Consultation Responses

BEFS responds to consultations by drawing together the views of its members and associates.  Consultation responses from the last two years are listed below in date order. If you are interested in older responses, please contact us.

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

BEFS focus for the response in this instance was 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.

The Principles of a Local Discretionary Transient Visitor Levy or Tourist Tax (02/12/2019)

A statement was issued in relation to this more technical and implementation concerned consultation. 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.

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

BEFS responded to the HES Consultation by completing the online questionnaire available, but also by supplying the Workshop report compiled after a recent HEWG meeting explored the questions raised with Members.

A comprehensive read which examines the issues with clarity, 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 can also be found from: RTPI  here, and RIAS here.

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

BEFS responded to the EES consultation making clear: the importance of accurate EPC ratings for all buildings, the necessary 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.

Call for views on Sustainable Cities and Communities (UN-SDG 11) (14/05/19)

BEFS response to the Scottish Community Development Centre’s call for views on UN-SDG 11 is quite naturally wide-ranging. The UN-SDG 11 covers (but is not limited to): access to adequate housing, sustainable transport systems, inclusive urbanisation, access to green-space, support for planning, and is the only SDG which involves strengthening and safeguarding the world’s cultural and natural heritage. BEFS 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 (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 Consultation (08/04/19)

BEFS responded to the Scottish Government, Scotland’s Climate Change Adaptation Programme 2019-2024 Consultation. This response related 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 (29/03/19)

BEFS responded to the Scottish Government Consultation on Scottish Charity Law. This 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 Consultation (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 Consultation (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 (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 (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 (19/09/18)

BEFS recently submitted a response to the Government consultation on the Culture Strategy for Scotland (open until 19th September). 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.

Energy Efficient Scotland Consultation: Making our homes and buildings warmer, greener and more efficient (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.

Consultation on the Energy Efficiency Standard for Social Housing post-2020 (EESSH2) (24/07/2018)

The Scottish Government is intending to build on progress already underway in the social housing sector throughout Scotland, with three quarters of the social housing stock already meeting the energy efficiency ratings in the first EESSH milestone set for December 2020. 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.

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

BEFS invited Lucy Casot, Head of the HLF in Scotland, to present to the Historic Environment Working Group, on HLF’s research in relation to the changes being proposed.  The sector-specific responses to a wide-ranging questionnaire have been summarised in the paper found here. BEFS supported many aspects of the changes but advised HLF to clearly retain their specific focus on heritage.

UPDATE: 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.

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

BEFS has responded to the latest Position Statement published by Scottish Government on the planning review. BEFS has expressed disappointment that the scope of the review has shifted from major reform to a series of procedural changes. BEFS has flagged up the inherent tension in seeking to balance greater community participation with the planning system while speeding up and simplifying decision-making processes.

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

This consultation proposes a gradual introduction of standards for energy efficiency and condition in private renting housing, using energy performance certificates as a method for assessment. BEFS has highlighted that EPC ratings do not apply readily to traditional buildings, and notes that management practice is a key factor, along with an understanding of how traditional buildings perform.

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

BEFS responded to the recent consultation on Engaging Communities in Decisions Relating to Land, suggesting that the guidance could go further in setting out the types of engagement considered appropriate in different scenarios; querying the meaning of ‘significant land holdings’; and also seeking clarification on how the guidance is to be used in urban areas.

Consultation on the future of the Scottish Planning system (04/04/17)

Responding to the consultation on the future of the Scottish Planning system, BEFS has highlighted the need for a more evidence-led approach; that the consultation is heavily weighted towards housing and infrastructure issues; questions the proposed removal of strategic development plans; highlights concern over the proposed removal of supplementary planning guidance.

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

This consultation sought views on the Scottish Government’s draft Statement on Land Rights and Responsibilities, which provides a set of principles to guide policy development and practice relating to the relationship between land and people. BEFS’s response seeks clarity on the status of the document, how it will be applied, and the meaning of ‘high standards of land ownership, management and use’. BEFS also highlighted the need to build capacity amongst community groups in taking on assets.

