Written evidence submitted by the Church in Wales
Summary
Context:
Challenges:
What is needed:
With these in place, there will be a more vibrant conservation building sector to supporting economic growth. It will encourage a wider range of apprenticeships and T-levels including heritage crafts and opportunities for existing tradespeople to up-skill and transition across to heritage work.
Detailed Response
1. What are the most significant challenges facing owners and operators of built heritage assets, and how are they affecting what those sites can offer?
The main focus of this response is the built heritage as represented by places of worship in Wales.
Context:
The Church in Wales is the Anglican denomination in Wales. It was created in 1920 after disestablishment from the Church of England.
The property of the Church in Wales is largely owned centrally by the Representative Body of the Church in Wales. Much of this property is significant built heritage.
The work of the church is organised, regionally, into 6 dioceses each with its constituent churches.
The Church in Wales operates 1221 places of worship (cathedrals, churches and chapels) across Wales. 897 (73%) are listed buildings and of these:
136 are Grade I listed
333 are Grade II* listed
428 are Grade II Listed
According to DataMapWales https://datamap.gov.wales/layers/inspire-wg:Cadw_ListedBuildings, there are:
In addition, the Church in Wales owns 28 listed church halls, and 91 other listed buildings (mainly dwelling houses).
The Church in Wales is currently holding 110 closed churches. One of these is Listed Grade I, 24 Listed Grade II* and 38 Grade II.
Key Point: The Church in Wales owns a very significant proportion of the built heritage of Wales and is a single landowner of built heritage across the whole of Wales.
Management Arrangements
As with other religious denominations in the UK, places of worship are managed by each local congregation. In the Church in Wales, each place of worship sits within a Ministry Area which covers a defined geographical area and includes a number of church buildings. A ministry area may sit within a number of Community or Town Council areas.
Each Ministry Area is managed by a Ministry Area Council – these are local trustees elected from the congregations of the constituent churches. Most members of the Ministry Area Council will be volunteers. Clergy allocated to the Ministry Area receive a stipend (funded by the local church and some central church sources).
The Ministry Area Council has the duty to plan, fund and organise the repair, maintenance and improvement of each church (and churchyard) within its area. It is supported by the Church in Wales in various ways:
Key Point: The Church in Wales’ portfolio of nationally important, built-heritage assets are owned centrally but managed by local volunteers through each local Ministry Area Council trustee body.
Consent Arrangements
The Church in Wales is a denomination that benefits from Ecclesiastical Exemption. This system regulated under the Ecclesiastical Exemption (Listed Buildings and Conservation Areas) (Wales) Order 2018. This means that works to open churches are exempt from the Listed Building Consent procedures as would be applicable to any other listed building owner of a Listed Building.
However, works to buildings must obtain a Faculty. A faculty is an ecclesiastical permission granted by the Chancellor of each of the six regional dioceses. This is a judicial court process whereby the Chancellor decides whether permission (a faculty) should be granted after external consultation and advice from a specialist Diocesan Advisory Committee.
The Diocesan Advisory Committee brings together considerable professional and specialised advice from its voluntary members as well as advice from in-house staff. This represents a considerable human resource in terms of advising on the future care and management of built heritage. There are approximately 15 FTE posts involved in the process plus around 60 volunteer advisers offering their advice and expertise to the process. The faculty system is entirely funded by the Church.
The scale and nature of faculties being applied for can be seen at Care of Church Buildings Annual Report - The Church in Wales
Key Point: Works to church buildings (listed and unlisted) are carefully assessed and approved through the faculty system which is supported, largely, by volunteer specialist advisors. The faculty system replaces Listed Building consent and is run at no cost to the taxpayer
The Significance of the Church’s Built Heritage
The built religious heritage of the Church in Wales is significant in terms of the proportion of Wales built heritage that it represents but also its geographical spread across the whole of Wales.
It is especially significant because these are built heritage assets that have been in public use for centuries and are still freely accessible to all. These are assets that feature in the lives of many of Wales’ citizens in terms of both religious observance but also life events like baptisms, marriages and funerals. These buildings tell the story of the people of Wales.
The heritage of these buildings often contains features of the highest quality and creative skill such as carvings, statuary, wall paintings, silverware, stained glass etc. These buildings are akin to an art gallery in every community.
