RTPI Scotland's response to Inventory of Historic Battlefields - Revisions to Selection Guidance

On 16 July, RTPI Scotland submitted a response to Historic Environment Scotland (HES) on a proposed updated selection guidance for Scotland’s inventory of historic battlefields consultation. Read the response below.

Overview

Question 8: How do you view the stated purpose of the inventory of historic battlefields?

Slightly disagree

Do you have any further comments on this section:

We note that Paragraph 6 of the draft Annex acknowledges the important link between the battlefields inventory and the planning system. However, although the draft recognises the important role of the planning system to aid "understanding, protection and sustainable management" of historic battlefield sites, it fails to make clear the mechanisms through which planners are able to fulfil this important duty.
Historic Battlefields are addressed under Policy 7 of Scotland's Fourth National Planning Framework (NPF4), which was formally adopted by the Scottish Government in February 2023. This NPF4 policy requires development proposals which affect nationally important Historic Battlefields to "protect and, where appropriate, enhance their cultural significance, key landscape characteristics, physical remains and special qualities". It is primarily through this NPF4 policy that Historic Battlefields are protected through the planning system and which makes the inventory a critical resource for planners assessing new development proposals on historic battlefield sites.
We believe the Annex Overview should acknowledge the important role of the National Planning Framework in protecting historic battlefield sites through the planning system. This would enhance transparency and public understanding of how the planning system and inventory interact to protect and enhance historic battlefield sites.

What is a Battle?

Question 9: To what extent do you agree with the following definition of 'battle' for the purpose of selecting sites for the inventory? 'A battle is defined as involving at least two opposing groups of primarily military/martial forces, actively engaged in direct combat with the other, and with the primary intent of inflicting lethal damage upon the opposing force. 'We understand that there are other types of conflict site which would not meet this definition, such as the sites of sieges, or civil conflict.

Not Answered

Please provide any comments below:
No comment

How we decide if a battlefield is of national importance

Question 10: To what extent do you agree with how we decide if a battlefield is of national importance for the purposes of the inventory?

Not Answered

Do you have any comments :
No comment

What we include in a designation

Question 11: How do you view the elements we include in a battlefield designation?

Not Answered

Give your comments here:
No comment

How we draw the boundary of an inventory battlefield

Question 12: To what extent do you agree with 'how we draw the boundary of an inventory battlefield'?

Not Answered

Do you have any comments?
No comment

Inventory records

Question 13: How do you view the revised format and content of inventory battlefield records we are proposing?

Slightly disagree

Do you have any comments ?
See our response to Question 14 below

Question 14: How do you view our proposal to move supplementary research information into the National Record for the Historic Environment so that it can be read alongside, rather than as part of the inventory record?

Slightly disagree

Please provide any comments here:

Given the important role the planning system plays in protecting and enhancing historic battlefield sites included in the Inventory, it is important that any changes made to the information set out in the inventory has regard to how this will impact on planners using the inventory to fulfil their duties under the planning system.
As previously stated in our response to question 8, it is primarily through NPF4 Policy 7 that Historic Battlefields are protected through the planning system and which makes the inventory a critical resource for planners assessing new development proposals on historic battlefield sites. Policy 7 states that "Proposals should also be informed by national policy and guidance on managing change in the historic environment, and information held within
Historic Environment Records". In addition, NPF4 defines "historic battlefields" principally through their inclusion within the Inventory of Historic Battlefields and identifies the Inventory as the principal resource for these sites, further strengthening this intrinsic connection between the Inventory and the planning system.
Given the above definition, we are concerned that separating information from the Inventory and transferring it elsewhere will muddy the waters in terms of what information is required for planners to carry out their assessment of new development on historic battlefield sites.
In order for the planning system to effectively protect and enhance historic battlefield sites in accordance with Policy 7 of NPF4, it is important that planners have a clear understanding of what information is required to undertake their assessment. We understand from our members that the Inventory is currently the primary resource used to access relevant information about battlefield sites. If this information is transferred elsewhere, there is a risk that additional uncertainty could be created as to what additional information should be sourced separate to that contained in the inventory.
We ask that Historic Environment Scotland give careful consideration to how these changes will impact how planners (as well as the public) navigate the inventory and the way in which it interacts with Scotland's planning system. Enhanced clarity, certainty and ease of navigation and access should be at the forefront of any proposed changes.

Anything else?

Question 15: Do you have any other comments on the revisions to selection guidance?

Give us your comments on the Lichfields recommendations:

We would simply reiterate our points raised in our response to questions 8 and 14 that the Annex should acknowledge the important role of the National Planning Framework in protecting historic battlefield sites through the planning system. This would enhance transparency and public understanding of how the planning system and inventory interact to protect and enhance historic battlefield sites.
Also, it is important that any changes made to the information set out in the inventory has regard to how this will impact on planners using the inventory to fulfil their duties under the planning system. We understand from our members that the Inventory is currently the primary resource used to access relevant information about battlefield sites to ensure compliance with Policy 7 of NPF4. If this information is transferred elsewhere, there is a risk that additional uncertainty could be created as to what additional information should be sourced separate to that contained in the inventory.
We ask that Historic Environment Scotland give careful consideration to how these changes will impact how planners (as well as the public) navigate the inventory and the way in which it interacts with Scotland's planning system. Enhanced clarity, certainty and ease of navigation and access should be at the forefront of any proposed changes.