Controls which do not appear
in the HPR programme
Conservation areas
156. Conservation Areas were established in the Civic
Amenities Act 1967 as areas of "special architectural or
historic interest the character or appearance of which it is desirable
to preserve or enhance". Initially the sole protection afforded
was simply a requirement for extra publicity to be given to planning
applications and a duty for local authorities to pay special regard
to the desirability of preserving or enhancing the character or
appearance of such areas. There was no control over demolition,
although this was soon recognised as a major shortcoming and remedial
measures were introduced in 1974. Although we did not concentrate
upon controls in conservation areas during the inquiry, we gained
the impression that the original aspirations for conservation
areas have never been matched by an adequate regime of control
to enable local authorities to manage them.[301]
Mr Venning, Secretary of the Society for the Protection of Ancient
Buildings, told us that it was "surprising what you can get
away with in a conservation area",[302]
and we are advised that there are for instance more controls over
works to trees in conservation areas than to the extension or
alteration of facades of buildings.[303]
We identify two particular failings: demolition control (compromised
by the 1997 Shimizu decision, the effects of which are
not confined to conservation areas), and the disincentives for
local authorities to use powers to suspend permitted development
rights.
157. The notorious Shimizu decision effectively
permitted owners of most unlisted buildings in conservation areas
to demolish a part of their building without the consent of their
local authority; only demolition of the whole building required
consent.[304] The decision
also made explicit that any proposals involving only relatively
minor demolitions need not be notified to the national amenity
societies. The decision is widely seen as perverse, and we were
told that the present Government had indicated soon after the
decision that it would try to resolve the situation.[305]
DCMS announced in its 2003 consultation paper on the historic
environment that existing controls over demolition were to be
considered as part of the research under way for the review of
the General Permitted Development Order;[306]
but there is little sign of any result. According to witnesses,
several Ministers had indicated that they wanted to bring forward
legislation to change the position, but time had not been found.[307]Baroness
Andrews gave us an assurance that the forthcoming White Paper
would address the problems caused in the light of the Shimizu
ruling, and she said that her Department would "certainly
be taking account of Shimizu, hopefully restoring the levels
of control that were in place before"; but little appears
to have been done so far to undertake any systematic collection
of evidence of damage caused by the ruling.[308]
The Government's approach
in addressing the Shimizu decision has been dilatory
and unacceptable. Nothing is to be gained from further delay,
and steps to place the previous understanding on a secure legal
footing should be given a high priority.
158. It is possible for local authorities to introduce
greater protection for buildings in conservation areas by suspending
householders' automatic right to undertake certain work without
planning permission, by issuing what are known as Article 4 Directions.
These require prior public consultation but are cumbersome to
administer and enforce, vary in what they control from area to
area, and may subject the local authority to claims for compensation
by owners denied the opportunity to make such alterations.[309]
As with Shimizu, the Government has indicated that it would
consider the reasons why local authorities are reluctant to use
their powers to withdraw permitted development rights in conservation
areas;[310] but once
again progress seems painfully slow, despite support for change
from practitioners.[311]
DCLG should aim to complete
its consultation on the General Permitted Development Order and
bring forward a statement of intent by the end of 2006.
The case for a statutory duty of care
159. There is no general duty, either under statute
or at common law, on the owner or occupier of a building to do
anything to stop it falling into a state of advanced decay. It
was suggested to us that a statutory duty of care, such as that
placed upon housing associations, would be an effective way of
forcing owners - private or public - to maintain their properties
in good condition.[312]
The Planning Officers' Society envisaged such a duty for local
authorities.[313] Others
believed that such an approach would be wrong, at least for private
owners. The Historic Houses Association and the Country Land and
Business Association argued that what the government policy framework
should encourage was the willing cooperation of owners, and the
HHA told us that "the stick is there for the basic protection,
the carrot for doing the positive conservation".[314]
We believe
that a statutory duty of care could be a significant disincentive
to private owners to take on properties where unique features
and required conservation standards make maintenance particularly
expensive or problematical, and we reject the idea.
Buildings at Risk
160. The concept of defining Buildings at Risk was
developed by English Heritage in the mid 1980s, and a policy was
launched in 1987 jointly with a small number of pilot authorities.
