On 29 June, RTPI Scotland submitted a response to Historic Environment Scotland's consultation on updating the Historic Environment Policy for Scotland (HEPS).
About the RTPI
At the Royal Town Planning Institute (the RTPI), we champion the value of planning in building thriving places and communities. With over 27,000 members worldwide, we support planners at every stage of their career: raising professional standards, shaping planning policy, and proudly awarding chartered status, the highest professional accreditation in UK planning.
For over a century, we have empowered planners to deliver positive impact: creating healthy, inclusive, economically and environmentally sustainable places. As the voice of the profession, we advocate, support, and lead with purpose, professionalism, and passion.
Using HEPS
2. How frequently do you refer to the Historic Environment Policy for Scotland (HEPS) when making decisions related to the historic environment?
Never
3. How do you use HEPS?
The Royal Town Planning Institute is the member organisation for town planners in the UK and internationally. Whilst we do not specifically use HEPS to make decisions that will directly affect the historic environment, we support planners at every stage of their career by raising professional standards and shaping planning policy that has a wide range of built and natural environment implications. As a member organisation, we understand the importance of HEPS to support our members as they make decisions that will impact on the historic environment. As such, we have an interest in ensuring such guidance remains relevant, up to date, and accessible to support our members as they carry out their planning duties.
4. Are there any barriers that make HEPS difficult to use?
HEPS has been a useful guidance document that works well at a high level to assist our members who are required to make decisions that will impact on the historic environment.
However, upon our review of the guidance, it has come to our attention that there are aspects that are now out of date. In particular, ‘Sources of further information and guidance’ on page 18 should be updated to acknowledge the planning advice notes that have now been withdrawn by the Scottish Government – i.e. PAN 2/2011 and PAN 71. Although these practice advice notes are still available to view on the Scottish Government website, they no longer carry formal policy weight. If reference is to continue to be made to these, their change of status must be acknowledged within HEPS.
There also appear to be a number of broken links on page 18, including to the:
- Designations application form
- Historic Environment Circular 1: Process and Procedures
- Managing Change Use and Adaptation of Listed Buildings
We also note that the Canmore website has now been retired and redirects to trove.scot.
Whilst, broadly speaking, HEPS remains a relevant and useful guidance document, it is important that references to useful sources of information and guidance be kept up to date.
5. Can you provide an example of a recent decision where HEPS played a role?
No comment
6. Which policies in HEPS do you utilise most in your decision‑making?
No comment
7. Are there any additions needed to HEPS to support good decision-making for the historic environment?
Related to our response to question 4, it is important that any refresh to HEPS have regard to the latest guidance, strategies and policies.
We note that HEPS was published in 2019, prior to the publication of Scotland's Fourth National Planning Framework (NPF4) in 2023. We believe that HEPS should have regard to the policy objectives of NPF4, and that NPF4 should be cited as a source of further information on page 18 of HEPS – particularly Policy 7 (historic assets and places) of NPF4, the intent of which is to “protect and enhance historic environment assets and places, and to enable positive change as a catalyst for the regeneration of places”.
Understanding and Recognition of the Historic Environment
8. How clear is this section in explaining how to understand and apply policies and principles on understanding and recognition of the historic environment?
Moderately clear
9. Are there any improvements that could be made to the information presented to enable better decision making?
HEP1 provides clear advice as to how decisions affecting the historic environment should be informed by an understanding of its cultural significance, which can take many different forms, be subject to change over time and mean different things to different people. We broadly agree with the Policy and supporting core principles and how they are applied, as set out under HEP1.
Notwithstanding the above, this policy could be further strengthened by also including reference to environmental significance, as well as cultural significance, of historical assets and places – i.e. the significance of the historic environment to places as well as to people. Broadening the scope of this policy would result in closer alignment between HEPS and NPF4, which requires planning decision-making to give significant weight to the global climate and nature crises. Understanding what the historic environment currently contributes to the sustainability of a place, to our climate change objectives and to addressing the nature crises are equally as important as understanding the cultural significance of a place.
