Memorandum submitted by the Country Land
and Business Association
COUNTRY LAND
AND BUSINESS
ASSOCIATION
1. The CLA represents the interests of 38,000
members in England and Wales who together manage over half the
agricultural land of those countries. Our membership is constituted
of landowners, and professionals who are acting on behalf of many
other farmers, both landowners and tenants. Our members are thus
involved in all aspects of rural land management and business
in England and Wales; including the management of landscapes designated
as National Parks, Areas of Outstanding Natural Beauty and Sites
of Special Scientific Interest. They manage land included in old-style
Countryside Stewardship Schemes and Environmentally Sensitive
Areas—now renamed the Environmental Stewardship Scheme—and
Tir Gofal in Wales.
2. CLA members own many of the listed buildings
and monuments of England and Wales, from Grade I properties through
to the thousands of Grade II unstarred buildings, many of which
are agricultural or commercial and not residential. These are
often part of the integrated working estates—big or small—of
rural landowning businessmen. CLA members also provide land and
capital for investment in farming or other rural business, and
they account too for 38% of private rented housing in rural areas.
They generate income and jobs in the rural economy and are involved
in rural tourism, from managing the landscape through to ownership
and management of tourist attractions and accommodation.
3. The purpose of setting out this wide
variety of activities is to draw attention to the integrated nature
of land business management and to put the ownership and management
of listed buildings, monuments and historic landscapes at the
centre of a wider picture, in which environmental stewardship,
the maintenance of buildings and the conservation of historic
monuments must be funded by economic activity. The best security
for the future of listed buildings, monuments and landscapes is
a successful rural economy, with economic use of buildings and
landscapes.
INTRODUCTION
4. Heritage is a wide concept that embraces
both man-made and natural historic assets. Our heritage includes
many thousands of listed buildings and scheduled ancient monuments,
a high proportion of which are situated in rural areas. They form
an essential part of the historical backdrop to how we live now.
The main uses of listed buildings are residential, agricultural,
commercial, and educational and other uses of benefit to the public;
some have no use. The public has a legitimate public interest
in the conservation of this heritage.
5. The vast majority of historic buildings
and monuments are privately-owned, situated on private land and
maintained, restored and repaired largely through private funds.
They can best be conserved, therefore, in the context of long-term
and viable land management.
6. A high proportion of all scheduled ancient
monuments, conservation areas, listed buildings and historic landscapes
are located in rural areas. But the maintenance of the historic
fabric of Britain, something most of us take for granted, is expensive,
and private owners, because most listed buildings are privately
owned, are effectively paying for an important public good. Without
these listed buildings—from small medieval cottages through
ancient farm buildings to grand stately homes—and historic
landscapes, the tourism industry would be much less effective
than it currently is.
7. Thus the importance of landowning to
the long-term management and conservation of this heritage cannot
be over-emphasised, and it is vital that Government finds effective
ways to work with and support private owners.
CLA ANSWERS TO
SPECIFIC CONSULTATION
QUESTIONS
1. What the Department of Culture, Media and
Sport should identify as priorities in the forthcoming Heritage
White Paper
The White Paper must include:
(i) Recognition that the best security for
the future of the rural historic environment is a successful rural
economy that permits new economic activities to take place in
listed buildings that are no longer used for their original purposes.
(ii) Recognition that listed buildings, monuments,
conservation areas and historic landscapes will be conserved through
the provision of enlightened and flexible planning, tourism, environmental
and regeneration policies that enable integrated management of
these assets, undertaken largely by the private sector, for the
benefit of current and future generations.
(iii) A commitment and programme to deliver
the Heritage Protection Review as described in "The Way Forward"
paper. Specifically: a single unified designation list, introduction
of statements of significance, and a statutory right of appeal
for owners in respect of new designations.
(iv) A commitment to putting a case forward
to HM Treasury for a strong, strategic funding stream, particularly
for English Heritage and for the conservation of the "everyday"
historic environment, commencing with the CSR 2007.
(v) A commitment to ensuring that the conservation
of the historic environment is a priority, especially with respect
to its importance as a nation-wide visitor attraction for, notably,
the Olympics. The historic environment and its conservation attract
high levels of national and international tourism and contribute
substantially to GDP.
(vi) A recognition of the contribution that
the historic environment makes to a range of government objectives,
and a commitment that the DCMS will act as the lead organisation
in this regard. The conservation of the historic environment cuts
across many Government departments, notably DCMS, DEFRA, ODPM
and others including HM Treasury, Transport, Education, Health,
and Trade and Industry.
(vii) A requirement to introduce "heritage
proofing" in policy development and decisions over land use
planning.
