The Governance Context for Adaptive Heritage Reuse: A Review and Typology of Fifteen European Countries

ABSTRACT Recent years have seen growing international interest in the practice of ‘adaptive reuse’ of heritage buildings, promoted as a financially more viable and environmentally sustainable way to achieve both regeneration and conservation. In parallel, adaptive reuse has emerged as an aim in national policy frameworks and EU governance. Much of the writing on adaptive reuse reflects its nature as a design practice and concentrates on the material form intervention may take. This paper has a different approach, considering the institutional factors that support adaptive reuse occurring, as part of a multi-faceted and complex conservation-planning assemblage, across fifteen European countries. Focusing on regulatory systems for heritage and planning, governance systems, human and financial resources and policies on civic engagement and participation, thematic analysis is used to generate a typology of approaches across the continent, grouping the countries considered into three clusters. The typology proposed is not fixed, but a way to conceptualise the similarities and differences in institutional and policy-contexts that facilitate or restrict adaptive reuse. It contributes to a more informed overview of the context for adaptive reuse and the possibilities of learning from different policy contexts.


Introduction
Recent years have seen growing international interest in the practice of 'adaptive reuse' of heritage buildings, promoted as a financially more viable and environmentally sustainable way to achieve both regeneration and conservation. In parallel, adaptive reuse has emerged as an aim in national policy frameworks as well as in EU governance. The latter also emphasises a commitment to participatory approaches to cultural heritage management, recognising the potential role of heritage in fostering social cohesion and democratic engagement. In this paper, we present our analysis of the policy and governance arrangements relevant for adaptive heritage reuse in fifteen European countries. Our aim in undertaking this work is fourfold. First, we want to understand which policy and governance spheres are important in facilitating, or acting as a barrier, to adaptive heritage reuse. Second, we are conscious that in a particular context, different factors may work in countervailing directions, and therefore we considered how these work in combination. Third, we seek to group the countries studied based on our analysis. Important themes emerge around heritage regulation, its integration with spatial planning, possibilities for citizen participation, and resourcing. Fourth, we aim to propose a provisional typology for the different contexts in which adaptive heritage reuse occurs in the countries considered, as part of a framework for understanding how adaptive reuse is situated in and affected by the various conservation-planning assemblages. This allows a critical and reflective understanding of the various policy systems and thematics at play and encourages positive change and knowledge transfer.
The paper has been developed from EU Horizon2020 project, OpenHeritage. 1 The project is premised on the positive potential of adaptive reuse for heritage management and making better places. Within OpenHeritage there is a particular focus on inclusive civic engagement as an important and powerful dimension of a broadly-based policy of adaptive heritage reuse that is democratically inclusive and reaches beyond heritage assets where economic value can be easily capitalised. Heritage, in this context, is considered as a valuable resource for creating social cohesion and promoting democratic engagement, and this normative position has influenced the development of this paper.
In the next section of the paper, we address adaptive reuse as a concept and practice, embedded within specific conservation-planning assemblages. We move on to describe our methodology and elaborate on the idea of a typology of policy and governance arrangements, and why this is useful. Our results focus on factors affecting adaptive heritage reuse before presenting our country typology. Finally, we reflect on how adaptive heritage reuse can be facilitated and consider issues of transferability and institutional learning.

