Ruskin Lane Consulting Autumn 2013 | Page 39

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