The Institute of Historic Building Conservation (IHBC), the UK’s professional body for built and historic environment conservation specialists, has responded cautiously to the recent update on progress with the ‘Penfold review, an initiative intended to ease the burden of ‘non-planning consents’ in England.
IHBC Chair Jo Evans has highlighted the need to maintain the emphasis in the original report on the need for a credible and competent conservation service providing high quality customer service to all users.
Jo Evans said: ‘We welcomed Penfold’s focus on improving conservation services in local authorities, and its concentration on the consent process. As any business, applicant or neighbourhood group knows, the best conservation advice is not simply about re-stating cultural values. Conservation advice is more often about how best to manage buildings and places as a cultural resource, one that has to be sustained as far as possible by the full range of its economic and environmental values. Such advice demands very particular conservation skills, knowledge and experience.’
‘Adrian Penfold’s original report made it clear that skilled conservation specialists are essential in order to deliver a credible customer service in conservation. The importance of the IHBC’s range of skills in delivering satisfaction for all users was clearly understood then, and this is reinforced by the very welcome practical focus on consent processes that characterise this update.’
‘However the IHBC is very disappointed that there is little recognition of the impact of the 25% drop in local authority conservation capacity since the discussions about many of these reforms first took place. We are especially concerned that proposals may be impossible to deliver in the context of ongoing local authority and other cuts without severe threats to the historic environment.’
‘So if Adrian Penfold’s initiative is to succeed, it must maintain its original recognition of the value of skilled, locally informed conservation specialists – working both within and outside the local authority – and maintain its focus on helping establish a service that is credible and fit for purpose, both as regards conservation and clients’.
Interim Commentary
1. The IHBC warmly welcomes the proposed development of the list descriptions (Report: A1 & C) which will help inform the understanding of special interest, or ‘significance’. However, we are concerned that there may be insufficient capacity to undertake this work and there are further questions about the cost, time taken to complete the re survey and whether wider changes might be implemented before the lists are improved.
2. Both A2 (Certificate of Immunity from listing or scheduling), and A3 (Statutory Management Agreements), have been discussed in the context of earlier proposed changes to legislation, and these could prove useful tools in the conservation management of historic fabric, buildings and places. However with ever reduced capacity in local authorities and in English Heritage we are unclear about where the capacity to take on additional tasks might come from.
3. On A4, and the proposed removal of Conservation Area Consent (CAC) for the demolition of unlisted buildings, these changes do not now appear, on the face of it, to involve a redefinition of ‘demolition’ to bring this within planning control. This was considered previously as part of wider discussions about legislative change. However it appears here without any reference to the need for a clearer and more robust system of management, sanction and enforcement.
4. The introduction of a ‘prior-approval’ system (B.1), where properly supported may prove to be a useful change to the existing process. However service standards could be compromised if experienced conservation services are not available to oversee the procedures. This could threaten the interests of the developer as well as local and neighbourhood interests.
5. The section covering the proposed certification from independent specialists (B2), is a challenging concept, but must be supported by a competent and credible local authority specialist conservation service, reinforced by comparable overarching skills and capacity in English Heritage. It is essential that local knowledge and relevant skills are available and supported by informed and skilled regulators and private practitioners. It is not possible for a generic planning or historic environment management service to deliver effectively without such conservation capacity, and that capacity must be clearly signalled to all users.
Nor can these conservation challenges be responded to through simple outsourcing or delegation, as DCMS sponsored research has clearly demonstrated. This confirmed that local skills, knowledge and expertise in the authority’s internal conservation specialist cannot be matched for delivering returns, value and outcomes from public investment.
Download the update at LINK
For background see the IHBC NewsBlog at:
https://newsblogs.ihbc.org.uk/?p=2795
https://newsblogs.ihbc.org.uk/?p=2793
https://newsblogs.ihbc.org.uk/?p=1506
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