9th March 2026.
(by email: PlanningPolicyConsultation@communities.gov.uk)
Dear Planning Policy Consultation Team,
The Prehistoric Society is dedicated to furthering the understanding of our prehistoric past and conserving prehistoric remains for the future. Our members are passionately interested in prehistoric sites, collections and excavations both in Britain and abroad.
In this capacity, we are writing to respond to the consultation on the proposed reforms and other changes to the National Planning Policy Framework. Our responses relate particularly to policies H1-10, and questions 185-191 in the questionnaire to the government consultation.
To begin (q.185), the Society agrees with the importance of implementing the additional duties under Section 102 of the Levelling-Up and Regeneration Act, given the central important of heritage in creating and managing sense of place and community. The regeneration of communities must have regard for the heritage of the people and areas which constitute these communities. To quote the current NPPF, section 16 underscores that “Heritage assets are an irreplaceable resource and should be conserved in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of existing and future generations.” It is therefore imperative that its importance is clearly recognised in the new reforms.
The setting of sites is of particular importance for the prehistoric sites which are the particular focus of this Society. Their natural fragility, the massive timespan covered by many prehistoric sites, and the paramount importance of their setting, all reinforce the need for specialist input when assessing asset significance. In particular in assessing the significance of its setting, as laid out in paragraphs 194 and 195 in the existing NPPF: especially avoiding being hemmed in by modern buildings as well as preserving sightlines.
With regard to question 187 (“Do you agree with the approach to plan-making for the historic environment, including the specific requirements for World Heritage Sites and Conservation Areas, set out in policies H1 – H3?”), we agree wholeheartedly that world heritage and conservation areas are by definition of extreme importance, both now and in the future. As irreplaceable site of heritage, and community- and identity-making, it is imperative that they are cared for and that that care is frequently reassessed and reassured by specialists. We do, however, strongly recommend adding the need “to identify, assess, and conserve” as far as possible the setting of “heritage features” in HE1.1.a, as in the wording for World Heritage Sites in HE2.
In response to questions 188 and 189, we agree that the approach to assessing the effects of development on heritage, laid out in H5 appears sufficient. These elements need to be considered from the planning stage and integrated throughout, and the onus should be on the applicants and developers to ensure these are undertaken. It is the duty of specialists to ensure these are made and fulfilled to the highest standards. We also agree with the paramount importance of bringing vacant historically-significant buildings back into use and to bring their use in line with current and developing energy standards to improve liveability and to address as the growing climate energy. All mitigations brought up in HE6 seem reasonable to ensure sensible use.
We thank you for all your work in reforming the NPPF and wish you a smooth remaining passage of the reforms, carrying the importance of heritage assets to communities and the vital place of setting in understanding, appreciating, and ensuring the survival of heritage assets, particularly heritage assets constructed in prehistory, for future communities and taking a part in combatting the climate crisis.
Yours faithfully,
Dr George Prew-Stell Dr Robert Bewley
Advocacy Officer, Prehistoric Society President, Prehistoric Society