Adaptive Heritage Reuse
There is no standardised definition of adaptive reuse and synonyms for the practice abound, including remodelling, rereading, undoing, recycling, alteration, upcycling, creative reuse and reactivation. In this paper, we take adaptive reuse to mean the change of function of a building or place from one use or user to another that requires some level of material change. Our particular focus is on adaptive heritage reuse. By this we mean both the reuse of buildings officially attributed heritage status (e.g. 'listed') and also buildings without such legal status which have heritage value and meaning to a given community. While strongly associated with the conservation of buildings that have been considered of historic value, adaptive reuse is a term that is increasingly being applied to a diverse range of historic contexts, including places and landscapes. Adaptive heritage reuse projects range from careful schemes of architectural conservation to more radical interventions, involving substantial demolition and change. Similarly, adaptive reuse projects might be small-scale community-based projects or prestigious commissions undertaken by 'starchitects' and everything in between. Interest in adaptive reuse is not new. As a term it entered the lexicon of architectural and conservation discourse in the 1970s, but it is an ancient practice as for reasons of economy and symbolism buildings have always been recycled and put to new uses. In the post-war period, a reaction against high modernism and 'clean sweep' planning provided new impetus for advocating adaptive reuse. Seminal thinkers such as Jane Jacobs (1961) were arguing the case for the importance of retaining old buildings for the cheap and flexible accommodation they provided, considered as an integral part of dynamic and successful cities. 2 However, it was the emergent conservation movement, evident across many 'western' countries, that was most active in promoting what was coming to be called adaptive reuse, as part of strengthening the case for conservation as an economically practical as well as culturally desirable goal. 3 There was a particular focus on reusing former industrial buildings, sites, and landscapes where deindustrialisation developed as a major force or urban transformation 4 which continues today. 5 In the intervening decades the practice of adaptive reuse has been steadily on the rise. The 2008 financial crisis provided further stimulus, in many countries leading to a drop in new-build projects, and an increase in re-use projects as part of an economic urban regeneration strategy. 6 As a potential solution to both economic and environmental goals, adaptive reuse has emerged as a policy aim in several countries and more recently also in EU governance and funding. 7 This forms part of a wider focus on instrumentalising heritage -often through reuse -capitalising on the economic value of local identity and historic character 8 to achieve urban regeneration, 9 and tourism development. 10 Furthermore, the adaptive reuse of the historic environment is considered to be more sustainable than new construction, 11 and is often seen as part of the 'reduce, reuse or recycle' discourse, reducing material waste, 12 containing the embodied energy of materials and labour, 13 something that has reached into mainstream architectural debate through, for example, the British Architects' Journal #Retrofirst campaign. This too, in a context of UN Sustainable Development Goals, the European Green Deal, and the various climate emergencies local authorities have been declaring over the recent years, makes the sustainability framing of adaptive reuse a more attractive practice for policy makers. Thus, the increased focus on adaptive reuse is connected to the development of specific policy programmes within the context of heritage and planning, but also to other policy agendas, such as urban regeneration, crisis recovery, tourism development, the support of creative industries, increasing environmental quality, increasing wellbeing and quality of life, promoting 'localism', and reducing carbon emissions.
Alongside the practice of adaptive reuse, a considerable literature has developed, with a notable upswing in publications over the last decade or so. 14 Within this extensive literature, there is a significant focus on design and technical issues. Indeed, there is a significant strand of this literature that is not concerned with adaptive heritage reuse as such but is more preoccupied with conceptualising adaptive reuse as a distinct design discipline. 15 A focus on design and materiality similarly extends into the more specifically heritage-orientated literature, related to traditional heritage precepts such as authenticity or 'genius loci'. 16 Within the heritage sphere, as alluded to above, there has been an ongoing focus on the reuse of the legacies of industry. Many of the books that have emerged in this field are collections of case studies of projects, assembled to support the principle of adaptive reuse or to act as a 'how to' guide. Some work is emerging on policy enablers for adaptive reuse, 17 and on how a policy of adaptive heritage reuse can have wider consequences such as erasing and highlighting certain histories, or how mobilising aesthetics and temporary use can lead to gentrification. 18 With this paper, we approach the subject from a different angle, largely absent from the literature, by focusing on the policy and governance frameworks and other institutional factors that influence the practice of adaptive heritage reuse. We can understand this context for adaptive heritage reuse as a conservation-planning assemblage. 19 Whether adaptive reuse is possible, and under what terms, is framed by the relevant institutional organisations and other actors, and their interrelationships, together with law, regulation and policy, the availability of financial and human resources and within the context of normalised practices and discourse. The assemblage is the combination of these elements. While we can analyse such assemblages at different spatial scales; for example, the influence, on the one hand of international conventions or, on the other very local relationships, the key spatial scale we focus on here is national, as, for example, it is at this level that key cultural institutions are located and laws made, in most of the countries that we consider.
Our focus is upon an analysis of the conservation-planning assemblages across fifteen European countries, both inside and outside the EU. We are interested in what makes adaptive heritage reuse more, or less, easily achievable. If adaptive reuse is to be promoted as a practice, it is important to think not only about the design principles that might drive a successful and respectful intervention, but to understand the key contextual factors that enable or inhibit adaptive reuse. For a policy of promoting adaptive reuse to be successful it is important to develop an understanding of the practice that goes beyond documenting and cataloguing individual projects, to analyse what factors will support or hinder the practice. For this paper we have deliberately avoided seeking to illustrate our typological categories with representative case studies from our fifteen countries, since practices of adaptive heritage reuse are shaped by multiple and complex factors, and maybe successful despite an unfavourable policy environment, so they do not map simply on to the typological categories we have developed. Furthermore, factors that enable adaptive reuse in terms of policy, governance, and resourcing, should not be considered in isolation from each other. What is critical is the interrelationship of these factors, how they combine, or not, to provide a fertile context for adaptive reuse.

