Memorandum submitted by the Historic Houses
Association
OVERVIEW
1. The Historic Houses Association's (HHA)
locus in this inquiry is that the 1,500 member houses, parks and
gardens in membership contribute significantly to the cultural
and economic life to the nation, as demonstrated in this submission
below. Over 500 of these houses are open to the public, more than
those in the stewardship of the National Trust, English Heritage
and their equivalents throughout the UK, combined. In 2004 these
houses welcomed almost 15 million visitors. If the 1999 calculation
of the British Tourist Authority that 96% of tourism spend is
outside the house entrance charge itself still holds true, then
these houses are responsible for generating upwards of £1.6
billion into the local and national economy.
2. The inquiry is timely. In her essay,
"Better places to live", published in 2005, Culture,
Media and Sport Secretary Tessa Jowell began with the words:
"Britain's historic landscape, urban and
rural is recognised by those who live here and those who visit
as one of its greatest cultural assets. We should be proud of
it, and we should cherish it, and it is the duty of Government,
whether in London, Edinburgh or Cardiff to protect it and promote
it for every one."
3. And yet the future of our heritage is
under threat. There is an enormous backlog of repairs, within
the sector of privately owned castles, houses and gardens, estimated
in 2002 at £490 million (HHA figures based on its own survey
work) and elsewhere in the heritage sector. At the same time the
grant support available for restoration from English Heritage
and its equivalents in Wales and Scotland is "flat-lined"
(falling in terms of what it can buy) and the flexibility for
estates to plan their expenditure in the One Estate Election,
which was ended in 2001, has yet to be replaced. Add to that the
demands that the Olympics will place on the use of total Lottery
receipts, let alone the ever present pressure on Government finances,
and the prospects for Britain's heritage managers look depressing.
4. Ironically, this coincides with wider
and better understanding of the value of our heritage, as shown
by the following findings:
— 40% of employment in tourism depends
on a high quality environment, including the historic environment;
60-70% in rural areas (National Trust 2001);
— 96% of the public believe that heritage
is important to teach us about our past and 76% agree that their
lives are richer for having the opportunity to experience this
country's heritage (2002 MORI Poll).
5. There is also the intrinsic value of
our heritage—in the words of one HHA member: "our built
heritage is beautiful, unique, fragile and very easily destroyed".
6. The inquiry coincides with an important
conference in January 2006 on identifying this value, both the
intrinsic value of heritage and the indirect but substantial benefits
to the economy and society.
7. So this is a highly appropriate time
to review whether current policies can support the conservation
of our heritage for this and future generations and what changes
may be needed to enable such conservation.
8. Our submission is founded on our members'
practical experience. We believe that:
— the intrinsic value of heritage—this
goes beyond its economic, educational and social benefits—should
be recognised. Much is irreplaceable, lost for ever once it is
gone. This heritage comprises not only buildings, but in the case
of historic houses the landscapes that surround them and the works
of art and the furnishings that they contain—the entity.
Throughout this submission, where we refer to historic houses,
we imply the inclusion of that critical entity;
— understanding of heritage supports
our understanding of individual and common identity, our place
in history and our vision for the future. It is a prerequisite
for a healthy modern society;
— conserving buildings and landscapes
from our past helps meet not just government objectives for culture
and tourism, but also health, education, urban and rural regeneration
and employment;
— public and charitable ownership of
our heritage is important but the major part of our built and
natural environment is still maintained by private owners. Should
current owners, many of whom open their houses to the public,
cease to be able to maintain this heritage, the risk is that properties
and their contents, under different ownership, might well become
less accessible to the public—that would be an own goal
for public policy;
— the public policy framework should
enable owners and heritage managers to make their valuable contribution.
Policies for taxation, tourism, licensing, lottery funding, grant
support, coastal management and EU policies, including succession
law, are all relevant. In all this, it is important that heritage
is adequately valued in the Treasury Green Book, which focuses
on environmental value.
9. This HHA submission responds to the specific
points set out in the inquiry, but in so doing seeks to make concrete
proposals for action, to be taken by Government, its agencies,
local authorities and the private owners of heritage properties.
