HISTORIC SCOTLAND GUIDANCE NOTES - MANAGING CHANGE IN THE HISTORIC ENVIRONMENT

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1 Department of Corporate Support Planning & Economic Development Division Head of Planning & Economic Development: If phoning or calling please ask for: Alison Donald (01563) Ref: BE1 (AD/) A Neish Dip TP.MRTPI East Ayrshire COUNCIL Date: 3 December 2009 Gordon Mackie Historic Scotland Longmore House (E8) Salisbury Place EDINBURGH EH91SH Dear Gordon HISTORIC SCOTLAND GUIDANCE NOTES - MANAGING CHANGE IN THE HISTORIC ENVIRONMENT Thank you for consulting with East Ayrshire Council on the above consultation. In general terms, East Ayrshire Council is supportive of the new approach to the guidance, in respect of (i) the move away from having one comprehensive guidance document to having a series of topic specific guidance notes; (ii) the more accessible and user-friendly nature of the notes; and (iii) the positive tone of the guidance notes. With regards to the specific questions posed by Historic Scotland, I am attaching a note outlining East Ayrshire Council's detailed comments and suggestions. I trust you will find this useful in finalising the guidance notes. Should you require any further information, please do not hesitate to contact Alison Donald at the number shown above. Yours sincerely (~~ Development Planning and Regeneration Manager 6 Ci-cC)fC"rsmr FT KILMARNOCK KA11JB TEL FAX

2 East Ayrshire response to consultation questions Backqround 1. In what capacity are you involved. or have previously been involved with seekinq advice on the Historic Built Environment? Local Authority Content of Guidance Notes 2. Do you think the quidance notes present Scottish Minister's advice on the Historic Environment in a clear and consistent manner? East Ayrshire Council is, in general terms, supportive of the content and style of the new guidance notes. It is considered that the notes are written in an appropriate level of detail to make them accessible and straightforward to developers and members of the public. It is also noted that the general tone of the guidance notes is. positive rather than restrictive and that the guidance notes give flexibility in order that appropriate approaches can be tailored to the requirements of specific buildings or sites. In terms of the content of the specific guidance notes, East Ayrshire Council would make the following comments: Accessibility The document is considered to be clear and concise, providing practical and helpful suggestion to owners of historic buildings and sites. It is suggested that an additional paragraph on the principles of inclusive design would be helpful in making readers aware that by adopting an inclusive approach they will be making their buildings more accessible to the majority of visitors irrespective of their age,' ability or gender. With regards to the ke~1issues (Page 2), in reference to point 3 it may be worthwhile to include co:ntact details for the Scottish Disability Equality Forum, the umbrella organisation for all Access Panels in Scotland ( As an addition to point 5, it may be worth noting that some local authorities have an Access Officer, who may be able to support an Access Panel and be able to provide additional/specific information on providing an inclusive erlvironment. On page 4 it is suggested that reference should be changed from 'local accessibility groups' to 'local access panels'. As shown on page 7, it is suggested that references to 'chair lifts' should be replaced with 'stair lifts'. On page 9 the reference to the need for design and access statements in support of listed building applications is particularly supported.

3 Boundaries East Ayrshire Council welcomes the principle of this guidance note, but has Demolition The demolition guidance note provides useful information and criteria against which applications for demolition can be assessed. The guidance in relation to the economic viability test is considered especially useful and provides the Council with a greater clarification in terms of what should be sought from applicants. Doorways The guidance on doorways is considered to be relatively comprehensive and offers clear advice. The Council would, however, raise one area of concern, in that the document is not altogether clear with regards to when there is a change in function of a door. i.e. it is not used the same way now as it was when the building was constructed. In this kind of situation, there needs to be a balance between ensuring any alterations respect the character of the building, whilst at the same time allowing the building to function for its modern use. Extensions The extensions note is' considered to represent a very flexible approach to extensions to historic buildings, with the options outlined in the contextual deign section indicating, that depending on the characteristics of the particular property, potentially a wide variety of extension types could be taken forward. It is however considered, that although this flexible approach is appreciated, perhaps greater guidance is needed with regards to the circumstances in which the different types of extension would be appropriate. In contrast to the previous point, the 'Extensions to Ground Plan' section is considered to offer some quite specific guidance to applicants and planners with regards to limitations on extensions. There is therefore some concern that this section, in some ways contradicts the support for the 'assertive contrast' type of extension. Fixtures East Ayrshire Council ~elcomes the principle of this guidance note, but has Interiors East Ayrshire Council welcomes the principle of this guidance note, but has

4 Micro-renewables East Ayrshire Council acknowledges the importance of this guidance, giving the increasing need to be able to integrate historic buildings and modern renewable energy technologies. It is considered that this note will need to be kept under review, in order to keep the guidance up-to-date with advances in technology. Setting The principle of this guidance note is considered to be well founded, in order to ensure greater account is taken of the setting of a listed building in decision making. It is however, unclear, as to how this guidance should be used. i.e. is it guidance that applicants should work through when submitting an application that my impact on the setting of a historic Structure or is it something that Local Authorities should be taking a lead on, by for example, including appropriate pr9visions in the development plan. Clarification on the purpose of the guidance would be useful in the 'Key issues' section. Shopfronts and signage East Ayrshire Council welcomes the principle of this guidance note, however, it is concerned that there is a lack of detail within the guidance to make it as useful as it potentially could be. Whilst it is acknowledged, that the appropriateness of certain shopfronts is very much dependent on local characteristics, it is considered that some more detail in relation to key points to address when proposing or assessing a shopfront design would be worthwhile. ' It is noted that whilst the guidance note is entitled 'Shopfronts and signs', there is very little guidc~nce on the signage element. Again, more detailed guidance specifically relating to signage would be appreciated. As part of this, it is suggested that the note should include reference to deemed advertisement consent and the potential for the local authorities to remove this right, should it be considered that greater control over advertisements and signage would significantly enhance a particular area. In terms of the security section, it is considered that greater guidance could be given as to the forms of security that should and should not be encouraged. Structures East Ayrshire Council welcomes the principle of this guidance note, but has Roofs East Ayrshire Council supports both the principle of this publication and the content and level of detail within it. The section on slate is considered particularly worthwhile and helpful.