These buildings sit in the heart of communities. Indeed, many Welsh place names start with ‘Llan’ which refers to the ancient sacred site of the church and is often combined with the name of Saint to whom the church is dedicated. The place of worship, and its associated Saint, is embedded in many of the place names of Wales.
But these buildings are not just physical assets. They are still places of community gathering and activity. In addition to regular worship and life events, they offer venues for community activities (foodbanks etc), concerts, festivals and social events. Through all these activities, the public interacts with its local heritage in a unique and special way. The National Churches Trust Report House of Good report The House of Good research | National Churches Trust makes this impact clear.
The local management of these buildings means that local people are engaged directly with built heritage. It means that local volunteers directly manage a significant proportion of the nation’s heritage. Every Ministry Area Council, through its volunteers, acts as a form of building preservation trust for its local listed building. A unique facet of religious built heritage is that it is completely rooted in the local community.
But therein lies it greatest challenge. If this vitally important aspect of the nation’s built heritage is to be cared for in the future, there will need to be viable uses, adequate funding, and sufficient and suitable people to manage it in the future.
The Challenges
The significant challenges facing the Church in Wales, as owners and operators of built heritage assets, are:
Our listed places of worship, have now reached a point some 150 years or more after they underwent major restoration work in the 19th Century. They are facing a crisis of repair following the ageing of that 19th Century construction work. To address this, significant funding is needed to stave off serious issues of deterioration, and often somewhere between one and two hundred thousand pounds of major repairs (re-slating, stonework repairs, stained glass repairs etc). The major works to built heritage undertaken in the 19th century is now failing.
Wetter winters caused by climate change are impacting building condition. 19th century rainwater systems cannot cope with the severe deluges we are experiencing and solid masonry walls are increasingly saturated with shorter drier periods to permit drying out. Built heritage is not coping with changing weather conditions.
The reality is that the traditional use of a place of worship is often simply not a viable model to sustain the care of the building going forward. Places of worship will need to be used in new ways and by new groups in the future. Developing new uses needs people with energy and drive and sustainable funding models. New uses also may require changes to the building which have to be justified to obtain consent. It is not a safe assumption that the pattern of use of these buildings will sustain them in the future.
Fewer people are attending church than in the past (though not in all places). Congregation members are generally older and built heritage is, perhaps, less appealing to younger people who are often more engaged with natural heritage or perceive built heritage as having negative associations with past (contested heritage).
Many heritage organisations have education programmes and these need to be supported and enhanced. The built heritage sector needs to engage better with younger people, including in schools, to ensure the next generation is inspired to take on the challenge of the nation’s built heritage in the future.
The present model of caring for our church buildings requires there to be sufficient numbers of people, in the local community, with the right skills and knowledge to manage what can be complex assets. That is increasingly difficult to achieve in every location. People with the capacity and skills to manage these assets is a key challenge.
There are very significant challenges with finding contractors willing and able to undertake specialist work to built heritage. Part of the challenge, is that there is inadequate and unpredictable funding available so it is difficult for church building managers to develop a programme of work to encourage contractors to train and develop their skills and interest in this work.
Contractors need to be sure of a pipeline of work; too often the conservation building sector cannot offer the certainty that contractors need - other building sectors are more reliable.
There have been initiatives to develop training programmes and these should be developed further but unless this is a flourishing, viable sector for contractors, we will struggle to encourage new entrants and trainees.
More and better trained contractors are needed to undertake appropriate works to built heritage. A secure funding environment is crucial to enable this.
Built heritage needs maintenance and repair. This is often specialist and expensive work (not helped by a lack of contractors working in the sector). Funding is explored in the next section but is a fundamental challenge.
Repair of built heritage happens when money is available often after extended periods of fundraising or grant application effort. Works often have to be phased to meet available funding but without any certainty of funding for later phases.
Grant funding is largely awarded on the basis of project outcomes to ensure more and a wider range of people engage with heritage and addressing community and other societal needs. For the vast majority of churches especially in small communities, this is very challenging – there needs to be a greater acceptance among grant funders that repairing a nationally important heritage asset is, often, a significant benefit to society and communities in its own right. Retaining a building in public use is a significant and valuable objective. Most of our built heritage needs a stable and secure funding stream to ensure its conservation, restoration or continued preservation.