We propose that:
(i) the budget for English Heritage (EH)
grant support should be increased in the 2007 Spending Review,
to start to reverse years of real terms cuts, in time to improve
the state of England's heritage before the expected tourist inflow
in advance of the 2012 Olympics and 2012 Diamond Jubilee; this
would bring long term economic benefits (Q1, 2, 5 and 6);
(ii) there should be a new limited fiscal
relief for the maintenance of historic buildings, because the
revenue for most houses is insufficient to fund maintenance and
repairs, grant support from EH is now inadequate to fill anything
more than a small part of this gap, and Heritage Lottery Fund
(HLF) support is not generally available for this purpose, in
relation to the two-thirds of heritage property that is owned
and managed in the private sector (Q1 and 5).
10. We also propose that:
(iii) The Spending Review in 2007 (SR 07)
should also support the DCMS's PSA target to increase public access
to and understanding of our heritage with funding to enable EH
to support ongoing learning and access projects, with additional
sponsorship funding from the private sector if necessary (Q4).
These initiatives are also needed to better involve local communities
in the care of their local heritage (Q7);
(iv) the share of Lottery funds available
to the HLF should be at least maintained, and DCMS should monitor
closely the overall revenue from lottery games available to lottery
funds, in case the new game to support the Olympics draws revenue
from the existing games (Q1, 5 & 6);
(v) support is needed for the retention of
conservation skills essential to the maintenance and restoration
of heritage property, through sector skills councils and the England
Rural Development Programme (ERDP) of the EU Rural Development
Regulation (Q1 and 7);
(vi) conservation of traditional farm and
estate buildings should also receive a share of support under
Axis II, "natural resources", of the ERDP (Q5);
(vii) the implementation of the Heritage
Protection Review should be accompanied with resources to assure
effective local delivery (Q1);
(viii) a clearer demarcation is needed of
EH's roles, with separate ring fenced budgets for EH's guardianship
and advisory roles (Q2);
(ix) a National Heritage Forum should be
established in Government to focus discussion in and outside government
and advice to Ministers (Q2);
(x) there should be an enhanced career structure
for Conservation Officers in the public sector (mainly local authorities),
involving sub-regional teams and mentoring from the better resourced
bodies, including national park authorities to officers elsewhere
(Q7);
(xi) planning policy should encourage development
to embrace and support successful heritage conservation. Enabling
development should, in principle, be facilitated (Q3);
(xii) charitable organisations, museums and
galleries and the private sector should co-operate more closely,
including at the regional and local level, to enable the best
use of conservation skills and specialist knowledge and to better
project the value and accessibility of the historic environment
to the public (Q6).
Q.1. What the DCMS should identify as priorities
in the forthcoming Heritage White Paper
11. The White Paper should be founded on
the principle that the maintenance and understanding of heritage
is a prerequisite for a healthy and modern society and economy.
The continued ownership and conservation of heritage in the private
sector, in trust for the future, should be recognised as the most
cost effective option for the delivering heritage benefits to
the public as a whole. Heritage should be embraced as a means
to fulfil a number of Government objectives, on health, education,
urban and rural regeneration and employment as well as culture
and tourism.
12. The specific priorities should be:
A. formulation and implementation of policies
for the tax treatment of heritage assets, funding support, planning,
tourism and regeneration that enable heritage owners and managers
to maximise the benefits from these assets. These policies are
covered in the response to Question 5 below;
B. policies to ensure that maintenance of
heritage is accorded priority so as to complement the 2012 Olympics
and the 2012 Diamond Jubilee, in order to maximise the benefits
of potential tourism in the UK as a whole as well as in London.
More generally, heritage is a key contributor to tourism revenue
and should be recognised as such.
The Olympics and the Diamond Jubilee in 2012
are an excellent opportunity to attract many more visitors to
the UK, not just London, in the years leading up to and following
2012 as the profile of the UK and London is further raised. For
these visits to be successful and to lead to a sustained upsurge
in tourism post 2012 England's heritage must be seen to be in
a good state of conservation and maintenance. Otherwise the showcase
of these flagship events could be counterproductive. The need
for decisions and action on Stonehenge provides a vivid example.
Positive cooperation between VisitBritain, Visit Scotland and
regional tourism authorities in the promotion of Britain will
also be essential.
C. Support for skills, both via domestic
policies, including sector skills councils and the EU Rural Development
Regulation—also covered in Question 7 below.
Long term conservation cannot happen unless the
necessary skills are retained. The danger is that heritage skills
will be given insufficient priority.
D. A programme of implementation of the Heritage
Protection Review.
