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?

• What interventions are needed to prevent the managed decline of heritage assets on publicly owned land?
• What can the Government do to make it easier for communities or local businesses to take ownership of historic buildings?

The most significant challenges facing owners and operators of built heritage assets result from a combination of complex factors:

Financial constraints:

• High maintenance and repair costs, often with intangible economic return. More generally, it is often difficult to ‘monetise’ the value of heritage assets and their upkeep and reflect this in a business case.
• A lack of funding to inspect frequently enough and to act on recommendations in a timely manner, which leads to further deterioration and, consequently, increased repair costs.
• Inability to easily access grants, with Heritage Lottery Fund (HLF) bids being highly competitive, which leads to delays, and subsequently further deterioration and costs.
• Need for expert staff to support management and maintenance of these assets, as well as to oversee fundraising efforts to fund them given competing priorities for capital funding.

Regulatory constraints:

• A complex legislative landscape, with complex administrative processes, make it difficult for non-experts (and in some instances, experts) to interpret and navigate the regulatory environment. For example, legislation relating to sustainability and energy efficiency can clash with legislation relating to heritage buildings, while permissions and consents require an increasing amount of documentary evidence, information and consultation exercises, often from a wide range of expertise, which adds to the complexity of the processes.
• The complexity of achieving a satisfactory balance between meeting modern-day needs and retaining elements of historic and architectural value, while making any changes or alterations economically viable.
• A lack of clarity on when it is acceptable to enable change. When assessing a building’s significance, the complexity of deciding which areas are worth preserving, and where a greater degree of intervention is acceptable is challenging. Common examples include the replacement of windows, layout reconfigurations, and extensions. Applications are reviewed on a case-by-case basis, sometimes despite the existence of precedents for approval. Additionally, procedures used to streamline decisions by conservation officers in one local authority may not be acceptable in a different local authority area.
• The points above are true not only of works directly to historic buildings, but also of new developments within historic places or near historic buildings (i.e. that affect their ‘settings’ – see further commentary below under question (4).

Workforce / human resources:

• There is a limited workforce in the UK with the skills and experience to work on historic buildings.
• There are limited, and in some cases, no, in-house conservation officers in councils, where decisions in the planning processes are therefore outsourced to external parties.
• There is a lack of knowledge from building owners(and, in some cases, surveyors) who do not understand the importance of using contractors and advisers with the skills and experience to work on older buildings.

To prevent the managed decline of heritage assets on publicly owned land, it would be helpful to improve their financial sustainability, such as via access to direct funding or to a wider pool of grants, and to streamline the processes and timescales associated with the planning legislation. While Listed Building Consent is free, there can be substantial costs and time associated with preparing an application depending on the expertise and documents required. Where appropriate, the implementation of long-term maintenance and management agreements could avoid the need to apply for Listed Building Consent and provide clear guidance for future changes and repairs. Tax reliefs for conservation works could also help improve the financial sustainability of heritage assets.

It is also vital to implement measures which could boost the numbers and quality of the UK workforce working in historic assets. The promotion of specialised apprenticeships and training programmes in heritage-related crafts through, for example, grants or tax relief schemes for accredited companies would be one route, alongside campaigns to promote the heritage sector and heritage careers. Mandating the use of certified heritage professionals on appropriate projects, improving recruitment through industry partnerships with schools, establishing government-funded apprenticeships and reviewing the capacity and resourcing of the planning workforce would further help with recruitment and up-skilling in the heritage workforce.

It would also be helpful to increase public awareness of the cultural importance and wider economic benefits of historic buildings and sites to shift perceptions of historic buildings as being liabilities. An economic metric on the “value of the historic built environment” (i.e. £ value on the user experience and access to culture) would be a useful universal metric for building business cases.

2

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

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

Grants are often insufficient either in number and/or the amount of funding provided; they are highly competitive, and often require external expertise to support bids at an additional cost and time to councils, without guaranteed success.

There are several lottery funders, or distributors of the National Lottery Funding (NLF). They independently decide which projects are eligible for funding, as outlined in each of their specific organisational strategies and associated funding streams. Each distributor operates as a non-departmental public body, which is ‘arms-length’ to Government, and so subject to strict Government guidelines on the distribution of public money. There are also a large number of non-arms-length lotteries available for consumers in the UK, with the consequence that the level of funding available to National Lottery distributors is stagnating. This comes at a time when the demand for NLF has increased, due to increased needs of individuals and communities experiencing disadvantage, marginalisation, or inequality, alongside reductions in government spending and sustained, rather than increased, levels of personal giving or philanthropy to good causes. 

