Written evidence submitted by Built Environment Forum Scotland
Built Environment Forum Scotland (BEFS) is an umbrella body for organisations working in the built environment in Scotland. Drawing on extensive expertise in a membership-led forum, BEFS informs, debates and advocates on the strategic issues, opportunities and challenges facing Scotland’s existing built environment.
Relevant consultation responses from BEFS can be seen below, as many issues overlap and demand associative consideration:
Circular Economy (Scotland) Bill – Call for views
Building Community Wealth in Scotland
Climate Change Targets Bill - consultation
Pre-Budget Scrutiny 2025-26: Funding for Culture - consultation
Wellbeing and Sustainable Development (Scotland) Bill
Town Centre Action Plan Review -Call for Evidence
Budget Scrutiny 2024-25: Funding for Culture
Delivering net zero for Scotland's buildings - Heat in Buildings Bill: consultation
BEFS notes that some of the issues and areas explored below are devolved but are included for context and to inform ‘the view from Scotland’.
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?
Recognition of the cross cutting value of investment in built heritage assets is a significant challenge.
As stated in Scotland’s strategy for the historic environment, Our Past, Our Future; ‘The historic environment creates significant economic benefits for Scotland. It creates good, green jobs across the country, and is a major reason that millions of visitors come to Scotland each year. It inspires blockbuster movies, video games, and internationally recognised food and drink products, and creates myriad opportunities for learning, socialising, and exercise. This activity supports thousands of businesses, as well as activities that have proven wellbeing benefits for participants. The historic environment can therefore be a key asset in helping us to build a wellbeing economy, and an economic system that operates within environmental limits, and that enables both current and future generations to live well.’ Historic buildings are not only visitor sites and portfolio assets but also centres for business and community wealth generation. The prevention of the decline for heritage assets should therefore be treated as an issue of Community Wealth Building and national economic health, rather than to be seen primarily as a question of tourism. Further, historic buildings are homes (including owner-occupied). BEFS reaffirms that working within and developing procurement practices to support local economies, including Small and Medium sized Enterprises (SMEs) and micro-businesses, and improved access to training and labour markets for disadvantaged communities and individuals is a crucial part of supporting the historic built environment.
Scottish existing built environment assets contains a huge amount of embodied energy and potential for positive interventions. In 2022, 49% of dwellings had some disrepair to critical elements, and 18% of all dwellings had an urgent disrepair to critical elements (SHCS 2022), and the cost of urgent repair is high. BEFS have consistently advocated for a culture shift where maintenance is considered a recurring necessary measure to avoid higher costs for the Scottish Government at later stages. We said in our response to Delivering Scotland’s circular economy: A Route Map to 2025 and beyond: ‘Adapting, repurposing, and reusing our current building stock presents an enormous opportunity to provide skilled employment, carbon solutions, and more homes. If fully recognised within measures towards a circular economy, the skilled work provided through these channels would be positive for national and local economic recoveries. The opportunity of retrofit would create labour-intensive, localised job creation. BEFS has frequently lobbied for skilled, green employment in relation to this work’
From BEFS Climate Change Targets Bill consultation response: ‘Until the need for buildings to be well maintained is addressed future governments will likely remain in a cycle of dealing with building neglect and decay that require carbon intensive interventions which would undermine the carbon targets set. We would highlight the National Planning Framework 4 (NPF4) position statement that raises the need for carbon assessments in planning decisions, and maintain that this should be embedded within the Climate Change Plan, but also that housing stock maintenance be taken into account concerning the allocation of carbon budget surplus. Effective maintenance may mean that deficits, too, can be planned and accounted for more efficiently’.
Historic Environment Scotland (HES) funding for the sector: HES sits within a wider portfolio facing at best economic stasis (and real-terms cuts), and at worst a raft of significant budget reductions. These cuts come in the context of the Government response to the Constitution, Europe, External Affairs and Culture Committee scrutiny. In the 2024-25 budget HES was allocated £74.2m, a £2.6m increase as the year before, however the increase from 2023-2024 was 3.8%, whereas the 2024-25 budget was 2%. This can be contrasted to the positively stark increase from the 2021-22 to the 2022-23 budgets, where there was a 25% (£14.2m) increase. The importance of examining the budget is not just to look at what is within the cultural portfolio - but to understand how our cultural heritage can be eroded through a lack of investment in data, in planning, and in regeneration; many of the aspects that help to support genuine place-based approaches.
