RESCUE is an entirely independent charity, which exists to promote the interests of
archaeology and the historic environment in the United Kingdom. We have no links with any
political party and are funded entirely by the subscriptions and donations of our members. It is with
this remit in mind that we are pleased to take this opportunity to respond to the consultation on the
PPS15 accompanying Historic Environment Practice Guide.

In the absence of specific consultation questions, and with the stated invitation to comment
on the text of the Practice Guide, it is clear that the simplest way to respond to this document is to
comment on the various issues with relevance to the respective paragraph numbers, and to
maintain the order of the document as it currently stands (the \u201cliving draft\u201d version of 24.07.2009)
Where issues of concern are not within numbered paragraphs (for example in the case of the boxes
inset within the text), this has been indicated by referring to the paragraphs on either side. Where
we feel there have been omissions, or where there are additional overarching points of concern, we
have appended our comments under the heading of \u201cGeneral Issues\u201d following the comments on
the specific text. Throughout the document there are a number of obvious typographical errors
which we have not raised, as presumably these will be corrected later in the drafting process.

Historic Environment Practice Guide.
Paragraph
5

The Government\u2019s \u201c...statement on its vision for the historic environment...\u201d should be the
underlying keystone of the PPS and its supporting guidance. It is unreasonable to expect fully
informed comments on these documents to be returned without such a manifestly important
statement of intent being available. A lack of joined-up thinking is evident here, and is extremely
unhelpful to the process.

The attempt to define \u201csignificance\u201d is well meaning but ultimately flawed. Each and every
historic site has its own unique character, history and significance, which can only be fully defined
through investigation and study. The wording here implies rather that significance could potentially
be ascertained through designation \u2013 with designated \u201cassets\u201d already being seen as more
significant than non-designated ones. This of course is not the case and the wording here needs to
be tightened to make clear that this is not what is intended.

The definition also excludes a number of elements of our historic environment that are
equally \u201csignificant\u201d. The \u201cstrictly defined\u201d historic environment is poor terminology for example \u2013
since the vast majority of our chronological past is undocumented and therefore not \u201chistoric\u201d at all.

In addition the reliance on \u201cpast human activity\u201d excludes the vast corpus of environmental data \u2013 a
particular issue of concern to archaeological study of prehistoric settlement, occupation patterns and
palaeoenvironments. It is certainly the case that environmental factors influenced past human
activity rather than the other way around, as the definition given here would imply. Furthermore, the
definition appears to exclude surviving elements of our past landscapes such as heritage trees or
peat bogs, which it can reasonably be argued are equally as important as surviving human
structures \u2013 if not more so.

The definition also indicates that archaeological investigation of an asset may be required to establish or understand significance. This is true, but it strongly implies that there is a known asset to investigate in the first place. Unfortunately for the implementation of this premise, it is the case that the vast majority of the country remains archaeologically unexplored \u2013 meaning that there must be an enormous number of sites and finds of \u201csignificance\u201d that await discovery. Indeed this was proven to be the case very recently with the discovery of the Staffordshire Hoard of Anglo-Saxon gold and silver. What provision is there within either the PPS15 policy framework, or the Practice Guide advice, to take account of the possibility of currently unrecorded and therefore unknown sites and /or finds of significance existing on a site, and therefore making provision for archaeological prospection on hitherto unexplored sites to take place? It appears, very little in fact \u2013 a situation which MUST be rectified prior to these documents being issued formally.

As this is a planning \u2013 related practice guide, it must be acknowledged within the text that
there will at times be conflicting opinions as to the nature of the \u201csignificance\u201d of a site. It would be
helpful here to not only define how a final decision should be reached, but also which individual or
body would be the final arbiter of a decision (whether it be the owner, their agents, the Local
Planning Authority, English Heritage or the Secretary of State).

Whilst it is clear that the first key stage of assessing significance is understanding the nature
of the asset, there is no provision within this paragraph for archaeological remains that are currently
not recorded in HERs or local archives, because as outlined above, they await initial discover. A
great deal of pre-determination archaeological evaluation carried out under PPG16 is designed to
better assess the likely nature and extent of hitherto unrecorded archaeological sites \u2013 as well as for
those for which little information is available. This is a key component in ensuring better-informed
planning decisions are made.

