Written evidence submitted by the
Bath Preservation Trust

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 impact of climate change - Extreme heat, overheating, increased rainfall and water ingress risk damage and deterioration of heritage assets. This can potentially cause physical damage, restrict access, displace occupants and harm collections.
• Heating and cooling and comfort for users of buildings - Heritage assets can be more challenging places to occupy given that the spaces can be hard to heat, draughty, damp or prone to overheating.  This can restrict the suitability of the site for certain uses. For operators such as museums this can impact on visitor experience if temperatures are not ‘comfortable’ and/or access is restricted (closure during winter months).
• Energy costs – Older buildings that are energy inefficient are more expensive to run. This may have financial implications as energy efficiency retrofits can be expensive and can sometimes require expert knowledge and skills.
• Accessibility - Historic buildings may have narrow doorways, differing levels, steep staircases, and uneven floors, which can make it difficult for people with disabilities to move around. The layout and materials of historic buildings can present design challenge for the types of accessibility modifications. 
• Listed building consent requirements. The cost, time and expertise involved in making necessary changes to fabric, including repair and retrofit. There can be resistance to making physical changes to historic buildings, especially from conservation officers and planning legislation in place to protect significance. 
• Funding for cyclical maintenance and capital works can impact assets, collections, occupiers, and users. Funding models for heritage can be complex and specialised advice required on grant source conditions and their constantly changing emphasis. 
• VAT being charged for repairs and materials adds additional complexity. The mixed supplies rule makes it difficult to avoid VAT even for exempt supplies. Material costs for historic buildings are already higher than for modern equivalents.
• Public engagement – reliance on secondary spending if admittance fee is nil or the aim is to keep it low.  Discretionary spending cannot be relied upon, and operation of refreshment facilities requires significant investment, including regular.
• Environmental Health visits/ Food Hygiene Rating inspections.  
• Location of site (transport problems in rural/remote areas).  Less participation with some groups.  Visits based on weather/seasons.
• Staffing - (dependency on volunteers, comparatively low wages, workload/wellbeing, often sites can be remote and therefore difficult to staff since travel costs usually borne by volunteers, loss of skills, lack of appropriate skills). 
• Supply chain for heritage conservation crafts and skills pushes prices up and can cause delays to repairs.

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

• Ensure that early on, the owners are aware of the significance of the asset, re-use opportunities (interim and long-term), social, economic and environmental benefits that its continued use may bring. 
• Community engagement and awareness raising.
• Monitoring to identify deterioration and prioritize necessary repairs.
• Some sort of system, where the owner is obliged to flag the potential need to manage the decline of the building with appropriate bodies (Local Authority, DCMS, HE). 
• Proactive maintenance, inspections and budgets, volunteer participation in maintenance.
• Comprehensive heritage management plans.
• Alternative/diversified funding sources. Grants, sponsorship, community fundraising. This might include grants for Statements of Significance or preparing Conservation Management Plans to inform the owners and assist with applications for funding. Key to wider regeneration. 
• Adaptive reuse strategies, allowing for managed change while sustaining heritage value.
• Funded feasibility studies. 
• Funding for CPO (source of funding always an issue) where owner has consistently failed to respond to Urgent Works Notices, etc. Enforced letting/leasing (community and charity projects sometimes have access to other sources of funding). Reduce the opportunity for late- stage remediation works by negligent owners to avoid CPO.

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

• If being transferred from public ownership, ensure that buildings are sold at less than market value, if the new use can be demonstrated to bring social, economic or environmental benefits to the area. 
• Ensure specialist advice/support regarding the maintenance, duties if listed and retrofitting of historic buildings is available.    
• LPAs to provide free pre-app advice so that new owners have some clarity as to what can be achieved. 
• Ensure that information about condition and significance is made available to purchasers. 
• Make any associated covenants clear to purchasers.
• Public bodies to publicise Community Asset Transfer schemes more widely, with concise guide to procedure.
• Public bodies to have robust asset transfer policies/strategies in place. 
• Work with charitable organisations as an enabler (like Bath Preservation Trust). For example, we would be willing to support acquisition by using charitable status and knowledge to create community land trusts (CLT) or other charitable mechanisms to protect heritage. For example, we have incorporated two independent charities into our group, to safeguard heritage assets.

