The Gardens Trust has submitted a detailed response to the government’s consultation on the National Planning Policy Framework (NPPF).
We welcome the aims to clarify the National Planning Policy Framework (NPPF) and this ‘seismic regearing’ also opens up the opportunity to clarify how we protect our park and garden heritage through planning policy and statutory status.
The Gardens Trust’s response to the proposed NPPF reforms centres on 5 main concerns about how historic parks and gardens are protected through planning policy and identifies opportunities to achieve this.
- Recognising the historic environment throughout the NPPF. We welcome the new framework and its structured policies, but advises that heritage considerations are currently treated as peripheral rather than embedded across all planning policies. In particular historic parks and gardens provide vital green infrastructure throughout the environment — moderating climate, supporting nature recovery, and enabling recreation — and should be treated accordingly.
- Integrating heritage across all policy chapters. We welcome the dedicated historic environment chapter as essential guidance on a complex subject, but advises that heritage must be woven into other chapters including climate, design, and economy, rather than appearing as an afterthought. Small wording amendments throughout the document could achieve this.
- Strengthening protection for registered parks and gardens. This is our most pressing concern, to ensure full recognition and protection for historic parks and gardens by all stakeholders. We advise that registered parks and gardens should have their own distinct sub-section in the NPPF (alongside World Heritage Sites and Conservation Areas), given their unique scale and complexity. We call for harm to all registered parks and gardens — regardless of grade — to be considered “wholly exceptional,”. We strongly object to the removal of the “less than substantial harm” distinction from Policy HE6, which we regard as an essential nuanced tool in planning decisions, particularly for Registered parks and gardens as a particularly complex land-based designation.
- Clarifying statutory status. We urge the government to implement Section 102 of the Levelling-Up and Regeneration Act, which would introduce a formal statutory duty to have special regard to registered parks and gardens. Currently these sites are misleadingly categorised as “historic non-statutory” in government mapping tools, leading to inadequate planning assessments.
- Increasing specialist advisory resources. We highlight a significant shortage of expert practitioners advising decision-makers on historic designed landscapes, and suggests expanding its own statutory consultee role — contingent on additional government funding.
