Written evidence submitted by the Wales Heritage Group

The Wales Heritage Group consists of organisations in Wales that are statutory consultees for the Listed Buildings and Ecclesiastical Faculty systems. Many of the questions and issues raised by this inquiry are common to Wales, hence our wish to contribute to the Select Committee’s deliberations. Some of our members will have made their own independent submissions, but this submission represents the collective response of the Group, whose members consist of the Welsh branches of:

• Society for the Protection of Ancient Buildings
• Friends of Friendless Churches
• Council for British Archaeology
• Georgian Group
• Victorian Society
• Twentieth Century Society
• Garden History Society / Welsh Historic Gardens Trust
• Civic Trust for Wales
• National Churches Trust
• Theatres Trust
• Association of Preservation Trusts Wales
• Addoldai Cymru (Welsh Religious Buildings Trust)
• Royal Society of Architects in Wales
• Historic Buildings and Places
• Capel
• Heneb
• Heritage Trust Network
• Caring for God’s Acre
• The Patrimony Committee of the Catholic Church

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?

• Climate change: increased risks of flooding, wildfire, wind and storm damage and coastal erosion.
• Inflation: the costs of looking after heritage are growing at a faster rate than consumer prices, with the rising costs of energy, insurance premiums, materials and the skills to maintain historic buildings.
• Falling income: national and local government funding for heritage has suffered two decades of decline, impacting the sector’s capacity to deliver solutions, leaving the sector stretched and vulnerable.
• Conservation cuts: cuts to local authority planning teams result in a lack of conservation advisers and results in long delays to decision-making. This undermines the role of the planning system in the protection of historic buildings and disincentivises engagement by homeowners.
• Pay rates: low rates of pay are a major deterrent to working in the heritage sector, resulting in what the Heritage Alliance has called a ‘brain drain’ from the sector.
• University cuts: low pay has a substantial knock-on effect on the tertiary education sector, where fewer students are opting for heritage-related degrees; universities are responding by closing departments and making staff redundant with a consequent loss of research and expertise.
• Local authority ownership: all these challenges are compounding the impact of past under-investment in the heritage sector, especially by local authorities who own a significant proportion of the buildings on the heritage at risk register.
• Technical knowledge: there is a lack of understanding of how to repair and conserve historic buildings among architects and planners and a lack of understanding of the merits of retrofitting to conserve embodied carbon and energy. This leads to inadvertent damage to buildings through the use of unsuitable materials and techniques.
• Skills: there is a skills shortage of conservation-educated craftspeople. This makes it increasingly difficult and expensive to undertake work to listed buildings.
• Social change: the heritage sector is heavily dependent on voluntary effort but many voluntary bodies that support the heritage are seeing a decline in membership and a loss of financial support.
• Philanthropy: heritage depends to a high degree on donations, bequests and grants from philanthropic bodies. Charities report that it is increasingly difficult to raise such funding as social attitudes to giving are changing and people are less willing to make donations.
• Heritage crime: theft, arson and vandalism have risen significantly in the last decade, including the removal of roofing materials that leave buildings vulnerable to weather and further damage.

What interventions are needed to prevent the managed decline of heritage assets on publicly owned land?

• Fiscal policy: charging VAT on the costs of building repairs and maintenance has long been an issue for the sector, since new building works are exempt from VAT, which means there is more of a financial incentive to demolish historic buildings (e.g. Victorian schools) and build something new on the site than to restore, convert or upgrade existing buildings.
• Listed Places of Worship Grants Scheme: every few years the sector expends energy on advocating the continuation of the Listed Places of Worship Grants Scheme, which enables Listed Places of Worship to reclaim VAT on repairs and alterations over £1,000. For an annual cost of c. £24m a year, and an average grant size of around £4k paid out to 500 applicants a month, this scheme delivers a high level of benefit, keeping places of worship in good repair and supporting construction companies and craft skills. This scheme needs to be made permanent so that places of worship can plan in confidence for future repair work.
• Heritage at risk: if historic buildings are not looked after, they decline rapidly. Local authorities should give a higher priority to working with owners to help them make better use of their assets (including, for example, empty accommodation above shops).