This should include implementation of the recommendations
from the June 2004 "The Way Forward" document, in particular
on combining the designation lists, the introduction of statements
of significance and of an appeals mechanism in relation to new
designations. The biggest obstacle to success for the Review will
be the lack of resources to train and employ Conservation Officers
capable of working constructively with owners. Providing sufficient
resources and enhancing the career structure of Conservation Officers
is therefore a priority—this is covered in greater detail
in response to Question 7 below.
Q.2 The remit and effectiveness of DCMS, English
Heritage, and other relevant organisations in representing heritage
interests inside and outside Government
DCMS
13. The sector needs a strong Government
champion to promote the enormous public value of our cultural
heritage across Government and outside and support the growth
of the sector. DCMS should be that champion and should put heritage
at the heart of its cultural policy.
14. The historic environment must be seen
as a positive force for change. Its central role in economic and
social regeneration, liveability, local quality of life and community
cohesion needs to be recognised and supported.
15. HHA supports Heritage Link's (representing
80 heritage groups from national organisations to small, specialised
groups) call on government, through its "Statement of Concern",
to:
— publish a policy statement putting
heritage centre stage in the development of cultural policy in
the Department for Culture, Media and Sport;
— introduce "heritage proofing"
in policy development and decisions over land use planning, new
development, regeneration, and transport infrastructure, and require
the Ministers in each Department to report annually on progress.
16. DCMS has a small budget and profile
and should present the heritage case within and outside Whitehall
with vigour and understanding. The focus on sport and media within
DCMS has diverted attention away from heritage. DCMS should raise
the profile of heritage and its contribution to national life
across Government. SR 07 will be a test of DCMS effectiveness.
It will be necessary for DCMS to present a clear strategy for
delivery, including support for strengthening the sector's capacity
and building a strong heritage case in advance of decisions relating
to the SR.
17. The HHA believes that there is a compelling
case for a National Heritage Forum chaired the Secretary of State
for Culture, Media and Sport, the purpose of which would be to
provide a focus for discussion and the provision of policy advice
to Ministers on all aspects of the historic environment.
18. DCMS alone cannot be the sole mouthpiece
for heritage in Government. ODPM and DEFRA—as well as the
DTI, DfES, DWP, HMT and HMRC—all have a strong stake in
heritage as indeed do the GoRs, RDAs and local authorities. The
inclusion of heritage within the brief of Green Ministers is a
positive step but needs to result in positive action. The historic
environment should be recognised as an integral and essential
component of sustainable development, weighed critically in planning
for a sustainable future and used creatively as a social and economic
driver. Robust cross-governmental support is needed for those
responsible for the stewardship of the historic environment, through
advice, targeted grant aid and fiscal incentives.
English Heritage
19. English Heritage has an essential role
to play as independent statutory adviser, national heritage champion
and funder. It needs to be properly resourced to do this.
20. English Heritage needs to be reinvigorated
and reinforced and given a stable and guaranteed future, giving
it a vital period of organisational stability.
21. However, there needs to be a much clearer
demarcation of EH's guardianship and advisory roles with clear
ring fenced budgets.
22. The separation of the Historic Properties
function from the advisory/statutory roles within EH is welcome.
Its joint role as guardian and sector champion has the capacity
to create tensions at a time of tight budgets, and so it is critical
that budgets for EH properties and wider grant support are separated,
and transparently so.
Voluntary sector
23. Although the delivery of tourism is
often fragmented and heritage supported in practice by thousands
of individual owners and small organisations, such as preservation
trusts, in recent years the heritage sector has come together
to share skills and expertise, promote policy on core issues and
make common cause to Government. The role of Heritage Link is
extremely positive in promoting the central role of the voluntary
sector in the stewardship of the historic environment.
Regional Development Agencies (RDAs)
24. The recognition by RDAs that the historic
environment is a positive element in economic growth, but also
needs to be conserved in order to survive to fulfil this role,
is patchy. Understanding of the cultural contribution of heritage
is also patchy. The role, effectiveness and influence of the Cultural
Consortia and the Historic Environment Fora should be challenged
and the experience and expertise of their members examined and
enhanced.
Q.3. Balance between heritage and development
needs in planning policy
25. ODPM should aim, in consultation with
DCMS, Defra and EH, to develop planning policy that encourages
development to embrace successful heritage conservation. In practical
terms, this will have to involve the following approaches:
26. Planning policy should encourage development
to embrace and support successful heritage conservation. In brief:
A. There should be recognition in EH and
Local Planning Authority (LPA) polices that non residential listed
buildings need an underlying economic use to secure their future.
