Identifying 'heritage significance' in EIA
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Wardell Armstrong's Dave Hodgkinson discusses the controversial top-down approach to assessing the significance of heritage assets in environmental impact assessment (EIA)
The use of the term “significance” when discussing impacts is part of the established terminology of the EIA process. However, significance and its identification has become a central theme of heritage assessment and have effectively replaced “importance” or “sensitivity”, when discussing archaeological or built heritage assets.
The adoption of the concept of significance has caused some disquiet, not least because the term does not appear in any of the primary legislation relating to scheduled ancient monuments, listed buildings or conservation areas (AMAA 1979, P(LBCA) 1991) and was to be included in the heritage protection review, which has been postponed.
English Heritage, in its programme of presentations introducing the concept of “heritage significance” have been at pains to state that the term is synonymous with importance and that the terms are interchangeable; similarly, “values” can replace “interest”.
The concept of heritage or cultural heritage significance was first used in the Burra Charter (1979) which established that cultural significance means the “aesthetic, scientific, social or spiritual value for past, present or future generations” of a site.
English Heritage, in its Conservation Principles (2008), adopted the concept of heritage significance to encompass “the sum of the cultural and natural heritage values of a place”, the values being defined as aesthetic, communal, evidential and historical.
The use of the term “significance” with relation to heritage assets then appeared in the Planning Policy Statement 5 and was defined as “the value of a heritage asset to this and future generations because of its heritage interest”.
The interest may be archaeological, architectural, artistic or historic. The discrepancy between this and English Heritage’s conservation principles was noted in a footnote.
The definition of significance was further amended in the national planning policy framework (NPPF) to state that significance may be derived from the asset’s setting as much as from its physical form.
How do you establish heritage significance?
The County Historic Environment Record (HER) contains information on all known archaeological and historical sites, buildings and landscapes on a county-by-county basis. However, the HER does not provide quantification of significance.
Sources that can assist in the determination of significance, include:
- English Heritage selection criteria for listing buildings based on historical development, key features rarity and value;
- English Heritage monuments class descriptions, for archaeological sites, with criteria which include rarity and completeness, (formerly in PPG16);
- English Heritage has recently produced themed guides on designation scheduling selection, on topics such as transport, which provide a more holistic approach based on values; and
- Regional research frameworks which present assessment of the archaeological resource of a region identifying gaps and opportunities for understanding and protection.
The available criteria for identifying significance all relate to the aesthetic, historic, archaeological or architectural values and are based on professional opinions.
The attribution of significance is therefore the result of a top-down assessment and based on what a select group of professionals consider should be preserved.
How then is the communal value of a heritage asset assessed, taken into consideration and evaluated at EIA level? And what happens when public opinion differs from that of the informed professional?
In general, when undertaking an EIA or any other heritage assessment, it’s not possible to undertake widespread public consultation beyond exhibition events. The “significance” of a heritage asset therefore seldom includes the value to local communities, and, when consulted, community opinion can run counter to professionals’ as to what is worth preserving. Two recent cases prove this point.
The first involved a derelict industrial monument, which was a scheduled ancient monument and grade II listed building. While emblematic of an industry for which the town was once world famous, the building was considered as an eyesore and a barrier to the redevelopment by the local community.
Due to its status it was ring fenced within the masterplan and saved; it is now sitting within a modern regeneration scheme facing an uncertain future and local opinion is that the funds used to save it should have been redirected to other causes.
The second case involves a large, Victorian hospital, also in a state of decline. Two heritage assessments have concluded it is not of sufficient quality to be listed, but that it is of local value.
The community have a strong attachment to the building as a landmark and as a significant part of their daily lives; many were born, cared for or had relatives who had passed away in the hospital.
Despite this attachment, and a set of strong communal “values”, the building was not listed and therefore not preserved. The building will be demolished to make way for housing.
Both cases demonstrate that, despite the principles of heritage significance assessment which places an emphasis on communal values, the overriding factor in determining significance remains the established top-down approach.
The determination in the NPPF that heritage assets should be preserved “in a manner appropriate to their significance”, will continue to generate conflict.
Until a systematic methodology is developed and adopted for assessing communal values as part of heritage significance, the established system of informing local communities of the significance of their built environment will persist and continue to throw up challenges.
It remains to be seen how this can be addressed under the proposals put forward within English Heritage’s national heritage protection plan.
This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.
Dave Hodgkinson is technical director (archaeology and heritage) at Wardell Armstrong
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