National Heritage Protection Plan review (2014)

The first (2010-15) National Heritage Protection Plan (NHPP) was an English Heritage Plan much criticised by the CLA and others for focusing almost entirely on research and on new heritage designation, and largely ignoring the other 90 per cent of heritage protection, especially the great and growing problems in the heritage consent system, which greatly threaten heritage (and cause major problems for CLA members).  This review is at least beginning to ask the key questions.  The CLA response stresses the importance of broadening the scope of the NHPP to identify all the real threats, and of devising and implementing effective solutions.  It also stresses the importance of English Heritage/Historic England becoming willing to work closely with its key stakeholders to achieve this.

The CLA heritage adviser sits on the NHPP's external Advisory Board

Review of progress towards the 2020 energy efficiency objective and a 2030 energy efficiency policy framework

This consultation response answers EU questions regarding the implementation of a revised Energy Efficiency Directive which envisages more stringent rules for buildings.  It follows the Commission's Climate and Energy proposal for an absolute target for energy savings in buildings, which has no discernible distinction between public and private buildings.  Although the UK is known to be ahead of many EU countries in the setting draft Minimum Energy Performance (MEP) regulations and mechanisms for the implementation of standards (Green Deal and ECO funding, mandatory fines and bans on the letting of sub-standard stock); the CLA uses this consultation response to identify flaws in the current UK MEP program as articulated in the CLA Housing Policy: Tackling the Housing Crisis in England.

The CLA response to this consultation also paves the way for an EU funding bid designed, over a two year period, to illustrate the flaws and provide solutions to current MEP proposals.

Cornwall Local Plan Consultation

This Local Plan consultation response seeks to ensure that Planning Practice Guidance issued March 6th 2014 is used by the LPA to correctly identify housing need and allocate sites accordingly.  Elements of this response, particularly regarding five year supply and points 2a-2d, can be used as a model to respond to other Local Plan consultations.

Wales: Proposed amendments to the Ancient Monument and Archaeological Areas Act (2014)

It is currently very difficult to prosecute even the most damaging offences against scheduled monument in Wales, and the Wales Assembly Government, as part of the ongoing Heritage Protection Review in Wales, is proposing minor amendments to the relevant statute to make prosecution easier.  This CLA response generally sees the proposals as proportionate but stresses the need for effective guidance.  It points out the importance of dealing effectively with offences against scheduled monuments perpetrated by trespassers on members' land, and the need for some form of heritage crime initiative to deal with this problem.

Review of Property Conditions in the Private Rented Sector including the control of Legionella Bacteria in Water Systems

This consultation response highlights the effectiveness of Selective Licensing when compared to blanket Mandatory Landlord Registration.  The CLA response rejects restrictions on the use of section 21 notices and outlines the subjective nature of the Housing Health and Safety Ratings System.  DCLG is made aware of the recent ECO Amendment Order which will allow for vacancy in rented properties whilst deep renovation work is being carried out and the link is made with the Council Tax (Exempt Dwellings) (England) (Amendment) Order 2012 - where vacancy for the purposes of repair work, is actively discouraged.

Finally, DCLG is made aware that guidance regarding Legionella and the need to undertake assessments, is insufficient for the domestic private rented sector.

English Heritage New Model (2014)

This DCMS public consultation sets out proposals to split English Heritage into two from April 2015.  This will create firstly a new charity (to be called English Heritage) to look after the 420 sites like Stonehenge, and secondly a new body (to be called Historic England) which will take over English Heritage's role in the Planning system and in advising government on heritage.

Enterprise and Regulatory Reform Act 2013 Secondary Legislation to accompany the Heritage Provisions (2013)

The heritage section of the Enterprise & Regulatory Reform Act 2013 makes a number of minor changes to the listed building consent system, including for example the creation of statutory heritage partnership agreements and certificates of lawful works to listed buildings.

 

CLA69 - Saving VAT on work to heritage and other existing buildings

There is a widespread concern that VAT at 20 percent is forcing owners of heritage to cancel or cut back work, both repair work and alteration vital to the long-term health of heritage buildings. This handbook points out the many ways in which VAT can be saved, in the hope that this will enable owners to continue to modernise and repair their heritage and other existing buildings.

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