Sympathetic conversion is a much better outcome than a descent
into dereliction. The 2005 Heritage Counts report is to be commended
for its recognition of this reality, in particular in relation
to the conversion of farm buildings.
The review of the Class Consents Order for ancient
monuments should also look to viable management of land around
monuments, including with the support of Stewardship, as the best
guarantor of the condition of the monuments.
B. LPAs should be guided to view heritage
buildings and conservation areas as positive contributors, wherever
possible, to economic regeneration and the quality of life within
their areas. This does not mean a blanket ban on new development
or modern buildings in town centres; rather a focus on conserving
good design, whatever the vintage. Also, dogmatic adherence to
protection in planning policies can lead to buildings deteriorating
or falling down and LPAs should be guided that allowing an economic
use for heritage buildings is often the best way to secure their
future.
C. Where there are unavoidable conflicts
between development and conservation imaginative solutions will
be needed. A comprehensive resolution of the conservation and
access problems for Stonehenge may look expensive now, but stands
to produce a legacy that will bring benefit in the future.
D. World Heritage designations, when used
as a positive brand and when backed with financial resources,
can assist in the enhancement of heritage, the visitor experience
and the local economy. The financial commitments entailed in interpretation,
access management and maintenance must be met with funding to
go with the designation. At the same time any new constraints
imposed on owners must be in proportion to the distinctiveness
of the site and be practical to follow.
E. Enabling development. LPAs should start
with a presumption of looking favourably, within the existing
terms of Local Development Framework planning policy, on applications
for development that serve to financially support the conservation
of heritage assets.
Q.4. Access to heritage and the position of
heritage as a cultural asset in the community
27. Managers and stewards of the historic
environment need help and support to look after it for future
generations in order to continue to help realise its potential
and unlock the full promise of historic assets.
28. HHA seeks a redefinition and broadening
of the public's understanding of heritage and its contribution
to everyday life, the economy, quality of life and our happiness.
There is a growing recognition of the untapped potential of the
historic and natural environment as an economic, educational,
community and social resource and the contribution is makes to
identity. A high quality historic environment is vital in terms
of its huge contribution to the economy and quality of life, creating
jobs, stimulating urban and rural regeneration, supporting education
and lifelong learning and helping rural businesses. Visiting,
living, working and enjoying our most beautiful places enriches
people's lives and provides spiritual replenishment. Our heritage
may also underpin the sense of place and identity for those who
live close to it—those who raised £1.5 million for
the restoration of a church in a Northumberland village demonstrated
this particular value of heritage, one which can now be enjoyed
by the villagers' successors in future.
29. The National Trust's Valuing our Environment
research (2001) demonstrated the economic importance of the natural
and historic environment, showing that some 40% of employment
in tourism depends directly on a high quality environment—including
beautiful houses and their estates. This figure rises to between
60% and 70% in a rural context.
30. There is a burgeoning public interest
in history and heritage—recent MORI polls have found that
96% think heritage is important to teach us about our past and
76% agree their lives are richer for having the opportunity to
experience this country's heritage. In the last decade there has
been a growing interest in local distinctiveness and local history
in particular, and take up of the HLF/Countryside Agency Local
Heritage Initiative and high viewing figures for TV history programmes
suggest that this is both a local and a national phenomenon.
31. However, it is vital that heritage policy
makers and practitioners take the long view and recognise the
intrinsic importance of heritage—its existence value.
32. There is some recognition within Government
of the inherent value of heritage and within her essay, "Better
Places to Life: Government, Identity and the Value of the Historic
and Built Environment 2005", Culture Secretary Tessa Jowell
articulates the value of heritage in terms other than economic,
education and social policy benefits.
33. There is a need for an access champion
for the sector which is funded and supported to act across the
sector.
34. The DCMS's current PSA target to reach
out to new audiences for the historic environment is demanding
and the sector cannot be achieved without support, including the
provision of advice to heritage managers, education authorities
and communities. At present, there is no ongoing support—everything
is done on a project basis, which means initiatives can flare
and die and opportunities are not maximised. The PSA target has
come without any additional funding to achieve it; this is placing
intolerable burdens on those charged to deliver it. The failure
of Heritage Link's recent outreach bid to the Treasury's Invest
to Save bid was highly revealing in that the project was not seen
as "additional" and yet there is no other support available
to deliver it. A service is needed which is similar to those which
the MLA provides for museums, libraries and archives in developing
capacity within the sector and promoting innovation and change.
35. Guaranteed funding is needed for skilled
interlocutors, such as that provided by the Black Environment
Network.