Funding streams need to be clear, reliable and easy to obtain given the local, volunteer base of building managers.
The Listed Places of Worship Grant Scheme gives a grant to listed places of worship equivalent to the VAT on building works. This is an essential lifeline to the sector. Without this, less work will be undertaken, buildings will deteriorate further and more buildings will be forced to close. We cannot stress how important this scheme has been. The recent announcement of capping of grant to £25,000 for 2025/6 is having a significant impact on major projects. Whilst the average grant awarded may be in the region of £25,000, we are aware of significant projects which have recently started for around £1million e.g St Peter’s Ruthin Denbighshire. The capped grant puts these projects in great risk of failure. That directly impacts on the local economy and jobs.
Existing sources of funding are fragile, uncertain and inconsistent. They are generally complex and challenging to obtain especially for local volunteers.
What interventions are needed to prevent the managed decline of heritage assets on publicly-owned land?
We assume that ‘managed decline’ here refers not to any cynical neglect of maintenance and conservation that can sometime occur where a heritage asset is viewed as an obstacle to long term commercial development, but to a situation where an owner either does not have the funds, or the knowledge, to implement a long-term programme for the full conservation of a heritage asset in perpetuity.
We assume this question refers to heritage assets owned by central or local government. Church in Wales property is owned by a registered charity so is not ‘publicly-owned’ as such. However, these are assets in public use, of great importance to local communities. Not all publicly-owned heritage assets are in public use.
We suspect that heritage assets on publicly-owned land face very similar challenges to our own in terms of condition, climate change, viable uses, funding, people and availability of contractors.
The interventions needed for heritage assets on either publicly or privately owned land are likely to be very similar too. We explore these in our answer to Question 5.
What can the Government do to make it easier for communities or local businesses to take ownership of historic buildings?
In many ways, historic places of worship are already ‘owned’ by local communities even if not in a strict legal sense. Whilst legal title is held centrally, each church is the responsibility of the local congregation and they are able to use that building to benefit the wider community.
However, where congregations shrink, there can no longer be sufficient people or a viable basis for the building to continue in use as a place of worship. Where this occurs, the Church in Wales is keen to work with others in the community who might be able to sustain the building in a new way. To enable this to happen, the following is needed:
Our experience is that the timescales needed for community groups to be in a position to proceed with acquiring an asset are in the region of 3-5 years. Community Right to Buy Schemes tend to operate in much shorter timescales and are unlikely to enable significant progress. Support is needed for longer periods to enable sustainable schemes to be developed.
2. How effective are the current funding and finance models for built heritage?
In a church context, funding comes from:
Whilst the scheme has been retained until March 2026, the grant is now capped. This reduction in grant and, the potential loss of the scheme, will have a significant impact on the amount of future building repair and maintenance undertaken. Buildings will deteriorate further and more buildings will close; the economy will suffer as less work will be available for contractors. This scheme must be retained.
All of the above sources of funding are fragile, uncertain and inconsistent. Fundraising, donations, legacies and asset sales will depend on local circumstances.
Grants come from different sources and have different criteria and deadlines. Navigating grant regimes and developing a plan to apply is difficult especially for local community volunteers. Better coordination and linking of grant regimes would help.
Invariably, works are usually funded for a phase of work rather than all necessary works. There is no certainty that later phases of work will be funded and, often, later phases are not achieved.
What should long-term public funding for the sector look like?
We think the Listed Places of Worship Grant Scheme is a model of what public funding should look like. The hallmarks of the scheme are:
It is also a scheme that demonstrates how a limited amount of government funding can provide a key foundation for seeking other grants and the confidence for local managers to develop funding bids.
Whilst other funders have a variable range of desired outcomes for funding, Government funding should provide for the basic needs of listed building repair and maintenance. A basic and permanent scheme that provides core funding for core works would be invaluable and act as a catalyst for wider schemes and applications.