Sources and Methods
The fifteen cases selected were: Austria, Belgium (specifically, Flanders), France, Germany, Hungary, Italy, the Netherlands, Poland, Portugal, Romania, Slovakia, Spain, Sweden, Ukraine, and the UK (specifically, England). 20 Data was gathered through systematic documentary analysis supplemented by expert interviews, by a team of researchers in eight universities across Europe, covering all necessary languages. The data collection covered in each country the legal and policy framework of areas pre-identified as influencing how adaptive heritage reuse can or cannot be facilitated: planning and landuse governance, heritage management and conservation, building codes and regulation, funding and financing mechanisms, with wider fields of culture, sustainability, and engagement included where relevant. The research aimed to map the general context and the most important trends, the main actors, the relevant act and codes, policy directions, thematic programmes, strategic documents, and tools in these areas, ranging from the national to the local level. Based on these country overviews, 21 we identified the barriers and incentives in promoting adaptive heritage reuse in each country and explored whether and how the relevant policy areas are integrated with policies about socio-economic development, participation and bottom-up initiatives, the cultural and creative sphere, and environmental sustainability. 22 From this analysis, four major themes emerged. We used these to create axes that span between the extremes of a supportive and unsupportive context for facilitating adaptive heritage reuse. Our approach was to construct groupings based on qualitative characteristics along the thematic axes, focussing on the national policy level. We achieved this by a comparative analysis of the country overviews, based on close reading. The thematic analysis was triangulated with a scoring system where each country received a score from 1 to 4 along the four axes, leading to a ranking and hierarchical cluster analysis. Scores relied on qualitative judgment, and we acknowledge that despite thorough research on the policies and institutional arrangements, our scoring could not fully overcome uneven knowledge of different systems. To mitigate this limitation, the scoring was undertaken by a group of four researchers from various countries and various disciplines.
Leading from the thematic analysis and country scoring, we sought to group countries based on the patterns we recognised and how they clustered based on the numerical scoring. The results presented in this paper are based on placing countries in one of three groups. The purpose of these is discursive, in prompting debate rather than a definitive 'solution'. The categories created are not rigid -other groupings are possible -nor is the position of a particular country in a particular grouping fixed. Whilst a degree of long-term stability can be observed, the institutional context for adaptive heritage reuse does change and sometimes quickly. We consider the three groups created as a provisional typology: a typology allows an explicit cross-country comparison to facilitate discussions and awareness about the distinctive and similar national policy features related to adaptive reuse. As Hantrais (1999) describes, cross-national comparative studies can bring into relief conditions that otherwise might be taken for granted by researchers and policy makers within any given national context, thereby stimulating new perspectives and discussions. 23 However, the lack of comparative literature on heritage policy and practice has been noted by Mualam and Barak (2019). 24 There is some work on cross-national heritage policy, for example, by Pickard 25 and by Stubbs,26 and the HEREIN database, 27 which gives an overview of national regulatory systems for heritage and conservation, but with the aim to map out, and not necessarily undertake a comparative study or develop a typology. Previous typologies developed for adaptive heritage reuse focus on classifying the type of heritage (e.g., industrial, religious, residential) or the type of intervention in a building. 28 In contrast, the typology we propose explicitly focusses on governance context, rather than the heritage 'object'.
A typology focused on governance has been developed for planning systems. 29 As Nadin and Stead (2013) explain, for the typology of planning systems they co-developed, categories based on a comparison of common attributes are created, which is a complex task as systems may be similar according to some criteria, and dissimilar according to others. The concept of 'ideal types' (as defined by Max Weber 30 ) helps here. These are abstract constructs against which empirical examples may be contrasted, reflecting some elements of the ideal types, but not necessarily all. Ideal types are particularly useful when exploring a reality that is little known or, in the case of policy contexts, immensely complex. In line with Nadin and Stead, our goal is not to classify policy-approaches, which runs the risk of shoe-boxing countries into categories, but to promote comparison across countries along themes relevant in the wider conservation-planning assemblage for facilitating adaptive heritage reuse. The key criterion for evaluating the usefulness of groupings was whether these groups provide a meaningful hermeneutic to understand the diversity of policies and regulations towards adaptive heritage reuse. From these we can begin to consider the transferability of insights about adaptive reuse policies whilst keeping in mind that transferability, when it comes to these complex, multilevel, and context-dependent policy contexts, is not straight forward. 31