• Enforcement: as a last resort, local authorities should use the powers that they already have to enforce repairs when historic buildings are neglected. Too much of the cost of neglect is borne by the public purse: owners who neglect buildings should be prosecuted and / or made to sell.
• Training programmes: to create a new generation of skilled craftspeople.
• Adequate funding: especially for local authority planning teams, ensuring conservation advice is available in all areas of the country.

What can the Government do to make it easier for communities or local businesses to take ownership of historic buildings?

• Community asset transfer: one of the biggest challenges of the next decade is going to be the closure and potential disposal of the historic churches and chapels that make up the majority of listed buildings in the UK. There is little understanding of the alternatives to closure, including community asset transfer, which needs to be promoted, alongside an effort to encourage congregations to consult the wider community about the future for these buildings at a much earlier stage.

• Listed Building Consent Orders: encourage the constructive use of Listed Building Consent Orders (https://historicengland.org.uk/images-books/publications/drawing-up-local-listed-building-consent-order-advice-note-6/heag009-listed-building-consent-order-an6/), particularly in urban areas with consistent architectural styles, ensuring that there is clear guidance in place and minimal delay to routine maintenance works (e.g. the installation of double glazing or certain types of insulation).

2. How effective are the current funding and finance models for built heritage?

• Chronic underfunding: the Heritage Alliance Insight Report (‘On The Brink: Heritage in the Cost of Living Crisis’) shows that there is a £3bn backlog of essential repairs and maintenance just for listed historic houses and churches. This suggests that the current funding models are not effective, possibly because of a reliance on diminishing levels of central and local government funding.
• Heritage and government objectives: reductions in spending on heritage result from a view that heritage is a luxury, a ‘nice to have’, whereas it can contribute to the achievement of so many of the government’s objectives for economic growth, housing and preventative health.
• Motivating people: the grants that are available to help with the repair and maintenance of historic fabric are not always taken up because of the lack of community-minded people willing to take on the challenges of making applications, raising funds and managing projects: a survey conducted by the Church Times in 2024 pointed to the reluctance of people willing to serve as churchwardens and take on the tasks of fundraising and fabric maintenance. We need to make it easier for people to take on these roles, with training and advice and simplified procedures and the sharing of good practice.

What should long-term public funding for the sector look like?

• Small amounts make a big difference: by contrast with some sectors, the heritage sector is very lean and efficient, often based on the efforts of volunteers, and small amounts of additional money are able to make a very big difference. The first step for long-term funding would be to halt the decline in finding and commit to maintaining the current levels of central government funding to arm’s-length bodies and executive agencies delivering vital heritage services. The next step would be to invest in the sector and unleash the growth and social good heritage can deliver by allocating a higher percentage of the national income to heritage.
• A Culture Growth Fund: the Heritage Manifesto published by the members of the Heritage Alliance calls for a new Culture Growth Fund: a major new phase of investment in the future of our heritage that is  widely supported by the public: 73 per cent of UK adults agree that it is the role of government to fund the heritage and that the UK government has a moral obligation to protect our heritage.
• Funding for conservation officers within local government
• Apprenticeship schemes which incentivise heritage skills development
• VAT equalisation with new build development
• Funding for public education and outreach programmes which provide conservation-led guidance to listed building owners, architects and construction workers. This will prevent many long-term issues, reducing the need for future interventions.
• Grants for capital works on public buildings, especially for energy efficiency- Informed by appropriate surveys (CARE accredited surveyors)
• Funding to early intervention schemes that tackle minor issues (such as water penetration) before they accelerate and create major, expensive issues which put buildings At Risk.

3. What role does built heritage play in the regeneration of local areas and in contributing to economic growth and community identity?

• Economic and social value: heritage is part of the solution to so many of today’s economic and social issues. With government support, it could make a major contribution to the nation’s housing targets through the conversion of otherwise empty properties. It is the basis for the hugely important and growing tourism sector in the UK, which in turn plays a role in the perception of the UK internationally. It has significant wellbeing value and the potential to play a role in preventive medicine and to deliver social prescribing and mental health services. It inspires the creative industries and provides locations for film and TV productions, and it attracts property and business investors to the UK. To unlock all this public wellbeing requires that heritage be recognised for its potential and embedded in all government strategies.
• Local value: in addition, the value of heritage to people and communities is beyond measure. Heritage is the backdrop to our lives, and high-quality heritage is vital to everyone’s quality of life. It results in places where people want to live and visit. Vice versa, places with poor quality suffer a downward spiral of decay that increases anti-social behaviour and alienation. There is a tendency to intervene too late, when it is expensive to do so (and the word ‘regeneration’ encapsulates this – communities should not be allowed to deteriorate to the point where regeneration is necessary). We need a national effort to protect and enhance what we have inherited and to make better use of the solutions that already exists (for example, by taking conservation management plans more seriously). .