RESCUE is pleased to note that the importance of Historic Environment Records is
recognised. However HERs and the advisory services which they support are constantly under
threat of removal by short-sighted and short-term local authority internal departmental and
budgetary considerations. To enable policy HE1 of the PPS to be implemented, HERs and historic
environment advisory capacity must be made a statutory requirement of all local planning
authorities. Whilst we recognise that it is not strictly the remit of the Practice Guide consultation to
call for this, it is impossible to see how it can be implemented in those areas where such services
have already been removed or operationally curtailed. English Heritage MUST take the opportunity
of using this feedback to indicate to the Government that implementation of this PPS is reliant upon
such services and resources being in place.

The definition once again incorrectly refers simply to \u201chuman endeavour\u201d. Note the
comments we have given above regarding wider areas of environmental heritage that are also
contained within the information held in modern HERs.

The wording here could be more explicit in its meaning. For example, the phrase \u201c...planning authorities may find it useful to:..\u201d is easily dismissed, and should be more proscriptive for use in an effective planning system (\u201clocal authorities should:\u201d would be far better). A bullet point indicating that: \u201clocal authorities should make reasonable policy provision for exploring the possibility

example of such provision can be seen in Surrey, where local planning policies requiring
archaeological assessment and if necessary evaluation prior to development on sites over 0.4
hectares in size have resulted in the discovery of a number of sites, some of regional or national
significance. Such sites have the potential to reshape our interpretation of past settlement and
occupation in the south-east of England, and sites of comparable importance must remain as yet
undiscovered across the rest of the country.

Information regarding heritage provision within Local Development Frameworks is not clear
or easily digested. It should be recognised within the LDF process that policies regarding the historic
environment must be included in Core Strategies. There appears to be conflicting advice on this
issue being given to local authorities, with the result that some authorities do have heritage-specific
policies within the LDF documentation, whilst others do not. This apparent confusion will not lead to
a sustainable or easily comprehensible national planning system. The Practice Guide should make
it much clearer that local authorities are required to have their own policies regarding the historic
environment, and where actually these should be located within the LDF documentation. In many
cases, it will sadly now be too late for local authorities to include historic environment policies within
their Core Strategies.

The large blank area in this box where the desk-based assessment procedure should be
outlined is not helpful and suggests that there was inadequate input from archaeological specialists
in the drafting of this Practice Guide (as they would instantly have noted the omission). See
discussion relevant to the inset box between paragraphs59- 60 with regard to this section also. With
regard to the text available for comment on evaluation, it must be stressed that this technique is not
only used when interest is indicated by assessment. It is frequently used where assessment has
proven to be inconclusive, and is indeed, our only fully reliable method whereby a site can be
examined for the evidence relating to non-visible archaeology or prehistoric remains. The phrase
\u201copening up\u201d and the suggestion of CCTV as a technique of archaeological evaluation further
suggests a lack of expert input in the drafting of these paragraphs, which we strongly recommend is
rectified following this consultation.

With reference to the final sentence, it should also be pointed out that there are a great
many historic environment specialists and archaeological experts working in relevant organisations
that arenot members of the Association of Local Government Archaeological Officers. ALGAO is
not an inclusive organisation, so the majority of Archaeological Development Control Officers, HER
Officers, Landscape Advisors, Finds Liaison Officers and Conservation Officers working within local
authorities and who should be listed within this section as useful contact points, are specifically
excluded from ALGAO\u2019s membership by its selective constitution. RESCUE suggests that either this
is taken into account within the wording of this section, which should be changed to recommend the
relevant local authorities as the appropriate contact point,or (and most preferably), English
Heritage, as a major sponsor of ALGAO, should strongly encourage the body to revise its
constitution and make its membership more inclusive and relevant.

This paragraph appears to be focussed almost exclusively on standing buildings. Some
consideration is required to make the paragraph relevant to all heritage assets \u2013 including buried
remains and landscapes.

A statement should be added outlining that where the understanding of significance has not been adequately determined, it is reasonable for the local authority to request further research and possibly archaeological fieldwork to reach a planning decision.