(viii) A commitment by DCMS to formulate
policies for beneficial tax treatment of the maintenance and repair
costs of heritage assets. Maintenance of the historic environment
is undertaken largely by private owners, at great expense (not
least because they are paying VAT at 17.5%), whether the assets
have an economic use or not.
(ix) A commitment for DCMS to resolve, with
ODPM, the current lack of resources to train and employ Conservation
Officers able to work in a constructive fashion with owners of
listed buildings.
(x) A commitment to DCMS support for traditional
building skills through LANTRA (DfE) and the EU Rural Development
Regulation Axis 3 and the Heritage Lottery Fund. English Heritage
and local authority Conservation Officers often require maintenance
and repair of historic buildings to be undertaken using traditional
skills and traditional materials, but traditional skills are in
serious decline and in some instances long term conservation is
very difficult to achieve.
2. The remit and effectiveness of DCMS, English
Heritage and other relevant organisations in representing heritage
interests inside and outside government
(i) DCMS
The public's perception of DCMS, and its commitment
to the historic environment, is that it is focused on a relatively
small number of iconic sites more than the "everyday"
historic environment; this focus was prevalent in the Secretary
of State for Culture Media and Sport's essay "Better Places
to Live". Iconic sites by definition are rare, and a greater
focus is needed on the everyday historic environment which people
are more likely to live, work in, or walk past.
The conservation of the historic environment
is long-term, as demonstrated by our introductory paragraphs.
Government policy tends to be short-term, evidenced for example
by the continuing annual cuts in English Heritage's budget. The
perception remains that Government sees the historic environment
not as an opportunity but as a burden, and that the positive role
that its conservation has to play in regeneration (ie quality
of life) and tourism is still not sufficiently recognised by Government.
The Government is focussing on Quality of Life
in its strategy for Sustainable Development. There is thus a great
opportunity and necessity for the DCMS to use Quality of Life
to raise the status of the historic environment in both its own
agenda and the wider Government agenda.
We therefore respectfully suggest that DCMS
must demonstrate, by actions and additional funding (CSR 2007)
particularly for the "everyday" historic environment,
that it:
— is the Government champion for the
promotion of the conservation of this country's historic environment
and cultural heritage and will fight its cause at all opportunities;
— recognizes the important contribution
made by private owners to the care of the historic environment;
— understands the important contribution
that the historic environment provides to our culture and qualify
of life;
— understands the importance of the
historic environment to our domestic and international tourism;
— will consult both the voluntary sector
and the private sector wherever they are caring for, and funding,
the historic environment.
(ii) English Heritage
English Heritage is rightly lauded for the good
work it does but, as a result of continuing downward pressure
on its budget, it is much less effective than it could and should
be in the conservation of the historic environment.
The comments the CLA received from its Heritage
Survey (2005) were that owners and managers of the historic environment
often perceive English Heritage to be "unhelpful", especially
in terms of its inability to provide grant aid to maintain most
listed buildings of all types in rural areas, buildings which
of course have been listed for public benefit.
This perception is unfortunate, because as the
CLA knows English Heritage often works very successfully with
private owners and others in the voluntary sector.
English Heritage must be properly resourced
to be able to carry out its duties as the independent statutory
adviser, regulator, and funder of the historic environment, and
to allow it to plan for a stable long-term future. Continued cuts
in its budget might well lead to its regulatory role becoming
paramount and it largely ceasing to be an advisor and funder.
Of course it has a further role as the conservator of its own
historic properties, and it is important that its budget is divided
between the two roles to prevent tensions arising.
If the public perception of English Heritage
is to become more positive, the budget cuts must stop and its
budget must be increased each year so that it can properly fulfil
its role and responsibilities.
(iii) Heritage Link
Heritage Link acts as a very important link
assisting its 81 members, including nearly all the non-public
bodies involved in the historic environment, to lobby the Government
on core issues. In the three years since it was set up it has
raised the profile of the heritage sector and is seen as an organisation
with which DCMS and English Heritage and other bodies must work.
The CLA fully supports the work that Heritage Link undertakes.
(iv) Private owners
Private owners are heavily involved in the historic
environment, and demonstrate leadership and commitment to its
conservation through long term management and funding of maintenance
(respondents to the 2005 CLA Heritage Survey each spent an average
of £29,000 pa).
The CLA has done much to promote the idea that
our built heritage is a priceless asset that must be conserved
for future generations, through for example our involvement in
the government's Heritage Protection Review, and other fora including
Historic Farm Buildings and Heritage Link.
