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 statement supports measures that increase the accessibility and usability of Scotland’s dwellings, improving quality of life and enabling people to stay in their homes for longer – positively contributing to the continued use and occupancy of existing buildings. For any interventions and decisions which impact on traditionally constructed homes and the historic environment, BEFS points to existing guidance on the adaptation of historic or designated properties.
BEFS broadly agrees with the metrics proposed and supports the drive to improve the energy performance of Scotland’s homes, including traditionally built properties. The inefficiencies of the EPC in relation to traditional buildings has been raised previously and BEFS would reiterate that the existing built environment is the most sustainable building resource we have, through the embodied energy present and the potential for adaptation and reuse. Assessed appropriately our existing built environment presents an enormous opportunity to provide climate solutions. As such we are pleased to see greater consideration given to fabric within the proposals but would hope that inclusion of a Fabric Rating could and should positively contribute to a fabric first and maintenance approach to Scotland’s buildings, alongside appropriate retrofit.
In response to this call for views on the Visitor Levy Bill, BEFS statement reiterates previous comments given on this topic, and continues to emphasize the central role that the historic environment specifically – and the built environment more widely – play as a direct contributor to the tourism offer of Scotland. BEFS notes that the historic environment can be directly impacted by tourism; the economic, cultural, environmental, and social value of Scotland’s places, sites, and landscapes being appreciated by visitors comes at a price. As such, any legislation and ensuing revenue must be part of a wider conversation towards a successful management plan to simultaneously celebrate and protect our natural and built heritage, whilst ensuring quality of life for Scotland’s communities.
BEFS response welcomes this guidance on effective community engagement in local development planning, for communities and local authorities, and supports all moves towards clarity on how planning authorities can comply with their legal duties to engage with the public when preparing their local development plans. Questions around delivery – in particular around capacity of local planning authorities’ duties regarding monitoring and reporting – remain.
BEFS response reiterates the important role that the existing built and historic environment can and should play in a sustainable circular economy.
BEFS recognises the intentions of the proposed changes, towards easing pressure on planning teams to deliver ambitious net zero targets, and to enable easier implementation of climate beneficial solutions within planning. This response urges caution however, as unintended consequences of some of the proposed exemptions should be considered, in particular around the proposals for replacement windows, solar panels and potential impacts on conservation areas and other designations.
BEFS considers that the importance of examining the budget is not just to look at what is within the cultural portfolio – but to understand how our cultural heritage can be eroded through a lack of investment in data, in planning, and in regeneration; many of the aspects that help to support genuine place-based approaches.The Culture Strategy as it stands speaks to a different time, with different pressures, different benefits, and a different social and economic outlook. What is needed is a mechanism that can leverage action for delivery and collaboration. BEFS questions whether another Strategy or Action Plan needs to be formed (or refreshed as it is phrased here), and whether the strategies within the sector could instead be supported to deliver effectively.
BEFS strongly welcomes the inclusion of cultural heritage and the historic environment as components but would suggest that presenting cultural heritage and natural heritage as separate criterion could undermine their fundamentally symbiotic nature.
BEFS considers that the benefits of local living and 20 minute neighbourhoods are well laid out with clear links to the Place Principle, Scotland’s National Performance Framework and UN Sustainable Development Goals, to help deliver the policies as set out in National Planning Framework 4 (NPF4). The collaborative approach taken is to be encouraged but there remain questions around delivery and how this can be implemented and resourced, enacting meaningful change though regional policy, Local Development Plans and Local Place Plans
BEFS response broadly supports that local authorities should be granted greater ability for discretion over increased rates and premiums, noting the possibility for unintended consequences in introducing additional powers; and consider that the efficacy of the intended discretionary nature of increases would depend on the capacity and resource of local authorities to fully – and holistically – consider ‘local circumstances, including balancing the needs and concerns of their communities with wider economic and tourism interests’, including good outcomes for the existing build and historic environment. BEFS has regularly lobbied for the continued use and re-use of existing buildings in addressing societal needs, as well as contributing positively to Scotland’s climate and net zero agendas.
BEFS response highlights the lack of appreciation for the cross-cutting benefits that come from cultural-heritage means many across the sector are continually explaining and reiterating the wide-reaching positive impacts of their work. It calls for greater alignment with the UN-SDGs particularly SDG 11.4: ‘Strengthen efforts to protect and safeguard the world’s cultural and natural heritage’. The additions of Targets and Outcomes, taking into account cross-sectoral inputs, could help to: incentivise, and enable, cross-portfolio working to deliver against net-zero, wellbeing and wider community aims.