Communities: The Scottish Government have a strong community empowerment agenda which has brought in a variety of new rights and responsibilities. In relation to SDG 11, one of the most central elements of this agenda is the Community Right to Buy. Funds have been made available to enable communities to buy land and certain assets, but it could be questioned whether the resources and skills necessary to run, maintain and sustain some of these endeavours have been as equally supported. Communities need to be genuinely empowered, not burdened by default.
In conjunction with the Scottish Land Commission, DTAS ran an award winning 2-year pilot programme to support communities take on vacant and derelict sites. The programme was successful at addressing smaller scale sites – often in built up areas/town centres; learning from this that could be developed upon to improve the approaches taken to address vacant and derelict sites – particularly those smaller sites that have a disproportionate impact on communities.
Of Compulsory Sale Orders in the Land and Assets pillar BEFS would reinforce the view of the Community Ownership Support Service that it is a ‘potentially powerful tool, particularly in urban Scotland to help address dereliction and unproductive land - land banking etc.’ https://www.gov.scot/publications/community-ownership-in-scotland-2023/
Planning and National Planning Framework 4 (NPF4): ‘Addressing the climate emergency and nature crisis requires us to ensure that existing assets are maintained and capitalised on, limiting adverse environmental impacts and waste. Land and buildings that are vacant and derelict can be a blight on communities and disincentivise investment. […] Community activity and ownership can also encourage and allow local people to participate in the care and maintenance of their local areas and buildings.’
Places of Worship: It was recently announced that the Listed of Places Worship Scheme has been renewed for one year with reduced budget and a cap of capital projects of £25K, until 2026. This will have an impact on current projects and creates uncertainly for pipeline projects; the scheme is treated as match funding by most funders, including HES and NLHF, and the balance of funding will now have to be found elsewhere at a time when the funding landscape is already challenging. Further we would consider the importance of funding as part of wider management plans within the current context of places of worship in transition – often coming out of worshipful use – and the need to address the pipeline of soon to be marketed buildings and associated grounds. We fully support HES view that ‘planning ahead for the future of these buildings is important to prevent these falling into disrepair, becoming dangerous and unattractive to any restoring purchasers or community groups that could potentially take these on in support of new uses.’ These are places which may be designated (for example as listed buildings or scheduled monuments) and may hold a significant place in the lives of communities, both of place, and of interest, as well as being a major part of the town/city/village-scape in which they are found. Positive outcomes for these will be - like all planning decisions - both specific to each case, and complex; careful and appropriate management can ensure good decisions further down the line.
2. How effective are the current funding and finance models for built heritage?
Not answered.
3. What role does built heritage play in the regeneration of local areas and in contributing to economic growth and community identity?
- How can heritage buildings be supported to increase energy efficiency and contribute to the Government’s net zero targets?
The historic and existing built environment can, and does, deliver across the policy spectrum. From health and wellbeing benefits to our existing built environment, our heritage assets (of all types and ages) can, and do, contribute positively towards net zero; as do traditional skills which not only enhance our places, but enable the provision of warm homes and long-term, skilled, employment opportunities; a focal point of regenerative strategies (particularly in relation to High Street decline, and Town Centre Regeneration) enabling a sense of place – whilst providing skilled employment, places designed to promote wellbeing, and adaptive buildings suited to new futures. The embodied energy present, and the potential for positive interventions is huge. Adapting, repurposing, and reusing our current building stock presents an enormous opportunity to provide skilled employment, carbon solutions, and more homes. These are solutions which provide benefits to economy, people and place.
In this, BEFs would cite the National Planning Framework 4 (NPF4), that ‘Scotland’s rich heritage, culture and outstanding environment are national assets which support our economy, identity, health and wellbeing’. NPF4 gives further clarity as to the cross-cutting nature (and importance) of how planning can support “Lifelong Health and Wellbeing” – the variety of factors listed within this description can usefully help to inform legislative definitions, ensuring place quality and green-blue environments, affecting population health, are taken into account.
4. What are the financial, regulatory and practical barriers to preserving built heritage?
- What policy changes are needed to make restoring historic buildings easier and less expensive?