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

In a review of the Scottish Household Survey, which provides data for many National Performance Framework indicators, BEFS endorsed the retention of questions on cultural participation (including visiting historic places) and views on culture, heritage and the arts. BEFS also endorsed retention of the measure on condition of pre-1919 dwellings (under the Household Condition Survey), and endorsed ‘rating of neighbourhood as a place to live’, and ‘participation in land use decisions’ as useful data, especially within the context of community empowerment.

Consultation on Scotland’s Relationship with the EU (05/09/16)

BEFS submits evidence to the Scottish Parliament’s Europe and External Relations Committee on Scotland’s relationship with the EU. Evidence gave a flavour of members’ involvement with the EU in terms of the relevant EU Directives, funding relationships, networks and projects, training and movement of people with specialist skills.

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

BEFS held a workshop on the 20th January to help assist organisations in forming their response to the above and you will find the report arising here. You can also read responses submitted by Archaeology Scotland, the Chartered Institute for Archaeologists and the National Trust for Scotland.

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

BEFS undertook a survey in Nov/Dec 2015 on the indicator and measure for the historic environment on the National Performance Framework. The survey sought responses on the current indicator and measure and on alternatives. The Report summarises the responses.

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

The Scottish Government announced a review of the planning system in September and BEFS encouraged it’s Members to take the opportunity to engage at an early stage. We have received copies of submissions to the independent review panel from PAS, Archaeology Scotland, Scottish Civic Trust, Architectural Heritage Society of Scotland, RTPI Scotland, National Trust for Scotland, Institute of Historic Building Conservation Scotland Branch and the Chartered Institute for Archaeologists. Historic Environment Scotland have also shared their submission.

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

BEFS HES Act Taskforce formed this response, primarily providing commentary on how the secondary legislation will function with recommendations to ensure transparency and parity.

The Smith Commission (30.11.13)

BEFS submitted comments to the commission on how further devolved powers to the Scottish Parliament could be to the benefit of the built environment.

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

BEFS members appreciate the need for improved broadband services and mobile phone signals across Scotland but encourage the Scottish Government to ensure that the quality of the public realm and historic environment are protected from poorly sited development.You can also read responses from the Architectural Heritage Society of Scotland and Archaeology Scotland.

Community Empowerment Bill (29/01/14)

BEFS  comments on the Bill arise from a workshop held with stakeholders on 15 January 2014. You can also read the National Trust for Scotland’s response.

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

BEFS welcomes the opportunity to comment on the redrafted section of the draft policy but does not support the presumption in favour of development that contributes to sustainable development. You can also read Archaeology Scotland’s response.

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

BEFS urges the transfer of the maximum level of funds (15%) to help ensure future management of sites of historic and cultural significance.

National Marine Plan (13/11/13)

BEFS welcomes the recognition given to the historic environment in the document and makes some specific recommendations regarding wording as well as case studies in supplementary guidance.

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

BEFS welcomed the collaborative nature of the draft Strategy, but raised questions as to how it will be implemented and clarity on how proposed actions will address the challenges. In responding to the merger between HS and RCAHMS, BEFS focussed on the impact of a new charitable body on the third sector, capacity at local level to inform decision-making and the relationship between the new NDPB and local planning authorities.

You can also read responses from Architectural Heritage Society of ScotlandALGAOArchaeology Scotland, Historic Houses AssociationInstitute for Archaeologists, Institute of Historic Building ConservationNational Trust for Scotland RTPIScottish Civic TrustSociety of Antiquaries of Scotland and War Memorials Trust.

Draft Scottish Planning Policy (23/07/13)

BEFS comment on the lack of weight given to the protection of the historic environment and call for it to have stronger links to all the Principal Policies of the SPP, acknowledging the valuable contibution it makes to Scotland’s economy and placemaking. You can also read responses from AHSS, ALGAO, Archaeology Scotland, Institute for Archaeologists, RTPI, Scottish Civic Trust and Society of Antiquaries of Scotland.

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

BEFS comment on the strategic role the historic environment should play in reinvigorating existing places and seeks recognition for the cumulative impact of smaller scale initiatives. You can also read responses from Archaeology Scotland, Garden History Society in Scotland and RTPI.

Getting across shared messages