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

Typically, the models rely on a complex mix of private, public and self-generated income streams, which are often far from robust.   When funding streams or bodies face cuts, there is an obvious impact on the sources of funding.  Too much reliance has been placed upon the National Lottery Heritage Fund since the late 1990s, with corresponding withdrawal of grants formerly administered by Historic England, leaving many owners of Heritage Assets unable to secure grants through any other source. Particularly exacerbated when unexpected or urgent work is required. 

Lottery capital funding requires a ‘charge’ to be placed on a property for 25 years. This restricts other financing models for occupiers. The same outcome could be provided through restrictive covenants or legal agreements without limiting the value of property to enable investment.

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

Perhaps a centralised/umbrella organisation, which with oversight could distribute funds more equitably across the sector and could perhaps look to provide funding for fundamental operations and not just project-based grant-aid. This was formerly operated by the Historic Buildings Council, then by English Heritage from the 1980s, using a variety of schemes to suit individual buildings, historic groups or town-wide improvement schemes.

Work with LGPS / public sector pension fund investment managers to explore and prioritise investment in restoration and refurbishment for assets, especially compulsory purchase for resale back to the market.

Some local authorities own significant numbers of historic listed buildings but cannot afford repairs – B&NES Council being one of many. LGPS / pension fund investments could meet the costs of refurbishment to make them financially viable assets, providing a longer-term income to the local authority.

Revisit former models, including Regional Development Agencies which could acquire historic buildings. Development Corporations also played a significant role in the 1990s to invest in community assets. Benefits might not have been felt at the time, but they have done since – e.g. Bristol Development Corporation helped regenerate many communities by investing grants in public and private buildings and infrastructure in St Werburghs, St Pauls, Lockleaze etc. The impact raised local pride, built community and the intrinsic and financial value of those places and heritage buildings is still experienced today.

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

Much work has been done on this subject for instance.

https://historicengland.org.uk/research/heritage-counts/heritage-and-economy/place-development/ (Historic England: November 2023).

In addition, individual historic city studies have shown conclusively the link between successful local conservation and regeneration schemes and economic improvements, most notably through increased tourism and spending.

Through regeneration new community identities can be formed and/or bolstered.  Built heritage can be fundamental to this as it can provide tangible links with identity/a ‘sense of place’. 

Hastings is a good case study of a place which effectively changed its demographic make-up and opportunity by investment in neighbourhood improvement. 

https://publications.parliament.uk/pa/cm200809/cmselect/cmseast/516/516we05.htm

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

• Appropriate resources for owners/occupiers – advice, education and support. 
• Free Local Planning Authority (LPA) pre-application advice for retrofit schemes.
• Listed Building Consent Orders for energy efficiency work(s). 
• A mechanism to support assessing and quantifying the public benefit of works to improve energy efficiency.
• A programme of study for LPAs to prioritise the need for constructive responses to Listed Building applications for energy efficiency measures.
• Funding to support LPAs and non-profit bodies that provide advice on energy efficiency. 
• A specific grant scheme for the retrofit of historic buildings (typical pre-1919 construction?). 
• Ensure that contractors have the specialist knowledge/skills to propose and undertake appropriate work to historic buildings.
• Consider VAT rates for work to listed buildings.
• Significantly improve access to information. The planning system is full of very well designed and consented retrofit information, but many people don’t know how to access this resource.
• Mandate ‘safe’ interventions which have limited opportunities to introduce harm – vented secondary glazing for examples. Make them exempt from LBA

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

Lack of or variable funding, often higher costs for ‘traditional materials’, specialist trades and professionals, potentially more maintenance costs and higher energy bills. 

Funding often preventing use of appropriate professionals to advise on sensitive repairs, restoration or regeneration, resulting in sub-optimal solutions which weaken the character of the repaired structure.

The planning system, particularly listed building consent, can be viewed as an expensive, drawn-out bureaucratic process.  

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

Review/reduce VAT rates, which currently favour demolition and new building over repair.

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

• The formulation of a robust apprenticeship model for small businesses. 
• Incentives to learn and pursue careers in roles such as traditional crafts.
• The reintroduction of small direct-labour groups in key sectors (e.g HE and Cadw)
• Guarantee paid apprenticeships for all NLHF / public funded conservation projects

Bath Preservation Trust

We are happy to engage with further consultation about the value and positive conservation of historic listed buildings and the built environment.

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