Results: Factors Affecting Adaptive Heritage Reuse
While many forms of regulation and policy can be relevant for framing adaptive heritage reuse practices, our analysis found that it is generally law, policy, and regulations relating to built heritage and spatial planning (including land use, design and building regulations), and their level of integration and alignment, that are critical in framing adaptive heritage reuse projects. 32 Further conditions found to have an important influence over adaptive heritage reuse include the level and type of resources available (human and financial), the degree of collaboration between various levels of government, and the level of facilitation of bottom-up initiatives, including support for the development of grassroots projects.
Reuse practices are thus initially framed by the intersection of heritage policy and planning systems within the complex context of urban or rural governance. This context varies from place to place and country to country due to significantly different institutional conditions and collaborations, different definitions of heritage, different national and local societal models between citizen and state, leading to, for example, different requirements and conditions for participation by local communities. The financial or human-resourcing of heritage programmes is also highly variable by location or even project. Availability of funding and expertise varies greatly, and also the availability of an access to various non-heritage-related funding streams and other local and regional resources and policies is often project or country specific. Relevant policy and funding can range from the creative industries, social and youth policies, agricultural and rural development, to sustainability and energy measures, and from crisis recovery strategies to tourism and regional development plans.
Four major themes emerged that we used as analytical axes: flexibility of regulation and policy; the integration of regulation and policy between heritage and planning systems and between levels of governance; support for civic engagement, and; access and availability of financial and human resources.

Axis 1
Flexibility of regulation and policy. Governance and policy systems in some countries appear to allow for risk-taking and flexibility in permitting adaptive heritage reuse to accommodate adaptations for the reuse(s) of heritage sites, while in other countries these systems are more risk averse and inflexible. The key questions are, are heritage conservation regulations strict or do they allow flexibility? Can heritage buildings easily be changed or not? Does the system encourage risk taking (discretion for local regulators, allowing either strict application of regulations or flexibility depending upon circumstance) or is it risk averse? Furthermore, how open is the concept of heritage, i.e., does it refer only to a very specific list of buildings, or is it more broadly applied (e.g., including intangible heritage, character, protected areas)? A more open approach allows the potential for more flexibility in intervention and (temporary) use, as well as a wider range and deployment of resources to support adaptive reuse.

