Consultations, Briefings and Evidence
BEFS responds to consultations, calls for evidence and compiles briefing papers by drawing together the views of its members and associates. If you are interested in older responses, please contact us.
BEFS is supportive of the Scottish Government’s Draft Infrastructure Investment Plan for Scotland, particularly the inclusion of existing homes within the definition of infrastructure; the support for resilient and sustainable places, and the acceptance of the recommendations previously made by the Infrastructure Commission for Scotland.
BEFS responded to the Scottish Government’s consultation on draft proposals for changes to Permitted Development Rights for the four development types selected for Phase 1 of their programme.
BEFS responded to the Scottish Government’s technical consultation on proposed amendments to Scottish Planning Policy and housing. The response by the Key Agencies Group can be found here.
BEFS highlights that addressing circular economy issues, contributing to the localism agenda, bringing in policy incentives for reuse/repurposing, and prioritising maintenance of our existing buildings, whilst considering the value of skills development within a newly invigorated Town Centre Action Plan, could provide the benefits for towns, and their people, that the group are hoping to achieve.
BEFS response to the Environment, Climate Change and Land Reform (ECCLR) Committee’s call for views reiterates the place of the existing built environment as part of the sustainable circular economy, a resource containing significant embodied energy, but also requiring a policy of maintenance to provide these benefits in full. BEFS also emphasises that seeing leadership invest in policy implementation in a decisive manner is central to the success of any Green Recovery policies, and that a lack of local authority resource would be one of the greatest barriers to a Green Recovery taking place.
BEFS response draws on arguments made previously in relation to the Circular Economy, the Built Heritage Investment Group, Housing to 2040, and the essential part the built environment plays in supporting a skilled workforce. Making sure that communities across Scotland can make their views heard will ensure the current policy work can go further, with increased economic and social benefits. Members’ submissions: SURF. Historic Environment Scotland’s submission.
Energy Efficient Scotland: Improving energy efficiency in owner occupied homes – Consultation Response (08/04/2020)
BEFS completed the online questionnaire and supplied a workshop report compiled after a recent HEWG meeting explored the questions raised with BEFS members. The ‘actions’ in the current plan were thought to tend more towards achievable than ambitious – respondents raised whether this was enough given the declared climate crisis? Members responses: RTPI and RIAS.
Prior to Stage 3 debates, BEFS had issued a briefing paper for MSPs, based on previous work by the Planning Taskforce and comments in relation to refreshed and new topics of interest to BEFS membership.
BEFS responded to the EES consultation highlighting the importance of accurate EPC ratings for all buildings, the time needed for the skills-supply chain to be in place, and the necessity for education around behaviour change, as well as mandatory adaptations, to truly enable holistic, substantial and significant change. BEFS sits on the Short Life Working Group in relation to this area.
BEFS response to the Scottish Community Development Centre’s call for views on UN-SDG 11 supports the Scottish Government’s adoption of the UN-SDGs but appreciates that meaningful change may only come from an active leadership willing to make hard choices, supported and steered by a strong Third Sector. The full UWS-Oxfam partnership publication can be found here.
BEFS responded to this consultation, reiterating points made previously about the importance of maintaining EU standards and principles in relation to environmental protections and governance. BEFS supported many aspects of the responses by Members, including: CIfA, Scottish Environment Link and NTS.
BEFS response relates to the important role and place of the historic environment within the Programme, including within high-level outcomes, as well as how the qualities of buildings within the historic environment were described within the consultation. BEFS did not respond to the SEA report in relation to this consultation.
BEFS response was in relation to BEFS as a registered charity in its own right. The response was shared with Members to help inform their own responses where relevant. The consultation is in relation to OSCR’s role as the charities regulator in Scotland and what powers OSCR has in relation to charity governance.
BEFS held a workshop to consult with members on Historic Environment Scotland’s two consultations that took place in February. This well attended event informed the responses for the two consultation responses below which were submitted via Survey Monkey. BEFS members also responded: Historic Houses.
BEFS held a workshop to consult with members on the two HES consultations taking place in February. This well attended event informed the responses for the two consultation responses below which were submitted via Survey Monkey. BEFS members also responded: SPAB
BEFS recent HEWG focused on a workshop gathering responses to the HES Historic Environment Policy Consultation (which closed at the start of December). The responses from this well attended event workshop were synthesised into a formal consultation response which was submitted via the online portal. BEFS have also been provided with responses from our Members Historic Houses and IHBC.
BEFS recently submitted a response to Historic Environment Scotland’s Corporate Plan consultation. The information in the response was compiled from the responses received from BEFS members across a range of events.
BEFS recently submitted a response to the Government consultation on the Culture Strategy for Scotland. BEFS consulted widely with members and also worked extensively with MGS, HLF, NTS and HES on shared concerns relating to the visibility of heritage within a strategy designed to be inclusive of all forms of culture.
BEFS has responded to the Scottish Government consultation on energy efficient homes. Energy Efficient Scotland will require minimum energy efficiency targets to be met by all buildings in Scotland and so it is considered vital that the views of individuals and public bodies are taken into consideration and used to shape the programme.
Energy Efficiency Standard for Social Housing post-2020 (EESSH2) – Consultation Response (24/07/2018)
EESSH2 proposes a longer term approach to removing poor energy efficiency as a driver for fuel poverty in social housing, and BEFS has responded to these proposals to set a challenging and aspirational target to maximise the number of social rented homes meeting an EPC band B by 2032.
BEFS, CIfA, Archaeology Scotland and ALGAO collectively responded to the Environment, Climate Change and Land Reform Committee’s call for evidence on EU Environmental and Animal Welfare Principles. The response emphasises the need to ensure that the protective measures currently enshrined within EU law are not lost or diluted due to Brexit.
BEFS responded to the final official consultation from DCMS – the Heritage Lottery Fund Policy Directions consultation. There were no substantive changes recommended – BEFS was keen that HLF continue to share data to enable better understanding of projects and organisational need across the heritage sectors.
BEFS submitted information to the Local Government and Communities Committee in response to their call for evidence. BEFS comments on the need for additional investment in planning to ensure improved community engagement, the need for regional planning to retain a statutory footing and for planning to have a statutory purpose that aligns with the UN Sustainable Development Goals. Member submissions: Archaeology Scotland, Cockburn Association, National Trust for Scotland, CiFA/FAME, RTPI Scotland, IHBC Scotland, RIAS, RICS, Architecture & Design Scotland, AHSS, ALGAO and PAS. HES response can be found here.
BEFS submitted information to the Finance and Constitution Committee in response to their call for evidence on the estimated financial implications of the Planning (Scotland) Bill as set out in its Financial Memorandum. BEFS submission comments on Strategic Development Plans, Local Development Plans and Local Place Plans.