BEFS supports action and initiatives that enable and support communities to benefit from their places and spaces. Adapting, repurposing, and reusing our current building stock presents enormous opportunities for skilled employment, carbon solutions, good places, healthy town centres and more homes; solutions which provide benefits to economy, people and place.
BEFS response reiterates the role of the built and historic environment in providing solutions towards net zero and a just transition.
BEFS notes the importance of a co-ordinated approach to this Managing Change Guidance for decision makers within the planning system, with the related technical guidance.
BEFS’ response to this consultation on the new draft historic environment strategy follows wide ranging and comprehensive consultation with Members.
We consider a new strategy to be a positive advocacy tool for the role of the historic environment across multiple agendas, outlining shared priorities for the heritage sector. Further clarity around monitoring and measurement of delivery of KPIs will be welcome as the delivery plan is progressed.
BEFS considers that the draft framework clearly sets out HES regulatory and advisory roles.
BEFS response reinforces concerns from the sector that the proposed new bill fails to recognise the contribution of the historic environment and any connection to existing historic environment polices and guidance. This is a missed opportunity – the historic environment is a key part of Scotland’s landscapes.
Stakeholder Consultation on the selection criteria and approach to National Parks in Scotland (30/11/2022)
This consultation from NatureScot is part of the commitment from Scottish Ministers to establish at least one new National Park by 2026. Exploring the contribution of the historic environment and cultural heritage to the role and approach of National Parks is welcomed and felt to be vital; embedding heritage where appropriate and ensuring that existing considerations are maintained and enhanced should be a key concern.
Read the response from BEFS Members: RTPI Scotland
BEFS welcomes the general principles of the proposals, but considers that there is still some work to be done towards a broader culture shift within the construction industries, as well as Scotland’s home-owners, businesses, suppliers, and manufacturers towards a fabric first – incorporating a maintenance first – approach to support the transition to net zero.
BEFS response recommends that the symbiotic nature of the existing historic (including the built environment) and the natural environment is recognised and fully integrated within land management.
Read BEFS Members, RICS response
Budget scrutiny 2023-24: Funding for culture Constitution, Europe, External Affairs and Culture Committee (22/08/2022)
BEFS response highlighted concerns from the Spending Review. The increasing Skills needs, the place of fair-work within the sector; as well as the challenges around public-private investment opportunities. The increasingly uncertain and challenging times we find ourselves in call for more certainty from Scottish Government funding, not less.
BEFS welcomes this consultation on the Circular Economy Route Map to 2025 and Beyond (running concurrently to the Consultation on the Proposal for a Circular Economy Bill), which we consider to be a broadly holistic, ambitious and well considered series of measures. As we have raised in previous consultations – most notably and recently in BEFS response to the draft NPF4 – the existing and historic built environment, whilst often recognised in part, lacks full integration; existing buildings, infrastructure and planning are positive solutions across a variety of areas, they should not sit separately.
BEFS is supportive of plans and proposals intending to facilitate the move to net zero, recognising the role that PDR for electric vehicle charging infrastructure and change of use has to play. However any changes should be just and equitable, ensuring quality place-making and – within the existing exemptions – changes must, where appropriate, align with and refer to the Historic Environment Policy for Scotland (HEPS). This could mean for some cases assessing impact on a sensitive designation would best be undertaken through a planning application rather than through prior notification/approval.
In forming this response BEFS received detailed views from Members both in writing and through a roundtable discussion.
Whilst BEFS notes general support for the consultation and the development of NPF4 as a broad and open process, some concern is felt that oversimplification has resulted in omissions – notably the clear list of benefits that the historic environment delivers, somewhat to the detriment of the historic environment’s representation as a national asset across planning and infrastructure.
Historic Environment Scotland’s response can be found here.
In forming this response BEFS received detailed views from Members both in writing and through a roundtable discussion.
BEFS recognises the draft Local Development Plan Regulations and Guidance’s clear aims at interconnectivity, clarity around policy landscape and a holistic approach. The guidance would benefit from greater consistency throughout, but the focus on re-use, infrastructure and read across to NPF4 and Scotland’s National Performance Framework (lacking in NPF4) is welcome.
