House of Commons Select Committee on Culture Media and Sport Enquiry into

Protecting, Preserving and Making Accessible our Nation’s Heritage

Memorandum from the Association of Gardens Trusts and the Garden History Society and prepared specially for the Committee

A1. Introduction

A1.1 This memorandum is presented jointly by the two leading amenity groups for the historic designed landscape in England.

A1.2 The Association of Gardens Trusts was established as a charitable trust in 1993 and comprises 35 County Trusts in England, together with another 10 in Wales. We have over 7,500 members who actively support the care and conservation of our historic designed landscapes, parks and gardens for the enjoyment and education of all ages. The Objectives of the Charity are to promote Gardens Trusts, and through them, the interest, education, appreciation and involvement of the public in matters connected with the arts and sciences of parks and gardens; and to assist in the protection, conservation, restoration or creation of parks and gardens in the United Kingdom for the education and enjoyment of the public.

A1.3 The Garden History Society is the national amenity society for the study and protection of historic parks and gardens. It is a statutory consultee on planning applications affecting sites on the English Heritage Register of Parks and Gardens of special historic interest which includes a wide range of designed landscapes. PPG15 states that the Society ‘has more experience of dealing with planning applications affecting parks and gardens than any other body’ (para. A16). Established in 1965 it is a charitable trust and has a membership in the region of 2000.

A1.4 Both organisations pursue a range of activities connected with research, conservation and planning and the Association supports the member County Gardens Trusts working with schools.

Information has been appended.

B2. The environmental, historical and cultural significance of designed landscapes

B2.1 The following extracts demonstrate the great importance of Britain’s designed landscapes and their wide range of influence in the life of the nation.

B2.2 “England is particularly rich in the designed landscapes of parks and gardens, and the built and natural features they contain: the greatest of these are as important to national, and indeed international, culture as our greatest buildings.” (Planning Policy Guidance 15 para 6.2)

B2.3 “people prefer to live and work in environments that are rich and diverse, and that blend the modern and the historic.” (The Heritage Dynamo: how the voluntary sector drives regeneration, Heritage Link 2004, p1)

B2.4 “The historic environment plays a central part in ensuring that distinctive neighbourhoods are created … new neighbourhoods that become recognisably “somewhere” rather than “anywhere” … historic buildings and areas should be seen positively as assets …” (ODPM Select Committee Report 2004).

B2.5 The historic environment brings direct economic benefits in terms of tourism and regeneration. VisitBritain’s Survey of Visits to Visitor Attractions, shows over 10 million visits were made to gardens in 2002. This figure represents more than a quarter of all visits surveyed in 2002.

B2.6 Research commissioned in 2003 by English Heritage, Sport England and the Countryside Agency showed that 62% of all adults in England had visited a public park during the previous 12 months. There were an estimated 1.8 billion visits to public parks over this period, more than half of which were to urban parks.

B2.7 People care about the historic aspects of their local environment. Of those questioned in a poll in Bradford, in 2003, 53% named ‘caring for neglected and derelict buildings’ as the biggest issue facing their local area, closely followed by ‘too many boarded-up, unused buildings’ (52%) and ‘the condition of gardens and parks’ (40%).

B2.8 The above evidence indicates that historic parks and gardens are an important part of our historic environment, and make a significant contribution to the quality of life for countless numbers of people, however often they are poorly understood and appreciated by those who determine how they will survive in the future.

B2.9 The historic environment is under resourced, both nationally via English Heritage, and locally via local authorities and expert advisory amenity groups. There is a need for more money to fund this work and for training people to carry it out. Owners should be positively encouraged to care for their historic properties and important garden structures. Financial incentives could be very positive, for example the elimination of VAT on repairs.

1 What the Department for Culture, Media and Sport should identify as priorities in the forthcoming Heritage White Paper.

1.1 The Unified List: More significance has been ascribed to the concept of a unified list of nationally important historic assets than it deserves. Professionals and developers are accustomed to dealing with overlapping designations, including those beyond the heritage field, (e.g. Green Belt, AONB, flood plain, SSSI): a unified list would make no appreciable difference to the time needed to check planning constraints or obtain appropriate advice on them.

