Memorandum submitted by the Institute
of Historic Building Conservation (IHBC)
1. The IHBC: The Institute of Historic Building
Conservation (IHBC) is the professional body of the United Kingdom
representing conservation specialists and historic environment
practitioners. The institute is a registered charity and exists
to establish the highest standards of conservation practice, to
support effective protection and enhancement of the historic environment,
and to promote heritage-led regeneration and access to the historic
environment for all.
2. Statement of support & core evidence:
The draft Bill has had an extended gestation period, and the IHBC
has been involved at many key stages, often as an informal "sounding
board" or a formal consultee. The institute has always welcomed
the opportunity to contribute to the evolution of the Bill, providing
comments informed by our membership's unique multi-disciplinary
and cross-sector conservation experience.
2.1 Our responses to the issues raised by
the committee build on previous and current representations (all
available at www.ihbc.org.uk):
— Culture Media and Sport Committee
Inquiry into "Protecting, preserving and making accessible
our nation's heritage"; Evidence of The Institute of Historic
Building Conservation, (IHBC, 2006).
— The Heritage White Paper Membership
Consultation (IHBC, 2007).
— Response to the Heritage White Paper,
Heritage protection for the 21st century, incorporating views
of the RTPI, IHBC and RICS (IHBC, RTPI, RICS 2007).
— (Draft) Joint response to the draft
heritage bill, still to be lodged, supported (at this time) by
IHBC, RTPI, RICS and others.
The evidence to this Inquiry relies largely
on current joint response to the draft Bill, though the actual
statements here are exclusively the responsibility of the IHBC.
2.2 The IHBC's long-standing individual
and collective support for the aspirations underpinning the draft
Heritage Bill reflects our awareness that the historic environment,
properly supported and managed, encourages the growth of successful
communities and secures extensive sustainable benefits. Adopting
conservation approaches in managing change in historic places
can:
— address economic and fiscal aspirations
across society, from supporting sustainable SMEs to enabling heritage
led regeneration;
— mitigate environmental pressures,
through promoting low-waste practices, conserving embodied energy
in existing structures and encouraging traditional, low carbon-footprint
materials; and
— resolve social pressures, through
embracing diversity, inclusion, quality of life indicators and
associated cultural values.
Proper implementation of the proposed legislation
will represent a turning point in how we realise the potential
of our historic places.
3. The overall aims and scope of the draft
Bill: The incomplete nature of the current draft Bill means that
any responses must be seriously qualified. We do recognise the
challenging timetable adopted for the development of the Bill,
but it is impossible to address substantially many of the issues
raised due to the lack of information. Comments on the draft bill
are provisional until further detail is brought forward, a process
that we anticipate will involve extensive further consultations.
3.1 Integration: Integration of heritage
protection into wider government initiatives and priorities has
been a recurrent concern of the IHBC through the history of the
Bill (eg CMS Inquiry response, IHBC, 2006). Heritage protection
must be intimately integrated with wider planning and related
environmental management systems, including fiscal incentives
for promoting conservation, such as investment funding for essential
market intervention and "flat VAT" etc.
There is little clarity on the crucial matter
of how the new regime will integrate with, and be supported by,
the planning system. We recognise that this is not necessarily
solely a matter for the Bill, but in the absence of detail, we
urge the establishment of a coherent cross-government strategy
to address the needs of historic environment conservation.
The IHBC has previously identified as priorities
initiatives to link planning, investment and heritage protection,
that together would help respond to the aspirations of the Heritage
White Paper (eg CMS Inquiry response, IHBC, 2006, paras 3.8, 3.18,
and after). Thus, the Bill, its statutory guidance, and complementary
initiatives, should and could encompass:
— detailed statutory and non-statutory
definitions of duties on local authorities, including possibly
a statutory duty of care and specific statutory services;
— detailed, up-dated guidance on historic
environment planning policy;
— clarifying and tightening conservation
area controls;
— fiscal and investment strategies
(including tax relief, such as "Flat VAT") to support
in the built heritage resource; and
— how Historic Environment Records
sit in the planning service, as the core new statutory duty actually
arising from the legislation;
We recognise that the new legislation and supporting
material has not (at least as yet) been able to address all these
challenges, or could not address some areas through primary legislation.
However we welcome the strong encouragement the Bill will provide
for a significantly higher standard of service through simplification;
clarification; standardisation; integration of systems and the
requirement to secure and consider specialist advice (Clause 106).
Altogether, this should provide an important enabling opportunity
for a more comprehensive heritage conservation regime.
3.2 Area & local designations: The central
importance of the Conservation Area in community-based heritage
management ("local delivery") was identified in the
joint response of key heritage professional bodies—IHBC,
RTPI &, RICS—following the publication of the Heritage
White Paper (2007). The Conservation Area is the historic "place"
to which most people relate, in which they live, work and play
and where they want to see clear, logical and easily understood
controls. Conservation area grant schemes have delivered substantial
social and economic benefits, especially in under-performing areas.
However, the draft Bill does not cover this area substantially.
We are especially concerned that departmental responsibilities
in government may ultimately be responsible for creating a new
heritage protection system that, by failing to integrate Conservation
Area protection, does not meet its aims and aspirations.
Clearly, as a tool in local designation, conservation
area reform should also be examined in parallel with local listing.
Both are recognitions of the importance to communities of the
local and regional heritage, which is often held in greater affection
and regard by the public than some nationally protected.
