness of the

UK planning systems in protecting and conserving the nation’s World Heritage Sites

• considers how better to integrate into the planning systems the advice and comments from UNESCO-related World Heritage advisory bodies

• considers how other key organisations involved with WHSs (specifically central government and its advisors, local authorities and World Heritage Steering Groups and Managers) can improve their effectiveness in engaging with the planning systems.

1.5 This document suggests many actions arising from the comments that were made at the workshop. These are set out after each section and drawn together in the appendix. The actions are ambitions and, given the resources available to WH:UK and its partners, not promises. 1.6 The views set out here are made on behalf of WH:UK, and are not necessarily those of any representatives of any Site, member organisation or individual member.

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1.7 A list of the abbreviations used in the document is set out at Appendix A on page 28.

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2. PLANNING ISSUES A. National Planning Policies 2.1 Each of the four countries that comprise the UK has its own planning system, yet state party responsibilities are not devolved. So the question was raised as to whether it would be better to have a consistent approach to planning policy in relation to WHSs, particularly at national level, across the whole of the UK. There is currently considerable variety in approach, as the following sections demonstrate. 2.2 The focus of these sections is on the principal national planning policy documents in each of the four UK countries. They do not consider in depth any supporting or related documents produced by the national governments or their agencies. Some of these documents have been updated since the workshop and may address some of the issues raised. England 2.3 UNESCO WHSs are not included in any primary planning legislation (Acts). The National Planning Policy Framework for England (NPPF) contains policies for the protection and conservation of the historic and natural environment, including WHSs. At the time of the workshop, the 2012 NPPF was in force. It has subsequently been revised and WH:UK submitted comments on the Draft version. The principal concerns expressed at the workshop related to wording that is very largely unchanged in the revised NPPF issued in July 2018, and the newer wording is referred to below. Planning Practice Guidance on Conserving and Enhancing the Historic Environment (2018) also addresses WHSs. 2.4 The NPPF sets out the national policy approach to WHSs. Of particular concern to workshop participants were paragraphs 132 and 133 of the 2012 NPPF (paragraphs 193 to 195 in the 2018 NPPF). Paragraph 194 of the NPPF states that “Substantial harm to or loss of…assets of the highest significance, notably…World Heritage Sites should be wholly exceptional”. Paragraph 195 continues: “Where a proposed development will lead to substantial harm to (or total loss of significance of) a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply: ● the nature of the heritage asset prevents all reasonable uses of the site; and ● no viable use of the heritage asset itself can be found in the medium term

through appropriate marketing that will enable its conservation; and ● conservation by grant-funding or some form of not for profit, charitable or

public ownership is demonstrably not possible; and ● the harm or loss is outweighed by the benefit of bringing the site back into

use. “ 2.5 Workshop attendees asked for a definition of “wholly exceptional” and “substantial public benefits” and whether precedents had been set that would assist in the understanding and application of these terms. WH:UK suggests that it is time to review how these paragraphs of the NPPF have been interpreted and whether precedents have been set. This review would be informed by analysis of a list of permissions and refusals of planning permission where substantial harm or total loss of a Site would have resulted from the proposed development.

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2.6 The NPPF approach to balance harm against public benefit can be seen to be at the heart of any dis-connect between the UNESCO World Heritage Convention/Operational Guidelines and the UK planning system. The UNESCO documents refer to how the Outstanding Universal Value (OUV), including integrity and/or authenticity, should be sustained or enhanced over time. They do not make any allowance or set any conditions whereby harm may be acceptable. Where change is inevitable and frequent, notably in the case of urban centres, this can cause problems. Paragraphs 3.13 and 3.14 of this paper explore this further. 2.7 Finally the NPPF fails to recognise that England has one natural World Heritage Site (the Dorset and East Devon Coast), which should be addressed in Chapter 15 – Conserving and enhancing the natural environment. WHSs are mentioned only in Chapter 16, which addresses the historic environment. WH:UK regrets that this issue was not addressed in the 2018 version of the NPPF, although it was pleased to note that WHSs have been awarded a higher profile than previously. Northern Ireland

2.8 Northern Ireland currently has one WHS – the Giant’s Causeway and Causeway Coast. In recent years there has been some improvement to the protection in planning policy afforded to the WHS designation. A new ‘Strategic Planning Policy Statement’ (SPPS) was published in September 2015.

2.9 The relevant policy states:

(Para 6.6) 'Development that would adversely affect the Outstanding Universal Value of a World Heritage Site or the integrity of its setting must not be permitted unless there are over-riding exceptional circumstances.'

(Para 6.7) ‘Inclusion of a World Heritage Site on a list published by UNESCO highlights the outstanding international importance of the site as a material consideration in the determination of planning and listed building consent applications, and appeals. Planning authorities must carefully consider applications affecting the Outstanding Universal Value of such sites, particularly taking into account the safeguarding of critical views to and from the site, the access and public approaches to the site and the understanding and enjoyment of the site by visitors.’

Para 6.29 states that it will be appropriate for a Local Development Plan covering an area with a WHS to ‘identify the site and its broader setting and to include local policies or proposals to safeguard the Outstanding Universal Value of such sites and their settings from inappropriate development’.

2.10 The SPPS represents a significant improvement on the previous Planning Policy Statement 6, which simply stated that ‘special consideration’ should be given to developments within a 4km radius of the WHS.

2.11 However, in a context where the Giant’s Causeway and Causeway Coast WHS has faced a number of significant planning challenges in recent years, it is important to note that the robustness of the new policies has not yet been tested. In addition, following a call for further evidence the then Minister for Infrastructure announced a review of the SPPS policies on development in the countryside and

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renewable energy in September 2016. Given the current absence of the NI Executive, the outcome of this review is not yet known.

2.12 There have also been a number of other changes to the delivery of planning policy in Northern Ireland. Local government was reorganised and new, larger, local authorities came into effect in April 2015. Responsibility for local development planning and development management transferred from central government to the new local councils for the first time since 1973, with locally elected councillors now at the heart of the planning process. The SPPS will not be given full effect until the two tier planning system in Northern Ireland is fully operational, when there is a full suite of new Local Development Plans in place.

Scotland

2.13 There are two national documents that set out the Scottish Government’s planning policies – Scottish Planning Policy (2014) (SPP) and the National Planning Framework (NPF). 2.14 SPP is the Scottish Government’s policy on how nationally important land use planning matters should be addressed across the country. It carries significant weight in the preparation of development plans and is a material consideration in planning decisions.

2.15 With regard to WHSs, the SPP states, in the section on Valuing the Historic Environment: “147. World Heritage Sites are of international importance. Where a development proposal has the potential to affect a World Heritage Site, or its setting, the planning authority must protect and preserve its Outstanding Universal Value.” There is no equivalent mention of WHSs in the section on Valuing the Natural Environment, although paragraph 196 states: “International, national and locally designated areas and sites should be identified and afforded the appropriate level of protection in development plans. “ The list of international designations included in this section does not include WHSs.