1.2 The proposed unified list seems unlikely to make for easier understanding, nor would it be easily established within available resources. 'Overlapping' designations are simply indicative that the site concerned is significant for more than one reason. A single listing would make no difference to the significance of a site or the number of reasons for its importance. Unless consolidating legislation affording uniform statutory protective designation for all components of it, a unified list would achieve nothing by way of clarification of the status of individual entries and their relative significance, especially as it seems that the statutory protection is not to be unified in its powers or effects.

1.3 Historic parks and gardens remain particularly poorly understood as elements of the historic environment. It is acknowledged that a significant number of nationally important sites have yet to be identified throughout England, let alone included, on the present Register, which at 1580 sites, may fall short by as much as 30 % of the entire nationally significant stock. Were registered historic parks and gardens to be subsumed within a single list entry there is a considerable risk that their significance would be overlooked still further. For example, if they sat alongside buildings, whose plight has a much higher profile within conservation and planning circles, parks and gardens as discrete entities may not receive the full attention they deserve in their own right. The c. 6000 locally important parks and gardens are in an even more perilous position, having hardly begun to be recognised as a constraint within the planning system at all. Although many local planning authorities have policies recognising them locally, few have given attention to their treatment as a planning constraint or allocated resources for their enhancement.

1.4 A single unified list could not provide a comprehensive definitive database: ongoing research and refinement of information in respect of sites and structures of interest would continually change it. Over time, changing perceptions may affect the cultural value ascribed to each component. Users are able to keep abreast of refinements to a particular data set more easily if the data sets continue to be held on separate lists. All the data sets are likely to be continually expanding. The various lists/registers/schedules would be more easily understood by users if:

· The criteria used by Inspectors to select sites and monuments for inclusion were to be explained more fully in a published handbook, although this is largely the case already for the Parks and Gardens Register.

· The setting of historic parks and gardens, together with important designed views, were to be mapped as is currently the case with the Welsh Parks and Gardens Register. At present they are described in the Register text, but a visual indication would assist accurate and easy identification within the planning system. A curtilage definition for historic parks and gardens, perhaps including vistas and setting beyond formally laid out parkland areas, might also be a useful tool.

· Resources were to be routinely available to review and update lists of protected sites and monuments: this particularly applies to scheduled sites and monuments of archaeological significance, a review of which has been promised for several decades without effect.

· English Heritage consultation procedures could be more strictly time-managed to guarantee a response within 14 days, and to guarantee that all the aspects of archaeological, historical and cultural interest within the consultation site are included in the advice given.

· English Heritage could produce an annual programme to indicate the particular priorities for review and amplification in the various lists/registers/schedules to be pursued during the forthcoming budgetary year.

· English Heritage could ensure that updates to the various lists/registers/schedules were efficiently and systematically notified to Government offices in the regions, local planning authorities and HER/SMRs. At present, communications addressed to Chief Executives commonly fail to reach planning officers responsible for conservation and the control of development, because non-planner administrators receiving them do not appreciate their significance. This is particularly so for the recently upgraded Parks and Gardens Register, which has not been published at all. Its upgraded entries are circulated to interested parties piecemeal, with all the attendant risk that they are lost in the administration very swiftly after receipt from English Heritage.

1.5 All these require of English Heritage more resources and more focussed administrative procedures. To devote resources and administrative effort to produce a single unified list would divert them from the more necessary tasks outlined, and would do little to improve the product.

1.6 Designation of historic parks and gardens at a national level is of the highest importance - both necessary and useful, given the absence of expertise in this area at local level which is likely to continue in the foreseeable future. An expert national overview is critical in identifying sites of national importance and in doing so also provides information about the context for sites of local interest. In addition registered sites and conservation areas do not necessarily overlap as area designations, if at all, but indicate quite separate considerations within the historic environment.

1.7 It would be useful in achieving consistency of designation and documentation if for all conservation area designations local planning authorities were to be required to seek endorsement from English Heritage, and for them to be required to submit supporting information and management proposals to satisfy a prescribed minimum format. Areas already designated should be subject to review and updating to such a prescribed standard over a phased period of time.

1.8 English Heritage has all the expertise and experience required to apply national designations within the historic environment objectively and accurately and carries this out with great rigour. Its main fault is that the process of designation is not transparent, and this not entirely its own fault as it has to advise the DCMS on listing and scheduling cases and on these does not have the final decision. The Parks and Gardens Register, while not entirely transparent in its decisions to designate is certainly much more transparent to public scrutiny in this area.

