Memorandum submitted by the Association
of Small Historic Towns and Villages (ASHTAV)
The Association of Small Historic Towns and
Villages (ASHTAV) is an organisation that works to unite amenity
and civic societies, parish and town councils and individuals
in small historic towns and villages throughout Britain. Our aim
is to preserve the beauty, vitality and distinctiveness of these
towns and villages, encouraging high standards of architecture
and planning and supporting local communities. We keep our members
informed of developments and best practice in government, planning,
environment, housing and transport through a website, seminars,
and quarterly magazine.
ASHTAV welcomes the opportunity to make a submission
to the Culture, Media and Sport Committee regarding the Draft
Heritage Protection Bill. Comments on the areas of interest specified
are set out below.
1. THE OVERALL
AIMS AND
SCOPE OF
THE DRAFT
BILL
1.1 ASHTAV supports the review of heritage
protection, and particularly the aim to make the process of heritage
protection more transparent and easier to follow for everyone,
benefitting small community groups, interested individuals and
historic building owners. We hope that the publication of enhanced
criteria, and guidance aimed at non-heritage professionals, will
bring success in this objective.
1.2 ASHTAV is very pleased to see that the
role of Conservation Areas and Local Lists in protecting heritage
is to be strengthened, helping to preserve local distinctiveness
and coherent historic environments. The enhancement of Conservation
Area powers to pre-Shimizu levels is very welcome. However, both
Conservation Area and Local List protection is reliant on strong
local policy, including the establishment of Article 4 directions,
currently underused due to complexity and a lack of will at local
government level. It is imperative that the new powers are backed
up by legislation that is easy to use by local authorities, and
that training is given in this area. We are concerned that there
is still no statutory duty on Local Authorities to maintain and
enforce their Local Lists.
1.3 It is stated in the Draft Bill that
increased consultation will be an important part of the new process.
However, although there is mention of consultation arrangements
with local and regional government and major stakeholders such
as developers and advisory agencies, there is very little mention
of consultation with the general public. ASHTAV maintains that
good consultation should take into account the views of those
living and working within a historic environment, and that local
communities should be regarded as important stakeholders in decisions
made about heritage assets.
2. THE ESTIMATES
OF COSTS
AND BENEFITS
SET OUT
IN THE
IMPACT ASSESSMENT
PUBLISHED ALONGSIDE
THE DRAFT
BILL
2.1 Assumptions are made in the estimates
of costs and benefits shown in the Impact Assessment which in
our view are unrealistic. Primarily we would disagree with the
statement that: "Unless clearly stated otherwise, we assume
that the number of people working within and using the heritage
protection system in the future will not deviate from current
trends". The changes involved in the transition to a unified
list, the necessity to re-evaluate many entries on the list, and
to establish some level of consistency alone will require a substantial
amount of work, and therefore increased staffing, and increased
cost. English Heritage would need vastly increased capacity to
deal with the load, which would be difficult under their current
funding levels without taking away funds from another area of
their work. We hope that this will not come at the expense of
project funding, building restoration and maintenance, or outreach
and interpretation.
2.2 ASHTAV is not a statutory amenity society,
but understands the common pressures and difficulties of maintaining
an excellent service and a heavy workload without a great deal
of staff or budget. It is judged in the Impact Assessment that
whilst there will be a cost implication for the statutory amenity
societies, this should not be taken into account due to the fact
that although the statutory amenity societies must be consulted,
they do not have to respond. In our experience the reality is
that any increase in the amount of paper work coming in or changes
in process made will have an immediate impact. The statutory amenity
societies should be given increased funding to enable training
to take place and to expand capacity to absorb the increased administration
the new system will require.
2.3 The impact on small societies such as
local civic societies is not taken into account. There societies
are often at the forefront of protection for their local environment,
and it would be beneficial to all if funding were provided to
increase their capacity, giving them the tools to utilise the
new heritage protection process.
2.4 As we discuss above, we see little evidence
in the Draft Bill that there will be increased public involvement
with the Heritage Protection system. ASHTAV would be keen to see
enhanced legislation and guidance to ensure consultation does
take place with local communities and interested individuals.
3. THE STAFFING
AND SKILL
LEVELS NEEDED
FOR EFFECTIVE
IMPLEMENTATION OF
THE PROVISIONS
IN THE
DRAFT BILL
3.1 There will be a need for an increased
number of staff, with relevant training and skills, to prepare
the enhanced register entries. Obviously this will take place
over time, but to have a truly integrated register some deadline
must be set for this, and adequate provision made in terms of
staff and skills.
3.2 ASHTAV is aware that there are still
Local Authorities who operate with only one Conservation Officer,
sometimes none at all, and very few archaeological staff. The
successful maintenance of Historic Environment Records will be
dependent on skilled and numerous staff to operate the system,
especially in terms of making the HERs accessible to the public,
in turn making the heritage protection process more accessible
to the general public.
June 2008
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