Ruskin Lane Consulting Autumn 2013 | Page 38

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