1.9 There should be no relegation of grade II registered parks and gardens to local lists. All the items on the Parks and Gardens Register are clearly stated by English Heritage to be of national importance, and this criterion has been carefully maintained by English Heritage in its selection of sites for inclusion since the Register was first begun in 1984. It has always been acknowledged inclusion on the Register is a very selective process, and represents only a very small proportion of historic parks and gardens. As far as grade II listed buildings are concerned some long-standing designations in this category may have been selected less rigorously than more recent entries, and could be reviewed in status. The question of the compilation of lists of locally-important parks and gardens is of course important itself.

1.10 Statements of significance would help to establish what features are of key significance for conservation. However, it would be difficult to produce exhaustive statements within the resources usually allocated for listing buildings, and given that Inspectors are not expected to carry out exhaustive internal assessments of buildings. As far as parks and gardens are concerned, there may be reluctance amongst owners to allow detailed descriptions of important features for security reasons, in that it is difficult and costly to provide high level surveillance for extensive open areas where there are rare and valuable plant collections, or garden ornaments such as statuary, fountains, etc, vulnerable to thieving. The present form of listing and Register descriptions appear to be adequate for basic planning purposes: where appropriate, more detailed research may be undertaken for appeal purposes, or preparatory to schemes of enhancement and used for conservation and management plans.

1.11 Management agreements should not replace statutory consents on major development and structural works. They do, however, have a useful role to play in supplementing such consents and ensuring that the historic significance of sites is fully understood at all phases of change. Such tools have since the 1980s been in use for the conservation of historic parks and gardens, for example in IHT Exemption cases and in informing Countryside Stewardship schemes, during which time a considerable body of experience has built up in terms of maximising their effectiveness. Ideally a conservation plan leading to an officially endorsed management agreement should be mandatory for all nationally important parks and gardens (i.e. those at present on the Register). However, this may be a very long term aim, partly because of cost implications for owners but also because of the cost of policing such schemes.

1.12 Management agreements between owners and English Heritage and local planning authorities would act as a framework for constructive and informed management, and to establish conservation and enhancement priorities. These should be subject to periodic review (say quinquennial) to allow for new research to be assimilated, refinements in management practices including technical advances, and updating. Agreements are particularly helpful in historic landscape management, where cultivation and management and renewal of planting can have a significant effect on the historic artefact. However, an agreement should continue to be endorsed by formal consent, albeit in streamlined form, so that there is still an opportunity for public representation.

1.13 The success of agreements as a management tool will depend on the willingness and ability to pay on the part of the owners for management plan preparation and the availability of resources for enforcement. There may be a case for increased public funding to support such initiatives, for example, extending the incentives available to farmers. Joint agreements could be a useful device to reconcile disparate concerns, but should continue to be subject to formal consent as above.

1.14 Local lists would be a useful protective tool, particularly as a basis for compiling them, and if demolition/ destruction of historic assets were to be subject to consent linked to development control and authorisation of replacement development. To be wholly effective local for parks and gardens, if English Heritage were to issue national criteria to be used lists should be given statutory recognition, as should nationally important parks and gardens.

1.15 Land Registry: Although the English Heritage Register of historic parks and gardens is statutory there is no legal protection for individual sites other than being material considerations in planning policy. The Association and The Garden History Society are concerned that often owners and prospective owners are not aware of the importance of sites and in our view it is essential that each Registered site is identified as a charge on the Land Registry. This would make a big difference for the future protection of a park or garden.

2. The remit and effectiveness of DCMS, English Heritage and other relevant organisations in representing heritage interests inside and outside Government

2.1 DCMS - Within the voluntary historic environment sector there is a concern and a perception that the DCMS seems to place more emphasis on the funding of sport. The Association of Gardens Trusts believes that historic parks and gardens are a valuable resource available to all that, besides aesthetic enrichment and enlightenment, encourages exercise, fresh-air, healthy living and the growing of food. The DCMS can promote these significant benefits.