Axis 2
The integration of regulation and policy between heritage and planning systems and between levels of governance. This axis reflects on systems of governance, with a particular focus on the relationship between heritage policy and spatial planning. The relevant policies and institutional structures are more integrated in some countries, and more siloed in others. The key questions are whether policies of planning and heritage protection produce a coherent and comprehensible policy-context for adaptive reuse, i.e., how well are policy and institutional practices integrated horizontally (planning and heritage systems) and vertically (e.g., between regional and local government)? Are there integrated ways of working on heritage and planning, i.e., are heritage and planning based within the same administrative department, and are applications for change to the historic environment decided upon by the same level of government? Are urban planning and heritage mechanisms separate or do they overlap? For example, do they have tools in common (e.g., conservation areas, integrated masterplans, integrated land use plans, etc.)? Complexity and contradiction can make navigation of the systems challenging, particularly for inexperienced actors. Integration of heritage and planning policies often also comes with seeing heritage as a 'useful' element within urban planning, thus making the system more geared towards reuse.

Axis 3
Support for civic engagement. Our research specifically targets adaptive heritage reuse where civic engagement and social benefit are priorities. This entails an inclusive approach towards heritage and broadens the circle of potential stakeholders interested in the adaptive reuse of heritage sites. Some policy systems explicitly encourage civic engagement in the adaptive reuse of heritage and related areas, while other countries have a more neutral position or actively discourage such engagement. The key question is whether civic engagement in adaptive reuse projects is encouraged by the institutional systems of planning and heritage protection and legally enabled? If so, how deeply does this extend and how is it supported? Is engagement actively encouraged and resourced (incentives, supporting different organisational structures, creating platforms) in terms of time, money, access, or, if civic engagement is happening, is it outside of (and perhaps despite) the institutional arrangements?

Axis 4
Access to and availability of financial and human resources. In some countries, those who start an adaptive heritage reuse project, can rely on a reasonably well-resourced context in terms of both funding (public and/ or private) and capacity (e.g. available experts, knowledge, information, support), while other countries do not have either. Thus, the key question is whether the institutional framework offers any resources, in direct funding or fiscal incentives to adaptive heritage reuse, and whether professional staff resources and organisations to support such projects are available? What kind of incentives, whether waivers (e.g. tax, procurement, levies) or grants exist, and are these directed towards listed buildings or protected monuments only, or are they available for a broader range of heritage reuse projects? Are they available for sites in private ownership? Are they for capital works only or can they support building use? Are there non-heritage funding schemes that can be channelled towards projects of adaptive heritage reuse? Are there experts within the system to undertake research, provide guidance materials, and generally help groups who want to undertake such a project?

Results: Grouping Countries
Using the thematic analysis and scoring exercise of national policies along the four axes, we developed three groups or 'types' of national framing for adaptive heritage reuse: countries where adaptive heritage reuse is common and facilitated; countries where it is supported and developing, and countries where it is difficult. We placed each country into one of these groups based on our analysis of characteristic trends. To reiterate, this positioning is not fixed and, for example, placing emphasis on different variables might produce a different grouping. Figure 1 gives an example of our analysis, in this case against charted against the criteria of flexibility and resources.

