We are extremely concerned that this change would have serious unintended consequences including the dilution of the special status of listed buildings and exacerbate the increasingly widespread under resourcing of skilled conservation officers in local planning authorities. We agree with our co-signatories that the merger of listed building consent with planning permission will diminish the architectural heritage of Wales and frustrate and impede the many people and organisations who care for it.
The text of the letter reads:
Wales has almost 30,000 listed buildings, ranging from castles to cottages to railway stations. All these are threatened by proposed changes to heritage protection. All are threatened by proposed changes to heritage protection. Under plans suggested by the Law Commission, listed building consent - which is required for demolition or alteration of listed buildings - would be abolished and merged with planning permission. The unintended consequence of this would be the dilution of the special status of listed buildings in the planning process and their potential future loss.
To have a single regime for the construction of an industrial shed and the demolition of a listed building would downgrade the importance of listed buildings. The change would also exacerbate the problem of the under-resourcing of conservation officers in planning authorities. We urge the Law Commission and the Welsh Assembly to reconsider these damaging proposals.
Henrietta Billings, Director, SAVE Britain's Heritage
Lucie Carayon, Director, Ancient Monuments Society
Dr Mike Heyworth, Director, Council for British Archaeology
Cyllene Griffiths, Director, Council for British Archaeology Wales on behalf of the Wales Heritage Group
David McKinstry, Secretary, The Georgian Group
Matthew Slocombe, Secretary, Society for the Protection of Ancient Buildings
Catherine Croft, Director, Twentieth Century Society
Christopher Costelloe, Director, The Victorian Society
John Darlington, Director, World Monuments Fund Britain
The consultation ends on 1 March 2018. We encourage you to read the Law Commission consultation in full (heritage matters are covered by chapter 13) and respond here.
The joint CBA and CIfA response was submitted to the Law Commission on 1 March and can be read in full below.