2.2 English Heritage – English Heritage as the lead body for the conservation of England’s historic environment has been successful in engaging with other organisations via the regional Historic Environment Fora (HEF). The Association of Gardens Trusts is working in partnership with the University of York and with the co-operation of English Heritage, to develop the HLF-funded Parks and Gardens Data Partnership. This will provide an on-line information resource on the country’s historic parks and gardens, which will be available to all. The Association is pleased to work with English Heritage to promote research, conservation and planning advice, education and to raise awareness of our historic parks and gardens in both urban and rural locations. This year (2006) the Association, sponsored by English Heritage, is holding a conservation conference, ‘Conflict and Resolution: Education Establishments in Historic Parks and Gardens’ at Bath Spa University, a ‘Capability’ Brown landscape. One of our member trusts (Yorkshire) assisted English Heritage carry out the ‘Landscapes at Risk’ pilot project. Trustees from member County Gardens Trusts represent historic parks and gardens on the regional Historic Environment Fora.

2.3 Local Authorities – Within local authorities in England there are only 1.5 professional members of staff who are specifically dedicated to the conservation of historic parks and gardens (Hampshire CC and Surrey CC). In other local authorities, conservation staff often have sparse knowledge of historic parks and gardens in their area due to lack of training. There are currently no conservation officers in some Yorkshire local authorities, yet up to a third of planning applications have a conservation element and some authorities have seen an increase in numbers of planning applications affecting listed buildings and conservation areas (Heritage Counts Yorkshire 2005, p7).

2.4 There is concern about the effectiveness of local authorities and other organisations relative to historic parks and gardens. Losses of historic parkland have been calculated for the first time. Nearly half of the parkland recorded by the 1918 Ordnance Survey Edition was no longer extant at the close of the 20^th century and, in some places, losses have been as high as 70 per cent. The principal causes of loss have been conversion to arable land, development and, more recently golf course construction. (Heritage Counts 2005, p10, 37-40). In Yorkshire 63% of Registered Parks and Gardens fall into medium, high or very high vulnerability bands. South Yorkshire, with a high urban population, has the highest number of most vulnerable sites in the Yorkshire region. (Heritage Counts Yorkshire 2005, p6)

2.5 Cemeteries nationally are in a poor state. In a study of cemeteries at risk in Yorkshire carried out for Heritage Counts 2004 85 per cent of those studied showed signs of visible development beyond the boundaries of the cemeteries which had an impact on the overall character of the landscape. (Heritage Counts 2004, p13). Although 35 per cent of Yorkshire Registered cemeteries are in conservation areas, none of the Local Plans for the region at present highlight the conservation of cemeteries as valued historic environments. (Heritage Counts Yorkshire 2004, p9)

2.6 The development of the regional Historic Environment Fora has been very successful in bringing together all parts of the historic environment sector including voluntary organisations such as the Association of Gardens Trusts/County Gardens Trusts and The Garden History Society. This enables the sector to work together and eliminate the fragmentation, which has been a criticism of the past. Similarly the non-governmental historic environment network, ‘Heritage Link’, which promotes the central role of the voluntary movement in the sector has in the region of 80 member organisations ranging from large organisations like the National Trust to smaller bodies such as this Association and The garden History Society. It enables the sector to speak with a more collective and concerted voice, communicates information and promotes research.

3. The balance between heritage and development needs in planning policy

3.1 Within the present planning system the environmental value of historic parks and gardens is often overlooked or regarded as less important than buildings and archaeological monuments. The provision of adequate information and advice to local interests on the importance of historic parks and gardens, at present largely lacking, is essential to help guide local decision-making and planning, such that important elements of the historic environment are not accidentally lost, due to ignorance of their value. Planning guidance in the form of a statement of policy and principles, as in PPGs 15 & 16, is valuable as a reference point in the preparation of plans and proposals. For individual sites, conservation management and enhancement plans and agreements form very useful guidance in practical respects, provided that they are drawn up to professional standards and regularly reviewed, and supported by realistic budgetary allocations.

3.2 It is vital that change respects, embraces and enhances the historic environment but this depends on understanding and assessment. Historic parks and gardens remain particularly poorly understood as elements of the historic environment. It is acknowledged that a significant number of nationally important sites have yet to be identified throughout England, let alone included, on the present English Heritage Register of Historic Parks and Gardens, which at 1580 sites, may fall short by as much as 30 % of the entire nationally significant stock. The c. 6000 locally important parks and gardens are in an even more perilous position, having hardly begun to be recognised as a constraint within the planning system at all. Although many local planning authorities have policies recognising them locally, few have given attention to their treatment as a planning constraint or allocated resources for their enhancement. And there are local authorities, which have not even begun to make a local list because they do not have the resources to fund this work. The result is likely to be irreversible damage to the quality of the historic environment, particularly in regards to historic parks and gardens.