Listed buildings were assessed against a formula based on condition
and occupancy and placed in one of six grades ranging from bad
condition and vacant (Risk Grade 1 - seriously threatened) to
good condition and fully occupied (Grade 6 - not at risk). In
almost all cases this could be done by an external inspection
and the exercise enabled buildings at risk to be prioritised for
grant aid or statutory action either to urgently and temporarily
keep the building standing or to effect more permanent repairs
by the owner (or by the local authority in default). Local authorities
have statutory rights of entry if necessary to survey buildings
and powers to require works to be done under both historic building
and planning legislation. Generally this work for conservation
officers is a low priority, partly because of inadequate legal
guidance and definitions of the actions possible; partly as a
result of local political inertia; and partly because it is long-term,
time-consuming workload. There is no statutory requirement to
undertake buildings-at-risk work; it is done as good practice
by conscientious local authorities, and we heard that a very large
number of local authorities did not have such registers.[315]
We have already noted (at paragraph 109) the case for including
the maintenance of Buildings at Risk registers as an ingredient
of statutory services to be provided by local authorities. A survey
by English Heritage in 1990-91 of 43,000 listed buildings in different
parts of England found that 7.3% were at risk and that another
14.6% were vulnerable.[316]
We understand that these proportions are not believed to have
changed significantly since, although no further systematic study
has been undertaken".[317]
English Heritage established its own register of Grade I and
II* Buildings at Risk in 1998 and calculated that £400 million
would need to be spent to remove their "at risk" status;
this figure was confirmed to us in oral evidence.[318]
We note that English Heritage has had some success in recent
years in reducing their tally, which has gone down from 1,615
in 1999 to 1,430 in 2005.[319]
World Heritage Sites
161. World Heritage Sites are at the top of the hierarchy
for the historic environment, being recognised as "of outstanding
value" and included on the World Heritage List held by UNESCO.[320]
There are currently 26 World Heritage Sites in the UK,[321]
ranging considerably in extent from Durham castle and cathedral
to the Saltaire model village based upon a textile mill near Bradford,
the Victorian mercantile heart of Liverpool and the entire centre
of the city of Bath.
162. World Heritage Sites are not recognised specifically
in statute (unlike National Parks or Areas of Outstanding Natural
Beauty).[322] They
are a material consideration to be taken into account by a planning
authority when considering a relevant planning application, and
the Chairman of English Heritage told us that they were "better
regarded" than other sites in the planning process.[323]
Mr Burton, Director of Policy at the National Trust, suggested
that there was an opportunity for additional protection: he observed
that "at the moment in planning terms World Heritage Site
status does not offer anything particularly special" and
that "the strength of the presumption against damaging development
for World Heritage Sites is not as strong as it needs to be",
particularly in relation to factors outside the planning process
such as inappropriate agricultural practices or major road infrastructure
schemes.[324] The Borough
of Telford and the Wrekin, in which the Ironbridge Gorge World
Heritage Site is situated, called for statutory designation for
Sites to ensure their protection.[325]
163. The most striking example of a World Heritage
Site suffering from such factors is Stonehenge, where the situation
remains degrading. Sir Neil Cossons was optimistic that there
was considerable support for current proposals being put forward
by the Department for Transport, and he hoped that the dignity
of the monument could be restored in time for the 2012 London
Olympic Games.[326]
Thirteen years ago, the Committee of Public Accounts identified
the standards of presentation and facilities at Stonehenge as
"a national disgrace"[327]
and it is shameful that delays to the road scheme have allowed
so little progress to be made. Sir Neil Cossons told us that there
was "an opportunity, uniquely … to sort Stonehenge out"
and that that nettle had to be grasped now, or another decade
would pass in which the people of the south-west would suffer
inadequate transport links and another eight million visitors
would "enjoy or endure" the site.[328]
All interested parties should
recognise that it is in the interests of the general public that
the current opportunity to reach a solution at Stonehenge should
not be lost.
164. In relation to statutory controls, not everyone
believed that there was a need for increased protection. Mr Lammy
was doubtful,[329]
and Mr Burchnall said that within the Sites themselves it was
"difficult to see what additional controls you would need
to introduce".[330]
Almost all Sites are covered by conservation area status (which
offers a degree of special protection), and local planning authorities
would have to consider the impact of proposals for nearby development
or tall buildings, as has been the case for the Liverpool World
Heritage Site.
