British Archaeology, no 9, November 1995: Comment

Back in late July, the Welsh Office published a document which, if implemented, will almost certainly mean trouble for conservation in Wales.

The document, Planning Policy Guidance (Wales), was circulated for comment at the height of the holiday season. A decision is now imminent on whether it will receive the final stamp of government approval.

The scale of the threat to conservation in Wales is out of all proportion to the interest this document has hitherto attracted. A press release issued in September by CBA Wales, the Institute of Field Archaeologists, and the Association of County Archaeological Officers, received little media coverage. It can only be assumed that the words `government', `planning', and `guidance' induce such immediate and total mental paralysis that few journalists felt inclined to tackle the story.

However, the consequences for Wales of Planning Policy Guidance (Wales), or PPG Wales, could include the destruction of archaeological sites which might otherwise have been protected, and the demolition or alteration of historic buildings which might otherwise have been saved.

Why? Because PPG Wales cancels all existing government guidance to local authorities in Wales, replacing a series of detailed documents (or PPGs) with a single document that is short, weak, and unclear. PPG Wales condenses, and simplifies, no fewer than 23 existing PPGs into a single document of fewer than 200 paragraphs.

PPG16, for instance, the ground-breaking document that established the importance of archaeology in the planning process, which was published in Wales in 1991, has been reduced in PPG Wales to a mere four paragraphs. Gone is the `presumption in favour of physical preservation' of important archaeological remains threatened by development. Gone too is the clear requirement that archaeological reconnaissance is made of development sites before planning applications are decided.

PPG15 - the highly-regarded document that covers historic buildings, conservation areas and other aspects of the historic environment - was published only last year in England and has not yet appeared in Wales. In PPG Wales, however, its original 60 pages have been reduced to just over six. Gone are no fewer than 30 complete sections, including those on the setting of listed buildings, trees in conservation areas, and spot listing. Other sections, for instance on World Heritage Sites and Historic Parks and Gardens, have been truncated to two sentences. Such a level of reduction suggests not precis but emasculation.

PPG Wales was originated at the Welsh Office during the incumbency of the former Welsh Secretary John Redwood - a politician known for his penchant for efficiency. There are several reasons, however, why PPG Wales will produce a less efficient service than the present system.

The first reason relates to what PPGs are actually for. PPGs state the criteria by which the Government expects decisions to be taken by local planning authorities, and they provide detailed practical guidance. PPG Wales, in being a simplified document, self-evidently provides less practical guidance than exists for local authorities in England. However, it is generally accepted that Welsh authorities need more guidance than English authorities in matters of conservation, not less, because their in-house expertise is presently limited.

Secondly, with PPG Wales a whole new tier of government advice will be created. The detailed guidance missing from PPG Wales will, supposedly, be provided by Technical Advice Notes (or TANs). However, nobody has yet seen what advice these TANs will contain. If they are closely based on the cancelled PPGs, the whole exercise becomes pointless. If, however, they depart from the PPGs in spirit or detail, the Government will have to explain why it is prepared to countenance a different level of care on the two sides of the Welsh border. TANs will introduce unnecessary complication into the system; and they will have a lower status than PPGs and be more easily disregarded.

Thirdly, PPG Wales will be monolithic and inflexible. Whereas individual PPGs can easily be updated, the `comprehensive' PPG Wales will be cumbersome to change.

The present Welsh Secretary, William Hague, must set PPG Wales aside. Instead, PPG16 (Wales) could now be reviewed, and PPG15 introduced forthwith into the Principality.

Richard Morris is the Director of the CBA