3.3 In a bid to raise awareness of our historic parks and gardens in the planning system County Gardens Trusts organise workshops for local authorities officers and elected members. These are supported by English Heritage (often as part of HELM) and The Garden History Society. Dorset and Northumbria Gardens Trusts are both holding workshops in the next few months.

3.4 Statistics from the annual survey of Visits to Visitor Attractions in Heritage Counts 2005 shows a 50 per cent increase in visits to gardens since 1989 (p66). In Yorkshire historic properties attract approximately one fifth of all tourist visits and visits to gardens, historic houses and urban visits have increased (Heritage Counts Yorkshire 2005, p12). In our view this type of information underpins the importance of finding the balance between heritage protection and development needs in planning policy.

4. Access to heritage and the position of heritage as a cultural asset in the community

4.1 Research by VisitBritain has shown that unspoilt countryside, interesting villages and market towns, castles, country houses and gardens are among the principal reasons why we chose to spend our holidays in England rather than abroad. (Heritage Counts 2005, p65). Visits to museums, art galleries, historic properties, gardens, heritage railways, places of worship and heritage centres accounted for over half of all visits to the Yorkshire region in 2004 (Visit Britain ‘Visitor Attraction Trends in England 2004’, August 2005).

4.2 In order to reach other communities and share cultural experiences, The Association of Gardens Trusts has become a member of Heritage Link’s social inclusion group. In Yorkshire the garden trust is working with Refugee Action and groups from other cultures to introduce families to the pleasures of visiting an historic park and garden. In 2005 a group of Iranians and Iraqis with the help of the National Trust shared a visit to Fountains Abbey and Studley Royal with members of the Trust and another such visit to a historic park and garden is planned for April 2006 working with a member of the Historic Houses Association.

4.3 County Gardens Trusts in many parts of the country are active in developing school grounds, promoting the benefits of gardens and running grant schemes which support the restoration and conservation of local parks and gardens. Trusts which have grant schemes include Cornwall, Devon, Northamptonshire, Surrey, Sussex, Yorkshire. In addition to working with schools the south western Trusts host an annual education conference. The Dorset and Derbyshire Gardens Trusts have schemes to help finance the studies of young people who want to enter horticultural work.

Can we put in more detail.

5. Funding, with particular reference to the adequacy of the budget for English Heritage and for museums and galleries, the impact of the London 2012 Olympics on Lottery funding for heritage projects, and forthcoming decisions on the sharing of funds from Lottery sources between good causes

5.1 English Heritage is one of very few agencies able to fund the repair and maintenance of privately owned historic buildings and landscapes, and the demand is high. In Yorkshire, 83 grade I or II* Buildings at Risk fall into this category (almost 70 per cent of the regional Register total). The annual regional grant available is miniscule by comparison. In practice there seems to be little available funding for historic parks and gardens outside the HLF public parks programme. The new Environmental Stewardship (ES) scheme should be very helpful but there needs to be improved provision of specialist advice to make the best use of the ES funds and to retain the historic design and integrity of a park for future generations. Any mistakes made now have the potential to remain for a very long time. Yorkshire’s Heritage Counts 2005 highlights an underprovision in the advice on cultural heritage available to landowners and managers compared to the provision of advice from the natural environment sector.

5.2 The Association of Gardens Trusts and The Garden History Society has already expressed concern about the cutting of grant to English Heritage announced in December 2004. This 6.6 per cent cut came on top of a £19 million decrease from the previous spending review. DCMS also informed English Heritage that it had to find at least £1million in the remaining three months of the financial year to April 2005 in order to “contribute to the reduction of council tax pressures in 2005/6”. In our view, as part of its re-organisation in order to ‘modernise’ and to try and balance this ever- decreasing budget in ‘real-terms’, we have an under-resourced historic designed landscapes team, and Register of Historic Parks and Gardens. In terms of historic parks and gardens it means that advice from English Heritage is extremely thinly spread. There are only five Regional Landscape Architects to cover the whole country - not helpful in the protection of sites under development pressure. There is little chance for new entries being added to the English Heritage Register, but more important than this, significant historic parks and gardens are being badly affected by poor development decisions.