165. There was more support for World Heritage Sites
to be recognised specifically under the proposed new designation
regime under the Heritage Protection Reform programme. Sir Neil
Cossons saw a need to look at what provisions there were and to
determine what was "possible and practical";[331]
and Mr Lammy said that it was important that Sites should be brought
into line with the new regime.[332]
The benefit would appear to be simply to offer a very distinct
signal of a Site's value.
166. Designation of a World Heritage Site does place
a burden upon the relevant local authority. It may take on responsibility
for preservation of the Site and provision for possibly substantial
numbers of visitors; the Borough of Telford and the Wrekin told
us that a considerable level of resources had been diverted to
carry out those responsibilities.[333]
Local authorities are also required by PPG 15 to formulate specific
planning policies for protecting such sites and to include those
policies in their development plans.[334]
Liverpool City Council told us that there were "costs associated
with doing that management plan" which went beyond the City
Council's own resources and which caused the Council to look for
external funding.[335]
Preparing information to support the initial application for inscription
as a Site is also time-consuming. The Local Authority World Heritage
Forum called for direct funding from DCMS to bodies implementing
World Heritage Site management plans, to help with the costs of
major infrastructure or preservation work.[336]
167. Some local authorities employ a World Heritage
Officer, to oversee custody of the Site, promote it and manage
its tourism, education and employment potential. It
is a judgment for each local authority as to whether the benefits
of employing such staff outweigh the costs, and we do not believe
that there should be a mandatory requirement for local authorities
to do so. We recognise that World Heritage Site status can place
extra cost processes
on local authorities and we believe that regional development
agencies should do more to recognise the strategic importance
of World Heritage Sites to local communities and to help local
authorities with these costs to maximise the benefits of World
Heritage Site status.
Fiscal policy to support heritage
protection
168. Two main routes are open to the Government to
provide financial support for the protection of heritage assets:
direct grant aid and tax relief. We have considered direct grant
aid through English Heritage and through the Heritage Lottery
Fund - at paragraphs 29 and 66 above. We concentrate here on different
forms of relief.
VAT
169. VAT, as a tax chargeable on business transactions,
goods and some services, applies in the heritage field to materials
for repair, the labour cost of repair when undertaken by firms
registered for VAT, and professional services required in preparation
for repair work, such as surveyors' and architectural consultants'
fees. Whereas the construction of new buildings has attracted
a zero-rate of VAT since its introduction in 1973, the repair
and maintenance of buildings has always been standard-rated. Until
1984, all alterations were zero-rated; the zero-rate was then
generally withdrawn for work on alterations except for work carried
out in the course of an approved alteration to a listed building.[337]
170. The harmonisation of tax policy at an EU level
normally prevents the Government from applying zero-rating (or
a reduced rating) of VAT to new fields (or extending existing
zero-rating). Agreement was however reached among EU Finance Ministers
during the UK EU Presidency in 2005 which afforded a window of
opportunity to apply to exercise an option to introduce a reduced
rate of VAT on the labour input of renovation and repair work
to private dwellings.[338]
The window closed on 31 March 2006 without the UK Government having
made an application, despite encouragement from English Heritage
and others.[339]
171. The issue of VAT-rating for repairs to listed
buildings united the sector perhaps more than any other in evidence.
We were told that the differential between rates applicable to
new build construction costs and repair costs penalised maintenance
and created perverse incentives.[340]
It encouraged alterations to listed buildings (at zero-rate);
and it encouraged owners to leave buildings to rot to such a state
that demolition was justified.[341]
The Campaign to Protect Rural England argued that the favouring
of new-build encouraged greenfield development but stagnation
of previously developed land, which contributed to a cycle of
decline and a trend towards rundown areas which were less attractive
to investors.[342]
The Architectural Heritage Fund drew our attention to the gains
for sustainable development arising from re-use and retention.[343]
172. We note that the former ODPM itself recognised
the cost-effectiveness of repair and refurbishment, citing evidence
from Heritage Counts 2003 demonstrating that older housing
"costs less to maintain and occupy over the long-term life
of the dwelling than more modern housing". ODPM found that
when the energy costs of demolition, site remediation and new
construction were taken into account, there was "an even
stronger argument for promoting the re-use of the historic built
stock".[344]
173. Heritage Link wrote to the Chancellor of the
Exchequer in March 2006 listing the various reasons why reduced
or zero rating should be introduced for repairs to listed buildings,
and urging him to take advantage of the window of opportunity
secured by EU Finance Ministers. The Treasury made no such move.