2.16 The NPF is a long-term strategy for Scotland. It is the spatial expression of the Scottish Government’s Economic Strategy, and of its plans for development and investment in infrastructure. The NPF identifies national developments and other strategically important development opportunities in Scotland. Statutory development plans must have regard to the NPF, and Scottish Ministers expect planning decisions to support its delivery. 2.17 Given the economic significance and potential of WHSs, there is surprisingly little reference to them in the NPF. There appears to be no reference to the Sites of Edinburgh Old and New Towns, the Forth Bridge or New Lanark. On the other hand, Paragraph 4.27 of NPF3 states: “Rural Scotland provides significant opportunities for tourism, outdoor sports and recreation, as reflected in VisitScotland’s National Tourism Development Framework, which development plans and planning decisions should support. Scotland’s two National Parks are exemplars of sustainable development and growth based on environmental assets and natural resources. World Heritage Sites, geoparks, biosphere reserves and dark skies parks are distinctive assets …” while paragraph 4.32 states: “…The Crinan and Caledonian canals are important assets, as are the World Heritage Sites in Orkney and St Kilda – and those included on the tentative list of sites for nomination in Caithness and Shetland…“

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2.18 The view was offered that this policy context is sufficiently robust. By their nature, policies can be interpreted in more than one way. Rather it is the support on the ground (governance, strength of partnerships, wider political priorities) that is sometimes lacking. The value of WHSs needs to be better appreciated outwardly and at a strategic level. Wales 2.19 Planning Policy Wales (PPW), Edition 9 was published in 2016. It is currently being revised. Technical Advice Note 24, section 3 was published in May 2017 and is supplemented by the guidance document ‘Managing Change in World Heritage Sites in Wales’ also published in May 2017. The Welsh Government is also currently producing a National Development Framework. This will be a 20-year spatial plan for Wales. It is not included in the considerations below. 2.20 The current PPW addresses the approach to World Heritage in development plans at paragraph 6.4.5. It states that “the adoption of supplementary planning guidance, which is consistent and agreed between all relevant authorities, is considered to be the most effective way of implementing the conservation of World Heritage Sites.” In terms of development management: “The impacts of proposed developments on a World Heritage Site and its setting and, where it exists, the World Heritage Site buffer zone, is a material consideration in the determination of a planning application” (Paragraph 6.5.2) and “Certain permitted development rights are restricted on land in a World Heritage Site” (Paragraph 6.5.3). Conclusion 2.21 Overall, some members offered the opinion that England’s NPPF offers greater protection to Outstanding Universal Value than the national planning policies for other parts of the UK. This view suggests that a more consistent approach would be helpful. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Ensure that UNESCO WHSs are mentioned in any new relevant Planning Acts

WH:UK; Ministry of Housing, of Communities and Local Government (DCLG)

Record and review cases where paragraphs 194 and 195 of the NPPF have been used as a means of monitoring the performance of this policy. and seek to understand how the NPPF wording has been interpreted.

WH:UK to lead with support from WHS managers, local authorities, Department of Digital, Culture, Media and Sport (DCMS), DCLG, Historic England (HE) and Natural England (NE).

Engage with reviews of national planning systems in all parts of the UK and comment on behalf of World Heritage Sites

WH:UK

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B. Heritage Impact Assessments 2.22 Tools are available to help assess the impact of development proposals on WHSs. These tools include Environmental Impact Assessments (EIAs) and Heritage Impact Assessments (HIAs). EIAs arise from the EU’s Environmental Impact Assessment Directive (2014/52/EU), and are governed by regulations. HIAs are not statutory, but may form part of an EIA. 2.23 The International Council on Monuments and Sites (ICOMOS) has produced guidance on HIAs. Their approach is endorsed by the World Heritage Committee, which “encourages States Parties to integrate the EIA/HIA processes into legislation, planning mechanisms and management plans, and reiterates its recommendation to States Parties to use these tools in assessing projects, including assessment of cumulative impacts, and before any final decision is taken” (Bonn Committee Session 2015). 2.24 WH:UK recognises that HIAs are a useful tool for decision-makers, but it has a number of concerns, as follows: : • disagreements with the baseline can result in no agreement on the outcome of

the HIA in terms of impact. • there may be a lack of understanding that OUV impact is a series of layers –

cultural, historic, landscape and visual. This emphasises that the relationship with other assessment methodology is critical and nothing should be viewed in isolation.

• the assessment of the impact of a development upon the OUV of a WHS will often require input from a number of disciplines. The tools used are not always consistent. Further, none of the techniques used by any single discipline can adequately assess the totality of the impact of a major development. It is important that HIAs take this holistic view.

• professionals can reach sometimes dramatically different conclusions about both the magnitude of a development and its impact, which can lead to a polarisation of views. Different parties (and therefore their professional advisors) have different interests and therefore interpretations. Even local authorities may have conflicting interests, especially if the authority stands to gain from a development. One solution would be for HIAs to be produced by an independent body. Another would be to ensure that the decision-maker has expertise and capacity to enable a critical evaluation of HIAs submitted by applicants.

• the 9 point scale (from major beneficial to major adverse) to judge the significance of the effect of change can be applied subjectively and alternative “facts” used in the process

• the quality and amount of information contained within varies significantly.

2.25 Despite these caveats, WH:UK would like to see HIAs given a statutory underpinning. In particular, Assessments should be required for any development with the potential to impact a Site’s OUV and its setting and/or buffer zone. 2.26 There is also an issue about how attributes are treated in the methodology. ICOMOS is clear that it is the attributes that convey a site’s Outstanding Universal Value. The use of attributes was introduced in ICOMOS’s methodology to try to make statements of OUV more understandable and applicable in impact assessment. This method is now common in recent/revised WHS and other management plans. While ICOMOS’s methodology suggests that attributes may need to be more specifically defined during the HIA process, it does not seem to allow for the fact that the degree

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of significance for different assets in complex Sites will vary. The methodology should take this into account, although this would afford the opportunity for further differences of view between experts. 2.27 The cumulative impact of “minor” development is another issue for some sites, such as the Royal Botanic Gardens, Kew. Here significant parts of its OUV are the outlooks and settings. The cumulative impact of minor development is causing the gradual erosion of significant views, and the rural or open backdrop of the Site is being lost. In England, Planning Practice Guidance on Conserving and Enhancing the Historic Environment recognises the need for local planning authorities to consider cumulative impact, and draws attention to the fact that “developments which materially detract from the asset’s significance may also damage its economic viability now, or in the future, thereby threatening its ongoing conservation”. 2.28 At the workshop, some attendees requested training on the use of the ICOMOS methodology. This training is needed by local authority members and officers, and other organisations. 2.29 Finally, using both EIAs and HIAs in relation to one application can be costly, time-consuming and confusing. It would be helpful to clarify the relationship between the two, agree the circumstances in which each is appropriate and consider how duplication of effort to inform each can be avoided. Generally, there should be greater clarity of guidance and consistency of application across the UK in relation to all of the above. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTIONS RESPONSIBILITIES Press for the HIA process to be given a statutory underpinning across the UK for proposals with the potential to impact a WHS’s OUV and setting.

WH:UK to lead with support from Cadw, HE, Historic Environment Scotland (HES), and Northern Ireland Environment Agency (NIEA)

Press ICOMOS to recognise in its methodology the need to take into account the varying significance of different attributes specific to the OUV of a Site

WH:UK

Press for HIAs to be undertaken by independent bodies

WH:UK

Encourage a common and clearly understood approach to EIA and HIA across the UK.

WH:UK

Training to be provided on the ICOMOS HIA methodology.