The National Lottery Heritage Fund (NLHF) is an exceptionally competitive fund; the City Corporation and other organisations therefore need to think and act strategically in terms of planned and live applications to the various NLF distributors to minimise the level of internal competition caused by multiple applications to the same NLF distributor across the same period.

Additionally, the programmatic and administrative requirements of grants are often significant, requiring additional time and expertise to deliver and sometimes making it unfeasible to apply for and deliver the grant.

This makes the management of the heritage portfolio incredibly challenging for an organisation with such an extensive and diverse portfolio as the City’s, making the progression of key heritage projects extremely difficult due to the challenges in securing the funding.

Long-term public funding for the sector could include direct grants or a wider pool of grants, the promotion of specialised apprenticeships and training programmes in heritage-related crafts through, for example, grants or tax relief schemes for accredited companies and recruitment campaigns to promote heritage and heritage careers

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 hugely important in defining the identity of a place and investment in heritage is an investment in people and civic pride. London’s visual identity is derived in great part from the historic buildings and places of which it very largely consists; the Houses of Parliament, Westminster Abbey, St Paul’s Cathedral, and the Tower of London are long-standing and highly popular tourist attractions, instantly recognisable and internationally iconic, generating enormous footfall and spend every year. But it’s not just these internationally famous assets – there are many examples of heritage-led regeneration projects. Subject to parliamentary approval being granted to the removal of market rights from the site, the regeneration of the Grade II* Smithfield East & West Market Buildings and grade II Rotunda is expected to attract over 1 million visitors annually and create c.600 direct jobs. In addition, it will deliver considerable local impacts in term of access to culture enhanced well-being.  

Built heritage plays a very important economic role through tourism, both domestic and international and this is at the heart of the City Corporation’s strategic cultural objective, ‘Destination City, which aims to drive visitor footfall and spend into the Square Mile. St Paul’s, the City Churches, Bevis Marks Synagogue, the Livery Halls, the Roman and medieval remains – the City is fortunate to possess an outstanding and unique collection of heritage assets which, together, tell its two-millennia story as an international finance centre. Increasing physical and intellectual access to and celebrating these heritage assets lie at the heart of the emerging City Plan 2040 and the Destination City agenda.

The coexistence of and interrelationship between the historic City and the modern, dynamic Square Mile is what makes the City of London unique. It’s critical that one doesn’t inhibit the other, that celebration of our built heritage doesn’t come at the cost of economic growth, and that it is more widely recognised that the heritage of a place can coexist with and even be reinforced by growth. This is an important issue for the City and for other historic places which need to achieve growth.

An obstacle to this is the concept of ‘setting’ in planning legislation and policy, or ‘the surroundings in which a heritage asset is experienced’. As this implies, setting is an intangible, ever-changing and difficult to define concept. Matters of setting are often highly subjective as a result. Yet, while setting is, of course, important, changes to setting typically do not have the same potential impact as direct impacts to the fabric of an asset. Nevertheless, setting and direct impacts are equated in planning policy, and many in the sector consider such visual changes to be harmful and object to proposals on this basis. The result is often a drag on the ability to deliver growth in locations with heritage assets.

This is a particularly important issue for the City Corporation. Our emerging City Plan 2040 and its underlying evidence base identifies a need to deliver an additional, minimum 1.2m square metres of additional office floorspace if the City of London is to remain globally competitive as an international financial centre. Proposals for the City’s tall building Cluster have been shaped to accommodate this need while respecting the settings of key heritage assets and creating reasonable limits for  growth.

While the City Corporation seeks to deliver new employment floorspace in the City, some developments, particularly taller building proposals in the City, have been subject to significant opposition because of perceived setting impacts.

The City Corporation acknowledges that there are some instances where such visual change could be harmful. However, oversensitivity to setting impacts has created a perception that, in historic places like the City, growth and conservation are incompatible. The City Corporation strongly considers that this perception has to be overcome in order for historic places to meaningfully develop and grow. As such, the City Corporation would like to see a refocusing of the l concept of ‘setting’.  This would involve a realignment of policy and practice, in the planning and heritage sectors, so that growth and conservation are properly seen as interrelated forces.

We greatly value the heritage of the Square Mile and London more widely. However, the approach to setting in the National Planning Policy Framework (NPPF) risks entrenching the perception problems discussed above, stagnating growth and setting cities in aspic. Cities – particularly those with the most dynamic growth potential, including the Square Mile – need to be able to grow and change, conserving and celebrating their heritage while also welcoming new, sustainable development.

