CONSULTATIONS
Merger of Historic Scotland and RCAHMS
Q
Do you agree with the functions set out for the new body?
Yes, but the way legislation and policy is implemented is not
covered. The implications for the rearrangement of governance are
not covered. There is no clear statement as to how the Minister can
preserve the functions of two organisations, protect all members of
staff, and at the same time have a £10million cut in budget and
produce a resilient organisation which will meet the objectives of the
strategy. With heritage one of Scotland’s major industries any cuts in
funding for the heritage sector will be counter-productive and a false
economy. What is required is increased investment.
Q
Do you agree that the proposed approach to the
discharge of Scottish Ministers’ Heritage Management
functions is appropriate?
Yes, but the operative word is “discharge”. The new body should get
greater authority from this arrangement, BUT it must not be subject
to political intervention. This is asserted within the document, but
guarantees are required. Staff within such a body need to be able to
speak out on from an informed and skilled point of view without fear
of contradiction or indeed fear of loss of their jobs. There is likewise
a requirement for all decision-making to be undertaken in an open
and transparent manner; there is a public perception, not always
incorrect, that decisions can be taken behind closed doors.
Q
Do you expect the proposed creation of a new
organisation to impact on you or any particular group of
stakeholders?
The AHSS provides services complementary to the objectives set
out here, working with central and local government to maximise the
understanding of built heritage issues and help educate
stakeholders. As such we get some financial assistance. It is
imperative that bodies such as the AHSS are enabled to take
heritage through to the community as we operate more directly
within it. But it is also important that they are able to constructively
criticise where this is due without fear of political or other resistance
or bias. The new structure should be in a better position to more
effectively facilitate organisations such as the AHSS through grant
aiding as a way to reach into the community and ensure more
thorough coverage of conservation issues. The AHSS for instance
has cases review panels in the major centres that peruse and
comment on conservation related planning applications.
Draft Scottish Planning Policy
Sustainable Economic Growth
Housing
Q
Q
Do you think that the measures outlined in paragraphs 15
to 23 are appropriate to ensure that the planning system
supports economic recovery and sustainable economic
growth?
There should be cross reference to regeneration utilising existing stock
including that considered heritage. Regeneration in this way often
encourages greater diversity at a suitable scale while retaining a sense
of place and community. Sustainable development and sustainable
economic growth should be defined in the SPP and the government
should examine whether both are needed. The word ‘development ‘
has a specific meaning in planning, as does ‘community planning’,
which does not have a spatial element and the SPP should define the
language used and ensure that SPP is free from jargon.
Do you think the approach to how national parks address
their housing land requirements, as set out in paragraph 90,
is the appropriate approach?
Generally yes. National parks though have a very specific
responsibility to the environment, not only in natural terms, but in the
combined synthesis of built heritage, independent or village
grouping, within a rural heritage. This includes historical significance,
but does not preclude modern interventions. New build and new
interventions must be sensitive to this. Mass soulless development is
to be avoided at all costs within the national parks. Large mobile
home parks are the worst offenders.
Heat & Electricity
Location of New Development – Town Centres
Q
Do you think that local authorities should prepare town
centre health checks?
Perceptions and hence the basis of health checks are on current /
traditional ideas of what town centres should be. Many are failing and
have little hope of regaining their original roles against other factors,
but can be regenerated on different criteria eg greater housing
components, greater social roles etc. This needs lateral thinking and
work-shopping. While such