How can heritage buildings be supported to increase energy efficiency and contribute to the Government’s net zero targets?

• Developers: government policy should place greater emphasis on the reuse of existing assets rather than the erosion of ‘green’ or ‘grey’ belt sites, for example by encouraging developers to realise the potential of taking on heritage assets that can be used for much-needed housing.
• Developers should also be encouraged to re-use Non-Designated Heritage Assets (NDHAs), not just Listed Buildings. NDHAs also contribute to local community wellbeing and sense of place, and can offer considerable potential for adaptive reuse, which saves carbon.
• Technical: better solutions are needed to make historic buildings more environmentally sustainable with an emphasis on retrofitting existing buildings and on whole-life costs rather than demolishing and rebuilding. Applications for the demolition and replacement of historic buildings should require whole life carbon assessments, including the carbon of their demolition and construction, not only operational carbon costs.
• VAT equalisation for repair works with demolition and new build development of a site will remove the incentive for carbon-intensive construction works.
• There is a need to develop a skilled workforce who can retrofit for energy efficiency in older buildings using appropriately hygroscopic materials.

4. What are the financial, regulatory and practical barriers to preserving built heritage?

• Recognise that these barriers do not exist: let us be clear that the idea that there are financial, regulatory and practical barriers to preserving and enhancing built heritage is a political position, and one that has been challenged over and again and shown not to be a fact. Such regulatory ‘barriers’ as exist are measured and manageable and are there to protect society’s interest in the environment – the alternative is a free for all. Heritage compliance is not difficult and is far less onerous than the many other regulatory regimes that are used to control quality and safety standards in the building industry, or to manage the engineering and logistical challenges.
• Pre-planning advice: greater use should be made of pre-planning advice to help those who wish to alter or extend historic properties and increase their chances of a successful outcome. Such advice is often freely given by voluntary bodies, or available at minimal costs from national heritage agencies and local authority conservation officers.
• Better resourcing for local planning departments to ensure that the planning system works efficiently.
• Better guidance for owners and developers on how to manage and conserve historic buildings to ensure that planning applications pass through the system quickly and reduce the need for additional resources. Cadw’s guidance on preparing Heritage Impact Assessments is a good example of how to provide this.

What policy changes are needed to make restoring historic buildings easier and less expensive?

• Counteract the myths: again, it is not true that the constructive conservation of historic buildings is difficult nor expensive; to say so perpetuates a myth that serves developers who want to maximise their profits by developing greenfield sites.
• Demand more in return for planning permission: we give planning permission away too easily in the UK and do not make enough demands on developers. If developers were taxed for permission to develop greenfield sites and made to contribute to the extra infrastructure costs of their developments, there would be more of a level playing field between restoring historic buildings and new builds.
• Support the National Amenity Societies who provide free advice!

5. What policies would ensure the UK workforce has the right skills to maintain our heritage assets?

• Use the policies that exist: it is not new policies that are needed so much as making use of the existing policies and making them work. For example, apprenticeships theoretically offer an attractive way to develop practical skills while avoiding the indebtedness that results from university study; one needs to ask why apprenticeships have not been taken up when they represent such an obvious route to skills development and employment. We need to find out why there has not been a mass take-up of apprenticeship schemes and make sure that they are fit for purpose.
• Adequate funding to ensure the survival of higher education institutions that provide specialist learning and skills that support the heritage sector, e.g. archaeology degrees.
• Apprenticeships across all skills, trades, qualification levels, e.g. Historic England’s Heritage Apprenticeships.
• Where Local Planning Authorities are under the most financial pressure, the historic environment is most at risk through staff cuts to non-frontline services such as planning and conservation advice. People in all areas deserve to have high-quality planning advice available to ensure the conservation of their local built heritage. Consistent funding for fully qualified conservation and archaeology advisers will ensure that the areas most in need of the social and economic benefits of heritage do not suffer from a lack of local expertise.