Written evidence submitted by Maintain our Heritage

1. Maintain our Heritage[1] thanks the Committee for the opportunity to contribute to this timely inquiry.

Summary

2. The nation’s historic buildings are facing a crisis of maintenance.  They are therefore deteriorating at an unnecessarily rapid rate. 
3. This is largely due to:

3.1                  the Government’s failure to correct the long-recognised ineffectiveness of the legislation to require the maintenance of historic buildings;

3.2                  the absence of any general duty to maintain such buildings, or indeed buildings in general, even when they have the capacity to cause serious casualties;

3.3                  the unfortunate policies of Historic England (HE) and the National Lottery Heritage Fund (NLHF) to allocate all their available grant funding to repairs rather than routine maintenance; contributing to:

3.4                  the building conservation movement’s obsession with the rescue of historic buildings through repair projects rendered unnecessarily expensive by long periods of neglect.

4. Climate change is also a major factor, which is being exacerbated by the refusal of HE and NLHF to adapt their policies on maintenance, even in the face of repeated research studies urging them to do so.
5. After setting out some background, we will expand on these under four of the Committee’s terms of reference, namely:

5.1                  how effective are the current funding and finance models for built heritage;

5.2                  what should long-term public funding for the sector look like;

5.3                  what are the financial, regulatory and practical barriers to preserving built heritage; and

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

Background

6. Maintain our Heritage is a not-for-profit group created in 1997 by a group of architects and campaigners dissatisfied with the losses of historic buildings caused by the obsession of the UK building conservation movement with the finding of permanent new uses, often after prolonged periods of avoidable neglect, followed by a rescue of the threatened building at significantly inflated expense.  The movement should instead focus on basic maintenance at minimal expense. 
7. We have since conducted a major research project, implemented practical collective maintenance projects and monitored developments in and beyond the UK. 
8. We are aware that the scope of the Committee’s inquiry is limited to England, but we will use some evidence from the other home countries, since their issues, policies and legislation are virtually identical to those of England.

The Effectiveness of Current Funding and Finance Models

9. The current funding and finance models for the built heritage are almost entirely unfit for purpose and contribute significantly to the rapid decline and loss of historic buildings in England.
10. In summary, this is because:

10.1             grant funding for historic buildings from HE and NLHF has only ever been available for repair rather than the routine preventive maintenance which would avoid the need for such repairs or render them much cheaper;

10.2             these policies have been adopted despite – and almost, in defiance – of Parliament, which has repeatedly given these bodies powers to grant-aid maintenance as well as repair;

10.3             NLHF is by far the largest funder of historic buildings in the UK, but its strategies are increasingly unrelated to the practical priorities of the built heritage, notably by refusing grants to small and remote churches unable to meet its demands for unattainable “outcomes”; and

10.4             NLHF and HE grants unduly favour the expensive and usually avoidable repair of “buildings at risk” on HE’s register of such buildings, which HE has adopted as one of its corporate performance measures.

11. Other bodies, notably the charity the Architectural Heritage Fund, substantially funded by DCMS over many years, follow similar policies.
12. We will examine these in turn.

Grant Funding for Repairs only: not Maintenance

13. In 1953, Parliament passed the Ancient Monuments & Historic Buildings Act which gave Ministers the power to make grants for the repair and maintenance of historic buildings, on the advice of a Historic Buildings Council (HBC) to which HE is the successor.  The legislation (as amended in 1983) now states:

“[HE] may make grants for the purpose of defraying in whole or in part any expenditure incurred or to be incurred in the repair or maintenance of a building which is situated in England and which appears to the Commission to be of outstanding historic or architectural interest….”[2] [our emphasis]

14. Unfortunately, in 1953, HBC immediately adopted a policy not to make any grants for maintenance (other than to some under-endowed National Trust properties).  This may have been due to the abnormal number of country houses then at risk, many of them dilapidated after requisitioning during the war.
15. HE’s policy not to grant-aid maintenance remains to this day, 72 years later.
16. I and others have repeatedly tried to persuade HE to review this policy, but without success.  I had an exchange of correspondence on this with HE (then English Heritage) in 1995.
17. EH’s response included statements such as these:

“It is simply not realistic to suggest that we should divert funds into maintenance to avoid buildings possibly becoming at risk in the future at the expense of buildings that are at risk and will be lost without grant aid.”

“The "stitch in time" philosophy of grant aid is superficially an attractive one, and English Heritage from time to time considered the scope for providing assistance for routine maintenance. But the reasons for not doing so are obvious….”

