'mitigation is probably the principal aim of the impact assessment process, especially if conservation involves managing, rather than preventing change.' Kate Clark, Informed Conservation, 2001, p.28.
You frown. What’s this? So far the Heritage Impact Statement has been an intriguing read but near its conclusion, a new section entitled ‘Recommended Mitigation’ has given you reason to pause. Mitigate what now? Someone please explain.
Mitigation = the process of identifying ways of minimising or avoiding
We hear you and let us begin by stressing that this section has not been slipped in to trip you up or subvert your design ambitions. Nor is it an airy-fairy, heritage consultant wish list that warrants swift condemnation. What you are in fact reading are battle-tested and/or inventive strategies with the singular aim of reducing the potential of your proposal to harm or diminish the established heritage significance of the place under scrutiny.
At Touring the Past, we have always found the term ‘mitigation’ somewhat legalistic and officious. It seems to clash with the vibe of our heritage assessments, which stress a familiar, jargon-rejecting unpacking of the what, why and how about a place’s heritage significance. We have always rather fancied ‘amelioration’ – with its undertones of enhancement and betterment – but we are realistic about which currents to buck and we genuflect respectfully to the wide-spread use of mitigation in heritage circles.
As touched upon above, mitigation measures turn up most often in the concluding pages of Heritage Impact Statements. Although, they also make appearances in the consent conditions issued by regulatory authorities – more on this later.
Heritage professionals suggest mitigation actions at the tail-end of the heritage impact assessment – a process which analyses the potential effect of change on cultural heritage significance via a multitude of factors, such as the nature of the impact (direct, indirect, cumulative) as well as its duration, extent and scale (click here to learn more). More often than not, potential damage can be remedied simply by a proper in-depth 'reading' of a site. At the heart of mitigation is understanding, and appropriate information, directed towards the decisions which need to be made, are central to design decisions. Now, while the most effective form of mitigation is avoidance of disturbance – be it to significant fabric, layout, use, sight-lines or design elements – realistically this can sometimes be unavoidable. In such situations, heritage specialists have an ethical obligation to offer measures to minimise the magnitude of the negative impact, remedy (or restore) what cannot be reduced and compensate/record what cannot be remedied.
Yet to be crystal clear, circumvention or the consideration of alternatives is the ideal form of heritage mitigation. And the possibility that the impact of an unreasonable or unnecessary adverse decision could be mitigated is not a sound justification for that path to be taken. When mitigation is considered needed, a suite of options will be carefully examined by the heritage consultant, with the specifics of the site, nature of the development and degree of achievability in mind. For example, in situations where indirect impacts on heritage assets appear, perhaps the intrusion of an unresponsive element into a historic setting, the focus of mitigation efforts would be on diminishing the level of its noticeability or presence. In such instances, recommendations along the lines of providing screening, integration or a buffer are common. Landscaping, as ever, can be key here.
In more drastic cases, when the probable impact is of a more direct, dramatic and/or permanent kind, more muscular forms of mitigation may be required. This could entail suggested repairs/reconstruction/restoration actions; the removal of intrusive elements; choice of materials; timing and methodology; reversible work; temporary protection requirements; the dismantling and/or relocation of a building or structure; archival recording (click here); and/or active heritage interpretation (click here).
The above examples are just a taster. A myriad of mitigating approaches exists.
At this point, the wayward voice on your shoulder might be telling you to direct your consultant to jettison such inclusions. Resist it.
Firstly, ethically we can’t and won’t do that. At Touring the Past, while we will always willingly engage in dialogue concerning the reasoning behind a mitigation recommendation but we won’t remove recommendations from a report just because the owner/developer is opposed to them.
Secondly, woe become any heritage report received by the wily, ‘seen it all’ Council Heritage Advisor that does not pass the impartiality test. If the need for mitigation is clear and yet lacking, fair questions of partiality can be posed, all of which may challenge the very premise of your approach to the heritage place and lead to frustrating delays and reversals.
Thirdly, the heritage consultant’s mitigation recommendations are just submissions. You are under no statutory obligation to fulfil them unless they are conditioned by the decision-making body. Now unsurprisingly, such authorities will likely pay heed to the recommendations of the specialist but they will do so in the context of the wider area and previous decisions. In their weighing up of the complete planning picture they may deem them unnecessary and/or downgradable. Further, and this one we find is key, the presence of tailored mitigation measures provided by the heritage consultant can avoid situations where planning bodies ‘copy/paste’ mitigation templates into consent conditions, which can result in unnecessary, difficult to fulfil and costly requirements that can be trying to challenge.
Touring the Past is skilled and practiced in the assessment of heritage impact and its mitigation. We pride ourselves on our ability to deliver professional, impartial, on-schedule services that ensure the cost-effective discharge of your heritage obligations. Save yourself time and resources by contacting us first.
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