ICOMOS/Cadw/HE/HS/NIEA

C. Settings and buffer zones 2.30 ICOMOS’s HIA methodology focuses on OUV, but, in terms of planning, the setting of the site should also be considered when development is proposed. WH:UK recognises that each Site is different. In some cases there can be a buffer zone (primarily visual) and also a local setting that might be more about character. 2.31 The Planning Workshop raised a number of questions with regard to settings

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and buffer zones, including: • is there a difference between a buffer zone and a setting? • can a site have both? • are the attributes in both the same? • how should values be defined in settings/buffer zones? • are buffer zones appropriate for all World Heritage Sites, or only those that are

tightly defined? • should the approach to settings and buffer zones be tailored to each Site?

2.32 Many of the national supporting documentation by governments and their agencies address the issues of setting and buffer zones. This is helpful, but it would be more useful to gather advice into one place and have a single approach across the UK.

2.33 The resolution of the questions raised is important for both planning policy and development management. Given the interest in these matters, it may be useful for them to form part of a follow-up workshop. This would give the opportunity for Site Managers to share how settings and buffer zones are treated in planning terms for their Sites, and explore whether a common approach is possible and would be helpful. Greater clarity and shared understanding of the terminology used would benefit all stakeholders including land managers and owners, statutory bodies including local authorities, and potential developers. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTIONS RESPONSIBILITIES WH:UK to consult with members to see if it would be helpful to cover this topic in a follow-up workshop. Note: WH:UK’s annual conference in 2018 will address the issue of setting.

WH:UK and its members

Encourage the production of a single UK-wide approach to and advice on settings and buffer zones

WH:UK, DCMS, Cadw, HES, NIEA and other relevant government departments

D. Local plan policies 2.34 Together with any national and regional planning policies, local plan policies set the context for the protection and conservation of WHSs. The policies, along with other matters, will be taken into account when making decisions on planning applications. WHSs are also a significant factor in determining the location of sites for land allocations for specific uses. 2.35 Attendees at the workshop were shown examples of a number of local plan policies. They demonstrated variations in: • the areas to which they apply (i.e. the Site only, the Site and its setting/buffer

zone, or more general areas to which conservation policies would apply) • referring or not to the OUV and/or the Site’s attributes • how “public benefit” would be taken into account in development management • referring or not to the Site’s Management Plan • referring to a relevant Shoreline Management Plan • referring or not to the treatment of specific types of development related to the

Site (e.g. visitor facilities)

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2.36 It was suggested at the workshop that it may be helpful to: 1) produce a list of policies from all sites 2) draft a model policy

2.37 There is certainly merit in looking further into these suggestions. However, given the variety of sites –historic landscape, remnant or ruin, city centre, or natural environment – a variety of planning policy approaches is necessary, it would not be possible to produce a model policy applicable to all sites. In some areas, it is more useful to use supplementary planning guidance. Nevertheless, it would be helpful to have more consistency in the matters covered in policies, and perhaps the production of a checklist of such matters would be useful. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES WH:UK and members to produce a list of local plan policies from all sites

WH:UK and members

E. Development Management 2.38 Local authorities can face dilemmas when determining planning applications, especially when balancing the need to protect Sites with the needs for economic regeneration and housing. At the workshop there was a presentation on development management issues in the Blaenavon Industrial Landscape WHS. There the main challenge is the juxtaposition between Blaenavon as a living town and safeguarding the historic environment and OUV of the WHS. Another example concerns the Pontcysyllte Aqueduct and Canal WHS. A manufacturer of wood based products and a major employer in the local area is located within the Buffer Zone. The existing plant, which was well established before inscription is considered to be a blight on the landscape. Further applications have been submitted recently for development that will increase the scale of the facility but are essential to improving air and noise quality within the locality as well improving the efficiency of the business. 2.39 There is an issue of clarity as to who has authority to make decisions, particularly at a national level. For example as a condition of the inscription of the Pontcysyllte Aqueduct and Canal WHS there is a need to keep ICOMOS informed of any developments relating to the former Flexys Site. A masterplan has recently been commissioned for Trevor Basin and the former Flexys site but there has been confusion as to who should be consulted and when. There appear to be conflicts with Cadw’s role as a statutory body. 2.40 The situation is complicated further when a Site lies within or adjacent to more than one local authority. Again the situation at the Royal Botanic Gardens, Kew provides an example. In this case, there are several recent and proposed development schemes in Brentford, in the London Borough of Hounslow, on the north bank of the river opposite Kew where conservation harm is weighed in relation to other public benefits gained. The public benefits are enjoyed by London Borough of Hounslow, usually in the form of S106 or Community Infrastructure Levy (CIL) payments. The harm is experienced by Kew Gardens in the London Borough of Richmond in terms of visual impact on the WHS. The decision making process is thus flawed in that the benefits are enjoyed by the decision making authority, and the harm is experienced by third parties.

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2.41 Another issue is the treatment of contemporary design in WHSs. Given the variety of Sites, this is best dealt with on a case-by-case basis. New building design for development in WHSs, be it contemporary or otherwise, should be guided by the context. Contemporary design can be compatible and exciting if done correctly. This issue could be the subject of a workshop or part of a workshop. 2.42 In Edinburgh, work is being done to develop a tool that sets out the attributes really clearly to help case officers dealing with development proposals. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Encourage local planning authorities to work together on development proposals that affect WHSs within or adjacent to their boundaries

Local planning authorities, with assistance from WHS Managers/Steering Groups

WH:UK to consult with members to see if it would be helpful to cover the issue of contemporary design in a follow-up workshop.

WH:UK

F. Monitoring

2.43 It is important to gauge the effectiveness of local plan policies in the protection and conservation of WHSs and to identify how the policies themselves and their application might be improved. The results of monitoring the effectiveness of local plan policies should form part of the Periodic Reporting. 2.44 In some areas, local plan monitoring systems may already include the effectiveness of WHS policies. This should be standard practice for all local plans that cover WHSs or land adjacent to them. WHS managers/Steering Groups could offer their expertise to develop monitoring indicators. They could also take responsibility or offer their assistance in undertaking the monitoring itself. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Local planning authorities should be encouraged to monitor the effectiveness of policies relating to WHSs as part of their local plan monitoring process.

Local planning authorities, with assistance from WHS Managers/Steering Groups

Develop a database of case law relating to the application of local plan World Heritage policies

WH:UK and members

The results of such monitoring should be used in Periodic Reporting on WHSs.

WHS Steering Groups

G. Engagement of World Heritage Site Managers and Steering Groups 2.45 The early engagement of WHS managers and Steering Groups (“World Heritage Site representatives”) both in local planning policy development and the management of development proposals is critical. Some suggested that WHS representatives should be statutory consultees. Whether or not WHS representatives are awarded such recognition, it is essential that representatives develop good working relations with their planning departments and elected

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members, so that they are consulted regularly at relevant stages of planning processes (see more under section 4 below). In Sites with very large numbers of listed buildings, (for example the City of Bath which has more than 5,000), this approach may not be practical. In such cases, it would be better that the planning decision-makers have the training and tools to deal with World Heritage matters rather than passing them onto another consultee (see Section 5B below). SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Develop close links with local planning authorities to ensure processes are in place for early consultation on planning matters.