18. The full exchange is exhibited at Annex 1[3].
19. It has long been a fundamental precept of good building conservation practice that such buildings should be maintained as far as possible rather than repaired.  This goes right back to the writings of John Ruskin and William Morris, founders of the movement in the UK, and it is now enshrined in a series of international charters, notably the ICOMOS Burra Charter of 1979[4].
20. HE promotes building maintenance, in its publications and on its web site.  It seems to take the view that financial support is unnecessary, despite all the mounting evidence to the contrary.
21. This policy is in stark contrast to that of the Pilgrim Trust, a grant-giving charity, which decided in in early 2000s to fund the National Churches Trust to administer a grant scheme for maintenance and minor repairs.  This is virtually the only national source of such funds for churches.
22. A desk study of 30 churches by HE itself, published in 2019[5], confirmed that costs of repair are significantly greater for badly-maintained buildings.  It nevertheless made no changes to its policy not to grant-aid maintenance.

NLHF as funder of Historic Building Repair

23. Since its formation in 1994, the National Lottery Heritage Fund has given grants for the repair, only, of historic buildings.
24. There are two issues we wish to raise.  The first is that its grant budget has always been vastly larger than that of HE, but NLHF has pursued its own, successive strategies which are inadequately researched, poorly consulted on, poorly supported by professional advice, and have had the effect of excluding from eligibility large numbers of historic buildings in dire need of support and contributing to the problem of neglect.
25. NLHF has made such grants conditional on applicants (often churches) fulfilling certain “outcomes”, principally the involvement of more people in the heritage.
26. For small and remote communities, and some others, this has proved an impossibility.  Remote historic buildings, often Grade 1 and 2* churches requiring repairs well beyond the means of the locality, have been denied grant aid. 
27. Word soon got around among churches that applying to NLHF was a waste of time.  In a speech to the Historic Religious Buildings Alliance (HRBA) on 5th June 2024, the chair of NLHF, Dr Simon Thurley, revealed that there had been a 35% reduction in applications to NLHF from churches in England since 2017[6].
28. In our discussions with NLHF over many years, it has become clear that it does not take account of anything other than its own strategies and the “one size fits all” approach to its self-imposed requirement that more people should be involved in the heritage.  This has become a bigger issue since 2002 because it had a joint scheme with HE for church repairs from 1996 to 2002.
29. So in Maintain’s opinion we now have a paradoxical situation in which the nation’s biggest funder of heritage has few professional resources and a strategy detached from the real needs of the heritage, while the specialist funding agency (HE) has the professional resources but a fraction of the funding.
30. NLHF has recently announced a “strategic initiative” under which it will make at least £15M available to places of worship, particularly in rural areas.   As usual, however, these funds will be confined to repair projects.

NHLF and maintenance

31. The second issue is NLHF’s attitude to maintenance.  Like HE, Parliament gave NLHF the power to grant-aid maintenance, but for its 41 years of existence, it has refused to use it. 
32. Like HE, it immediately adopted a policy to exclude maintenance work from its grants.  This remains its policy.  It has resisted all attempts by Maintain and others to alter it.  The only changes it has made are:

32.1             to impose a poorly-enforced requirement that a grant-funded building is properly maintained for 10 years after the work is done; and

32.2             to recognise that poor maintenance of a building for which a repair grant is sought is a “risk factor” to be considered in assessing an application.

33. It has specifically refused two suggestions from Maintain, namely:

33.1             to give enhanced levels of repair grant aid buildings which have been well-maintained, the materials of which (eg roof coverings) are simply time-expired, thus creating an incentive to good maintenance; and

33.2             to make grants available for works to facilitate future maintenance, for example by installing access hatches and fixed ladders which would enhance the likelihood of good maintenance and greatly reduce its cost.

34. We believe these decisions are short-sighted and poorly researched.
35. The nearest NLHF approached a practical recognition of the value of maintenance is that between 2007 and 2012 it funded a project by the Society for the protection of Ancient Buildings (SPAB) initially called “Faith in Maintenance[7]”. 
36. This was essentially a training scheme for churchwardens and others concerned with the maintenance of churches.  It trained some 5,000 volunteers, and won a Europa Nostra award.
37. In accordance with NLHF rules, however, the funding only lasted three years.  A successor scheme was devised, called “Maintenance Co-operatives”, and lasted a further three years.  It then closed.
38. The concept that the built environment needs constant maintenance, for ever, appears not to accord with NLHF’s thinking that all projects must be time-limited.  In an organisation devoted to heritage, we find this extraordinary.
39. We do not believe NLHF’s management has been adequately held to account for these policies.