174. The Government has cited two reasons for resisting
calls to reduce or zero-rate VAT for repairs to listed buildings.
The first, in response to the report by the former ODPM Select
Committee on The Role of Historic Buildings in Urban Regeneration,
was that the Government "had seen no compelling evidence
that the absence of a reduced VAT rate on repairs significantly
hinders the maintenance of historic buildings, and no evidence
that most of the benefit of a blanket relief for repair and maintenance
work would not just go to middle and higher income households
making improvements to houses already in a good state of repair".[345]
The second reason given, this time in response to a Parliamentary
Question tabled by the Committee Chairman asking whether the Government
would take up the opportunity afforded by the European Commission,
was that a reduced rate for the renovation and repair of private
dwellings was "one of a number of reduced rates introduced
into EU legislation on an experimental basis whose objective is
to create employment opportunities by stimulating demand through
lower prices" and that the Government had always chosen not
to participate, as it believed that its employment objectives
were "better targeted through measures such as the welfare
to work strategy and the New Deal".[346]
175. In the past, the Minister of Culture (Mr Lammy)
has described the case for change to the existing regime applicable
to repair costs as "unproven".[347]
When the question was raised with him in oral evidence, he said
that the he was "in constant dialogue" with Treasury
colleagues on the issue but that "gains specific to the heritage
sector might mean losses in other areas like new construction
and other things".[348]
He did not however offer a specific rationale for favouring new
build; nor was any given in the Government response to the ODPM
Committee in 2005.
176. Mr Lammy told us that it would "be unusual
to restrict that kind of VAT relief [i.e. zero-rated] to one sector".[349]
This is not a convincing argument, given that the Treasury has
agreed to refund VAT payments for repairs to listed places of
worship and memorials. The Chancellor announced in the 2006 Budget
that the refund scheme would continue until 2010-11 and that it
would be extended to cover professional fees and repairs to fixtures
and fittings.[350]
177. The present
VAT regime for repairs distorts priorities, rewards neglect and
works against conscientious maintenance of historic assets. The
result can be either a slide towards demolition or a call on public
funds for grant aid. We find it extraordinary that the Government
did not take up the opportunity afforded by the EU earlier in
the year to seek a carefully targeted relief when urged to do
so by Heritage Link, on behalf of the sector. Opting in would
have cost the Government nothing. The chance to secure such a
relief has passed for now, but the Government should instead take
a policy decision to return as grants some or all of the VAT paid
on repair work to listed buildings. At the very least, building
preservation trusts and other charitable institutions should be
beneficiaries of such a scheme. In addition, proper consideration
should be given to including heritage properties in private ownership
where a clear public benefit can be demonstrated. The Treasury
should recognise that the majority of potential private owner
beneficiaries would not be high income earners; and many of the
buildings at risk that would stand to benefit are not residential
properties.
Fiscal relief for private owners
178. The Historic Houses Association proposed a "new
limited fiscal relief" for the maintenance of historic buildings,
to help fill the funding gap caused by the fall in the level of
grant support from English Heritage.[351]
It pointed out that such a relief would allow owners to have more
control over the timing of conservation work and possibly to secure
better value for money.[352]
The Association expanded on the idea in oral evidence, suggesting
that it be framed as an annual relief capped at a certain level
and offsetting the cost of repairs against owners' personal income.
The trade-off would be a degree of public access, similar to that
required for a grant from English Heritage.[353]
179. This is not a new problem: the Historic Houses
Association told us that the threat 30 years ago had been "really
bad" and that after the Second World War up to a thousand
houses had been demolished and major sales had taken place. The
situation may be less severe currently, but it is undeniable that
the range of grant funding available is not as great as it was.
The National Trust, we were told, was no longer in a position
to take custody of such houses;[354]
and it was put to us that without some form of Government support,
houses would gradually become denuded of effects and would eventually
be sold.[355]
180. The Chair of the Heritage Lottery Fund listed
three choices for a private owner of a historic building: maintain
it, turn it into a trust (thereby opening the door to support
from the Fund) or sell it.[356]
The question is: which option is of greatest benefit to the general
public? Sale of the home may bring in a new owner and a new source
of money to be spent on necessary repairs but offers no promise
of any gain in terms of public access. The trust solution offers
benefits to both the owner and the public. The argument put to
us by the Historic Houses Association, however, favoured preserving
a historic home as a live asset, in family ownership, in return
for public access. Much of the appeal of Doddington Hall in Lincolnshire
was the distinctive way in which the house had been furnished
and the signs that the house was lived in rather than solely for
display. It should not be assumed that all owners of significant
buildings have at their disposal sufficient funds to ensure the
maintenance and repair of these national assets. For those who
are prepared to offer a reasonable degree of public access, an
incentive in the form of a limited tax relief would be effective.
