Supplementary memorandum submitted by
Carrick District Council
IMPLICATION ON
RESOURCES AND
THE SETTING
UP OF
A NEW
COMBINED REGISTER
The proposal to set up a new combined register
is heartily welcomed and the provision of an online register of
heritage assets, accessible by the public, will substantially
reduce the number of enquiries received by Local Authorities.
However if the legislation is to be changed, so that in cases
of prosecution for unauthorised work (section 90 (2)), it will
be a defence for the defendant if he can prove that he did not
know that the structure was registered and had taken all reasonable
steps to ascertain whether or not it was registered, it is vital
that the information on these registers is accurate. Over the
last three years I have been working with Cornwall County Council's
Historic Environment Service who have been plotting the District
Council's Listed Building GIS data on the County Historic Environment
Record. By overlaying English Heritage's records it has demonstrated
that in my own district, there is a 70% discrepancy resulting
in over 800 listed building records being wrongly plotted on the
English Heritage database. Further a large proportion of addresses
are either incorrect or have changed. I spent three months checking
our data. However few other local authorities have had the resources
to make such checks and anecdotally many rely on the owners of
listed buildings to inform them of inaccuracies in their mapping.
The resource implication in the provision of a new combined register
and also improved Historic Environment Register has got to include
resources for checking accuracy of data which can only be done
at the local level.
REVISED CLAUSES
FOR CONSERVATION
AREA
— The proposal for wider consultation
on the designation, variation and cancellation of Conservation
Area is noted and is currently undertaken as good practice. The
publication of management plans for Conservation Areas is also
good practice (following English Heritage's guidance). However
even when they were included as local BVPIs it has been difficult
to persuade all local planning authorities to invest in resources
to commission appraisals and management plans. In Cornwall there
are 146 Conservation Areas and over the last five years the district
councils have commissioned 34 appraisals and management plans.
In my own authority it has cost £76,000 over the last two
years pay for five appraisals and management plans. I have obtained
funding for these through grant schemes and as part of Growth
Points funding and have allocated 0.8 fte staff resources over
the last two years to manage this work, to produce sustainability
appraisals and work with the local plans team to ensure that the
recommendations are embedded within the Local Development Framework
process. I will not have funding opportunities for further management
plans. A sensible timetable and additional resources will be required
to meet provisions of the proposed clause.
— Re combining Conservation Area Consent
and Planning Consent. As a result of Shimizu the number of Conservation
Area Consent has dropped significantly. In Cornwall during 2007
there were 79 applications most of which were accompanied by Planning
Applications. Therefore the perception that the change in procedure
will make massive savings is, in my opinion, flawed.
— The proposed change as part of clause
9 of the revised clauses on Conservation Areas is welcomed and
will increase management of change and will restore an element
of pre-Shimizu protection. It will however substantially increase
the number of applications requiring specialist advice. In 2009
it is anticipated that the new Cornish unitary authority will
be responsible for determining 18,000 applications. Approximately
a third will either affect a listed building or conservation area.
This does not include applications affecting the World Heritage
Site which fall outside a conservation area/are not listed.
July 2008
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