The Listed Places of Worship Roof Repair Fund in 2015/16 was another effective Government grant for our sector. It was targeted, had a clear priority and effective administration and support. For our sector, it is an example of what public funding for built heritage should look like. The evaluation of the scheme in April 2017 stated:
It is clear that the RRF Programme has achieved its primary objective, and has successfully administered funding to allow Listed Places of Worship to carry out urgent repairs in order to render buildings watertight. The vast majority of Listed Places of Worship with completed works reported their building to be both watertight and weatherproof following completion of the repairs undertaken.
However, an extremely positive aspect of the RRF has also been the wider outcomes and impacts across local communities, in addition to the original aims of the programme.
The National Churches Trust in its Every Church Counts campaign suggest £50 million is needed across the UK for major repairs to places of worship. This would be a significant help.
3. What role does built heritage play in the regeneration of local areas and in contributing to economic growth and community identity?
Built heritage is fundamental to a sense of place. History and historic legacy are the scaffolding that supports communities and societies in the present.
Listed buildings are key landmarks within a community or landscape. Built heritage tends to be located at the centre of villages, towns and cities as they are the remains of the original settlement. There is barely a local area in the UK, save for the new towns, that does not have built heritage and listed buildings at its heart. Places of Worship are often foremost in that identity.
Built heritage in good condition enhances local areas and engenders a sense of pride; conversely, built heritage that is dilapidated significantly reduces the appeal and character of an area.
Built heritage is also adaptable. There can be an assumption that built heritage cannot accommodate new uses that can help to regenerate an area. We have not found this to be true where schemes are developed with care by appropriately experienced and qualified professionals.
Economic growth’ can be assessed by several metrics, but one is that of the retention of a building rather than its loss, especially in an age of concern over climate change and carbon management. Whole life costing of structures strongly suggests that the retention and repair of existing fabric rather than its replacement has today to be the sensible starting point, one that usually always starts positively, from an economic point of view, as it can only reduce building costs to reuse rather than to demolish and replace.
Heritage buildings have tended to survive because they convey in various ways the confidence, or wealth, or ingenuity, or simply the sense of well-being of past ages and this is a good rallying point for successful new development, and the economic growth that goes with it.
Places of worship are in public use and available to all. Many are open every day and, to our knowledge entry is free. These buildings are important assets in the visitor economy and many are part of networks and trails. There is still great potential to exploit this opportunity further.
How can heritage buildings be supported to increase energy efficiency and contribute to the Government’s net zero targets?
Support for better decision-making
Currently Listed Building Consent is not generally given for the installation of solar panels on listed buildings unless they are more or less invisibly sited. This stringency should be relaxed, particularly so that the south facing roofs of churches, an absolutely ideal site functionally, can be used to benefit the church building, the congregation and net zero targets
Key regulatory decision-makers (including, amongst others, Diocesan Advisory Committees, CADW and local authority conservation and planning officers) to be supported and trained to be better aware of new technologies and approaches to install them in listed buildings.
Local Knowledge and Training
Congregations generally do not consider their heating system nor energy use until something fails and they find the building without heating or lighting - when such a failure becomes a crisis. Owing to a lack of pre-emptive action, when a crisis does occur, the church concerned often feels left with little choice other than to quickly react by replacing like with like e.g. a new gas boiler for old, effectively tying the premises to fossil fuel use for the next 15 to 20 years.
There needs to be a sustained training programme of local managers of built heritage to help them make the right long-term decisions.
Unfamiliar and uncertain application of low-carbon technology:
Much of the current emphasis on low-carbon technology focuses on heat pumps; yet, from the energy audits undertaken to date, it is clear that heat pumps will be suitable in only a minority of church buildings. Quite apart from issues of cost, they will not work technologically, because they generate a slow, steady flow of heat, which is not capable of heating a very large volume of air in poorly-insulated churches, particularly when they are only used a few times a week. Substantial improvements in insulation are in many cases unwise as they would generate damp problems in historic building structures.
Sizeable reductions in carbon emissions can nevertheless be made by switching the focus to making people feel warm, rather than by trying to heat the whole air-volume of the church, accompanied by careful and very selective improvements in insulation. Electric air heaters, fitted under church pews, have been fitted in some churches and work effectively. Electrically-heated pew cushions are another potential solution.