5.3 The Association would like to support the cultural aims and objectives associated with the London 2012 Olympics. However there remains within the voluntary historic environment sector, a real concern that the 2012 Olympics will drain funds away from the historic environment and that as a result many of the places which we enjoy, will lose out. This could be critical at a time when there is pressure for increased development, particularly in the south east. With eyes and money diverted elsewhere we could lose or compromise historic sites whether it is an historic garden or remnants of medieval forest.

6. What the roles and responsibilities should be for English Heritage, HLF, local authorities, museums and galleries, charitable and other NGOs in maintaining the nation’s heritage

6.1 All these organisations are important and increasingly most are working together. County Gardens Trust’s/AGT work on a shoe-string relying on voluntary effort to research and record, give advice, educate and publicise historic parks and gardens and usually funding the work themselves. Many small voluntary organisations in the sector are similar. We depend for some financial help with administration on English Heritage ‘Capacity Building Grant’ and in working independently try to deliver our joint objectives relative to conservation, research, education etc. Regional Historic Environment Fora have successfully brought diverse organisations working in the historic environment together and enabled them to engage with other sectors such as culture, planning and the economy.

6.2 English Heritage is the main driver in sustaining the historic environment and pulling the diverse strands together. Heritage Lottery Fund does an excellent job in funding a wide variety of historic environment projects. Without these two organisations the voluntary sector (which also delivers so much) would not be able to function as effectively. The HLF delivers money to projects great and small when there are no other sources of funding. It has proved to be a life-saver for significant parts of the historic environment including public parks. It is vitally important to maintain and improve funding to English Heritage and the HLF.

6.3 The Countryside Agency National Heritage Unit has also proved to be very important for sustaining historic parks and gardens by means of the work which it does on Inheritance Tax Exemption for outstanding landscapes and the funding of Heritage Landscape Management Plans.

7. Whether there is adequate supply of professionals with conservation skills; the priority placed by planning authorities on conservation; and means of making conservation expertise more accessible to planning officers, councillors and the general public

7.1 Local authorities are essential to the protection and management of the historic environment. In 2003, local authorities spent nearly £50million on planning and other services connected with the conservation of the historic environment … study carried out by Oxford Brookes University which demonstrated that there was an average of 1.7 full-time equivalent conservation staff employed by each local authority in England, and that this number is falling …

7.2 English Heritage has brought in outside expertise to implement initiatives like the Landscapes at Risk survey; but this provides no long-term support or continuity for the management of the historic environment. Historic Environment Records facilities may have more staff than two years ago, but many are on short-term contracts.

7.3 Furthermore other activities to support the historic environment are patchy across local authorities. For example a number of authorities in Yorkshire have not researched and assessed their historic parks and gardens of local or regional significance and as a result do not have policies for their protection.

7.4 In addition to the shortage of traditional construction crafts practitioners, there is a growing skills shortage in horticulture and particularly those needed to maintain historic gardens. A new report out very shortly (2006) on mapping careers and skills needs of the botanic and historic gardens sector will say that 276m people visit 1,800 gardens, parks and properties every year and that these same sites attract 20 per cent of all overseas tourist visits.

Andrew Colquhoun, RHS Director General, “There’s a skills problem across the board, whether it’s finding someone to work in your back garden or to tend historic and botanical gardens. Borders and flower beds in our finest parks and gardens could be grassed over unless we encourage the next generation of gardeners and managers.”

7.5 Skill gaps Inevitably, every professional in this sector has skill gaps in matters beyond the scope of the discipline of the profession concerned. It would be difficult to extend the remit of every professional to full competence in every aspect of heritage conservation, but administrative procedures could be refined to ensure that when appropriate, expert advice would be sought and taken into account in decision making. However, there is undoubtedly a major skill gap in terms of the understanding of historic parks and gardens, both nationally within English Heritage, at regional level in Government Offices, and at local level in local planning authorities. As noted above at English Heritage there are only five Regional Landscape Architects to cover the whole country. In some Government Offices, decisions as to whether to call in cases referred to them are made by administrators who lack special expertise in the historic environment/designed landscapes. Within local authorities in England there are only 1.5 professional members of staff who are specifically dedicated to the conservation of historic parks and gardens. This gap in professional understanding and education means that this valuable element of the historic environment is undoubtedly suffering from unnecessarily greater destruction than other elements of the historic environment (confirmed by SHER 2002, p. 28, which states that a much higher proportion of planning applications are submitted for grade I and II* parks and gardens than for other national designations).

