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.

Infrastructure Investment Plan – Consultation (18/11/2020)

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.

Permitted Development Rights (PDR) in Scotland – Consultation on Phase 1 Proposals (12/11/2020)

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.

Scottish Planning Policy and Housing – Technical Consultation (09/10/2020)

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.

Town Centre Action Plan Review – Call for Evidence (18/08/2020)

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.

Green Recovery – Call for Views (07/08/2020)

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.

UK Withdrawal from The European Union (Continuity) (Scotland) Bill – Call for Evidence (31/07/2020)

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.

Just Transition Commission – Call for Evidence (30/06/2020)

BEFS response focuses on the opportunities for skilled work that the built environment, and particularly a maintenance agenda, can provide across Scotland; fulfilling the immediate need as demonstrated by the Scottish Housing Condition report; highlighting the multifaceted benefits these measures would bring economically, socially and in relation to our transition to net zero. BEFS also highlights the asks made by the Built Heritage Investment Group, which support these aims, as well as the work of the Infrastructure Commission and its recommendations.

Advisory Group on Economic Recovery – Call for Views (31/05/2020)

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.

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.

Housing to 2040 – Consultation Response (27/02/2020)

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.

Planning Performance & Fees – Consultation Response (13/02/2020)

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.

Replacement of European Structural Fund in Scotland – Consultation Response (12/02/2020)

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.

Permitted Development Rights in Scotland – Consultation Response (28/01/2020)

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.

Sustainable Development Goals in Scotland – Briefing Paper (16/01/2020)

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.

Developing Scotland’s Circular Economy – Consultation Response (18/12/2019)

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.

Role of Public Sector Bodies in Tackling Climate Change – Consultation Response (04/12/2019)

BEFS response focused on ensuring appropriate training and skills for interventions within historic buildings were considered. BEFS also took the opportunity to reiterate concerns around how EPC ratings are assessed in relation to traditionally built properties.

Local Energy Policy Statement – Consultation Response (04/12/2019)

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.

Local Discretionary Transient Visitor Levy or Tourist Tax – Consultation Response (02/12/2019)

BEFS stated the role of the built environment as being a direct contributor to tourism; and also impacted by tourism. BEFS was clear that responding to further consultations, in relation to revenue allocations and benefits for place, was eagerly anticipated. Read HES’ response here.

Financial Viability of Listed Buildngs – Parliamentary Petition (29/10/19)

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 Scottish Government 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.

Climate Change & Environmental Action Plan  – HES Consultation Response (18/06/2019)

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.

Planning (Scotland) Bill – Stage 3- Briefing Paper (17/06/19)

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.

Energy Efficient Scotland – Consultation Response (17/06/19)

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.

Empty Homes in Scotland – Parliamentary Evidence (17/05/19)

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.

Sustainable Cities and Communities (UN-SDG 11) – SCDC Call for Views (14/05/19)

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.

Environmental Principles and Governance in Scotland – Consultation Response (11/05/19)

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.

Climate Change Adaptation Programme 2019-2024 – Consultation Response (08/04/19)

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.

Scottish Charity Law – Consultation Response (29/03/19)

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.

Designations and Scheduled Monuments – HES Consultation Response (19/02/19)

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.

Demolition and Use and Adaptation of Listed Buildings – HES Consultation Response (15/02/19)

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

Historic Environment Scotland’s Historic Environment Policy – HES Consultation Response (03/12/18)

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.

Historic Environment Scotland Corporate Plan 2019-22 – HES Consultation Response (02/11/18)

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.

A Culture Strategy for Scotland – Consultation Response (19/09/18)

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.

Climate Change (Emissions Reduction Targets) (Scotland) Bill – Parliamentary Evidence (23/08/18)

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. The response supports the adoption of the most urgent action in respect of emissions targets and calls for a commitment to work towards zero net emissions by 2050.

Energy Efficient Scotland – Consultation Response (24/07/2018)

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.

EU Environmental & Animal Welfare Principles – Parliamentary Evidence (27/03/18)

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.

HLF’s future direction and funding – Consultation Response (22/03/2018)

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.

Planning (Scotland) Bill – Parliamentary Evidence (01/02/18)

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 ScotlandCockburn AssociationNational Trust for Scotland, CiFA/FAMERTPI Scotland, IHBC Scotland, RIAS, RICS,  Architecture & Design Scotland, AHSS, ALGAO and PAS. HES response can be found here.

Planning (Scotland) Bill Financial Memorandum – Parliamentary Evidence (26/01/18)

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.

Places, People and Planning Position Statement – Consultation  (11/08/17)

Energy Efficiency and Condition Standards in Private Rented Housing – Consultation (30/06/17)

Engaging Communities in Decisions Relating to Land – Consultation (16/06/17)

Future of the Scottish Planning System – Consultation (04/04/17)

Land Rights and Responsibilities Statement – Consultation (09/03/17)

Scottish Household Survey – Consultation (02/03/17)

Scotland’s Relationship with the EU – Parliamentary Evidence (05/09/16).

Historic Environment Scotland’s Draft Corporate Plan – HES Consultation (08/02/16)

Report on the Survey on the NPI for the Historic Environment (19/01/16)

Review of the Scottish Planning System (01/12/2015)

Historic Environment Scotland Act: Secondary Legislation Consultation (27/03/15)

The Smith Commission (30.11.14)

Historic Environment Scotland Bill Stage 3 Debate – MSP Briefing Paper (03/11/14) 

Historic Environment Scotland Bill – Briefing Paper (27/06/14)

Historic Environment Scotland Bill – Parliamentary Evidence (22/04/14)

Changes to Permitted Development Rights for Development by Telecommunications Code Operators (18/04/14)

Community Empowerment Bill (29/01/14)

Draft Scottish Planning Policy: Sustainability & Planning (16/12/13)

Common Agriculture Policy Budget: Pillar to Pillar Transfer 15/12/13)

National Marine Plan (13/11/13)

Joint Consultation on the Historic Environment Strategy for Scotland and the merger of HS and RCAHMS (31/08/13)

Draft Scottish Planning Policy (23/07/13)

National Planning Framework 3: Main Issues Report and Draft Framework (23/07/13)

Delivery of Regeneration in Scotland Inquiry – Parliamentary Evidence (15/03/13)

Getting across shared messages