An understanding of the environmental significance of historic assets and places should, in our view, be included in the ‘Understanding and Recognition” policies and principles of HEPS, either within HEP 1 or by creating a new policy within this section.
Managing Change in the Historic Environment
10. How clear is this section in explaining how to understand and apply policies and principles on managing change in the historic environment?
Moderately clear
11. Are there any improvements that could be made to this information to enable better decision making?
Although we are broadly supportive of the HEPS policies under the ‘Managing Change’ section, we do believe there are opportunities to strengthen these policies. In particular, HEP4 states that “opportunities for enhancement should be identified where appropriate”. Seeking out opportunities for enhancement is critical to managing change of the historic environment in a way that has truly positive outcomes for current and future generations. As such, we believe ‘enhancement’ should be embedded across the other policies within this section of HEPS.
For example, in HEP2, we believe that the understanding, enjoyment and benefits of the historic environment should be enhanced, as well as secured, for present and future generations. Adding the word “enhanced” into HEP2 is a small change that has the potential to significantly broaden the meaning and impact of this policy in a way that takes a proactive and forward-looking approach to managing change within the historic environment.
Likewise, we believe that this could also be captured within HEP3, by requiring that plans, programmes, policies and strategies, and the allocation of resources be approached in a way that protects, promotes and enhances the historic environment. Including the word “enhances” acknowledges the first and second bullet points under the core principles of this section of HEPS, that “some change is inevitable” and “can be necessary for places to thrive”. Managing change is not about preventing change, but about ensuring that change has a positive impact on the historic environment for current and future generations. Whilst we acknowledge that preventing loss plays an important part (and is quite rightly captured in the policy), it is also about maximising opportunities for enhancement.
Further to the above, whilst minimising detrimental impact on the historic environment is important, we believe HEP3 should also include reference to positive enhancements that will further promote and reinforce the environmental and cultural significance of historic assets and places. This type of approach would ensure improved alignment with NPF4, Policy 7 of which represents a shift in policy away from simply preventing loss, to proactively enhancing and bringing about positive change to historic assets and places. This policy shift should be reflected not only within the headline policies, but also within the core principles and how they are applied, moving away from simply an ‘avoid’ and ‘minimise’ approach to change, to one that recognises the potential of change to positively enhance the historic environment for current and future generations.
In addition to the above, and as previously submitted in response to question 9, we believe the principles applied under this section should include an understanding of the environmental (as well as cultural) significance of a place or asset. This would also bring about closer alignment with NPF4, which requires planning decision-making to give significant weight to the global climate and nature crises.
Working Together
12. How clear is this section in explaining how to understand and apply policies and principles on working together in regards to the historic environment?
Moderately clear
13. Are there any improvements that could be made to this information to enable better decision making?
We agree that both HEP5 and HEP6 belong under the ‘working together’ section of HEPS. Whilst HEP6 focuses on understanding and balancing the differing (and often competing) objectives of people and communities, HEP5 is about understanding and balancing differing (and often competing) place objectives which are crucial to the delivery of sustainable places.
The balancing and working together of both people- and place-objectives is critical to ensure that people are “empowered to use their heritage to develop their communities and places in a sustainable way”. People and place objectives are, therefore, not mutually exclusive. However, the core principles and how to apply them components of this section of HEPS currently appear to say very little about balancing place-objectives, instead focusing more heavily on the interests and values of people. In our view, both need to be given equal weight within this section of HEPS to achieve truly sustainable development outcomes.
In the above regard, the publication of NPF4 in 2023, represented a policy shift away from traditional approaches to ‘sustainable development’, embracing a proactive approach that gives greater prominence to the climate and nature crises as policy foundations. In accordance with Policy 7 of NPF4, this includes the policy outcome that historic places and assets support “the transition to net zero” and “are resilient to current and future impacts of climate change”. This section of HEPS is currently silent on this important policy outcome and we believe that it should be more clearly reflected within the core principles and the way that they are applied to ensure greater alignment between the HEPS guidance and NPF4.
