From a heritage perspective, one area that needs to be clearer as the White Paper progresses is conservation – the process of managing change to a heritage asset and not simply preserving the status quo. This is one area that is inherently subjective and reliant on professional judgement.

Understanding what is important about a place (or significance) is what matters; and then responding and complementing that significance with new development.

But these are two areas that are arenas for debate: First, what is important, and to whom? Second, the appropriateness of any new development.

How much certainty can the Government provide to a topic area that is inherently uncertain and often the cause of delay to planning applications?

The White Paper attempts to give confidence through national and local design codes evocating historic Neo-Classical pattern books, an approach stemming from the idea of “Beauty”. That concept has its recent origins in the Building Better, Building Beautiful Commission and its report Living with Beauty (January 2020) – a response to the perceived falling median of design quality.

The idea of raising the threshold for acceptable design is excellent and welcome to many, looking towards higher standards and, as Christopher Katkowski QC recently remarked, to avoid slums of the future.

But exactly whose idea of beauty will triumph and therefore influence what will be built on or near our historic places?

Research by the think tank Demos has shown “engagement in the planning system is often dominated by those that are less supportive of new homes in their local area” (People Powered Planning, 2019 pp. 5). And so the Government’s aspiration of democratically-led local design guides must strive to be a broad church, finding those people that do not normally engage in planning matters, helping to avoid a single form of development that may not appeal to all.

At the same time there is research suggesting that “People are attached to local materials and to vernacular ways of building that have inserted themselves comfortably into the landscape” (Living With Beauty, pp. 33). The direction set by the Government, influenced by that thinking, appears to focus on a conservative type of heritage and beauty, one that looks towards the arguably fetishised period of the eighteenth century, and also to rural England in particular.

I am relieved to hear that there will still be a place for bold architecture that lies outside of design codes, subject to making a persuasive and robust case. Without that flexibility we risk losing the joy of exciting and innovative architecture like Gianni Botsford’s House in the Garden in Notting Hill; or the bold design of Herzog and de Meuron’s 2016 Blavatnik School of Government in Oxford’s historic centre.

But make no mistake: to deliver such projects outside of the proposed “growth” areas will require keen advocates and negotiation with planning authorities. Heritage is subjective and hotly debated, in the same way that our understanding and feelings about "beauty" differ between communities.

Instead, I would suggest more certainty in heritage cases could come from reallocating funds from the streamlined planning system to under-resourced conservation teams in local authorities.

Experience shows that officers with time to give consistent well-considered advice, and from a place of local knowledge, provide more certainty for our clients and so accelerate the pre-application process in exactly the way that the Government intends.