36. The development of new and creative
connections between people and places, connections which can be
grown and sustained, needs to undertaken carefully, thoughtfully
and sensitively. If attempted hurriedly or carelessly with insufficient
understanding, opportunities can be lost for ever and communitites
turned away.
37. Essentially, the asset on which all
of this is dependent must be protected, conserved and sustained.
38. Heritage mangers are struggling to achieve
the objectives of providing access and a learning resource, as
well as contributing to regeneration and economic growth, when
set against the need for essential maintenance of the asset itself.
At one major house in Lincolnshire, for example, the owners have
spent £900,000 out of income generated by the estate, on
maintenance and conservation of the house and its surroundings
over 30 years. Without that work, a recent learning and access
project, supported by the Heritage Lottery Fund (HLF), would not
have been possible. Current work to measure the public value generated
by our heritage needs to be coupled with wider understanding of
the need for effective stewardship, protection and the support
to do this.
Q.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;
39. No assessment of the adequacy of funding
from English Heritage or other sources is complete without an
assessment of the capacity of private owners, who manage the majority
of heritage assets, to fund conservation themselves. This inevitably
brings in the issue of the taxation regime as it affects conservation
of privately owned heritage. This submission makes recommendations
on EH grant provision, on fiscal relief for maintenance of historic
properties and comments on other taxation matters, including the
Conditional Exemption arrangements (ie in relation to Inheritance
Tax) and VAT.
40. If the Government is serious about heritage
and its contribution to a modern, outward looking economy, then
it should begin a programme of reversing the real terms decrease
in EH grant support in the SR 07. We also propose that the
2007 Budget should be used to introduce a limited fiscal relief
for the maintenance of historic buildings, not only to enable
owners to fund conservation work, but also to bring more of our
heritage into public accessibility.
41. English Heritage's budget for all restoration
work is broadly on the same level as that available to that of
the MLA. However, a significant part of EH's budget is committed
to a relatively small number of major, national projects, leaving
individual regions small sums—some less than £1m—for
all the grant funding in the region.
42. In recent years this EH budget has been
declining in real terms, even though the costs of conservation,
which include a relatively high labour and skills content, have
been rising. According to EH figures, in real terms, its grant
in aid over the five years has fallen by a total of almost £10
million. Over the three years 2005-06 to 2007-08 EH calculates
that a further £14 million shortfall will have accumulated.
43. Alongside a reversal of this decrease
in EH grant support, a limited Historic Property Maintenance Relief
would enable owners to fund more conservation work themselves.
44. The relief would enable owners of historic
properties to offset income against the costs of maintenance,
with a ceiling on the amount of relief claimed and subject to
the provision of agreed public access. Larger, more diversified
houses, which were capable of securing treatment under Schedule
D, Case 1, would not be eligible for this relief.
45. There are two main reasons why such
a relief should be supported. The first is that public policy
to conserve the built heritage would become more effective, because
the cost-effectiveness of private ownership would be more directly
enlisted than through complete reliance on a grants-based approach.
Owners would be able to carry out conservation work on a timetable
and scale that matched their circumstances. By undertaking work
over a sustained period, the "stitch in time" approach,
and by shopping around for skills at reasonable prices, owners
can often carry out conservation work at a lower cost than if
it were all to be publicly supported. The second reason is that
at current or even improved levels of grant funding, the need
for conservation will outstrip the capacity to fund it. If current
owners cannot fund this work, then properties will decay and some
at least will cease to find opening to the public worthwhile.
This loss of access would directly undermine the basic objectives
of Government policy to broaden access to our heritage. This specific
proposal would not preclude consideration of proposals from other
for relief in the case of gifts of art to the nation during the
lifetime of the donor. It is also noted in passing that the Government
has yet to respond to the Goodison Report of 2004 in relation
to encouraging the donation of art.
46. There are several other broader reasons
why support for the maintenance of historic houses and gardens
is a sound investment.
47. These properties make a positive contribution
to the economy that is disproportionate to the scale of their
individual operations. In 1999 BTA estimated that 96% of heritage
tourism expenditure was outside the house entrance gate. A similar
pattern now would indicate a contribution by historic houses and
gardens in the realm of £1.6 to £2 billion. Against
that background it is not surprising that the Duchess of Northumberland,
creator of the Alnwick Garden, which has received public financial
support and which has helped to reinvigorate the Alnwick area,
was recently invited to speak alongside the Prime Minister on
the subject of North East Regeneration. Money spent on conserving
this heritage is well spent. Without maintenance of the fabric
of Alnwick Castle, the garden would lose its spectacular backdrop.
