Consultations
ASHTAV welcomes the oportunity to participate in Government consultations.Here are our responses to:-
Draft Heritage Protection Bill
Unlocking the talent in our comunities
Seeing the history in view
Future Landscapes
DRAFT HERITAGE PROTECTION BILL: Consultation on Conservation Area clauses
ASHTAV welcomes the publication of the Conservation Area clauses, as Conservation Areas are of particular concern to many of our members. We are very glad to be given the opportunity to comment on the clauses.
Clause 1. We are pleased that the term ‘Conservation Area’ will have such a wide remit, allowing local heritage
to be viewed holistically, reducing confusion and creating more opportunities for designation through the various types of ‘special interest’.
Clause 3. ASHTAV believes that there should be wider consultation prior to the designation, amendment to that designation, or cancelation of a designation. Local amenity societies, historical societies and individuals often
have a wealth of knowledge regarding their local area, and would be able to offer an informed opinion on such
designations.
Clause 5. Likewise, we would like to see the wide consultation of relevant national and local groups, and the local public, prior to and during the production of Conservation Area Management Plans. We are very pleased to see that a duty will be placed on a local planning authority to produce a Management Plan for each Conservation Area, and would encourage the use of local expertise in the production of these Plans.
Clause 9. ASHTAV welcomes this clause, which confirms the Government's intention to reverse the 1997
Shimizu decision. In general, the clause would appear to give a much stronger protection to Conservation Areas than hitherto. However, we are concerned that there is no mention of enforcement for damage of the special
character where it constitutes archaeological or artistic interest. Archaeology in particular is a very significant part of the overall local heritage landscape, and if it will no longer be protected by local designated Areas of
Archaeological Significance, measures should be in place to prevent its destruction under Conservation Area
legislation.
I hope that these comments on the Conservation Area clauses are of use and interest. Please do not hesitate to contact me for further information.
ASHTAV broadly supports the ideals of the consultation document ‘Unlocking the Talent of our Communities’, and welcomes the recognition that the participation of society in economic and physical regeneration and local democracy is key to the future of historic towns and villages. We are very keen that the heritage assets of towns and villages, and the activity surrounding these assets, is seen as a part of improving the physical environment, creation of jobs, provision of training, and community involvement, all targets of neighbourhood renewal. Heritage-led regeneration is often the most successful, providing a sense of community ownership lacking in entirely ‘new’ projects.
Throughout the document it appears that regeneration and renewal is essential an urban concern. Having worked with smaller rural communities, ASHTAV has found that the pressures which lead to the need for economic and physical regeneration are rife in many towns and villages, particularly those which have had strong past connections to a now defunct local industry or agriculture. ASHTAV considers that the issues facing these areas, including lack of jobs, disappearing infrastructure, and a drain of young people, are explored further during preparation of the Community Empowerment White Paper. We are pleased that the need to tailor any programme of regeneration and renewal to local circumstances has been recognised.
The ASHTAV response to certain of the specified questions in the consultation document is set out below:
What is the role of government in encouraging and supporting citizens to be active?
Government, both central and local, should support local groups both in terms of offering funding to expand capacity in these groups, and in ensuring that their voice is heard through effective and relevant consultation on local matters. ASHTAV has worked with local societies to prepare locally relevant policy documents, for example
Village Design Statements and Conservation Area Appraisals. The incorporation of this type of locally prepared document into the local government policy system would help ensure that the concerns of local people were heard from the first, rather than decisions be taken and then consultation take place.
What steps need to be taken to revive involvement in local civic and democratic roles?
Society as a whole, both local people and civic and amenity societies, has become resigned to the fact that
concerns voiced in consultation exercises will often not be regarded in decisions taken by local government. As
stated above, a greater degree of community led forward planning could remedy this situation, and encourage
greater participation. However, the key is to ensure that consultation is effective, relevant, and transparent, and
happens before decisions are taken. Local societies can often provide a focus for community involvement, and
as such should be encouraged throughout the process.
How can the power of consumers be better used to improve local services?
Historic towns and villages can lose vitality when their local services are reduced or taken away, for example a
lack of public transport, or a post office closure. In more rural areas there are difficulties in reaching essential
services such as hospitals. Local government should have a duty to ensure that all communities have effective
public services, and should take creative steps to making public services viable. Support for co-operative and
community run services should be given, both in terms of funding and advice.