WHS Managers/Steering Groups and local planning authorities

H. A planning guide/training 2.46 Another suggestion from the workshop was the production of guidance on the interpretation of planning guidance, operational guidelines, etc. However, a great deal of guidance exists already, and further guidance could create confusion. There is also a need for flexibility in interpretation and application, and a guide could be too prescriptive and unresponsive to changes in legislation and case law. WH:UK could produce a list of the key planning guides. Another suggestion is that it could be useful to compile the guidance (e.g. local plan policy/ supplementary guidance note) for each site to share good practice. 2.47 Ongoing training/workshops would be more beneficial in ensuring better consistency in interpretation and approach. This training could include coverage of the key processes involved in planning policy-making and development management. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Production of a list of key guides to the planning systems

WH:UK

Produce an organisational diagram showing responsibilities within the UK World Heritage sector

WH:UK

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3. THE ROLE OF UNESCO-RELATED ADVISORY BODIES IN THE UK’S PLANNING SYSTEMS

A. UNESCO and its advisors – roles, responsibilities and accountability 3.1 The World Heritage Committee has no planning powers. However, it can take sanctions, including, as a last resort, the deletion of a WHS from the World Heritage List. Also the Committee can provide advice to State Parties as it sees fit. State Parties meet their obligations through the application of domestic legislation and guidance. 3.2 It was clear from the workshop that there is a significant amount of confusion about the responsibilities and remit of the various bodies that advise UNESCO regarding WHSs, and dissatisfaction regarding how they operate with regard to the UK planning systems. There were requests for a list of the bodies involved, with a brief description of their roles/responsibilities and relationships. (“Managing Change in World Heritage Sites in Wales” produced by Cadw in May 2017 is helpful in this respect.) 3.3 Attendees expressed frustration about the perception they had of the lack of accountability and transparency of these bodies and how appointments are made to them. This issue is particularly sensitive given that recommendations on heritage issues can be very subjective. WH:UK considers that the standards of openness to which the home nations work should apply to the advisory bodies. 3.4 One suggestion to help develop better relationships was that there should be reciprocal advisory arrangements between WH:UK and ICOMOS. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Produce a list of the bodies that advise UNESCO, including their responsibilities and remits.

WH:UK

Clarify the membership of these bodies and how appointments are made.

WH:UK

Press for the same standards of openness to which the home nations work to apply to UNESCO advisory bodies

WH:UK

Approach ICOMOS UK to suggest reciprocal advisory arrangements with WH:UK

WH:UK

B. The Reactive Monitoring Process 3.5 Workshop attendees were not clear about how the decision to start this process is made and who makes it. The process itself needs to be made clear and transparent. There need to be transparent criteria for the ending of an inspection regime and the removal of a Site from the “at danger” list. The ICOMOS website contains some information on these issues, but the precise decision-making criteria are not set out. 3.6 Where an entrenched dispute develops there should be scope for an independent review and mediation process, with recommendations to all parties.

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This would help ensure that all partners - developers, government bodies and advisors and UNESCO and advisors - are behaving responsibly. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Clarify who initiates the Reactive Monitoring process, the process itself and exactly how decisions are made.

The World Heritage Centre

Press for the introduction of an independent review process where an entrenched dispute develops

WH:UK, DCMS

C. Timescales and delegation 3.7 There can be a disconnection between the planning systems’ timescales and those of UNESCO’s advisory bodies. This happens because of the very infrequent meetings (often annual) of the UNESCO bodies and the lack of capacity in some of those bodies to make timely responses. There needs to be connectivity and consistency between those involved in the process and timetables that work for all parties. With regard to planning applications, there should be engagement by WHS representatives with ICOMOS/IUCN upfront to inform and coordinate WHS input. 3.8 Related to this point, there is a need early in the planning process to clarify which UNESCO-related body will speak on its behalf. The World Heritage Committee itself meets only once a year, so the planning decision-making process rarely dovetails with Committee meetings. In such circumstances, planning authorities and other interested parties should be informed early on to which body the Committee will delegate authority to respond on its behalf. 3.9 There is also a need to clarify whether responses not made by the World Heritage Committee itself carry the Committee’s full weight. If not, it is very important to know what weight should be attached to responses made by its advisors. While mission and other reports usually give a good idea of what the Committee will decide, it would be useful to review whether UK decision-makers themselves have attached differing weights to the responses from the various UNESCO bodies. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Discuss with the relevant UNESCO advisory bodies and the World Heritage Centre how to ensure that the timing of advice fits into planning process timescales

WH:UK, DCMS and UK government departments responsible for planning

Agree a system with the World Heritage Committee to ensure there is early clarity on which of its advisory bodies will speak on its behalf when planning proposals are made

WH:UK, DCMS and UK government departments responsible for planning

Where the World Heritage Committee delegates the giving of responses to one of its advisors, it should make clear what weight should be attached to any such response

WH:UK, DCMS and UK government departments responsible for planning

Review how UK decision-makers have treated responses from UNESCO bodies

WH:UK and members

16

Keep a public record of all referrals made to the UNESCO World Heritage Centre under S.172 of the UNESCO Operating Guidelines.

DCMS

D. Plain language 3.10 Workshop attendees felt that some UNESCO language (such as OUV, attributes and setting) isolates UNESCO from the local planning/national planning contexts, the general public and the decision-makers (councillors). This is an important issue to avoid the perception of top-down decision-making and to encourage local authorities to take greater ownership for their sites, as discussed earlier. 3.11 On the other hand, the UNESCO system is global, with wording that must translate between English and French. This can lead to a style of language that an English speaker might not regard as ‘everyday’. To ask UNESCO to modify language to our particular taste might be seen as being naïve and undermine WH:UK’s credibility. It would be better if WH:UK Site managers/Steering Groups and planners took every opportunity to explain the terminology in relevant documents and at meetings where planning decisions are made. 3.12 Some government guidance now helpfully addresses the issue of terminology. (See, for instance, in England, “Planning Practice Guidance on Conserving and Enhancing the Historic Environment”, and “Managing Change in World Heritage sites in Wales”.) SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES Authors of planning documents that cover WHSs and WHS management plans should ensure that the terminology used in relation to sites is clearly defined.

Government departments, local planning authorities, WHS managers

E. The protection of sites and the public benefit of development 3.13 As noted earlier, the English planning system allows that where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities may allow a planning application if there are substantial public benefits that outweigh that harm or loss. In Scotland, this dilemma has faced planners in every major development proposal that has affected the WHS in Edinburgh over many years. Examples are the Royal High School, the new St. James shopping centre and Caltongate. 3.14 However, UNESCO’s assessment of proposals focuses on conservation issues only. This situation could lead to real difficulties for decision-makers, who may need to weigh the potential loss of inscription against substantial public benefit. It is unlikely that the UK planning system and UNESCO Guidelines will converge. The action here therefore is to manage the bridging of the gap when it occurs.

17

SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITIES When there are differences between development which is permissible under the UK planning systems but unacceptable to UNESCO, work to facilitate dialogue and action to bring all sides together to find mutually acceptable solutions.

