THE ARCHITECTURAL HERITAGE SOCIETY OF SCOTLAND RESPONSE TO SCOTTISH HISTORIC ENVIRONMENT POLICY CONSULTATION ON LISTED BUILDING CONSENT “The Architectural Heritage Society of Scotland (AHSS) i a independent membership-based ‘charity that works to promote the study and protection of Scotland’ historic buildings. The AAHSS weleomes the opportunity to camment onthe above draft document asthe Society has ‘an interest in all documents and guidlines that have ramifiatons for Hated buildings. The Society offers the following comments in response to the 4 questions posed in the consultation document Question 1: [Are these reasonable tests to set for applications for listed building consent for alterations? Ifnot, why not? Tes essential thatthe statement of significance and consideration ofthe impact of proposed changes toa listed building, which are mentioned at paragraph 45, should be submitted with the application so thatthe planning authority can assess the appropriateness ofthe alterations. is likely that addtional material may be supplied bythe applicant regarding the history oF other aspects ofthe significance of the building and these could be used in conjunction with tho list description to assess whether or not changes should be approved. In addition significant change should be closely defined to avoid excuses of dovbt on the part of the applicant as to whether a statement of significance and impact assessment ae required It is not noted if any change is proposed to the existing exemptions and. voluntary arrangements for listed building consent for eclesiatical buildings. The AHSS supports the ‘continued exemption for intemal changes to ecclesiastical buildings in use as such on the rounds that changes tothe interiors ofthese buildings for liturgial reasons are part of an suthentc pattern of adaptation of these buildings, However, we would welcome clarification ‘810 whether the exemption also applies to Chorch Halls Further tothe considerations outlined in paragraph 4.6 regarding changes of use, it should also be stated that changes of use tha wl return building to its original use will generally be supported eg the return of offices in city entre townhouses to their orignal domestic ute. In addition, amenity societies have a role to play in suggesting altemative uses that may be ‘more appropriate fora particular building These may bein put forward in response to a Fisted building consent application or by a publication ar conference that addresses reuse of a particular building type (eg. the Scotish Civie Trusts recent publication, New Uses for Former Chureh Bung). suLnc-osQuestion Are these considerations the appropriate ones to be applied when considering an application for listed building consent? Ir not then why not? ‘A number of important considerations are missing from the lis, We suggest the following should be incl: ‘+The impact of the proposals onthe broader setting ofthe listed building. Inthe case of listed buildings in built up areas, the steetscape importance of listed buildings is very ‘high, with the fisted building often providing a landmark and visual anchor fora area, ‘Thus changes toa listed building may have far-reaching implications onthe character of fn are, end this should be taken into consideration even if adjacent tilings are not listed, For listed buildings in rural areas, the landseape importance of listed buildings is often high and reeent proposals for wind Farms have indicated how vulaceabe the settings of ited buildings ean be changes i the broader landscape. ‘+ Technical considerations should be taken into account. This includes isues such asthe suitability of materials, impacts of climate change on the sizing of rainwater goods et. ‘and may mean that on occasion changes from the original design are justified inorder to keep the building in good repai. {In addition, there would appear o be a misprint inthe document. Page 14 ite "economic.or publi" whereas under 4.10 item e tates “economic and publi should both read “and” Tes felt they Question 3: Are these considerations the appropriate ones o be applied when considering applications for listed building consent for demolition? If not, then why aot? At paragraph 4.9, we suggest that Building Preservation Trust are included as key players in the search fr atemative uses forthe building ~ as a Preservation Trust may beable to cay ‘out work that would enable a building to remain in use more economically than a commercal developer or private building owner Historie Scotland should also consider the introduction of grants to keep listed buildings secure and wind and watertight in order to borrow time and allow a longterm solution to be found. The availabilty of such grants would encourage responsible building owners to ‘mothall their buildings when they wee stil in a reasonable state of repair o that overall ost to bring them back into use would be reduced ater than just available when ‘demolition is proposed, by which time a listed building may be in an advance sate of derliton, Question 4: Are there any other principles which Historie Scotland should adhere to when implementing Scotish Ministers’ policy om listed building consent? Ifs0, then what should they be and wh At 51, bit is important thatthe review of policies on Listed Building Consent isa public process, with consultation an integral pr. ‘At 51, 6, we suggest that seminars, such as those recently held for local authorities and amenity bodies on Listing, would be very valuable to inerease understanding both of the policies covering listed building consent bu also of how they are applied in practice, using Worked examples to illustrate how decisions are reached. Such seminars would be of great interest othe AHSS as they could be iterated into aur proposed training for easeworkers on [AHS cases panelsAnnex D Equality impact Assessment ‘While no question is asked of consultes, you solicit our opinions on whether such an assessment wil be necessary and what the equality issues are likely to be, The AHISS considers tat providing acess fr allo listed buildings i a relevant equality