3.3 Local government responsibilities: Recent
research recognises the current low priority given to conservation
in local government, and the equally damaging failure there to
integrate conservation services with wider corporate programmes.[1]
At the same time, the draft Heritage Bill gives local authorities
more direct ownership and greater strategic responsibility in
the management of their historic environment. This is an important
initiative. However given the parlous state of local government
resources, and the myriad wider pressures there, a corresponding
statutory duty that consists simply of having access to a Historic
Environment Record does not, in our view, constitute a duty commensurate
with the new responsibilities.
In the absence of more substantial duties, we
are especially pleased to see that the Bill goes some way towards
ensuring that adequate specialist direction is integrated into
the management process by requiring expert advice to be received
and to be taken into account (Clause 106). Though the clause needs
some refinement, this is an important step forward.
4. The estimates of costs and benefits set
out in the Impact Assessment published alongside the draft Bill:
The institute is convinced that the wider benefits accruing from
properly implemented Heritage Protection Reform should bring about
significant savings to government and society overall. At the
very least the new processes presaged by the Bill should help
streamline the planning and consent process and thereby play a
role in reducing development and related costs (CMS Inquiry response,
IHBC, 2006, paras 7-7.13). However we are less clear about the
precise details of the immediate costs, in particular costs attached
to transitional arrangements, or capacity pressures that may arise
from varied or new areas of responsibility.
Both the Heritage White Paper and the draft
Bill recognise that local planning authorities are the primary
vehicle for managing historic environment conservation, and are
central to the successful implementation of the new regime. In
our opinion it is impossible to quantify precisely the impact
of the proposed legislative changes on planning processes as they
currently operate, a point supported in the Impact Assessment.
However we do warmly welcome the formal commitment
by DCMS to underwrite capacity needs arising from any changes
(Impact Assessment paras. 8 & 43). In the context of significant
and potentially competing CMS capital and revenue commitments,
it is critical that this commitment is maintained. For our part,
and supported by the partners in our response to the Heritage
Bill, we will help monitor the developing impact of the changes.
We are keen to have positive and pro-active dialogue with the
relevant departmental interests—DCLG in particular, as well
as DCMS and the national heritage bodies—about the evolving
needs under the new system, especially as we get a better understanding
of its impacts.
We understand that all informed responses to
the draft Bill will raise concerns about capacity in local authorities
under the current and/or future legislative regimes. In this context,
and given the huge pressures under which the current system operates—a
matter on which the IHBC hopes to report further in the near future,
as information becomes available—we call for resources to
be dedicated urgently to improve the current situation. Research
by the IHBC, funded by English Heritage, shows that in 2006 more
than 10% of local planning authorities (excluding counties) have
no internal conservation service of any type, and about 2% take
no conservation advice of any form[2].
Clearly we cannot refine a historic environment conservation service
in line with the current proposals if that service does not actually
exist!
So, even before the matter of the specific costs
of the implementation are identified, at the very least there
is an urgent need for immediate capacity building in local authority
conservation services. This would ensure that, by the time the
reforms begin, there is a baseline capacity in each local planning
authority. Of course the IHBC is committed to providing guidance
and advice to secure best value from such investment.
5. The staffing and skill levels needed
for effective implementation of the provisions in the draft Bill:
This matter is intimately tied to the issue of resource impacts.
The wide-ranging skills needs and activities
in Historic Environment Conservation Services are outlined in
the IHBC's consultation document on skills and services, "Caring
for Places and People: Towards a common standard in historic environment
conservation services and skills"[3],
itself a consolidation of recent practice-based research. We urge
the committee to review the paper for its specification of a base-line
conservation resource or service. The paper also supports the
principle that conservation benefits arise when expert conservation
advice and skills are properly integrated within the planning
service.
Given the urgent need to focus on service definition
and standards, we are especially pleased to see that the Bill
goes some way towards ensuring that adequate specialist direction
is integrated into the management process by requiring expert
advice to be received and to be taken into account (Clause 106).
However, while we strongly welcome a comprehensive training strategy
from English Heritage to support the implementation of the new
legislation, on its own it will not be able to address core limitations
in the local authority services.
The poor salary structures offered to conservation
staff significantly affect recruitment and retention—not
least given the skills needs attached to the service, as noted
in our consultation above—and will continue to do so in
the future. The IHBC has built up an evidence base for salary
trends in local authority which has shown a steady rise in advertised
local authority conservation posts until 2004-05 and a steady
decline since. Should this represent a long-term trend it will
have significant impact on the implementation of the reforms.
Coupled with this is the ageing profile at the upper end of the
conservation profession that will see large numbers of experienced
officers retiring just as the reforms come into place. We are
concerned that, when there is a clear and worsening downward trend
in core conservation staffing, the Impact Assessment states "the
number of people working within ... the heritage protection system
in the future will not deviate from current trends".
Without specific targeted investment in the
short term, conservation services will continue to be cut through
corporate priority budgeting irrespective of the heritage reforms
proposed. Going back to our earlier remarks about integrated delivery,
this is not simply a matter for one department with a cultural
or even a planning remit. Historic environment conservation capacity
is an issue that must be addressed across government, just as
government as a whole will benefit from the proper implementation
of the proposed new legislation.
The institute does hope that you find this useful
and would be very happy to explore any of the initiatives in further
detail.
June 2008
1 Historic Environment Local Delivery Project, Consolidated
Report, (Atkins, April 2006), http://www.ihbc.org.uk/recent_papers/docs/Local%20Delivery%20Report%20by%20Atkins%202006.pdf Back
2
"Quantifying local planning authority conservation staffing",
IHBC 2006, http://www.ihbc.org.uk/recent_papers/docs/quantifying_lpa_conservation_staffing.pdf Back
3
See http://www.ihbc.org.uk/news/docs/people_place_consult.pdf Back
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