Buildings at Risk

40. Maintain takes the view that any historic building which is not being appropriately maintained is a building “at risk”.
41. HE, like its equivalents in Scotland, Northern iIeland and Wales and some NGOs such as SAVE Britain's Heritage, keeps a “Buildings at Risk Register” (BaRR).  We have major doubts about how HE’s operates because:

41.1             HE’s BaRR excludes all Grade II buildings (outside London) other than places of worship, the condition of which it does not monitor.  HE does not monitor the condition of the vast majority of England’s historic buildings;

41.2             BaRRs are a reflection of the increasingly 1960s orthodox belief that the appropriate treatment for neglected buildings is not to keep them in repair but instead concentrate on trying to find new owners and new uses for the by now rapidly deteriorating buildings;

41.3             HE has adopted the number of buildings on the Register as one of its corporate performance indicators;

41.4             this has led it, we believe, to concentrate its repair grants on those projects which promise to remove a building from the register;

41.5             this has in turn created a perverse incentive against maintenance.  If an owner (notably, a church) wants to get a grant from HE or NLHF, its chances of success are increased by skimping on maintenance, and becoming listed as a building at risk, thus endangering the building and greatly increasing the cost of the subsequent repairs.

42. We exhibit at Annex 4[8] an example of the process at work.  In 2016, HE added the Unitarian Church in Stoke Newington, London, to the BaRR, a move “welcomed” by the church.  It was awarded a grant of £1,855,000 by NLHF in 2017.
43. We believe HE should instead widen the scope of the BaRR to include all Grade II buildings, adopt a casework-led approach, spotting problems early and then identify incremental solutions such as grants for basic security, temporary uses and maintenance rather than exclusively for complete repair.
44. Historic Environment Scotland recently suspended work on its BaRR, pending a review of its effectiveness.

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

45. Maintain believes that public funding should be based on the principles set out in the main international charters on building conservation.  For example:

45.1             a historic building should be kept in use, ideally the one for which it was designed, and hence avoid periods of disuse;

45.2             as much as possible of its authentic, original fabric must be conserved for as long as possible through routine, preventative maintenance and conservation-based repairs;

45.3             the rising threat from climate change must be recognised, bringing major changes to the need for protection against water, wind, and temperature changes; and

45.4             vandalism, fire and arson must be minimised.

46. Above all, there should be more scrutiny by DCMS and Parliament.  A more rigorous approach should be adopted towards the assessment of the value for money of different approaches and the performance of the agencies concerned.

Introduce Long-Term Planning

47. Funding for the sector should become long-term, which in our opinion it is currently not.
48. Historic buildings are meant to be permanent features of the environment.  This alone ought to dictate that the funding of their needs should be looked at in a long-term way.
49. At present, most funding is deployed for individual repair projects, the need for which is currently treated by HE and NLHF as if they were completely unpredictable.  In reality, the timing and frequency of the need for major repairs can be predicted and costed, and the cost can be reduced through long-term decision making, through the use of long-term, possibly 100-year maintenance plans.  A tiled roof can last 150 years with good maintenance, or less than 50 with poor maintenance. 
50. Few historic buildings have such maintenance plans, but these should be encouraged and grant-aided, particularly for churches, so that the necessary expense can be planned for. 

End the emphasis on last-minute rescues

51. There must be a wholesale change of emphasis by Government, HE and NLHF away from supporting a diminishing number of expensive ”rescue” repair projects to encouraging routine, preventive maintenance in all historic buildings.  This will save many historic buildings, and cost less.

Grants to prevent problems, not cure them later

52. A long-term approach implies that HE and NLHF should introduce grant schemes for:

52.1             routine maintenance and minor works;

52.2             works to make access for future maintenance easier and less costly;

52.3             ensuring the continued availability of the requisite craft skills;

52.4             works preparatory to a building about to become redundant (on similar lines to one operated in the Netherlands);

52.5             works to adapt buildings to the dangers of climate change, notably the need to upgrade roof and ground drainage systems and flood prevention measures;

52.6             works to improve security, for example through surveillance, or for creating spaces for “live-in guardians;”

52.7             collective maintenance schemes, for example those carried out in some Church of England Dioceses[9], in Stirling[10],Flanders (Belgium) and on a nationwide scale in the Netherlands[11]);

52.8             the protection of buildings – whether in use or not – from the risk of fire and vandalism; and

52.9             comprehensive surveys of the condition of town centre buildings, particularly in view of the known dangers of under-maintained buildings to the public in such areas[12].