7.6 We recommend the following action to remedy the skills gap in terms of historic parks and gardens:

· Where those Government Offices which do not have historic parks and gardens experts have cases referred to them in this field, they should be required to consult with the English Heritage Regional Landscape Architect, and English Heritage should be required to provide a constructive response within a reasonable time frame.

· English Heritage resources are very limited in advising on casework on historic parks and gardens. This is a very significant skills gap, particularly where many interested parties who are entitled to benefit from the capacity of the Regional Landscape Architects do not receive adequate support because of the latters' overburdened workload. The Regional Landscape Architects' capacity should be targetted at planning casework as a priority, in this way using resources to address urgent threats via the planning system, and advise on the prevention of potentially irreversible damage.

· Extend English Heritage's statutory advice to local planning authorities should include grade II registered sites. As there are only ever likely to be a maximum of 2,500 park and garden sites on the Register, and in view of the serious lack of local expertise available, this would not be as onerous as, for example, advising on all Grade II buildings (of which there are over 300,000). At least three more Regional Landscape Architects are required to provide adequate coverage. We do not believe that it is as necessary for grade II buildings to be referred to English Heritage because local authority conservation officers have a great deal of buildings expertise already.

· English Heritage should provide sufficient resources to complete the Parks and Gardens Register as soon as possible, whether or not it becomes part of a greater listing device. As mentioned above, the Register is substantially incomplete and this represents a serious country-wide under-representation in the identification of nationally important sites, especially as local authorities are unable to identify nationally important sites themselves.

· English Heritage should publish the Parks and Gardens Register. The publication of the revised and completed Register should be a priority because this is the main tool used to inform local authorities of the importance of registered sites. It should be made available as a priority in hard copy as a printed and bound document which has a physical presence and standing in local authority offices. It should also be made available electronically on the Web.

· Every local authority must have at least one dedicated conservation officer. Conservation officers should be trained to have a broad understanding of the entire historic environment, as at present there is much ignorance about the context and value of historic parks and gardens. Local authorities should be required to buy in advice from competent professionals to supplement their conservation officers' experience on significant historic park and garden cases, particularly if English Heritage advice remains restricted to grade II* and I cases.

· English Heritage should increase its training sessions for conservation officers and other relevant local authority officers such as senior planners and local plan staff (in which some of English Heritage's own case-work staff beyond park and garden professionals should participate) to provide an overview of the importance of historic parks and gardens within the historic environment. This should be resourced to cope with training several hundred people within a short period - say 3 years. Thereafter, update sessions should be provided to take account of new legislation and case law, etc., and to train new staff.

· Provide further funding for the Garden History Society for its responsibilities as the statutory consultee in this area. The GHS provides excellent value for public money for the expertise which it brings to advising on planning applications for all registered sites at present, especially when it is realised that they have only 2000 members countrywide to support this work alongside the Government grant. However, its staff are seriously over-worked and under-resourced. There is a case to be made for providing generic advice to local authorities on particular issues as the GHS has done in its Planning Conservation Advice Notes which were published in 2005, instead of site by site comments. However, in view of the serious lack of expertise at local authority level, the expert advice which the GHS currently provides on a case-by-case basis is crucial in the local understanding of issues on individual sites. This is all the more important as English Heritage do not generally comment on applications relating to grade II sites (see above recommendation that English Heritage should advise on grade II registered sites). Generic advice notes, while laudable and very useful for owners and planners, must be supplemented with individual case-by-case advice. It is this bespoke information which is reported to local authority decision-making Committees. Advice notes will not have the same impact on individual cases. Where local authorities can be persuaded to consult with them, the GHS also comments on applications relating to unregistered sites (by definition of local rather than national importance), which is also an invaluable service and should be encouraged by central government financial contribution, thus widening further the understanding of this field.

January 2006