48. Maintenance expenditure supports traditional
skills, such as stonemasons, carpenters, joiners, thatchers, woodturners,
gardeners and others. These skills are then available for smaller
projects and maintaining publicly owned buildings.
49. An HHA survey in 2005 year revealed
that for 70 important houses the backlog of urgent repairs was
£20 million, compared to English Heritage restoration grant
offers of £1.8 million, and a similar broader survey in 2002
indicated a backlog of all work across all privately owned historic
houses close to £500 million.
50. The pressure on Government to ensure
that the 2012 Olympics will be adequately funded increases the
likelihood of further diversion of grant support funding from
EH to sport based expenditure within the Government's priorities,
even though the potential for heritage tourism BEFORE, during
and AFTER the Olympics will only be fulfilled if England's heritage
is in a well conserved state. This is a once in a lifetime opportunity
to showcase British heritage and to leave a real legacy of community
pride with all the concomitant benefits, where the role of Government
and its agencies can be one of "investors" rather than
simply of funders.
51. Funding of heritage support is not only
a matter for EH. The support necessary for retaining and improving
conservation skills will need to come mainly through sector skills
councils, and possibly through Axis III of the England Rural Development
Programme (ERDP) of the EU Rural Development Regulation; support
for conservation of traditional farm buildings should be accommodated
in Axis II of the ERDP; an enhanced career structure for Conservation
Officers in local authorities needs support from county councils
and national park authorities as well as EH.
The impact of the 2012 Olympics on Lottery Funding
for heritage projects
52. Confirmation is needed from DCMS that
it will (a) monitor closely the effect of the creation of a new
lottery game to raise money for the Olympics on the revenue available
for the existing lottery funds and (b) that if such revenue declines
as a result of the introduction of a new Olympic lottery game,
Government will revise upwards the share of lottery funds being
made available to the Heritage Lottery Fund.
53. There are already significant limitations
on the use of Lottery funding for heritage projects. The Heritage
Lottery Fund (HLF) has an established policy that support may
not be given which contributes to "private gain", except
where that is small and significantly outweighed by public benefit.
In practice HLF interprets this policy to reject applications
for support on privately owned property, except in limited circumstances:
(a) where there is "non-beneficial use" of the heritage
asset in question, such as follies or monuments; (b) for projects
to increase learning and access opportunities, and here it is
made clear that the funding (including matching funding) only
covers the costs of the project, with no gain to the owner, and
(c) some support for area based landscape and biodiversity projects
that may happen to include some privately owned property.
54. Therefore, the HLF cannot be seen as
in any way the "saviour" for restoration and maintenance
of the two-thirds of the national heritage that is owned and managed
in private hands. And, therefore, the commendable efforts of the
HLF in general cannot be cited as consolation for the repeated
cuts in the real terms budget of EH. The overall budget for support
for restoration and maintenance still suffers, whatever may happen
to the available funds for the HLF.
55. There is, nevertheless, an important
role for the HLF to play, not only in relation to community led
projects, but also in relation to the limited categories at (a)
to (c) above.
56. In broader terms, funding distributed
by the HLF has had a huge impact on the historic and natural environment
and has brought great benefit to local economics and communities
in places which are often lacking other support. As well as bringing
direct benefits for the identified good causes, funding has helped
to generate investment within places and presented opportunities
for regeneration and community growth. In this respect the HHA
supports the analogy of HLF as "investors" rather than
"funders" and has observed that investment can have
an effect hugely greater than the funds invested, particularly
when it involves other funders.
57. The danger is that the need to create
an attractive new lottery game to raise money for the Olympics
will draw income away from the existing lottery games, and as
a result the funds available to the HLF will further decline.
The areas of support most likely to suffer as a result are exactly
those regarded as marginal by the HLF, namely (a) to (c) above,
the only sources of HLF support for heritage in private ownership
and management.
The forthcoming decisions on the sharing of funds
from Lottery sources between good causes.
58. HHA is urging DCMS to at least maintain
the current share of lottery revenues going to the HLF, via the
current DCMS and HLF consultations.
