E-mail: agt@gardens-trusts.org.uk Web site: www.gardenstrusts.org.uk

Sally Embree

Conservation Department

English Heritage

1 Waterhouse Square

138-142 Holborn

London EC1N 2ST 9^th May 2007

Dear Ms Embree

Conservation Principles Policies and Guidance for the Sustainable Management of the Historic Environme - Second Stage Consultation

Thank you for consulting the Association of Gardens Trusts and for the invitation to the seminars that we attended in York and London.

As we noted in our comments to the first stage consultation, the Association agrees that guidance on conserving our historic environment is urgently needed and particularly promoting this to government and decision-makers and underlining the valuable contribution that the historic environment makes to enriching quality of life, sustaining tourism and economic success.

The language of the document appears to be easily accessible to our members and we understand that its use is for professionals and internally at English Heritage, however we have noticed that those who are not so familiar with the historic environment and conservation have had more difficulty. [eg Point 9 on page 29] This may present problems for councillors and others at local level.

As I’m sure you will agree, it is very important that this document is understandable to those involved in determining planning applications. Perhaps a shorter more accessible version to accompany this detailed document would be helpful.

We think that to prevent confusion there need to be greater definition of terms. For example ‘renew’ is not defined.

The following are our comments to your specific questions:

Q1 An important issue here is funding, and this can be a problem whether a private or public owner. There are also currently newer owners of historic property and landscapes with a lot of money to spend. Some changes can be justified – and can be exciting and our future heritage - but it is very important that established heritage values are not compromised. As noted in our comment above, maintenance is an important aspect of both established places and future schemes.

Q2 The diagram on p24 is misleading. There is no weight attached to any particular segment, although the differences in volume within the circle make it appear that there is. Values overlap; this is not apparent.

The Evidential Value has not brought out that the local may not be as important as the national/international and of course the reverse.

The Historical Value, para 11, should include that ‘many’ examples of a particular designed feature can show social and political trends to feed into understanding.

In Aesthetic Value it is not clearly expressed how the weight of different values and the identifying and ‘worth’ of emerging values can be resolved.

In Communal Value it is not clear how a national, regional, county or local value can be ‘weighted’ given that a battlefield for example, may have a great international importance but much less local importance.

Q3 Under para 34 there should be a mention of archives. Under para 47 we would like to point out that the visual envelope for a designed landscape can be extensive and requires research and understanding of the design intentions. Paras 53 and 54: A balanced view needs to be encouraged not a partial view, hence those with a wide range of knowledge and expertise should be important contributors to any assessment.

Q4 Not sure about this question. In gardens and landscape the definition of conservation tends to include the word ‘enhance’ but based on research and understanding and assessment. Living organisms have a finite life-span and for example re-planting will at some stage be necessary, so there is an opportunity to enhance an historic landscape where planting has been lost.

Q5 We agree that the continuation or reinstatement of appropriate routine management and maintenance is the foundation of conservation. As time progresses advantage should be taken of informed improved management regimes. Our experience is that local planning authorities are often powerless to enforce routine maintenance on private property or indeed maintain their own properties.

Q6 Places are a palimpsest so we consider that ‘original’ should be removed in para 71. Renewal occurs after the cycle of restoration has fallen into disuse and can be for technical as well as aesthetic reasons, where for example, Victorian changes have led to the exposure of fabric to weathering. There needs to be a precise definition for renewal and repair – renewal does not appear in the glossary.

Q7 We agree, however we consider that the word ‘met’ should be replaced by the word ‘satisfied’ in para74.

Q8 We agree, however intervention to increase knowledge is important and we consider that ‘funding’ would be very helpful. Funding would similarly be very helpful in other areas apart from research excavations.

Q9 We agree that restoration should be acceptable if the criteria set out in para 95 are ‘met’ with the addition of replacing the word ‘met’ with ‘satisfied’ and that future maintenance costs are considered. The latter is particularly pertinent for garden and designed landscape restoration. In para 87/88 we suggest that for example where there is compelling evidence for an early lost garden then re-creation may be valid. The term ’representation’ or ‘historically-based new design’ could be used for recreations not on original sites.

Q10 We agree with the terms for new work and alteration and particularly bullet points three to five. However we consider that the example in para 98 is perhaps not sufficiently sensitive. In addition, using the word craftsmanship, within the explanation for this section might be useful – para101.

Q11 The section on reconciling conservation with other public interests makes us very uneasy; the emphasis is the wrong way round. Other public interests should be reconciled with conservation. We are unhappy about the breadth of the statement and the opportunity to cause unacceptable damage to historic sites. In our opinion local designations also need to be stressed in para 106.

Q12 We agree. Enabling development should not set a precedent but be site specific.

Q13 Not aware of any.

Q14 In our view the final version of Principles, Policies and Guidance should be written and laid out to be as easy to follow as possible and without illustrated examples. We understand that there is more detailed guidance for historic parks and gardens and this could benefit from illustrated examples and case studies.

We are not clear about the relationship of this document and the new legislation for Heritage Protection. Similarly we assume that climate change issues will need to be included. Para 64-66 needs to feed through to the wider sustainability debate for example the issue of UPVc windows and doors in historic buildings/conservation areas; the cost of embedded energy; the cost of demolition, and so on.

Finally we would like to underline the importance of funding for the successful implementation of Principles, Policies and Guidance. This funding needs to be directed to expertise at English Heritage and training in the local planning authorities and with local councillors. There are still too many local authorities without conservation expertise and this is to be deplored. We would support English Heritage in its efforts to secure further government funding for this work.

Yours sincerely

Val Hepworth

Mrs Val Hepworth

Chairman