The total annual sum and the level of relief for each applicant
could be capped at a level that ensures an equitable distribution
of this incentive and prevents the pool from being scooped by
the largest applicants. We
recommend that DCMS should encourage the Treasury to assess the
cost of a limited relief set against income for private owners,
subject to the same type of requirements as those placed on owners
under the Conditional Exemption scheme.
Incentives to encourage maintenance
181. Neglect of a building's fabric leads to damage
and decay which, if unchecked, can have consequences for the structure
of the building. Repair costs can rise exponentially as a result,
and the burden of meeting those costs may in time fall upon the
public purse. Mr Venning, Secretary of the Society for the Protection
of Ancient Buildings, was one of several who argued strongly in
favour of encouraging better maintenance, and he urged DCMS to
take a lead in convening an interdepartmental working party to
promote maintenance of buildings. not just for their own good
but as a way of increasing sustainability.[357]
182. Mr Wilkinson, representing Save Britain's Heritage,
pointed out that preventative maintenance could save public money
and that there was a case for maintenance grant funding as an
incentive.[358] DCMS
has recognised the validity of much of the argument and it indicated
in A Force for our Future in 2001 that it would "explore
[with English Heritage] how a shift of emphasis towards preventative
maintenance might be reflected in grant programmes".[359]
DCMS has in the past shown welcome signs of recognising the
case for grant funding to encourage preventative maintenance work
on buildings. It should now report on progress made in developing
policy on such grant funding.
250 The CPRE for example supported the general thrust:
Ev 73; the Planning Officers Society said that advice on PPG15
(and 16) 'guides local authorities wisely". Ev 156 HC 912-III,
Session 205-06 Back
251
See Association of Gardens Trust Ev 36 Back
252
Q 126 Back
253
Q 126 Back
254
Ev 7; see also Q 208 Back
255
PPG 16 paras 21-2 Back
256
Research by K Aitchison; 2003-04 figures are an estimate only;
no reliable figures are available for Scotland, Wales or Northern
Ireland. See Ev 8 Back
257
Archaeology Forum Ev 8 Back
258
Standing Conference on London Archaeology (SCOLA) Ev 335; Mr Ayers
Q 218 Back
259
Head of Cambridgeshire County Council Archaeology Service Ev 8;
Dr Bryant Q 127 Back
260
Ev 71 Back
261
Q 364 Back
262
Revisions to Principles of Selection for Listing Buildings:
DCMS/ODPM Consultation Document, July 2005, para 31 Back
263
Ancient Monuments Act 1882 Back
264
Ancient Monuments and Archaeological Areas Act 1979 Back
265
Ev 129, HC 912-III, Session 2005-06 Back
266
Ev 129, HC 912-III, Session 2005-06 Back
267
See The Way Forward, DCMS, June 2004, p 10 Back
268
Ev 130, HC 912-III, Session 2005-06 Back
269
Archaeology Forum Ev 6; ALGAO Ev 46; Dr Bryant Q 107 Back
270
Q 213 Back
271
Ev 414 Back
272
Historic Environment Services Local Delivery Project, WS Atkins
2006, paras 5.6.1 and 5.6.2 Back
273
Revisions to Principles of Selection for Listing Buildings:
Planning Policy Guidance Note 15, DCMS/ODPM Consultation Document,
July 2005 Back
274
Q 299; The Way Forward, p 14 Back
275
Q 6 Back
276
QQ 303-5 Back
277
English Heritage, Ev 143, HC 912-III, Session 2005-06 Back
278
DCMS Ev 135; Dr Dungavell Q1 Back
279
Ev 130, HC 912-III, Session 2005-06 Back
280
Q 367 Back
281