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

Mitigating climate change and conserving historic buildings can be compatible goals. However, achieving these goals can be challenging, particularly for local planning authorities when determining applications for planning permission and/or listed building consent.

There are many interacting factors involved and there is no one-size-fits-all solution to making a building energy efficient. Historic England’s advice is to use a holistic approach which is developed based on an understanding of each building in its context and seeks to save energy, sustain the heritage significance and maintain a healthy indoor environment. The approach is known as the 'whole building approach' and anyone can use it. However, this can be technically very complex, often expensive, with outcomes that are not always successful, nor proposals that are always financially viable.

There is useful material on the Historic England website on how to increase energy efficiency. It would be beneficial to ensure this information is widely spread not only to public organisations but individuals. Additionally, the availability of advice within conservation officers’ teams - ideally free of charge for individuals, and at reduced fee for big organisations - as well as any form of tax relief would be welcome incentives to effectively promote and implement energy efficiency in historic buildings.

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?

Broadly speaking, trying to achieve compliance with all relevant areas of legal control in the conservation of public and private buildings of national interest is a very complex and challenging task, and very often, the result is the “clashing of worlds”, with applicants/owners of historic assets in the UK facing highly bureaucratic processes, difficult for non-experts (and in some instances, experts) to interpret and navigate.

Since the start of the identification and protection of the national collection of buildings at the beginning of the twentieth century, efforts have been made to make the process of plan-making and decision-taking less complex. Successive alterations and improvements in the legislation and guidance reflect the desire to create the best and most accurate methodologies - clearly demonstrable with the initiative to create this inquiry. All these improvements in guidance are great efforts that help to focus attention on what really matters, which is crucial as the financial and practical pressures on heritage assets are ever increasing.

Policy changes to make restoring historic buildings easier and less expensive could include simplifying processes, making them more accessible to non-experts; for local authorities to consider more often the implementation of long-term maintenance and management agreements (particular with owners of big portfolios), which would avoid the need to apply for Listed Building Consent; and centralised support with increased funding to be available to heritage officers to provide more support to owners.

On the question of the setting of heritage assets, the NPPF effectively treats the setting of heritage assets as being on a par with that of the assets themselves. A change to the NPPF could be made that explicitly removes consideration of setting from paragraph 215 of the NPPF, with a new paragraph that sets out that matters of setting should be treated as a matter of ‘balanced judgement’, in the same way that paragraph 216 sets out the approach to considering applications that could affect the significance of non-designated heritage assets. This would remove the requirement for public benefits to outweigh harm in matters of setting, better reflecting the likely impacts of changes to setting and – crucially – helping to ensure our cities can continue to grow and change while we celebrate and conserve our heritage assets.

Further to this, Historic England’s current guidance on setting is more complex than necessary and encourages a cautionary approach to development within the setting of heritage assets. If it were reframed to take a more proportionate approach to setting, it would allow growth and conservation to be seen as interrelated forces and not mutually exclusive, and help historic places to unleash their full potential.

The City Corporation would be pleased to liaise further on these suggestions and to support future work to develop them.

5

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

The heritage sector in the UK benefits from the varied and profound expertise of many organisations and individuals. These include, for instance, the owners of heritage assets, the commercial specialists in private practice, the researchers and educators in higher education, the officers in local and national government, and volunteers in the third sector, as well as heritage skilled suppliers, with its specialist contractors and consultants, and organisations like the City Livery Companies, which advocate for vocational training through the Livery Companies Skills Council.

However, there are currently significant limitations in the UK workforce with skills and experience to work on older buildings. The risk of knowledge and expertise being held by too few is further compounded as individuals leave organisations. Broadening an understanding of conservation within the organisations with big heritage portfolios would mitigate this risk.

Additional policies that would ensure the UK workforce has the right skills to maintain heritage assets could include:

• Mandating the use of certified heritage professionals on relevant projects.
• Improving recruitment by partnering with schools and community organisations to attract young people and providing specialised apprenticeships and training programmes in heritage-related crafts.
• Fully funded governmental apprenticeships
• A review of planning teams across the country to ensure they are sufficiently sourced with skilled staff would also be beneficial.

In recent years the Government has awarded funding to Councils and third-party trainers, via MHCLG and the Planning Advisory Service (PAS), in order that vital training can be provided to people managing our built environment. With diminishing internal capacity and capability, this vital funding was key to ensure the preservation of many assets across the UK. This funding is essential to ensure this vital training continues via independent, often not for profit organisations, such as Urban Design Learning: Home - Urban Design Learning.

Memorandum from the City of London Corporation

Submitted by the Office of the City Remembrancer