CONSULTATIONS
Public Consultations
I
n recent months, the AHSS responded to three
consultations: the Historic Environment Strategy for
Scotland, the Merger of Historic Scotland and RCAHMS,
and the Draft Scottish Planning Policy. Extracts from these
consultations are reproduced below to give readers an idea
of our contributions. Please contact the national office if you
would like to see the full responses.
A Joint Consultation on the Historic Environment
Strategy for Scotland and the Merger of Historic Scotland
and the Royal Commission on the Ancient and Historical
Monuments of Scotland (RCAHMS).
In his covering letter, National Chairman, Peter
Drummond raised two key concerns:
“Firstly, Scotland has been particularly fortunate in that
the vision of those who have guided the Commission has
left us with a national collection of information on the built
heritage which is second to none. It is absolutely essential
that this recording and interpretation role be carried on in
the new body. The experience from England suggests that,
unless such duties are explicitly stated in the enabling
instruments, then they will be weakened or even lost in
time. We therefore recommend, in the strongest terms, that
they be specified and protected in a robust manner.
Secondly, and equally importantly, we are of the clear
view that there is a need for a robust development
management process which recognises and protects our
built heritage. Whilst we understand and appreciate Scottish
Ministers’ desire to devolve decision-making to local
communities, there is a clear need to do so in a manner
which protects historic sites and provides such additional
resources as might be required to do so.”
Historic Environment Strategy for Scotland
Q
Are the overarching principles the right principles to
guide our activities over the next 10-15 years?
The historic environment must be seen holistically, both in our
urban areas and in our rural areas, and through this better
integrated in planning policy. It is, however, one of a number
of sometimes competing issues and one which,
unfortunately, does not always receive the weighting
appropriate. Those supporting and promoting ideas of
‘mainstreaming’ the historic environment must therefore
ensure that the historic environment is at the heart of policy,
not only in spatial terms but across other policy departments,
including social/community, economic and environment.
Q
Does the overarching aim reflect your ambition for
the historic environment?
These are good principles, but the informed decision-making,
leadership and collaborative working at all levels, skills and
capacity at all levels needs a structure to enable and ensure
it. A widespread lack of resources in local authorities,
particularly in heritage care and planning, needs to be
addressed through enablement by the new body. Large voids
have occurred to date in such capacities which, despite
encouragement from central government, remain. This in turn
places our built heritage at risk through inappropriate
development. Given anticipated continuing financial pressure
on local authority budgets over the short to medium term, it
seems likely that such skill shortfalls may not be addressed
within an acceptable timescale. It may be that these instead
can be met through shared resources and far reaching
linkages, however this has to be proactively addressed by
the new body rather than employing a predominantly handsoff approach.
38 I
THE ARCHITECTURAL HERITAGE SOCIETY OF SCOTLAND
I
AUTUMN 2013
Q
Do the suggested high level, cross-cutting actions
provide a reasonable basis to begin to take the
Strategy forward?
In theory yes; in practice no. With the reduction of the role of
HS as watchdog at least at an administrative / legal level,
across the council a