Ms Phoebe Duvall:

I very much agree about looking at them in their context. That is essential. I want to make some specific recommendations around endangerment. The current 2000 Act is systemically ineffective in protecting a lot of protected structures and buildings and architectural conservation areas that are in danger of being neglected. We do not think the draft Bill provides enough improvement in that respect. Two key points around that concern the problems with the definition of endangerment under section 251. For example, an owner can leave a building empty with no heat or monitoring, which can lead to serious damage in terms of roof failures, damp, vandalism etc.

That definition could be greatly improved. The same goes for the definition of "occupier", which should include all agencies or entities with a title interest in the building or with responsibilities for management. I would be happy to provide additional information on that in writing. Those are two key ways we could strengthen the protection of protected structures. Dr. Logue may want to come in.