WH:UK, DCMS, Cadw, HE, HES, NIEA, ICOMOS

18

4. CENTRAL GOVERNMENT AND DEVOLVED ADMINISTRATIONS

A. Responsibilities 4.1 DCMS is the lead Government department on World Heritage and is responsible for the UK’s general compliance with the UNESCO World Heritage Convention and for nominating sites. It liaises with the Devolved Administrations, the Ministry of Justice (for Crown Dependencies) and the Foreign and Commonwealth Office (for UK Overseas Territories). 4.2 Other Departments in England with an important role are the DCLG (which covers planning and the roles of local authorities) and the Department for Environment, Food and Rural Affairs (which funds NE, which is responsible for the national designations which cover England’s only natural WHS.) 4.3 HE is DCMS’s principal advisor on World Heritage matters for England. In the past this has caused some confusion for England’s natural WHS, where the relevant technical expertise resides with NE. 4.4 In Northern Ireland, in relation to the Giant’s Causeway World Heritage Site, the lead statutory authority is the NIEA. While it is clear that the ‘state party’ responsibility rests with DCMS, it is important that there is clarity about the roles, responsibilities and lines of communication between DCMS and the relevant authorities in the province. 4.5 The Scottish Government Culture and Historic Environment Division and HES liaise to ensure due and timely advice on World Heritage matters. The Scottish Government acts as the link with DCMS, and HES has its own relationship with HE. 4.6 Cadw is the principal advisor on WHS matters in Wales. Natural Resources Wales (NRW) is also actively engaged in managing aspects of the industrial landscape. 4.7 Some attendees at the workshop felt that central government needs to deal with WHSs more consistently and in the round – i.e. not just through DCMS. WH:UK appreciates that, for practical purposes, it is clearer if one Department takes the lead, provided there is good dialogue between Departments and agencies in all parts of the UK. 4.8 WH:UK is aware that difficulties may arise if there are differences of view between Government Departments. Such differences are exemplified at the Pontcysyllte Aqueduct and Canal WHS, which is a cultural rather than a natural site. Here NRW has recently been exploring the possibility of constructing an eel pass at the Horseshoe Falls (to prevent eels accessing the canal rather than continuing on their route along the River Dee). Whilst addressing an ecological concern, the adverse visual impact of this installation would conflict with Cadw’s priority of protecting the OUV and setting of the WHS. 4.9 WH:UK also appreciates that because there are substantial differences between sites, it is unrealistic to expect a consistent approach to be taken in all cases. There will inevitably be differences in how much emphasis is given to preservation, the restriction of change, or indeed efforts to turn the clock back.

19

B. Timing and transparency issues 4.10 The UNESCO World Heritage Committee asks governments to inform it of proposals that may affect the OUV of a WHS. They ask for notice to be given at an early stage and before any decisions are taken that would be difficult to reverse “so that the Committee may assist in seeking appropriate solutions to ensure that the OUV is fully preserved”. 4.11 This process raises a number of issues. Already noted are those of defining whether or not developments will have an adverse impact on OUV, and of timing, given the fact that the World Heritage Committee meets only once a year while in the UK planning decisions are taken much more frequently. In Northern Ireland the timing issues are potentially exacerbated by longer chains of communication. 4.12 Also of concern is the need for clarity and transparency about the process of identifying proposals considered to have a significant potential impact on OUV. The decision on whether or not to refer cases to UNESCO is taken by DCMS. In England, DCMS will first seek the advice of HE, who asks planning authorities to consult it at an early stage on all cases with significant potential impact on OUV. All cases for which HE requests call-in because of impact on OUV are considered for potential referral to the UNESCO World Heritage Committee. 4.13 WH:UK is concerned that there should be greater clarity and transparency about: ! how and at what stage in the process HE and equivalent advisers in other parts

of the UK do this ! how, if at all, these advisers involve WHS Steering Groups/Managers and local

planning authorities ! how DCMS considers the advice given by the advisers ! who provides advice to DCMS on natural sites. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Clarify the process by which proposals are examined for potential reference to the World Heritage Committee

DCMS

Clarify how HE and equivalent advisers in other parts of the UK fulfil their responsibilities and whether they involve WHS Steering Groups/Managers and local planning authorities

DCMS/ HE

Clarify who advises DCMS on natural WHS DCMS Undertake an audit of the s.172 referrals that have been made to UNESCO, including the identification of the reasons for referral and to examine consistency

WH:UK with DCMS

C. National Infrastructure Projects 4.14 Linked to this is the potential for applications to be dealt as “National Infrastructure Projects” or the equivalent. The processes of managing these major planning proposals differ from one part of the UK to another. It is important that

20

representatives of WHSs are engaged in these processes, but there is often a significant financial cost that has to be absorbed by national agencies and/or local authorities. The question arises as to whether DCMS and devolved governments should have more of a supporting role. D. Crown Estates and licensing for offshore windfarms

4.15 The Crown Estate, which has the rights to lease areas of seabed for offshore wind farms around the UK, launched a large-scale offshore wind programme called ‘Round 3’ at the end of 2009. It selected nine areas that it felt were suitable for windfarms. Its selection process involved the use of sieve mapping to eliminate areas within existing exclusion zones, the evaluation of remaining areas for potential restrictions and conflicts, and checking against other datasets for further constraints.

4.16 The experience with the Navitus Bay Windfarm proposals, which had the potential to impact the Dorset and East Devon Coast WHS, was that this exercise was inadequate, for two reasons. Firstly the process used was insufficiently robust - it should have resulted in the exclusion of the selected area at that stage for the reasons that the proposals were eventually refused by the Minister. This would have saved a significant amount of public and private expenditure, as well as anxiety for the public. Secondly, during that initial site selection process, the local authorities were excluded from participation. Their involvement would undoubtedly have resulted in a more robust assessment through the use of their detailed knowledge of their areas. WH:UK therefore recommends that pre-licensing processes should be more thorough and involve the local authorities and the WHS Steering Groups concerned. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY The Crown Estate’s site selection process for development sites at or adjacent to WHSs should be subject to rigorous environmental and heritage assessment, and involve the local planning authorities and Steering Groups

WH:UK and Crown Estates

E. Resources 4.17 Attendees suggested that the Government should recognise that more resources should be directed towards WHSs. Funding is essential for the day-to-day management of Sites, the development, implementation and review of management plans, and training. WH:UK notes that government funding is available for National Parks, Areas of Outstanding Natural Beauty and National Nature Reserves, and questions why similar funding is not available to the UK’s WHSs. It is aware that one-off project funding is sometimes available, such as the recent capital programme of works of £55m over 5 years that has been agreed via Kew Garden’s sponsoring ministry DEFRA. Even then, this does not address the full extent of the backlog of work (in excess of £100m) nor does it address the ongoing maintenance and repair costs going forward.

21

SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY WH:UK to work with the Government and its agencies to identify funding sources for the delivery of UNESCO convention commitments

WH:UK, DCMS, DCLG/NI Administration/Scottish and Welsh Governments, Cadw/HE/HES/NIEA

22

5. LOCAL AUTHORITY ISSUES 5.1 Local authorities have responsibility for local planning policy and making decisions on most planning applications. Authorities with WHSs within their boundaries may also support the management of sites financially and/or provide accommodation and management of World Heritage Staff. Their role in protecting and conserving Sites is therefore critical. 5.2 During the workshop, a number of issues were identified with regard to local authorities, in addition to the “planning issues” described in section 2 above. A. The need for a better appreciation of the significance of WHSs 5.3 Some attendees felt that local authority members and officers need better to appreciate the significance of the WHS in their area. 5.4 The understanding of Sites needs to go beyond their OUVs, and incorporate their economic benefit (or potential economic benefit), such as the value to the tourism industry. This would help inform planning decisions, and make for a better understanding of the contribution of Sites towards sustainable development. In some areas economic impact studies have been made of the value of the Sites and it was felt this should be used for all Sites. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Make available economic impact studies of sites already undertaken

WH:UK

Advise on undertaking an economic impact study/provide a standard methodology, possibly as part of a follow-up workshop

WH:UK

B. Training 5.5 There is a need for training on these issues, and such training (including tours of the Sites) needs to be on a rolling basis as council membership changes. Training needs to improve the ability, understanding and consistency of decision-makers. Specific expertise is needed within local authorities related to the OUV and setting of Sites, and understanding the language used by UNESCO and its advisors raised earlier (see 3.10 to 3.12). With reductions in staff, it is critical that those who remain staff are well trained to offset any loss of continuity. 5.6 It was suggested that WH:UK could develop a template for training that managers could use for briefings, and that there could be a standard presentation to introduce WHS issues, which could be augmented at the local level. 5.7 Another suggestion was that WH:UK should hold sessions with some local authorities to highlight issues/raise heritage profile. However WH:UK feels that it is more important that representatives of each Site develop good long-term relationships with their local authorities. The intervention of WH:UK could be counter-productive by being perceived as outside interference.