Maintaining and enhancing the economic and social
fabric of the historic environment is vital. However, the cost
of this is huge and met for the most part directly by the owner
of the building. Owners ought to be supported and encouraged for
the role they play in protecting the historic environment, but
in practice a major funding gap is now apparent.
(v) Historic Environment at Regional level
Regional Development Agencies
Research suggests that the importance of the
conservation of the historic environment in terms of its contribution
to regional economic growth, community inclusion, cultural heritage
and quality of life is often not well understood at RDA level.
We suspect that Government-level perceptions of the importance
of the historic environment pervade down to the RDAs, and that
this leads to a lack of understanding of the economic opportunities
which arise from the historic environment.
It will be essential that an equitable division
of strategic aims, objectives and funding are devoted to urban
and rural concerns during the production and delivery of Regional
Economic Strategies by RDAs. The recent consultation, for example,
on the South East Regional Economic Strategy 2006-16 makes just
two minor references to heritage assets, in terms of skills required
to maintain them and support of businesses that make use of heritage
assets. The draft RES makes no reference to their importance in
terms of their potential for generating income from tourism, nor
their importance in terms of our cultural heritage and what they
mean to our quality of life.
Regional Historic Environment Fora
These do produce the regional Heritage Counts
reports, and are certainly an opportunity to network. But many
people are unsure what they are supposed to achieve, and there
is a perception that they are "talking shops". If they
are to achieve real progress on the ground they need to be invigorated
with the correct expertise and incentives.
3. The balance between heritage and development
needs in planning policy
The vast majority of historic buildings, monuments
and landscapes are privately-owned and on private land. Listing
or scheduling clearly imposes a burden on the owner and occupier,
especially where the building has no economic use: it carries
obligations, and can limit the uses of land or buildings and there
is strict liability for breaches of the rules. Owners do not necessarily
have a problem with, but feel that the additional burdens are
not adequately recognized by the listing, planning or fiscal systems.
The historic environment can be conserved successfully, but only
in the context of long-term land management underpinned by viable
economic uses. Conversion to a new use is usually a much better
outcome for a listed building than a descent into dereliction.
The CLA was pleased to note that Heritage Counts
2005 recognizes the importance of the private owner in the conservation
of the rural historic environment, and that this conservation
relies on viable new uses being permitted for redundant listed
buildings.
The CLA's vision for the new PPS15 and PPS16
is to see the conservation of listed buildings, ancient monuments,
conservation areas and landscapes encouraged by planning policies
that enable integrated management of these assets within rural
estates and businesses.
The CLA therefore calls for:
— Planning and listed building policies
that positively promote new and suitable/sensitive economic activities
for non-residential listed buildings;
— A recognition that enabling development
can in appropriate cases positively help the funding of the conservation
of an historic asset;
— The requirement for positive and
constructive pre-application advice to owners and managers of
listed properties—this will require adequately qualified
and constructive Conservation Officers;
— A change of culture within local
planning authorities, recognising that the historic environment
can make a strong contribution to the economic, social and environmental
success of an area. This requires LPA's to accept that new economic
activity may be necessary for the longer term conservation of
a building; and that new, well designed, buildings may be necessary
for the long term conservation and regeneration of an heritage
asset or an area.
4. Access to heritage and the position of
heritage as a cultural asset in the community
The value of the historic environment is in
the contribution it makes to conserving culture, customs and communities
as well as its appeal to visitors, historians and landscape specialists.
That is why our rural areas are popular places to invest and work
in, as well as to visit. This value needs to be recognized by
DCMS, just as the conservation value of particular farming methods
are now recognized by DEFRA.
A perception remains that the Government sees
the historic environment not as an opportunity but as a burden,
and that the positive role its conservation has to play in rural
and urban regeneration and quality of life is still not sufficiently
recognized. This does not help the public to connect with the
benefits it provides. The Government needs to reconnect with all
those involved in the heritage community, to focus on the need
to conserve the historic environment, and to recognize the potential
it has as an economic, community and social, environmental and
educational resource. The historic environment has the potential
to provide business and employment opportunities, to encourage
domestic and international tourism, to stimulate rural and urban
regeneration, and to support education.
Many owners of historic properties already open
their buildings and monuments to the public and provide educational
open days for children and adults. In addition, many historic
properties have been put to new uses, opening up these buildings
also to the wider public—often at no public cost. It would
therefore seem appropriate to look at ways of widening the participation
of school children in activities that involve the heritage, not
least because this will build support in the long term, through
the next generation, for the continued conservation of heritage
assets. DCMS must work with the Department of Education on including
these activities within the curriculum and facilitating school
visits by removing obstacles faced by schools and private owners
in this area.
