The Architectural Heritage Society of Scotland (AHSS) has recently expressed its concerns to the Scottish Government regarding the implementation of Phase 3 of Permitted Development Rights (PDR) in Conservation Areas.
AHSS writes:
In a letter addressed to the Minister for Public Finance, Ivan McKee MSP, and Chief Planner, Dr. Fiona Simpson, AHSS highlighted several critical points regarding the potential negative impact of the new PDR on Scotland’s conservation areas. These areas are legally protected due to their special architectural or historic interest, and the society fears that the recent changes could compromise this protection.
One major concern is the lack of specificity in the new regulations regarding the materials used for replacing windows in conservation areas. AHSS emphasised that replacing original timber windows with uPVC alternatives could severely detract from the character of these areas. Not only does this undermine the visual integrity of historic buildings, but it also ignores the significant difference in environmental impact between timber and uPVC. Timber windows, as a natural product, have only a tenth of the carbon dioxide emissions associated with uPVC windows and sequester carbon dioxide, thus contributing positively to environmental sustainability.
AHSS also warned that the new PDR could lead to long-term damage to Scotland’s built heritage. The society stressed that while addressing the climate emergency is crucial, it should not come at the expense of the character and integrity of Scotland’s conservation areas. The potential weakening of heritage protection could have adverse effects on the economy, tourism, and the overall sense of place that these historic environments provide.
In response to AHSS’s concerns, the Scottish Government, through Lyndsey Murray, acknowledged the society’s input but affirmed the decision to move forward with the new PDR. The government emphasised that PDR are designed to reduce the need for full planning applications, thereby saving time and resources for both homeowners and planning authorities. However, the government assured that the special architectural and historic interest of conservation areas was a key consideration throughout the consultation and legislative process. To mitigate potential negative impacts, the new PDR includes provisions for ‘prior approval’ in certain cases. This process, though less rigorous than a full planning application, still allows authorities to consider the design and external appearance of alterations, particularly in conservation areas. Additionally, the government highlighted that the new regulations do not apply to World Heritage Sites, and that listed buildings will continue to require listed building consent for any alterations. Local authorities also retain the ability to restrict PDR in specific areas through Article 4 directions.
While AHSS acknowledges the government’s efforts to balance heritage protection with the need for modernisation, it remains concerned about the broader implications of the new PDR. The society continues to advocate for a more cautious approach that prioritises the protection of Scotland’s historic environment while addressing modern challenges like climate change. As Scotland’s built heritage faces increasing pressures, AHSS stands committed to ensuring that any development or policy changes do not erode the very character and history that make these areas unique. The society will continue to engage with the government and other stakeholders to protect the integrity of Scotland’s conservation areas for future generations.