Scotland’s high streets and town centres have seen much change over a number of years. BEFS response to this Call for Views focused on the question of how to keep town centres alive. To achieve this it is important to recognise the existing built environment as a valuable national asset; Scotland’s high streets and historic town centres have a role to play across the board, within sustainable development, homes, jobs and infrastructure and wellbeing.
The Regulation of energy efficiency in existing non-domestic buildings: call for evidence (25/02/2022)
Responding to this call for evidence as part of the draft Heat in Buildings Strategy, BEFS notes the importance of enforcement to aid regulation. BEFS would highlight the need for regulations and protections to align, complement and further enable those that already exist for traditionally constructed and historic buildings incorporating a nuanced approach.
The Role of Local Government and its cross sectoral partners in financing and delivering a net-zero Scotland (21/01/22)
In this consultation response, BEFS highlights the role the existing built environment can play in a sustainable circular economy. Adapting, repurposing and reusing buildings presents an enormous opportunity to provide carbon solutions, solutions which can provide benefits to economy, people and place.
In forming this response BEFS received detailed views from Members both in writing and through a round table discussion held on 06/01/2022. Other relevant consultation responses from BEFS can be seen below:
BEFS welcomes this consultation on proposed changes to Scottish building regulations. BEFS is broadly supportive of proposals intended to optimise improvement as set out in the draft Heat in Buildings Strategy, but notes the importance of a nuanced approach to traditionally constructed buildings.
Other relevant consultation responses from BEFS can be seen below, as many issues overlap and demand associative consideration:
BEFS strongly supports the drive to improve the energy performance of Scotland’s homes, including traditionally built properties, and therefore welcomed this consultation on the proposal to reform the current Energy Performance Certificate (EPC) as part of the draft Heat in Buildings Strategy.
Based on discussion at the Historic Environment Working Group (HEWG) and taking into account Member views expressed, BEFS submitted a short response to the Constitution, Europe, External Affairs and Culture Committee Call for Views to support their scrutiny of culture sector funding in Scotland.
BEFS broadly supports the proposed grant programmes and Grants Priorities outlined in the Historic Environment Scotland consultation document, with some caveats explored in more detail through question responses. In forming this response BEFS received detailed views from Members both in writing and through discussion at the Historic Environment Working Group (HEWG). Read Member Responses: SoAoS
BEFS response supports the Regulations as they stand, but notes that many of the concerns around LPPs remain unaddressed by the consultation. Guidance and further clarity is needed around a number of issues, most notably the lack of mitigation for inter-community conflict, and the lack of resourcing for either communities or Local & Planning Authorities. Read Member responses: SURF RTPI You can see the response from HES here.
BEFS response to Historic Environment Scotland’s consultation on Managing Change Guidance Note: Working on and near to scheduled monuments supports and reiterates points made by Member organisations. Read members responses: ALGAO, SoAoS, CIfA.
BEFS submitted a response to the Scottish Government’s Consultation on Scottish skills requirements for energy efficiency, zero emissions and low carbon heating systems, microgeneration and heat networks for homes. Members’ responses: AHSS.
Draft Heat in Buildings Strategy, Achieving Net Zero Emissions in Scotland’s Buildings – Consultation (30/04/2021)
BEFS submitted a response to the Scottish Government’s Heat in buildings strategy – achieving net zero emissions consultation. Members’ responses: AHSS.
BEFS Members are supportive of the aims and outcomes expressed in the Position Statement but have expressed concerns about delivery – mechanisms and policy hierarchies; and how SPP and current heritage protections will be usefully translated into the NPF4. Scotland’s Landscape Alliance’s response, HES.
BEFS submitted a short response suggesting alignment between natural and heritage protections, making considerations for people and place, and considering the values of landscape scale decisions.
BEFS submitted a short statement in response to the Scottish Government’s consultation on the Strategic Environmental Assessment of the update to the Climate Change Plan 2018-2032.
BEFS responded to the Local Government and Communities Committee’s call for views on the Scottish Government’s updated Climate Change Plan (CCPu) in relation to planning, housing, buildings, fuel poverty and green recovery.
Feedback from Members was largely positive. Those working with community groups around an asset (HTN and AHF) saw great benefit in the document’s approach. There were questions about what actions to take from the document, and whether more tailored, bite-size, sections would be available in the final iteration.
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.