Ev 130, HC 912-III, Session 2005-06 Back
282
Q 307 Back
283
Q 307 Back
284
Q 228 Back
285
Ev 84 Back
286
Ev 142, HC 912-III, Session 2005-03 Back
287
Q 308 Back
288
Q 306 Back
289
Heritage Protection Review: Assessment of eight pilot projects,
Historic Environment Conservation, April 2006 Back
290
Archaeology Forum Ev 6, ALGAO Ev 45, RESCUE Ev 304 Back
291
Ev 4 Back
292
Ev 6 Back
293
Ev 6 Back
294
Ev 150, HC 912-III, Session 2005-06 Back
295
Ev 121, HC 912-III, Session 2005-06 Back
296
Ev 136 Back
297
National Trust Q 56; Country Land and Business Association Q 77;
IHBC and the Planning Officers' Society Q 107; The Archaeology
Forum Q 211; RIBA Ev 314. See also Mr Lammy Q 360 Back
298
Ev 45 Back
299
Ev 84 Back
300
QQ 368 and 370 Back
301
See Mr Wilkinson Q1 Back
302
Q1 Back
303
Advice from Mr Bob Kindred, Specialist Adviser to the Committee Back
304
Shimizu v Westminster City Council [1997] All E. R. 481;
see Protecting our historic environment: making the system
work better, DCMS, July 2003, para 65 Back
305
Mr Venning, Q 2 Back
306
Protecting the historic environment: making the system work
better, July 2003, DCMS, para 65 Back
307
Q 6 Back
308
QQ 363 and 365 Back
309
Advice from Mr Bob Kindred, Specialist Adviser to the Committee;
see also Mr Coupe Ev 130 Back
310
Protecting our Historic Environment, DCMS July 2003, para
66 Back
311
Planning Officers' Society Q 109; Mr Kindred Q 128 Back
312
Mr Wilkinson Q 24 Back
313
Ev 154, HC 912-III, Session 2005-06 Back
314
Mr Way, Q104 Back
315
Dr Crowe Q 237 Back
316
Buildings at Risk - a sample survey, English Heritage,
1992, ISBN 1 85074 364 9 Back
317
Advice from Bob Kindred, Specialist Adviser to the Committee. Back
318
Q 333 Back
319
Buildings at Risk 2005, English Heritage Back
320
Sites are established under the World Heritage Convention, adopted
by UNESCO in 1972 and ratified by the UK in 1984. Back
321
Hansard 14 December 2005 col. 480 WH Back
322
Ev 226 Back
323
Q 312 Back
324
Q 60 Back
325
Ev 53 Back
326
Q 359 Back
327
Committee of Public Accounts, Twenty-ninth Report, Session 1992-93,
HC 252, Protecting and Managing England's Heritage Property,
para 34 Back
328
Q 359 Back
329
Q 366 Back
330
Q 144 Back
331
Q 312 Back
332
Q 366 Back
333
Ev 53 Back
334
Para 2.23 Back
335
Mr Burchnall Q 147 Back
336
Ev 226 Back
337
Hansard Written Answer, 8 June 2006, col.859W Back
338
Ev 161 Back
339
Q 343 Back
340
Mr Babb Q 142; Mr Spooner Q 170 Back
341
Ev 74; SAVE Britain's Heritage Ev 318 Back
342
Ev 74 Back
343
Ev 16 Back
344
Government response to the Eleventh Report of the ODPM Select
Committee, on The Role of Historic Buildings in Urban Regeneration,
Session 2003-04, HC 47-I, response to recommendation 4 Back
345
The Role of Historic Buildings in Urban Regeneration, 11th
Report of the Select Committee on the Office of the Deputy Prime
Minister, Session 2003-04, HC 47-I Back
346
Hansard Written Answer, 13 March 2006, col. 1983W Back
347
Hansard Written Answer27 October 2005, col. 527W Back
348
Q 388 Back
349
Q 393 Back
350
Financial and Budget Statement Report 2006 para 5.75 Back
351
Ev 182 Back
352
Ev 187 Back
353
QQ97 - 100 Back
354
See Mr Burton Q 70 Back
355
Mr Hervey-Bathurst, QQ 95 and 105 Back
356
Q248 Back
357
Q 12; see also evidence from Maintain our Heritage, Ev 232. The
merits are set out in detail in Putting it off: how lack of
maintenance fails our heritage, published by Maintain Our
Heritage, November 2004. Back
358
Q 12 Back
359
A Force for our Future, DCMS, 2001, para 4.13 Back