59. Recent decisions have already served
to reduce the annual expenditure budget for grant support from
about £330 million to about £200 million per year. Compared
to the sums available to EH, this sounds a lot of money, but for
the reasons given in paragraph 53 above it can be seen that HLF
funding is limited in its reach as far as the privately owned
and managed heritage sector is concerned, and HLF should not be
seen as compensation for successive real terms cuts in EH support
budgets
60. The economic, social, educational, community,
regenerative etc impacts which heritage projects can deliver for
people should be recognised.
61. There will be a growing need for help
for landscape and biodiversity support from the lottery if the
existing means of support—principally the Rural Development
Regulation of the EU's CAP—becomes constrained as a result
of the EU Budget settlement for 2007-13. It is not yet clear
whether even existing levels of Stewardship can be maintained
within this Budget, let alone increases or sufficient support
in upland areas, support for the conservation of traditional farm
buildings or for the retention of heritage conservation skills
62. Smaller organisations find it difficult
to access funds for learning and access projects under the HLF.
The case for enabling some of the costs of putting together small
projects to be included in the lottery grant should be revisited.
For this to be possible, and for the reasons above, the current
HLF share of lottery funds must at least be maintained.
The current arrangements for Conditional Exemption
from Inheritance Tax
63. In the 1998 Budget the Government announced
its intention to review the terms of existing agreements between
the Inland Revenue and individual owners of works of art, under
which such property was conditionally exempt from Inheritance
Tax in return for a certain level of access being granted to the
public, normally by appointment. The quality standards required
for such chattels to qualify for exemption in their own right
and the access requirements for future cases were redrawn.
64. The new arrangements were not welcomed,
partly because of their retrospective nature and partly because
of the fear that they would not be practical. The aims of conservation
in the house where works of art have their historical context
and open access can be very difficult to reconcile. In addition
demand for open access may be small in comparison to the costs
of providing it. Following these changes there was a sharp decline
in the number of new applications. For some owners the new requirements
on public access are not practically possible, eg for security
reasons, creating a real or potential liability for Inheritance
Tax. The alternative of payment of the tax reduces the resources
available for maintenance.
65. HHA has encouraged individual members
to explore with the Capital Taxes Office (CTO) the possibility
of using Heritage Open Days as the means to provide open access,
but the CTO is still in the process of reviewing existing arrangements.
It is too early to see whether this will work and in the meantime
the number of new applications has slowed to a trickle. As time
goes by fewer works of art will be available for public inspection
than in the past and because of the need to meet IHT liabilities
there are is likely to be greater sales of works of art and the
end of the association between particular works and particular
houses.
VAT on the maintenance and repair of listed buildings
66. HHA supports a proposal put by the UK
EU Presidency in December, but yet to be discussed by Finance
Ministers, for an optional reduction by member states in the rate
of VAT applied in respect of the labour input to the maintenance
and repair of buildings more than five years old. This proposal
would ameliorate the current anomaly under which new build and
alterations are VAT free but repairs are taxed at 17.5%. HHA hopes
that the Austrian Presidency will either bring the proposal to
the EU Finance Ministers Council on 24 January or to a subsequent
Council soon. Clearly, HHA would wish the UK Government to implement
the optional reduction in this country. Such a reduction would
also encourage the revival and greater availability of key conservation
skills.
Q.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
The Independent Sector
67. Private owners, who own and manage two
thirds of the nation's built heritage, should be publicly recognised
as the most economical and efficient stewards. And this recognition
should be put into practical terms in the heritage policies of
central government, English Heritage, regional government bodies
and agencies and grant givers, so private owners can effectively
fulfil their stewardship role.
68. The HHA has a particular role, as the
representative interest of privately owned houses in the UK. Government
and HHA should work together to explore fair and imaginative solutions
to the resource crisis.
English Heritage
69. English Heritage needs to be effectively
funded to fulfil its role as champion of heritage, sector leader,
policy and research developer, advocate, Government monitor and
trainer and adviser for the local authorities and the wider sector—see
Questions 2,4 and 5 for details. In essence:
— EH's role as lead body for the historic
environment sector at national, regional and local levels is strongly
supported. EH are regarded as an essential partner by the HHA
at all levels and one of the few agencies able to fund the repair
and maintenance of privately-owned historic buildings and landscapes;
— There should be a programme of reversing
the real terms decrease in EH grant support in the SR 07;
— There needs to be a much clearer
demarcation of EH's guardianship and advisory roles with clear
ring fenced budgets;
— EH should be resourced to fulfil
its role of access and learning champion for the sector.
Heritage Lottery Fund
70. The HLF's share of Lottery funds should
be preserved at its current percentage at the very least.
