Historic Environment Policy for Scotland – A Summary

BEFS Policy & Advocacy Lead, Ailsa Macfarlane, provides a summary of the new Historic Environment Policy for Scotland documents.

Almost two weeks ago HES launched its new strategic policy document, Historic Environment Policy for Scotland (HEPS) as well as a suite of new policy and guidance documents, which are designed to sit along-side HEPS, providing detail and application direction:

  • Designation Policy and Selection Guidance
  • Scheduled Monument Consents Policy
  • Managing Change Guidance: Demolition of Listed Buildings
  • Managing Change Guidance: The Use and Adaptation of Listed Buildings

Here, we take a first-look, a brief overview, of how far we’ve collectively come since the Policy Conference held by BEFS in early 2018. What was suggested by participants then (covers what has now become the suite of documents above) is perhaps a better reflection of where we are now than revisiting the extensive consultation process. The transformation, from HESPS to HEPS, has been extensive. The change is far more than just a shuffling of acronyms.

Historic Environment Policy for Scotland (HEPS)

The overarching suggestions in early 2018 included a slimmed down Policy document, with appendices presented as their own separate documents. This was definitely taken to heart – 70+ pages have been reduced to a far more focused 18 pages. A document that could be considered far more nimble, with a brevity which can be appreciated by many. A document which also received 232 consultation responses, a wide variety of opinions and voices to attempt to take into account. No respondent, or respondent group, should expect to see all their suggestions taken on board.

There were ‘asks’ for the vision to be broader, to include: resourcing, diversity, inclusivity, the intangible and sustainability. These all receive attention – whether directly as part of the Policies themselves – or as aspects of the challenges and opportunities section.

These inclusions demonstrate new ways of thinking and acting; new opportunities for policy to be increasingly relevant and accessible. However, there are aspects which did not get addressed: those of ‘placemaking’ and ‘stewardship’ failed to make the cut.

Could the wording around Climate Change have been stronger? The phrasing implies positive intentions but perhaps fails to express the immediacy of action now necessary. The challenges around climate change also enable a light to be shone on sustainable reuse, as well as highlighting the urgency of protective action needed in some instances.

Designation Policy and Selection Guidance

There is much to praise in this new document: the much needed link to the appropriate application form is now included; positive descriptions of how designation is carried out are present; diagrams provide a little more clarity in relation to inter-organisational involvement in the processes; the concept of reviewing designation is present early and applies across the designation landscape; Building Preservation Notices are an explicit part of the process (where appropriate); and each section follows a structure and rhythm, which promotes a far easier read than previously.

The removal of conservation areas from this document may be challenging to some, but helps to more clearly define which organisations should take responsibility for these designations. The lack of information around implications and penalties in relation to designations, as well as the necessity of appropriate maintenance, perhaps says more about the current availability of resource related to enforcement than about the document and directives themselves.

The revised descriptions for listing categories (A,B,C), sees the removal of the spatial/locality based elements, which could be seen as promoting further subjectivity. Widely understood and agreed definitions of, ‘outstanding’, ‘major’, and ‘representative’ may take some time to bed-in.

Scheduled Monument Consents Policy

This is probably one of the least altered of the policy documents – the legislation remains static, so there was little need to review and redraft. The beneficial aspects of intervention listed will be seen as a positive step by many, and the definitions of personnel as ‘competent’ rather than experienced, is noted as a further beneficial step towards more inclusionary language.

There could be concern noted that HEP 6 is not explicitly included within the document – as this type of Working Together in relation to Scheduled Monuments could be usefully highlighted to enable further connection between owners and legislative bodies.

Managing Change Guidance: Demolition of Listed Buildings

There could be much to say for each document, but as this is an overview, a few comments will have to suffice. There is clarity here on the protections and processes necessary. The positive additions in relation to asset transfer and community ownership give excellent pointers to those communities considering action.

Managing Change Guidance: The Use and Adaptation of Listed Buildings

It is a great positive to see that conservation statements have been added to the document. This is a useful addition.

BEFS expressed concerns around phrases such as, “The best use of a listed building is often going to be the one for which it was designed”, and, “The continued use of a listed building for its original function will normally be the best way to retain its historic character.”  This reads as a rather tight description, and could imply an organisation still too hesitant in enabling useful change, which could benefit places, people and the planet with sustainable decisions. It is the flexibility of many of our historic buildings that has seen them survive for centuries. Ironically, most of the illustrative examples supplied by HES in this document are not demonstrating their original use – but in doing so they do demonstrate the excellent variety of opportunities for change and adaptation.

Whilst it is an academic exercise to parse the texts, we have to focus on the task at hand. It is not the picking apart of words or phrases that will protect, promote and encourage the use, reuse, enjoyment and understanding of our historic environment – it is how the documents are used. How these documents enable protection, enforcement, and pragmatism of reuse, will be their true assessment. Our parallel report analyses how existing historic environment policy is being used in one area of the planning process, it would be good to see HEPS more frequently utilised.

HES are putting in place additional training for those who need/want to use these documents. This training will be key to fully embedding new policies and ways of thinking across a wide number of organisations. Practical supporting literature which details: the alignment of skills and standards necessary for procedures; the suggested flow through process charts of actions around particular legislative ask;, and a clearly expressed hierarchy of policies and legislation; are all training materials which will aid the user – whether professional or personal – to understand how these policies truly apply to the historic environment.

Ultimately it’s not the words themselves that become important, it’s the opportunity they represent to refresh training, refresh thinking and to answer questions, enabling better results for people and place.