In general, ASHTAV feels that the main task of the government will be to reassure communities everywhere that they are being listened to, and that their quality of life and environment is important at every level. There is a role to be taken by civic and amenity societies to help this process, giving a voice to communities and providing tools for empowerment.
ASHTAV response to consultation on ‘Seeing the History in View’, May 2008
Are there parts of the method that need clarification? Or conversely that should be cut out?
The methodology relies on use during environmental impact assessment, which is not always required for developments, even those that might have an impact on an important view. Cultural Heritage can be scoped out of the EIA process on
occasion. It would be useful to clarify what other opportunities there may be for establishing 'significant views' such as
local policy, and perhaps recommending the use of this methodology during the creation of development frameworks
and land-use documents.
Do you think a single method should be applied to any view, urban or rural? If so, would the proposed method be
suitable?
The proposed method should be suitable to any view, and we welcome the fact that the methodology aims to be relevant outside of London and in rural as well as urban areas.
Do you think this method would help to ensure that all aspects of the cultural heritage are properly considered in carrying out Environmental Impact Assessments?
If this type of assessment became a requirement of the EIA process, then it would certainly help ensure that different
perceptions of heritage are taken into account, and that heritage is viewed in a holistic fashion.
Does the proposed method consider the composition and design of a view adequately?
Yes; the method gives good advice in composing views to assess for significance. It is less clear when (aside from
during EIA) this significance appraisal would be undertaken. However, having this tool may encourage local authority to undertake more assessment of views, perhaps during conservation area appraisals and characterisation work.
Does the proposed method adequately analyse the heritage significance of a view as a whole?
Yes. It is useful to be able to measure the heritage across an area as a whole, and enables a much clearer analysis of the significance.
Would more worked examples be useful to you? If so, please make suggestions.
As ASHATV work predominantly in rural areas or smaller settlements, it would be very useful to have worked examples
reflecting these areas - for example, views of a historic town or village from its connecting countryside, with which it
probably has very strong links, could be of great significance in assessing fringe development. Also, rural views with
natural and man-made heritage assets could be explored, especially those that interconnect a series of sites or
settlements. The streetscape as view is also important to our work, and discussion of the impacts of street furniture
and infrastructure would be of use.
Do you have any more general comments on the content, use or applicability of this draft guidance (not covered by
the questions above)?
ASHTAV would welcome training in the new methodology for themselves (in order to disseminate this to our members), and for designers and local authority officers.
ASHTAV welcomes the publication of the draft policy document Future Landscape, and are particularly pleased that the built or manmade landscape is acknowledged to be of significance. In respect of the specific policies we have these comments:
Policies 1 and 2: We agree with both the objective (1) and the means of achieving it (2). The concept of protecting sites through careful future planning is already a feature of managing change for the built environment, and ASHTAV are keen that landscape characterisation, focusing particularly on the historic environment, continues to be at the forefront of decision making, continuing the course set by English Heritage. It
is important that all national bodies are engaged in the process. Key words from this policy which appeal to us as an organisation and our
members are “to proactively plan, protect and manage their [landscapes] evolution”.
Policy 3: To manage change effectively, it is clear that different areas will need different approaches; the proactive approach mentioned
above, together with a full understanding of the character of the each area, will hopefully lead to enhancement in all cases rather than
change which detracts from distinctiveness and beauty. One concern that we have is the structure for achieving this at a local level, where
local authority resources are scarce, and where expertise may not be readily available. We suggest that many local groups such as civic
societies may wish to help with character appraisal, enabling documents to be formed which could become part of development policy.
Policy 4: We applaud Policy 4, and hope that a best practice from consultation of many different interests can be developed from this. This is something that government, nationally, regionally, and locally, often fails to do.
Policy 6: We are pleased to see that the society based around landscapes is not forgotten, and that local cultural interests, traditions and
communities will be taken into account. ASHTAV considers that only through a thorough characterisation encompassing landscape,
buildings, culture, and other local drivers will be this be realised. We would welcome a closer relationship between the national bodies,
including Natural England, English Heritage, and the Museums, Libraries and Archives, as well as others, to bring the whole ‘package’ of the
landscape forward for protection.
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