RE: GS2934/2935 Mission and Pastoral Measure and Mission and Pastoral Regulations
I write ahead of tomorrow’s discussion at General Synod on proposals to recast the legislative framework that governs pastoral reorganisation and church closure and disposal.
The proposal would see the Mission and Pastoral Measure 2011 replaced with what is intended to be a more accessible set of materials, namely the Mission and Pastoral Measure and the Mission and Pastoral Regulations.
The principle of reviewing the Measure and its operation is welcome. Naturally there is much about the Measure that is not directly relevant to the work or concerns of the Victorian Society. However, parts of it are directly relevant, and are moreover expected to be increasingly so, not least due to the likelihood of more frequent church closures in the future. As a result, there are elements of the envisaged changes that are a cause of profound concern. Indeed, if implemented as proposed, the new legislative process would fail to appropriately serve historic church buildings; would fail to serve the general public; and would fail to serve the Church of England. In this latter sense it would represent an extraordinary act of self-harm.
Most concerning is the proposal to remove the present obligation to obtain a report from the Church Buildings Council on the historic, architectural and communal significance of the building before a recommendation of closure is made. Currently, this advice subsequently informs a Statutory Advisory Committee report, as well as enabling informed decision making prior to a decision being taken over the closure of a church building. That advice is independent, expert and appropriately timed, and is acknowledged by all parties to be extremely valuable. Elsewhere, such as under regulations 113, 114, 115, the general relegation of the advice and involvement of the CBC and the SAC, and the independent and wider scrutiny and expertise that these Committees bring to bear, can only be detrimental.
The rationale for doing this is unclear, while the implications of it are significant, and wholly negative. Why would anyone propose or welcome a less informed decision-making process? Why is the ability of the CBC to make representations on schemes where it sees fit being removed? Moreover, the proposals fail to adequately replicate this provision. Our view is that the advice of the CBC and the SAC cannot be replicated elsewhere, and it is naïve to imagine that already stretched DACs might be able to be afforded a similar level of resource, engagement and expertise.
The impact of removing and diluting the requirement for the CBC’s (and SAC’s) expert advice would be far reaching. A consequence of less well-informed decision-making would undoubtedly be a reduction in the level of protection and of scrutiny currently afforded church buildings. In so doing it would inevitably and directly increase the likelihood of inappropriate closure, change and or loss of what is an irreplaceable resource, and the nation’s most significant group of historic buildings.
This in turn invites uncomfortable questions for the Church over the suitability and effectiveness of the Ecclesiastical Exemption. If the Church cannot devise and operate a system that offers an appropriate level of protection for historic church buildings, of which it is custodian for all, then the Exemption’s very existence is called into question.
As others have also already pointed out, these buildings offer the Church an unrivalled opportunity for engagement and outreach, and for the furthering of its mission. It is therefore self-harm to enact a closure and disposal process that is less transparent and less well informed, if, as seems inevitable, that process will result in the closure of churches (and concomitant loss of fixtures and fittings) that perhaps ought not to be, or in a process of closure and disposal that alienates communities.
Finally, we wish to record our disappointment that we have not had the opportunity to engage more closely with the development of these proposals. Much like the proposed changes to the Measure to which we object, this process is one that has lacked transparency and engagement, and relegated advice and informed comment to a point at which it is almost too late to be taken into account.
I am afraid, therefore, that we oppose the changes proposed, and would urge their rejection by Synod. As noted above, reviewing the process is in principle to be welcomed, but the result should be something that not just offers a comparable level of scrutiny and protection as the
existing, but which also genuinely serves buildings, people and the Church.
Yours sincerely
James Hughes
Director
Church of St Peter and St Paul, Birch, Colchester. Photo courtesy of Birch InSpire
