All public comments to the Raynsford Review must be submitted by the end of the day today. If you have not already done so, please consider contacting them to add your voice to the call for interim protection. (See previous update for details) I hope that we will have achieved our goal long before the Raynsford Review is submitted, but if not, this will give us another opportunity to raise the issue, and put further pressure on the DCMS to respond. Below is the text of the submission I have made on behalf of the campaign: 'Automatic Interim Protection for buildings and monuments being assessed for statutory listing. I am writing to urge that automatic interim protection be given to buildings which are under consideration for listing. I started a petition [bit.ly/2xTJFTJ] to this effect following the deliberate destruction of a beautiful Jacobean ceiling dating from 1620 in a Bristol townhouse. This appears to have been done solely to frustrate the listing of the ceiling. This is only the latest in a long line of similar incidents, including most famously the demolition of the Firestone building [https://c20society.org.uk/100-buildings/1928-firestone-factory-brentford/] over a bank holiday weekend, and the destruction of ancient country pubs, important industrial heritage [https://cprekent.org.uk/news/standing-kents-built-heritage/], and striking C20 murals. Whilst this issue may not be considered to be central to the focus of this review, the effective conservation of our built heritage is in fact key to genuinely sustainable development. It is essential that decisions on the status and future of heritage assets are made quickly, openly and consistently in order to avoid delays and uncertainty for developers. But at the same time it is only reasonable to ensure that historic buildings are not wantonly destroyed before they can be properly assessed. Whilst it is difficult to precisely quantify, it is also clear that historic buildings make a major contribution to the economy of the UK. Historic England estimate its value to be tens of billions of pounds annually. [https://historicengland.org.uk/research/heritage-counts/2017-conservation-areas/heritage-and-economy/] The DCMS have stated that such incidents are rare. However, there is no data to support this assertion. For every example that attracts widespread public attention, there are surely many that do not. Each of these incidents represents the irretrievable loss of a piece of our country’s heritage, and all could be easily prevented. At the time of writing the petition has gathered more than 6.3k signatures. Many signatories are experienced planning and heritage professionals. Many heritage organisations have also publicly backed the campaign, including The SPAB, Bristol Heritage Forum, The Victorian Society, Save Britain's Heritage, The Heritage Alliance (who are an umbrella organisation representing most of the national heritage bodies), The Heritage Trust, The C20 Society, The Georgian Group, The CPRE, and The Southwest Federation of Museums and Art Galleries, along with many smaller civic and heritage societies and groups. Around 3k applications are made for listing each year in England, of which around 1k are successful. Under current UK legislation anyone can apply for a building to be listed. Interim protection can be given by means of a ‘Building Preservation Notice’. However, this can only be served by the local authority, and only a handful of BPN’s are served each year, leaving the great majority of heritage assets vulnerable to destruction during the listing process. In the case of archaeological sites under consideration as scheduled ancient monuments, there is no mechanism comparable to BPN’s. There are several reasons why LA’s do not commonly serve BPN’s. A major factor is fear of a compensation claim in the event that the listing application is refused. But even when LA’s do try to serve BPN’s, in some cases owners prevent access to the site to view the asset, thus frustrating the attempt. I have so far been unable to find a single example of a compensation claim in recent years in England, and CADW have been unable to find any examples at any time in Wales. [http://www.assembly.wales/laid%20documents/pri-ld10184-em-r/pri-ld10184-em-r-e.pdf (pg 59, para 263)] Interim protection was previously proposed in a 2008 draft Heritage Protection bill, which was not enacted [https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/228585/7349.pdf] However, the Welsh Assembly has now passed the Historic Environment Act (2016) for Wales. [http://cadw.gov.wales/historicenvironment/policy/historicenvironmentbill/?lang=en]. Interim protection for all heritage assets was included in this Act, and this measure came into force in May 2017. Alongside the provision of interim protection, this Act includes other measures to reduce the administrative burden of the listing process for owners/developers. In particular, it gives owners a statutory right to be consulted on listing, broadens opportunities for application for Certificate of Immunity from listing, and provides for heritage partnership agreements with owners. All of these measures seem fair, and by making the process easier for owners, also reduce the already minimal risk of compensation claims. In addition to these measures, the 2008 Heritage Protection Bill included measures to allow for the listing of only part of a building. This provision has subsequently been partly implemented, but there appears to be scope to further improve this. This would allow more targeted use of the listing process to give statutory protection to key heritage assets, while avoiding unnecessary administrative burdens in relation to less interesting parts of a building. In short, this legislative change is long overdue to eliminate a gap in protection for historic buildings that has allowed an unknown but significant number to be needlessly damaged or destroyed. The legislation has in large part already been drafted, with much of the groundwork having been laid by the abandoned 2008 Heritage Protection bill, and the successful Welsh Historic Environment Act. All indications are that it would incur little financial cost either to statutory bodies or to building owners, and the Welsh legislation has shown that it can be successfully combined with sensible measures to reduce administrative costs and streamline the process for developers.'