23

SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Train local authority members and officers in the significance and economic value of Sites, and explain UNESCO terminology

UNESCO bodies; WH:UK; local Sites Steering Groups and managers

Produce a template and standard presentation for member training

WH:UK.

Ensure specialist capacity exists in local authorities to inform decision-making in relation to WHSs

Local authorities with WHSs within their boundaries

Encourage professional bodies to be involved in training and build World Heritage issues into CPD . WH:UK could assist in provision and benefit from income

WH:UK with relevant professional bodies

Discuss training provision with the Planning Advisory Service

WH:UK

HELM Courses on World Heritage to be run and to include elected members

HE, WH:UK

C. Resources 5.8 Workshop attendees expressed considerable concern regarding diminishing resources in local authorities. They were particularly concerned at: ! any loss of expertise (as above) ! lack of specialist resources to do early upstream thinking in terms of potential

impacts ! lack of funding and/or managerial structures to protect and mount any defence

against unacceptable proposals. Central Government should be pressed for increased resources for local authorities and Steering Groups/site managers to support WHSs address planning issues.

5.9 Another issue is that local authorities are using the planning system increasingly as a way to secure funding for public benefits that could not be funded from the pubic purse. This is achieved in particular by means of S106 and the CIL. Local authorities thus stand to gain from approving planning applications that come before them. The danger is that this skews the process against third parties adversely affected by the proposed development schemes. An example is the Watermans Arts Centre, where the local authority will secure a new arts centre and affordable housing that will cause significant harm to the setting of Kew Palace. 5.10 To address this situation in cases affecting WHSs, there is a case for automatic call-in where the custodian of the Site has made an objection relating to OUV. The delay to the development process caused by call-in would incentivise developers to bring forward less controversial schemes. 5.11 Training is resource intensive and has to be carried out in an almost continuous cycle – for elected members/ planning officers etc. Another pinch point is the resource required to keep management plans up-to-date. Public consultation again is resource intensive and time-consuming. Certainly it would be ideal to have increased resources to support WHSs.

24

SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Press for greater resources for local authorities and Steering Groups/site managers to ensure specialist resources and capacity exists to address planning issues that affect WHSs

WH:UK

Press those responsible at national level automatically to call-in development proposals that Site custodians consider harmful to a Site’s OUV and/or setting.

WH:UK, WHS Steering Groups/Managers, DCLG/NI Administration/ Scottish and Welsh Governments

25

6. ISSUES RELATING TO WORLD HERITAGE SITE STEERING GROUPS AND MANAGERS

6.1 The previous sections have highlighted some of the opportunities for the involvement of Steering Groups and Site Managers in the planning system. These include: ! taking the opportunities offered by consultation and engagement exercises in

relation both to planning policy and development management ! helping local planning authorities to develop monitoring indicators for local plans ! ensuring early engagement with decision-makers on planning issues ! ensuring that decision-makers are well informed about WHSs ! preparing economic impact assessments of Sites to inform decision-makers ! engaging in HIA and EIA exercises to improve the quality of information ! assisting with the training of decision-makers and their advisors on World

Heritage Issues 6.2 Attendees at the workshop suggested a number of other areas for involvement, as follows. A. Clarification of how Steering Groups and Managers should be involved in the planning system 6.3 Some Steering Groups may not yet have considered how they or the Site Managers could be involved in the planning system. There should certainly be involvement in the development of planning policies, since these set the context for the determination of proposals. Should Steering Groups choose to get involved in specific applications, they need to ensure there is no conflict of interest if some Group members represent organisations that will also take a view on proposals. In such circumstances, Group members could choose not to take part in Steering Group discussions or the specific issues affecting the WHS need to be agreed and debate focussed on those issues. 6.4 In any case, it is helpful to be clear about the circumstances under which Steering Groups/Managers expect to be involved, and to communicate this to planning decision-makers. In this respect it may be useful to share standard Terms of Reference for steering groups and other management tools/experience. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Clarification of Steering Group/Manager involvement in the planning system

Steering Groups where this does not exist already

Sharing of standard Terms of Reference for steering groups and other management tools/experience

Site managers

B. Good practice on involvement in the planning system 6.5 Workshop attendees suggested that there could be closer cooperation and learning by WHS Steering Groups and Managers responsible for sites with similar characteristics. One specific suggestion was the production of a compendium of

26

good practice of involvement in the planning system. The good practice guide would include examples of specific issues/impacts of development and how satisfactory solutions were reached. 6.6 Another suggestion is to engage with and/or facilitate reciprocal visits with overseas planning delegations, to explore how well other planning regimes support WHSs. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Production of good practice guide on involvement in the planning system

WH:UK supported by Site Managers

Engagement with and/or facilitation of reciprocal visits with overseas planning delegations

WH:UK, individual Sites, professional planning organisations

C. The use of Management Plans 6.7 It is helpful to consider planning issues when preparing Management Plans. In particular, it is useful to look ahead to try to identify the sort of development pressures that may impinge on a Site. If the Plan is clear about the views of the Steering Group on such developments, it will better inform planning process. In this respect, it is also very helpful if a local plan makes reference to the Management Plan for a Site, and considers how planning policies will help ensure the Plan’s delivery. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Include in Management Plans Steering Group views on foreseeable development proposals

Steering Groups and Site Managers

D. Good practice guide on councillor support 6.8 It was also suggested that a good practice guide be produced to highlight Sites where there is good support for local councillors and decision-makers. Related to this suggestion was the idea of the production of a draft manifesto for local councils, which would include commitments to protect their WHSs. SUGGESTED ACTIONS FOR IMPROVEMENT AND RESPONSIBILITIES ACTION RESPONSIBILITY Production of good practice guide on councillor support, including a draft manifesto

WH:UK supported by Site Managers

E. Resource issues

6.9 While pressing for increased public sector resources, workshop attendees recognised that there is a need to think about how to manage and address issues in

27

the light of public sector cutbacks. Some Sites are pressing ahead with new financial and management arrangements, and it would be helpful to share experience. ACTION RESPONSIBILITY Develop plans for alternative funding models for sites that are heavily reliant on public sector funding

Steering Groups for Sites where this is or could be an issue

Compile a review of all current UK sites showing governance and funding models

WH:UK, with funding from HE, Cadw, HES and NIEA

28

APPENDIX A – ABBREVIATIONS Cadw The Welsh Government’s historic environment service CIL Community Infrastructure Levy DCLG Ministry of Housing, of Communities and Local Government DCMS Department for Digital, Culture, Media and Sport EIA Environmental Impact Assessment HE Historic England HES Historic Environment Scotland HIA Heritage Impact Assessment ICOMOS The International Council on Monuments and Sites NE Natural England NIEA Northern Ireland Environment Agency NPF National Planning Framework (for Scotland) NPPF National Planning Policy Framework (for England) NRW Natural Resources Wales OUV Outstanding Universal Value PPW Planning Policy Wales SPP Scottish Planning Policy SPPS Strategic Planning Policy Statement (for Northern Ireland) UNESCO United Nations Educational, Scientific and Cultural Organisation WHS World Heritage Site WH:UK World Heritage UK