The changes that many older buildings could undergo to form more sustainable assets, within more sustainable environments, is undoubtedly hampered by the current VAT rate on refurbishment and repair. The sector has long called for an enabling, through conservation and continued use, the full potential of Scotland’s built heritage asset by removing unequal application of taxation and VAT on restoration, maintenance and conservation works, whether through graduated relief or other fiscal incentives; incentivisation for use and reuse of traditional buildings through income tax powers, enabling through conservation and continued use the full potential of Scotland’s built heritage asset, and by removing unequal application of taxation and VAT on restoration, maintenance and conservation works, whether through graduated relief or other fiscal incentives. The current 0% on new build and 20% on refurbishment and repair does not help the re-use and adaptation of buildings which could become well-placed homes, workplaces, and service providers in often already connected places. BE-ST and Architecture & Design Scotland have also acknowledged this as a barrier.
Transfer to local communities does not deal with that fundamental problem: few have the resources to secure funding even where they are eligible, and in any even there is usually an element of risk which exceeds their capability. See recent report on VAT published by HES: https://www.historicenvironment.scot/archives-and-research/publications/publication/?publicationid=7f9dc403-5a5c-4375-be2d-b154009a625f
Maintenance and repair: BEFS would like to highlight the example of the recent work of the Scottish Law Commission around Owners’ Associations in Scotland. BEFS amplifies the view of BEFS members Under One Roof in that compulsory owners’ associations give ‘owners the tools to address not only repair and maintenance issues, but the need to retrofit tenement buildings over the next two decades’. BEFS stated in the consultation for the reform that ‘there may be an immediate increase in building works and positive impact on professions such as surveyors and the wider maintenance professions/trades. Increased demand will, it is hoped, lead to increased skills training provision […] in the long term, it is hoped that the proposed reform will result in a positive impact for home owners as well maintained tenements/flats may well command better prices as both maintenance and well managed’. Additionally, non-economic impacts include warmer homes and safer buildings. Ultimately, BEFS reaffirm that well-maintained places benefit people and communities, as well as raise awareness and move towards culture change towards maintenance and repair.
5. What policies would ensure the UK workforce has the right skills to maintain our heritage assets?
BEFS would highlight the need for the appropriate skills and training within planning teams to enable appropriate consideration of the needs of communities and an understanding of the value and contribution of historic and existing buildings as assets towards outcomes set within NPF4 and Scotland’s National Outcomes. Here BEFS would reiterate previous comments made by Historic Environment Scotland that ‘Good management of the historic environment and its component parts (including designated and undesignated heritage assets) is central to the delivery of economic, social, environmental and wellbeing outcomes, especially through place-based planning and action’.
Meaningful investment will involve a significant culture shift; requiring an investment in skills and a commitment to an aligned and holistic policy landscape, to enable smarter working, to avoid conflicting remits within planning authorities, and to ensure a streamlined approach, maximising expertise and capacity.
As an example, PAS 2035 recognises that pre 1919 buildings require particular expertise and recommends professionals with conservation accreditation in relation to the co-ordination and designer roles. The SQA level 3 course is based on 27 hours of learning time, installers will require practical courses dealing successfully with on-site challenges, rather than a class based course. Without the practical element, the course will be of limited value and will fail to deliver the step change in skills required to meet the retrofit targets and will result in countless failures that will require remedial work. Without integration of these shortages and skills gaps, and their considered assessment of future need – the outcome will be a disjointed and patchy skills pipeline that serves neither the jobs market, nor our built environment, whilst simultaneously failing to meet climate targets.
Delivering net zero for Scotland's buildings: Meaningful change will require Scotland’s home-owners, businesses, suppliers, and manufacturers possessing a clear understanding of who needs to do what, and by when. There needs to be an understanding of what heat systems will be recommended, what training needs to be in place, and what schemes will be available to help alleviate costs, or support training and further CPD. Consumer confidence needs to be built in the understanding of reliable systems, with the assurance that advice is accurate and impartial, and interventions will be well-suited to building type with skilled installation choices available. All need to understand that a fabric first incorporating a maintenance first approach will pay dividends, and help to support the transition to net zero. But it is not possible without a robust skills supply chain to maintain all of Scotland’s homes – from the traditionally built to the off-site modular, and everything in between.
BEFS responses to a number of Consultations in relation to the Built Environment can be found at: https://www.befs.org.uk/resources/consultations/
RESPONDENT INFORMATION
Name: Hazel Johnson, Director