5. Funding, with particular reference to the
adequacy of the budget for English Heritage and for museums and
galleries, the impact of the London 2012 Olympics on Lottery funding
for heritage projects, and forthcoming decisions on the sharing
of funds from Lottery sources between good causes
(i) English Heritage
The year-on-year cuts in English Heritage's
budget certainly give the impression, whether justified or not,
that the Government puts a low priority on the historic environment,
and that the DCMS is content to support a relatively small number
of iconic sites rather than promote the much broader "everyday"
historic environment. If the Government and DCMS are to demonstrate
commitment to the heritage sector, English Heritage's budget must
be restored to a workable level that takes account of its dual
advisory/grant aid and guardianship roles. The effectiveness of
DCMS in achieving this aim will be judged by how successful they
are at obtaining additional funding from the CSR 2007 dedicated
to the wider heritage sector.
(ii) Funding for Conservation Officers and
Traditional Skills
Funding support for the training and employment
of adequately-qualified conservation officers should come through
ODPM's Planning Delivery Grant. ODPM will require support from
DCMS for a case to be made for additional funding from the CSR
2007.
Funding to support training of traditional skills
should come through LANTRA and possibly from the EU Rural Development
Regulation Axis 3, but concerted lobbying by DCMS will be required
to achieve this.
(iii) Heritage Lottery Fund
The CLA has long argued the case for increased
resources to assist owners to meet public objectives for buildings
and monuments. The Heritage Lottery Fund is of great importance
to the voluntary sector, but very seldom provides grant aid to
the private sector, and only in cases where public benefit is
both substantial and extremely transparent
The National Lottery consultation, published
25 November 2005, suggests that funding for the heritage sector
will be equal to that for art and film, and sport. It seems likely
that the hug contribution lottery funding has made to the voluntary
and public-owned historic environment will not be sustained in
the future, and is less likely to fulfil its potential to contribute
to a better qualify of life and community cohesion.
There is an important case to be made for increased
Lottery funding for the heritage sector, including greater support
for the private sector where public benefit is clear.
(iv) Heritage and the Olympics 2012
Heritage as above has an important supporting
role to the 2012 Olympics attracting tourism, not just in 2012.
A new lottery game for the Olympics is however likely to have
a negative impact on funding for the Heritage sector, and DCMS
should commit to ensuring that any decline in heritage revenue
is combated by increasing other forms of heritage funding.
6. What the roles and responsibilities should
be for English Heritage, the Heritage Lottery Fund, local authorities,
museums and galleries, charitable and other non-Governmental organisations
in maintaining the nation's heritage
(i) Private Sector
Public recognition should be given to the role
and responsibilities of private owners who own, manage and fund
the majority of the built heritage in England & Wales. The
private owner's role and responsibilities require flexible and
practical heritage related policies at national and regional levels
to permit the economic re-use of listed buildings. The CLA, as
a membership organisation representing many of these private owners,
will continue to work closely with Government and English Heritage
to ensure that our members' interests are properly understood
but also to assist in the development of solutions to the great
and increasing heritage funding problem.
(ii) English Heritage
English Heritage must be properly funded to
provide adequately for its many roles and responsibilities: sector
leader and champion of heritage, policy and research development,
advocate, trainer and adviser for local authorities etc. English
Heritage requires a stable funding stream that permits it to undertake
its various roles in the most effective way possible.
(iii) Heritage Lottery Fund (HLF)
The role and responsibilities of the HLF should
be to support a balanced portfolio of heritage projects that are
in line with its purpose and objectives, including the rural historic
environment (built and natural), and in funding private sector
projects where clear public benefit can be demonstrated
(iv) Local Authorities
Local authorities have a role and responsibility
to develop flexible and practical planning, tourism and regeneration
policies for the built and natural historic environment to provide
for the three pillars of sustainable development as set out in
PPS1.
In order to provide a quality service to the
owners of listed buildings and monuments, local planning authorities
have a responsibility to employ well-qualified Conservation Officers
who are resourced to work constructively with private owners to
achieves positive outcomes on the built and natural historic environment.
This responsibility requires additional funding, perhaps through
the Planning Delivery Grant supplied by ODPM.
7. Whether there is an adequate supply of
professionals with conservation skills; the priority placed by
planning authorities on conservation; and means of making conservation
expertise more accessible to planning officers, councillors and
the general public
We have set out our comments on the need to
provide funding for well qualified conservation officers within
each local planning authority in paragraphs 5(ii) above.
Making conservation expertise more available
to planning officers, councillors and the general public also
requires additional funding to be provided to English Heritage
to undertake this role.
19 January 2005
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