In response to the Environment, Climate Change and Land Reform Committee (ECCLRC) Call for Views, BEFS worked with NTS and HES to support the pertinent sections of their responses. These focus on how Scots law would actively keep pace with EU legislation, supporting the enshrining of the four environmental principles, and how the proposed definition of ‘environment’ should broaden and therefore align with current SEA definitions.
BEFS response focuses on the opportunities for skilled work that the built environment, and a maintenance agenda, can provide; fulfilling the immediate need illustrated in the Scottish Housing Condition report; highlighting the economic and social benefits in relation to our transition to net zero. BEFS also highlights the asks made by the Built Heritage Investment Group and work of the Infrastructure Commission.
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. Members’ submissions: SURF. Historic Environment Scotland’s submission.
National Planning Framework 4 – Call for Ideas (30/04/2020)
A number of BEFS members submitted responses to the Scottish Government’s National Planning Framework 4 call for ideas: RTPI, Landscape Institute Scotland, CIfA, PAS and ALGAO. Historic Environment Scotland’s submission here.
Energy Efficient Scotland: Improving energy efficiency in owner occupied homes – Consultation Response (08/04/2020)
BEFS response focuses on: well-maintained buildings being the first step to safer, warmer homes; the EPC ratings being assessed and applied accurately for building type; and adaptations being appropriate for the health of both the occupants and the building in question. Members’ responses: RIAS, IHBC.
BEFS is glad see the inclusion of maintenance in the Scottish Government’s vision but emphasises concerns over a lack of connections across policy areas and highlights the continuing challenges of EPCs with regards to traditionally built properties.
BEFS response highlights that the revision of planning fees is an opportunity to embed a new approach to development which reflects the environmental benefits of reusing and re-purposing all Scotland’s existing building stock, because of the embodied energy.
BEFS would like to see a wider approach where the Climate Act, Communities Act, Infrastructure Commission Report and the National Planning Framework (NPF4) are considered to support healthy places, the wellbeing of citizens and the aims of a wellbeing economy.
BEFS responded to the Scottish Government’s consultation on their Proposed Work Programme, and associated Sustainability Appraisal (SA) report, for reviewing and extending permitted development rights (PDR) in Scotland.
BEFS issued this briefing paper to all MSPs ahead of the Sustainable Development Goals in Scotland, On Target for 2030? debate in the Scottish Parliament on 16th January 2020. BEFS contributed to the UWS-OXFAM report in relation to UN:SDG 11 – Sustainable Cities and Communities. Read the full report here.
BEFS responded to the Scottish Government’s Developing Scotland’s Circular Economy consultation on proposals for legislation, highlighting the absence of the built environment in the consultation document.
BEFS response focused on ensuring appropriate training and skills for interventions within historic buildings were considered. BEFS also reiterated concerns around how EPC ratings are assessed in relation to traditionally built properties.
BEFS response focuses on our existing building stock being our most sustainable resource, and making clear that Principles and signposting should include the Historic Environment Policy for Scotland and related Managing Change guidance.
BEFS stated the role of the built environment as being a direct contributor to tourism; and also impacted by tourism. Read HES’ response here.
BEFS was invited to respond to petition PE1749 on the financial viability of listed buildings. The petition calls on the Scottish Parliament to urge the SG to ensure that: 1) financial viability studies are conducted on listed buildings requiring restoration and/or maintenance, 2) responsibility of ownership is established for this work and; 3) financial assistance is provided where listed buildings are at risk of falling into disrepair.
BEFS completed the 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. 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 responded to the Local Government and Communities Committee’s call for views on a new inquiry into empty homes in Scotland. The response highlights a lack of appropriate knowledge and understanding around traditional buildings and the forthcoming recommendations in this area by the Scottish Parliamentary Tenement Maintenance Working Group.
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 responses by Members: 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 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.
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. 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. 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. Members’ responses: Historic Houses and IHBC.
BEFS recently submitted a response to Historic Environment Scotland’s Corporate Plan consultation.
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 responded to the Environment, Climate Change and Land Reform Committee’s call for views on the content of the Climate Change (Emissions Reduction Targets) (Scotland) Bill.
BEFS has responded to the Scottish Government consultation on energy efficient homes.
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.
BEFS responded to the final official consultation from DCMS – the Heritage Lottery Fund Policy Directions consultation.
BEFS submitted information to the Local Government and Communities Committee in response to their call for evidence. 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.