29

APP

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pla

nnin

g gu

ide

Pro

duce

a li

st o

f key

gui

des

to th

e pl

anni

ng s

yste

ms

✔

P

rodu

ce a

n or

gani

satio

nal d

iagr

am

show

ing

resp

onsi

bilit

ies

with

in th

e U

K W

orld

Her

itage

sec

tor

✔

THE

RO

LE O

F U

NES

CO

-REL

ATE

D A

DVI

SOR

Y B

OD

IES

IN T

HE

UK

’S P

LAN

NIN

G S

YSTE

MS

A. U

NE

SC

O a

nd it

s ad

viso

rs –

role

s,

resp

onsi

bilit

ies

and

acco

unta

bilit

y

Pro

duce

a li

st o

f the

bod

ies

that

ad

vise

UN

ES

CO

, inc

ludi

ng th

eir

resp

onsi

bilit

ies

and

rem

its.

✔

C

larif

y th

e m

embe

rshi

p of

thes

e bo

dies

and

how

app

oint

men

ts a

re

mad

e.

✔

P

ress

for t

he s

ame

stan

dard

s of

op

enne

ss to

whi

ch th

e ho

me

natio

ns w

ork

to a

pply

to U

NE

SC

O

advi

sory

bod

ies

✔

A

ppro

ach

ICO

MO

S U

K] t

o su

gges

t re

cipr

ocal

adv

isor

y ar

rang

emen

ts

with

WH

:UK

✔

B. T

he re

activ

e m

onito

ring

proc

ess

Cla

rify

who

initi

ates

the

Rea

ctiv

e M

onito

ring

proc

ess,

the

proc

ess

itsel

f and

exa

ctly

how

dec

isio

ns a

re

mad

e.

✔

32

A

CTI

ON

R

ESPO

NSI

BIL

ITY

WH

:UK

W

H:U

K

mem

bers

W

HS

S

teer

ing

Gro

ups/

m

anag

ers

LAs

DC

MS

D

CLG

/NI

Adm

inis

tratio

n/

Sco

ttish

and

W

elsh

G

over

nmen

ts

Cro

wn

Est

ate

HE

C

adw

/H

ES

/ N

IEA

NE

IC

OM

OS

/ot

her

UN

ES

CO

bo

dies

Wor

ld

Her

itage

C

entre

Pro

fess

- io

nal

plan

ning

bo

dies

P

ress

for t

he in

trodu

ctio

n of

an

inde

pend

ent r

evie

w p

roce

ss w

here

an

ent

renc

hed

disp

ute

deve

lops

✔

✔

C. T

imes

cale

s an

d de

lega

tion

Dis

cuss

with

the

rele

vant

UN

ES

CO

ad

viso

ry b

odie

s an

d th

e W

orld

H

erita

ge C

entre

how

to e

nsur

e th

at

the

timin

g of

adv

ice

fits

into

pla

nnin

g pr

oces

s tim

esca

les

✔

✔

✔

A

gree

a s

yste

m w

ith th

e W

orld

H

erita

ge C

omm

ittee

to e

nsur

e th

ere

is e

arly

cla

rity

on w

hich

of i

ts

advi

sory

bod

ies

will

spe

ak o

n its

be

half

whe

n pl

anni

ng p

ropo

sals

are

m

ade

✔

✔

✔

W

here

the

Wor

ld H

erita

ge

Com

mitt

ee d

eleg

ates

the

givi

ng o

f re

spon

ses

to o

ne o

f its

adv

isor

s, it

sh

ould

mak

e cl

ear w

hat w

eigh

t sh

ould

be

atta

ched

to a

ny s

uch

resp

onse

✔

✔

✔

R

evie

w h

ow U

K d

ecis

ion-

mak

ers

have

trea

ted

resp

onse

s fro

m

UN

ES

CO

bod

ies

✔

✔

K

eep

a pu

blic

reco

rd o

f all

refe

rral

s m

ade

to th

e U

NE

SC

O W

orld

H

erita

ge C

entre

und

er S

. 172

of t

he

UN

ES

CO

Ope

ratin

g G

uide

lines

✔

D. P

lain

lang

uage

A

utho

rs o

f pla

nnin

g do

cum

ents

that

co

ver W

HS

s an

d W

HS

M

anag

emen

t Pla

ns s

houl

d en

sure

th

at th

e te

rmin

olog

y us

ed in

rela

tion

to S

ites

is c

lear

ly d

efin

ed.

✔

✔

✔

E. T

he p

rote

ctio

n of

W

hen

ther

e ar

e di

ffere

nces

bet

wee

n ✔

✔

✔

✔

✔

33

A

CTI

ON

R

ESPO

NSI

BIL

ITY

WH

:UK

W

H:U

K

mem

bers

W

HS

S

teer

ing

Gro

ups/

m

anag

ers

LAs

DC

MS

D

CLG

/NI

Adm

inis

tratio

n/

Sco

ttish

and

W

elsh

G

over

nmen

ts

Cro

wn

Est

ate

HE

C

adw

/H

ES

/ N

IEA

NE

IC

OM

OS

/ot

her

UN

ES

CO

bo

dies

Wor

ld

Her

itage

C

entre

Pro

fess

- io

nal

plan

ning

bo

dies

site

s an

d th

e pu

blic

be

nefit

of d

evel

opm

ent

deve

lopm

ent w

hich

is p

erm

issi

ble

unde

r the

UK

pla

nnin

g sy

stem

s bu

t un

acce

ptab

le to

UM

ES

CO

, wor

k to

fa

cilit

ate

dial

ogue

and

act

ion

to

brin

g al

l sid

es to

geth

er to

find

m

utua

lly a

ccep

tabl

e so

lutio

ns

CEN

TRA

L G

OVE

RN

MEN

T A

ND

DEV

OLV

ED A

DM

INIS

TRA

TIO

NS

A. R

espo

nsib

ilitie

s N

o ac

tions

B. T

imin

g is

sues

C

larif

y th

e pr

oces

s by

whi

ch

prop

osal

s ar

e ex

amin

ed fo

r pot

entia

l re

fere

nce

to th

e W

orld

Her

itage

C

omm

ittee

✔

C

larif

y ho

w H

E a

nd e

quiv

alen

t ad

viso

rs in

oth

er p

arts

of t

he U

K

fulfi

l the

ir re

spon

sibi

litie

s an

d w

heth

er th

ey in

volv

e W

HS

Ste

erin

g G

roup

s/M

anag

ers

and

loca

l pl

anni

ng a

utho

ritie

s

✔

✔

✔

C

larif

y w

ho a

dvis

es D

CM

S o

n na

tura

l Wor

ld H

erita

ge S

ites

✔

U

nder

take

and

aud

it of

the

s.17

2 re

ferr

als

that

hav

e be

en m

ade

to

UN

ES

CO

, inc

ludi

ng th

e id

entif

icat

ion

of th

e re

ason

s fo

r re

ferr

al a

nd to

exa

min

e co

nsis

tenc

y

✔

✔

C. N

atio

nal

Infra

stru

ctur

e P

roje

cts

No

actio

ns

D. C

row

n E

stat

es a

nd

licen

sing

for o

ffsho

re

win

dfar

ms

The

Cro

wn

Est

ate’