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

Financial Barriers

53. The financial barriers we identify are:

53.1             the application of VAT at the full 20% rate to the repair, maintenance and alteration of historic and all other buildings;

53.2             the recent Government announcement[13] limiting the recovery of VAT under the Listed Places of Worship Grant scheme to £25,000 per building, and only until March 1926;

53.3             the refusal of grant aid for the maintenance historic buildings by the major grant-giving bodies, referred to above.

54. The Listed Places of Worship announcement will have the immediate effect of:

54.1             increasing the cost of any repairs or maintenance to a listed place of worship costing over £125,000 in a year.  In view of the high cost of the skilled work required, this figure is totally inadequate and is likely to result in the postponement or cancellation of many much-need repair work; and

54.2             casting doubt on the affordability of any repair or maintenance work to be undertaken by any listed place of worship after March 2026.

55. It is difficult to imagine a more retrograde step for the care of England’s historic churches.

Regulatory Barriers

56. The regulatory barriers we identify are:

56.1             the absence of any general duty on the owners to keep historic buildings in an appropriate state of repair;

56.2             the total inadequacy of the special legal powers Government and local authorities have to require the maintenance or repair of historic  buildings, which we will set out in more detail below;

56.3             the unnecessary beurocracy required by Government before even the inadequate repair power to require urgent works can be used for Conservation Area buildings(see below);

56.4             the total inadequacy of the general legal powers to require owners of all buildings to keep them safe and in good condition;

56.5             the confusion between HSE and local authorities over the always-feeble enforcement of existing duties to maintain workplace premises; and

56.6             the 2011 directions by Government to HSE and local authorities to scale back even this level of enforcement.

Practical Barriers

57. In all areas of building conservation, there are skill shortages.  The less work there is, clearly the fewer craftspeople will be able to work and develop their skills.  The expense of such work then rises, and the situation becomes a vicious circle.
58. All the agencies concerned need to work together to produce long-term funding plans which co-ordinate the funding of conservation work with the training and development of the necessary craft skills.
59. An additional problem of skills is that churchwardens and their equivalents are poorly trained in the care of historic buildings, and often make calamitous decisions about their care.  This is unfortunate as 45% of all Grade 1 listed buildings are churches.
60. The Church of England alone has 13,000 listed churches, many of them Grade 1 or 2*.  Since the ending of the SPAB “Faith in Maintenance” NLHF funded scheme, we are unaware of any systematic attempt to address this issue.
61. HE and/or NLHF should fund ongoing efforts by the Church of England and other churches, alongside conservation bodies, to train churchwardens and their equivalents in the proper management of this vital part of the nation’s heritage.

The Legal Powers

62. A remarkable feature of the building conservation scene in England is the absence of any requirement on the owner of a listed building to take any steps to maintain it.
63. Even more remarkable is that there is no general duty on their owners or those of any other buildings to keep them safe, either.
64. The only positive legal duty there is to maintain any building – listed or not – is for “workplace” buildings, under Health & Safety legislation, and there is non-binding “guidance” from HSE that such buildings should be regularly inspected by a competent person, but these are virtually unknown, not promoted by HSE, and seldom enforced.  A Maintain briefing note on this duty is attached as Annex 5[14].
65. What legislation there is in this area is of four types:

65.1             reserve powers for the Government, local authorities or HE to serve one or other of two types of notice under the Planning (Listed Buildings and Conservation Areas) Act 1990 Act (the 1990 Act) to require the owner to repair a listed building;

65.2             reserve powers for local authorities to service notices (or take urgent immediate action) under the Building Act 1984 (the 1984 Act) when a building – listed or not -is thought to have become dangerous;

65.3             a power under s. 215 of Town and Country Planning Act 1990; and

65.4             an assortment of powers under other legislation, notably the Housing Acts.[15]

66. These conservation powers have serious shortcomings, which we will describe below.

The Conservation Powers

67. The main powers in ss. 47 and 48 of the 1990 Act set out a general power to serve a “repairs notice” on the owner of a listed building, specifying what works are required.  If the work is not carried out within two months, compulsory purchase proceedings can follow.
68. S.54 sets out a power to carry out urgent works but only to an unoccupied, listed building.  There is a long and convoluted process whereby this power can be used on a Conservation Area building, with in every case Ministerial permission (see below).
69. The ineffectiveness of these powers has been universally admitted by successive Governments since at least 1980.  Little, however, has been done to improve them. 
70. The repairs notice/compulsory purchase power is ineffective because:

70.1             the Act imposes a huge administrative burden on the local authority, to specify all the works that the owner must take; and

70.2             virtually no local authority would in fact seek to acquire the building compulsorily. 