5 It is, however, noted that there is no reference in the guidance note to chimneys. It is considered that this is a significant omission, given that chimneys can greatly add to the character of a building and therefore need to be appropriately protected and maintained. External walls East Ayrshire Council welcomes the principle and content of this publication. The only detailed comment that the Council would offer is that some additional detail could be added to the section on harling in terms of its value and importance, as well as maintenance and repair issues. Windows East Ayrshire Council supports the windows guidance note and considers it to offer good general guidance. Whilst the document does not go into real detail, it is recognised t~at this is necessary in order to make it accessible to non-professionals. HOVl.:ever,it is considered that reference should be made in the document to the Historic Scotland publication 'Guide for Practitioners 6: Conversion of traditional buildings', which contains excellent detailed information on dealing with windows in historic buildings. In terms of the specific content, it is noted that there is a slight discrepancy within the guidance note with regards to double glazing. Whilst the section on 'Replacement' on page 6 indicates that 'new elements should match the original in all respects',the section on Double glazing on page 8 states that 'new windows will match the originals as closely as possible.' This issue should be clarified. It is further noted that key issue number 6 states that 'double glazing is acceptable where the existing windows are beyond repair and the new windows will match the, original joinery.' It is considered that this statement could prove misleading.as it suggests double glazing would be acceptable in every circumstance, incruding for instance A listed buildings., It is suggested that the window diagram on page 9 should be better integrated into the guidance note.. Whilst its inclusion is considered very worthwhile, it currently seems as if the diagram is a bit of an after thought, with no real heading or explanation. A slight amendment to the layout could therefore increase the usefulness of this diagram

6 Layout of Guidance Notes 3. What are your views on the layout and use of imaqes of the Quidance notes? East Ayrshire Council welcomes the new approach to the guidance, in terms of splitting the guidance into simple succinct documents based around specific topic areas. It is considered that this system will be far more accessible to property owners and other stakeholders than the previous Memorandum of Guidance. The layout of the notes, particularly the use of illustrations and the positioning of the illustrations down one side of the page, is considered to be effective and helps make the notes easy to read and understand. Future Guidance Notes 4. The 14 Guidance Notes replace Quidance from the withdrawn Memorandum. What aspects of the Historic Environment should be considered for inclusion in an expanded series in the future? East Ayrshire Council would suggest that a potential further note could focus on streetscapes within historic environments. This could include aspects such as surfaces, street furniture and street lighting, all of which contribute significantly to the setting of historic buildings and to the character of conservation areas. Such a guidance note could look at items such as whether the installation of new street lighting should most appropriately reflect the style of the area or whether modern designs would be more appropriate. I It is further suggested that greater guidance is required in respect of enabling development, particularly with regards to what detailed justification should be required to support a proposal for enabling development and how this should be assessed. Whilst English Heritage has provided good guidance that is widely used in Scotland, it would seem that specific guidance from Historic Scotland would be very useful. Whilst the nature of enabling development and the significant degree of detail that would be required in guidance, may make it inappropriate for inclusion in this series of guidance, it is nonetheless an area in which there is a specific guidance gap, which should be addressed.

7 RESPONDENT INFORMA non FORM: HISTORIC SCOTLAND GUIDANCE NOTES - MANAGING CHANGE IN THE HISTORIC ENVIRONMENT Please complete the details below and return it with your response. This will help ensure we handle your response appropriately. Thank you for your help. Name: ~~'v L ~"Cr:':'-L<2:~~Q ~\...,"""NI'.J\Na..." <2.~GN'J';-\\.~~~~~ "="'-'0 Postal Address:. \..\.:J": '\ '-"-~, \ C.~-::::,'"" ~'-"'''''':::.~\. \.~<;;: <3 c:~,<:w\,"s"~gc;\ \ ~\L-~~~N\J~~ I ~~",,~~ I. Are you responding: (please delete the line that does not relate to your situation) as an individual go to Q2a/b and then Q4 (b) on behalf of a group/organisation go to Q3 and then Q4 INDIVIDUALS 2a. Do you agree to your response being made available to the public (in Scottish Government library and/or on the Scottish Government website)? (please delete the line that does not relate to your situation) Yes (go to 2b below) No, not at all We will treat your response as confidential 2b. Where confidentiality is not requested, we will make your response available to the public on the [ollowing basis (please delete the lines that do not relate to your situation) Yes, make my response, name and address all available Yes, make my response available, but not my name or address Yes, make my response and name available, but not my address ON BEHALF OF GROUPS OR ORGANISA TIONS: 3 The name and address of your organisation will be made available to the public (in the Scottish Government library and/or on the Scottish Government website). Are you also content for your response to be made available? (please delete the line that does not relate to your situation) Yes ~ V-*~.~iltll,",u;14)v~~] SHARING RESPONSES/FUtURE ENGAGEMENT 4 We will share your response internally with other Scottish Government policy teams who may be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for the Scottish Government to contact you again in the future in relation to this consultation response? (please delete the line that does not relate to your situation) Yes -~ I\Yr;STOR I:" I'Em"t,E