s si

te s

elec

tion

proc

ess

for d

evel

opm

ent s

ites

at o

r ad

jace

nt to

WH

Ss

shou

ld b

e su

bjec

t to

rigo

rous

env

ironm

enta

l and

he

ritag

e as

sess

men

t, an

d in

volv

e th

e lo

cal p

lann

ing

auth

oriti

es a

nd

✔

✔

34

A

CTI

ON

R

ESPO

NSI

BIL

ITY

WH

:UK

W

H:U

K

mem

bers

W

HS

S

teer

ing

Gro

ups/

m

anag

ers

LAs

DC

MS

D

CLG

/NI

Adm

inis

tratio

n/

Sco

ttish

and

W

elsh

G

over

nmen

ts

Cro

wn

Est

ate

HE

C

adw

/H

ES

/ N

IEA

NE

IC

OM

OS

/ot

her

UN

ES

CO

bo

dies

Wor

ld

Her

itage

C

entre

Pro

fess

- io

nal

plan

ning

bo

dies

Ste

erin

g G

roup

s E

. Res

ourc

es

WH

:UK

to w

ork

with

the

gove

rnm

ent

and

its a

genc

ies

to id

entif

y fu

ndin

g so

urce

s fo

r the

del

iver

y of

UN

ES

CO

co

nven

tion

com

mitm

ents

✔

✔

✔

✔

✔

LOC

AL

AU

THO

RIT

Y IS

SUES

A

. The

nee

d fo

r a b

ette

r ap

prec

iatio

n of

the

sign

ifica

nce

of W

orld

H

erita

ge S

ites

Mak

e av

aila

ble

econ

omic

impa

ct

stud

ies

of s

ites

alre

ady

unde

rtake

n ✔

A

dvis

e on

und

erta

king

an

econ

omic

im

pact

stu

dy/p

rovi

de a

sta

ndar

d m

etho

dolo

gy, p

ossi

bly

as p

art o

f a

follo

w-u

p w

orks

hop

✔

B. T

rain

ing

Trai

n lo

cal a

utho

rity

mem

bers

and

of

ficer

s in

the

sign

ifica

nce

and

econ

omic

val

ue o

f Site

s, a

nd

expl

ain

UN

ES

CO

term

inol

ogy

✔

✔

✔

P

rodu

ce a

tem

plat

e an

d st

anda

rd

pres

enta

tion

for m

embe

r tra

inin

g ✔

E

nsur

e sp

ecia

list c

apac

ity e

xist

s in

lo

cal a

utho

ritie

s to

info

rm d

ecis

ion-

mak

ing

in re

latio

n to

WH

Ss

✔

E

ncou

rage

pro

fess

iona

l bod

ies

to

be in

volv

ed in

trai

ning

and

bui

ld

Wor

ld H

erita

ge is

sues

into

CP

D.

WH

:UK

cou

ld a

ssis

t in

prov

isio

n an

d be

nefit

from

inco

me

✔

✔

D

iscu

ss tr

aini

ng p

rovi

sion

with

the

Pla

nnin

g A

dvis

ory

Ser

vice

✔

H

ELM

cou

rses

on

Wor

ld H

erita

ge to

be

run

and

to in

clud

e el

ecte

d ✔

✔

35

A

CTI

ON

R

ESPO

NSI

BIL

ITY

WH

:UK

W

H:U

K

mem

bers

W

HS

S

teer

ing

Gro

ups/

m

anag

ers

LAs

DC

MS

D

CLG

/NI

Adm

inis

tratio

n/

Sco

ttish

and

W

elsh

G

over

nmen

ts

Cro

wn

Est

ate

HE

C

adw

/H

ES

/ N

IEA

NE

IC

OM

OS

/ot

her

UN

ES

CO

bo

dies

Wor

ld

Her

itage

C

entre

Pro

fess

- io

nal

plan

ning

bo

dies

mem

bers

C

. Res

ourc

es

Pre

ss fo

r gre

ater

reso

urce

s fo

r loc

al

auth

oriti

es a

nd S

teer

ing

Gro

up/s

ite

man

ager

s to

ens

ure

spec

ialis

t re

sour

ces

and

capa

city

exi

sts

to

addr

ess

plan

ning

issu

es th

at a

ffect

W

HS

s

✔

P

ress

thos

e re

spon

sibl

e at

nat

iona

l le

vel a

utom

atic

ally

to c

all-i

n de

velo

pmen

t pro

posa

ls th

at S

ite

cust

odia

ns c

onsi

der h

arm

ful t

o a

Site

’s O

UV

and

/or s

ettin

g.

✔

✔

✔

ISSU

ES R

ELA

TIN

G T

O W

OR

LD H

ERIT

AG

E SI

TE S

TEER

ING

GR

OU

PS A

ND

MA

NA

GER

S A

. Cla

rific

atio

n of

how

S

teer

ing

Gro

ups

and

Man

ager

s sh

ould

be

invo

lved

in th

e pl

anni

ng

syst

em

Cla

rific

atio

n of

Ste

erin

g G

roup

/Man

ager

invo

lvem

ent i

n th

e pl

anni

ng s

yste

m

✔

S

harin

g of

sta

ndar

d Te

rms

of

Ref

eren

ce fo

r ste

erin

g gr

oups

and

ot

her m

anag

emen

t too

ls/e

xper

ienc

e

✔

B. G

ood

prac

tice

on

invo

lvem

ent i

n th

e pl

anni

ng s

yste

m

Pro

duct

ion

of g

ood

prac

tice

guid

e on

invo

lvem

ent i

n th

e pl

anni

ng

syst

em

✔

✔

E

ngag

emen

t with

and

/or f

acili

tatio

n of

reci

proc

al v

isits

with

ove

rsea

s pl

anni

ng d

eleg

atio

ns

✔

✔

✔

C. T

he u

se o

f M

anag

emen

t Pla

ns

Incl

ude

in M

anag

emen

t Pla

ns

Ste

erin

g G

roup

vie

ws

on

fore

seea

ble

deve

lopm

ent p

ropo

sals

✔

D. G

ood

prac

tice

guid

e on

cou

ncill

or s

uppo

rt P

rodu

ctio

n of

goo

d pr

actic

e gu

ide

on c

ounc

illor

sup

port,

incl

udin

g a

✔

✔

36

A

CTI

ON

R

ESPO

NSI

BIL

ITY

WH

:UK

W

H:U

K

mem

bers

W

HS

S

teer

ing

Gro

ups/

m

anag

ers

LAs

DC

MS

D

CLG

/NI

Adm

inis

tratio

n/

Sco

ttish

and

W

elsh

G

over

nmen

ts

Cro

wn

Est

ate

HE

C

adw

/H

ES

/ N

IEA

NE

IC

OM

OS

/ot

her

UN

ES

CO

bo

dies

Wor

ld

Her

itage

C

entre

Pro

fess

- io

nal

plan

ning

bo

dies

draf

t man

ifest

o E

. Res

ourc

e is

sues

D

evel

op p

lans

for a

ltern

ativ

e fu

ndin

g m

odel

s fo

r site

s th

at a

re

heav

ily re

liant

on

publ

ic s

ecto

r fu

ndin

g

✔

C

ompi

le a

revi

ew o

f all

curr

ent U

K

site

s sh

owin

g go

vern

ance

and

fu

ndin

g m

odel

s ✔

✔

✔