Much work is being undertaken to investigate and develop new heating systems and technologies for buildings but rarely are these considered or tested in the context of built heritage. This needs to change and Government could sponsor detailed work in this area.
Energy Auditing
Currently, all churches are required to have a quinquennial inspection of their premises and an energy audit would accompany that process. Individual church energy audits, undertaken by suitably experienced auditors, enable the identification of building-specific, low-carbon options prior to the need to replace a heating system. However, there is a shortage, especially in Wales, of suitable energy auditors who are both experienced in auditing historic properties and familiar with the particular context of church buildings. So far, the Church in Wales has relied almost exclusively on the services of a single company.
There is an opportunity for Government to enable the training of future auditors and establish suitable apprenticeship schemes to upskill and/or train suitably qualified people in a unique area of work.
Heating Engineers
Invariably, local churches take advice from their local heating engineer, and most heating engineers like to stay in their comfort-zone, dealing with gas or oil heating, and therefore, tend to cast doubt on the efficacy and cost-effectiveness of electric alternatives. Equally, they may not be aware of the latest technological developments and also have the obvious vested interest in selling a new conventional boiler now.
The development of comprehensive training and awareness for heating engineers would be beneficial across all sectors as there is a need to ensure that heating engineers are upskilled and/or gain the necessary new skills to advise and install low-carbon technology in heritage buildings. The upskilling of this sector of the workforce might also help encourage investment in Welsh jobs.
Finance
Inevitably, as technologies are scaled up the relative cost per unit will come down. However, virtually every religious establishment in Wales will be looking to upgrade to low-carbon technologies at some point in the near-term, and consequently, there will be significant demand for finance streams and pressure on the existing limited funding sources.
The financial challenge is substantial. Initial energy audits on some sample churches suggest that the average capital costs to move churches to a net zero position is around £38,000 per church and that does not include the necessary investment in church halls and parsonages, and cathedrals will cost many fold more. The energy audit for Llandaff Cathedral indicated a capital investment of £250,000 to upgrade the Cathedral complex.
For all Church in Wales churches to approach net zero, the capital input would be in excess of £47 million and we will need to persuade congregations to raise the money to make the necessary investments, despite the fact that audits show that they will at best keep running costs flat.
Some specific funding for some exemplar pilot projects to demonstrate best practice would be very helpful. We have a number of potential pilot projects already identified.
Ongoing running costs
To achieve the necessary, widespread take up of low-emissions heating, the UK Government will need to reform fossil-fuel subsidies – approximately, 40 countries have already undertaken FFSR (IISD, 2021). The rebalancing of the relative pricing of gas and electricity would enable financially struggling churches (and households) to seek low-carbon options without the fear of the ongoing financial penalty.
4. What are the financial, regulatory and practical barriers to preserving built heritage?
Our answers above largely cover these questions.
Heritage legislation in the UK is, arguably, very well thought through but it fails to protect the historic built environment where it is not implemented. Given the responsibility for monitoring listed buildings usually falls on the Local Authority, built heritage, not infrequently, become at risk when owners default on repairs and regulatory powers are not used. This is invariably a consequence of lack of finance, resource or will depending on the Local Authority. Local authorities need the resources to recruit and train Conservation Officers who can implement the regulatory regime.
The Government should review the general VAT position for listed buildings. A new build extension to a listed building is zero-rated; repairs and maintenance work attracts VAT at 20% (though the Listed Places of Worship Grant Scheme does provide a grant for work to places of worship). There is a strong argument that this position should be reversed. Zero rating for VAT or repair and maintenance work would be a massive help to the sector. VAT on extensions would help to compensate.
5. What policies would ensure the UK workforce has the right skills to maintain our heritage assets?
An effective UK workforce to maintain heritage assets flows from a vibrant and sustainable built heritage sector. We believe this will be achieved by:
With these in place, there will be a more vibrant conservation building sector to supporting economic growth. It will encourage a wider range of apprenticeships and T-levels including heritage crafts and opportunities for existing tradespeople to up-skill and transition across to heritage work.
In simple terms, it is a ‘catch 22’ – there is no point creating a skilled workforce if there is no work for them to do, but there will be no work done if there is no skilled workforce.
Submitted by Alex Glanville - Director of Property Strategy
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