71. The threat posed by the notice is therefore widely understood to be worthless.
72. The section 54 urgent works power is fatally undermined by being confined to unoccupied listed buildings.  Occupation – not defined – is sufficient to defeat it.  If carried out, the works must be confined to those urgently necessary to preserve the building and there is a convoluted process to enable the owner to appeal against the cost, as some owners do, spending more on the appeal than the work would have cost.

Seventy Years of Inaction

73. Although the powers in other sectors have been developed over the years, those for historic buildings have not.
74. In Annex 2[16] we have set out the history of attempts to improve them, along with the many prompts that Government HE and others have missed to modify their policies towards the implementation of these powers.

Excessive respect for the presumed rights of Property Owners

75. This entire area of law is complicated by an overweening respect for the presumed rights of the property owner, whose building is nevertheless often the cause of serious danger to life and major environmental damage or loss of amenity to the neighbourhood and its residents. 
76. Just how excessive this respect is, and what an administrative burden it imposes, can be judged by the paperwork the Government expects before it approves, in the case of each building, the use of the power to get an unoccupied, unlisted building in a Conservation Area urgently repaired.
77. Ministerial permission is needed for local authorities to have the power to require urgent works to unoccupied non-listed buildings in Conservation Areas.  This however requires the submission of a huge dossier of information containing 11 different assessments and a bundle of all the correspondence, spelled out in a joint document[17] produced by HE and the Institute of Historic Building Conservation (mostly local authority conservation officers) .
78. The administrative effort required is therefore immense.  It has to be remembered that this power is intended to be used to get urgent works done to a Conservation Area building.
79. We contrast this with the process we recommend later that the UK studies, from the USA (see later).

The Building Act 1984 Powers

80. These powers, in ss 76-78 of the 1984 Act, give local authorities powers to intervene in the case of defective and dangerous buildings.  These situations can range from cases where the building is neglected to cases where buildings suddenly become dangerous as a result of vehicle impacts etc.
81. Their use is explicitly subject to listed building and conservation area controls (which in fact contain an exception for urgent works for safety and health purposes).
82. It is important to note that these are Victorian-style public health powers.  In other words, the local authority has to wait until the defective or dangerous condition of the building is apparent, before they can act.  There is no duty on them to inspect buildings and (because there is no duty to maintain a historic non-workplace building) the owner need do nothing to keep the building in good condition, even when this causes danger to the public.
83. The failures in this “wait and see” legislation may be measured by the multiple deaths, serious injuries and narrow escapes suffered as masonry falls suddenly from under-maintained buildings, the danger from which is not detected by the owner or local authority.

Maintain’s Register of Falling Masonry Incidents

84. Maintain has kept a register of these incidents since 1999, both in the UK and elsewhere, of which it becomes aware.  It is by no means complete.  It shows that “falling masonry” incidents are common in Britain.  This is attached as Annex 3[18].
85. We do not believe any other organisation keeps track of these incidents.  The register excludes incidents during building works and is concerned only with maintenance.  We believe our register only contains a fraction of the number of incidents happening virtually daily all over Britain.
86. The results are these:

87. There are some themes which emerge from this research:

87.1             a significant number of incidents involve parapets, chimneys and high-level details.  Parapets are particularly deadly and several have involved masonry falling onto people sitting or serving at tables outside the premises;

87.2             high winds and storms find out the defects at high level.  Increasingly stormy weather will thus increase the danger;

87.3             an astonishing number of passers-by have had narrow escapes;

87.4             the building owners concerned include Boots, High Street banks, supermarkets, department stores (notably Jenners and Selfridges), the Churches of England and Scotland, and local authorities;

87.5             very few owners have been prosecuted for failures under the Health & Safety requirements to maintain workplace buildings; and

87.6             there is a very serious issue in Scotland, where aware of the issue is now high, but still awaits a legislative response.

88. An obvious conclusion from the register is that historic buildings are a greater risk to the public than more modern ones, because:

88.1             the effects of time on the building are more pronounced; and

88.2             they are more likely to have stone or metal details at high level, which are particularly vulnerable to decay and damage in high winds.