71. HLF should have a responsibility, consistent
with the underlying objectives for all Lottery funds, to support
a balanced portfolio of heritage projects throughout the country.
Whilst this means it cannot support private benefit, it should
look favourably on projects in the independent sector that advance
its underlying objectives—see Question 5 above.
Charitable Organisations
72. Charitable organisations, such as the
National Trust, have a key role to channel the public's support
into practical conservation, with access, in a way that works
alongside the work of private owners. This relationship is generally
a very positive one but more co-operation, co-ordination and partnership
is to be encouraged particularly where specific skills and roles
could benefit the wider sector.
Museums and galleries
73. Museums and galleries also have a role
to work with private owners of heritage collections, works of
art or historic items wherever possible and we can report positive
and helpful co-operation in the HHA's regions. The help provided
by county archives such as in Hampshire is but one example. There
are opportunities to share experiences and resources, particular
through the regional hubs which embrace concepts of developing
skills and a knowledge base together with mentoring and support
networks at often isolated sites.
Q.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
Support is needed for the retention of conservation
skills essential to the maintenance and restoration of heritage
property, through sector skills councils and the England Rural
Development Programme (ERDP) of the EU Rural Development Regulation.
74. The shortage of craft skills is most
marked in rural areas and this was one of the key findings of
Heritage Counts 2005. According to the Campaign to Protect
Rural England and National Farmers' Union, more than two-thirds
of farmers said that there were no skilled builders or thatchers
within ten miles' distance of their farms (and this in itself
is a persuasive argument for lower rate VAT on labour-intensive
services). The HHA's experiences indicate shortages of expert
skills, in particular conservation architects. However, it should
also be noted that owners and managers of heritage properties
are taking an active role in assisting the retention of skills
and expertise through their conservation work. If more work could
be funded through the measures recommended elsewhere in this submission
the benefits in terms of support for skills would also be increased.
Ensuring the new system of heritage protection
can be implemented successfully requires a considerable increase
in capacity building and education in local authorities. There
needs to be a conservation service which is properly resourced
and structured.
75. Charitable organisations, museums and
galleries and the private sector should co-operate more closely,
including at the regional and local level, to enable the best
use of conservation skills and specialist knowledge and to better
project the value and accessibility of the historic environment
to the public. This is the point in our submission to note that
HHA set up a charity itself in the mid 1980s, the Heritage Conservation
Trust, to support the restoration of notable works of art in historic
houses. The Trust is currently engaged in a three year programme
to help restore works in 12 houses.
76. Local authorities play a fundamental
role in caring for and managing change in England's historic environment,
yet local policy and service delivery varies widely in range and
quality. The resultant lack of consistency both within LAs and
across the country leads to users of the service feeling frustrated
and let down.
77. The Review of Heritage Protection highlighted
corresponding concerns within local authorities, principally lack
of staff, expertise, experience and resources. The front line
role of Conservation Officers is hampered by low pay, lack of
career structure, and low status. Ideally a career structure which
would allow movement within the local authority into other disciplines
would have positive benefits. This is a problem that also afflicts
the provision of curators in locally authority run galleries in
the provinces
78. At present, only about 70% of planning
authorities have a designated Conservation Officer. Even where
they are appointed, individuals may not have specialist qualifications
or their knowledge may be limited to one specific period. This
means that assessment and decision are made on local experience
only, which, while important, can be without reference to the
national context.
79. The HHA welcomes the current research
project examining different approaches to delivering historic
environment services in planning for a successful transfer to
the new system by 2010.
80. There needs to be an enhanced career
structure for Conservation Officers in the public sector (mainly
local authorities), involving sub-regional teams and mentoring
from the better resourced bodies, including national park authorities
to officers elsewhere.
81. Because of the paucity of expertise
within certain local authorities, sharing of resources could reap
positive rewards. A regional or sub-regional team, as suggested
in the Designations Review, could be better equipped to assist
their respective authorities in developing policy and advice,
providing guidance on best practice, giving specialist advice
and providing a more consistent service.
82. To facilitate these improvements teams
might be best administered by county council or equivalent agencies
such as National Parks.
Support for learning and access projects of
the type described in response to Question 4 above could be used
to increase understanding of the potential of heritage to create
a sense of identity and pride for a community
83. Communities need skills to participate
in and engage with understanding and caring for their local historic
environment. Statements of Significance, the development of which
are widely supported, are notoriously hard to write and to involve
communitites in a meaningful way.
19 January 2006
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