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 NPPF. MHCLG’s ‘seismic regearing’ in this draft 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 focuses on:
- Recognising the role of the historic environment and heritage assets throughout the NPPF. We advise that the role of the historic environment and heritage assets needs to be embedded in topics such as sustainable development, climate change, supporting growth, green belt, design, healthy communities and the natural environment. Historic parks and gardens are part of our green infrastructure and vital to moderating climate impacts, nature recovery, and our health and wellbeing.
- Strengthening protection for registered parks and gardens. This is our most pressing concern, to ensure full recognition and protection for historic parks and gardens. We advise 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’, and for the reinsertion of ‘ less than substantial harm to the significance of a designated heritage asset ‘ (NPPF 2024 paragraph 215).
- Clarifying statutory status. We urge the government to implement Section 102 of the Levelling-Up and Regeneration Act 2023, which would introduce a much-needed statutory duty to have special regard to registered park and gardens.
- 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.