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

89. It follows from our analysis above that we believe extensive and fundamental changes are needed in:

89.1             the basic legislation; and

89.2             the policies and practices of Government, HE, NLHF, HSE and local authorities.

Legislative Action

Introduce a duty to maintain

90. We regard the present situation as scandalous. At present, the only legal duty to maintain – for “workplace” buildings under health & safety legislation – is almost unknown and poorly enforced;
91. It is important that there should be some basic duty to maintain both historic and other buildings, at least where there is a potential danger to life, and that this duty is systematically enforced.
92. A press report[20] on the 2014 inquest into the death of Julie Sillitoe by falling masonry in London states:

“The inquest repeatedly heard that responsibility for checking a building’s safety rested with the owner and that there was no legislation compelling the council or any other state authority to carry out checks unless it had been reported as potentially “dangerous”.

Publicise and enforce the existing duty to maintain workplace buildings

93. HSE has told us that it has taken no steps to promote awareness of the duty to maintain workplace premises, or its (2013) decision to publish “guidance” that this duty implies that a regime of routine inspections by a competent person is adopted.
94. We believe this failure is scandalous and is a contributory factor in dozens of similar incidents involving workplace premises, and to the loss of at least three lives.

VAT

95. The imposition of VAT on the repair of all buildings should be ended or the rate significantly reduced.  The Places of Worship Grant scheme should continue at least until such changes are made.

Consider Other Countries’ Approaches

96. Other jurisdictions have adopted far better approaches to the problem of building neglect.  Of the many, we highlight here some from the USA.

The USA

97. America has a number of measures and concepts which we believe Britain should study carefully.

Demolition by Neglect

98. The first is that of “demolition by neglect”.  In many areas, legislation is aimed at preventing a historic building owner achieving by neglect the demolition he has been refused permission carry out, or which is unlikely to be permitted.  A number of interventions are available to prevent this.

“Minimum Maintenance Codes” and Local Ordinances

99. One of the other methods available to American local authorities is either a minimum maintenance code or special provisions incorporated into local ordinances.
100. These can be used not merely to ensure amenity and public safety, but also for the conservation of historic buildings and the avoidance of area-wide blight, caused by landowners seeking to run down an area by neglect in order to justify demolition and redevelopment.

In marked contrast with the equivalent repairs powers in Britain:

100.1         the codes or ordinances sets out minimum standards to which ALL buildings must be maintained.  See below for how New Orleans requires roofs and rainwater goods to be maintained;

100.2         if the local authority inspector spots a defect in contravention of the Code, he issues a compliance notice, not unlike a parking ticket, and NOT requiring the high level of decision making and beurocracy required in the UK;

100.3         the owner can appeal this via an administrative appeal process (again, similar to that for parking tickets in the UK).  The appeal is heard by administrative adjudicators who are normally legally qualified;

100.4         if the work required is not done within the required time, there is a daily fine, and the local authority can do the work in default and recover the cost; and

100.5         many local authorities then publish details of all such notices on their web sites.

101. The Minimum Maintenance Code of New Orleans, Louisiana, states in relation to roofs, that:

“The roof and flashing shall be sound, tight and not have defects that admit rain. Roofs must be adequate to prevent dampness or deterioration in the walls or interior portion of the structure. Roof drains, gutters and downspouts must be maintained in good repair and free from obstructions. Roof water shall not be discharged in a manner that it falls onto adjacent property. Roof tiles, shingles, and any other attachments shall be properly attached and kept in good condition.[21]”

Façade Maintenance Requirements

102. Many towns and cities in the USA have adopted legislation requiring the routine inspection of facades over a certain height, and the filing of reports by qualified persons, along with plans for any remedial work required. This follows a series of fatalities caused by falling masonry.
103. A list of these is available online: https://nj.cooperatornews.com/article/facade-maintenance-laws

Conclusions

104. We believe the evidence we are submitting shows clearly that:

104.1         the financial, legal, policy and practical backing for the protection of the  nation’s built heritage is now is a dire state;

104.2         the Committee’s intervention is now sorely needed to challenge the complacency into which the situation has descended, without proper scrutiny for over 70 years;

104.3         there is a serious and urgent need to address the entire legislative, policy, resourcing and policy background to the maintenance of buildings in general, alongside that of historic buildings;

104.4         the backlog of maintenance, and growing problems such as climate change, and inexorably increasing the dangers arising from the official complacency which has enveloped this area of policy; and

104.5         mass casualty events cannot be ruled out unless immediate and effective action is taken at all levels.

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