Group 1. Adaptive Heritage Reuse: Common and Facilitated
In these countries, adaptive reuse was supported pre-crisis, and support often increased within the context of post 2008 recovery plans. Regulatory frameworks for heritage and planning are well integrated on a national level (through policy and plans, and/or in law) and levels of government tend to have clear relationships, roles and responsibilities in the process, with the local level usually being the place where most decision making happens for both heritage and planning. There is discretion on the local level. This creates a space where change and significance can be negotiated, more easily allowing a tailored approach to adaptive reuse cases. This generally facilitates reuse, but can create risk; for example, decision-makers can decide to say no to reuse, or to say yes to harmful proposals. While heritage regulations can be strict, policy and funding are often focussed on bringing buildings back into use, with the option to negotiate material change. An additional focus on 'using' heritage to contribute economically, socially and environmentally adds to more traditional ambitions of building 'national identity' or a narrow concern with the material conservation of 'cultural property'. These systems are (relatively) wellresourced in terms of capacity (people, time) and often also have funding schemes in place as well as tax or VAT incentives to support policy aims. These countries also tend to have other policies and programmes (e.g., in the fields of housing, sustainability, culture) that may integrate and stimulate reuse over new construction. Bottom-up approaches to enable adaptive heritage reuse are not necessarily institutionalised, but a regulatory system that is clear to navigate and that, in some cases, provides support for community groups, makes them more possible.
The three countries that fell most clearly in this group are England, the Netherlands and Sweden, as their conservation-planning assemblages are most clearly supportive of adaptive heritage reuse, sometimes by directly developing policy to support the practice. All three countries have heritage policy that uses a 'care for' rather than a 'protect from' approach when it comes to heritage. Germany and Austria have well-resourced heritage protection and management systems but with less flexibility or local discretion than the other countries in this group. The regulation of heritage here is generally focused on protection and in both countries, there are differences between various regions (Länder) in how heritage policy is integrated with planning. However, the resources invested and successfully integrated into the governance system, combined with a strong tradition of civic involvement, compensate to a significant degree for system inflexibility.

Group 2. Adaptive Heritage Reuse: Somewhat Established as a Practice or Developing, Regulatory Framework with Some Obstacles but Trending Towards Greater Flexibility
Typically, for countries in this group significant focus on adaptive reuse only started to appear in the post-2008 recovery period, often in the context of tourism and/ or regeneration schemes, sometimes stimulated through EU programmes and funds. This has introduced a new focus on the use of heritage as part of a programme of economic recovery and development, away from an exclusive preoccupation with cultural property protection. In common with the countries in group 1, some countries have strong, wellresourced, heritage regulatory systems. However, adaptive reuse practices are more difficult because of an inflexible heritage protection framework in combination with a lack of integration across planning and heritage systems. This creates complexities and contradictions that sets obstacles for projects, and especially for civic initiatives. In several cases, formal responsibilities for heritage and planning are situated on different levels of government, and these levels aren't always clear on who has responsibility for what. A frequent issue is that responsibilities for nationally protected heritage lie at a regional or national level, whereas spatial planning and regulation happen at a local level. This combined with a lack of institutional capacity and funding can lead to long procedural times (e.g., when all local applications need regional approval) and complex procedures. Most countries included in this group are in the process of seeking to address these issues and to make adaptive reuse easier. This can include aligning building regulations better with reuse and giving greater discretion over decision-making at local level. Funding and support for adaptive reuse in these countries tends to come from non-heritage sources (e.g., regeneration, tourism, social or sustainable development policies), especially when the heritage system is strict and heritage funding is only available for restoration projects. Overall, adaptive heritage reuse in this category is typically complex, making bottom-up projects more challenging, with difficult to navigate and opaque institutional arrangements, especially for those without experience, time, capacity, or resources.
In this group we included Flanders, France, Italy, Poland, Portugal, and Spain. As with the other groups, it is heterogenous, but there are some typical features in these countries. They have well established systems of heritage protection, but typically characterised by regulatorily inflexibility and a lack of integration with systems of spatial planning. Available resources enable projects to occur on the ground and overcome some of these complexities. Financing might be through access to EU resources to facilitate regional development (e.g., Poland) or for more traditional heritage conservation (e.g., France). Steps are being taken to better facilitate adaptive reuse. For example, Portugal is changing its building regulations to become less focussed on new build, in Poland the 2015 Act of Revitalisation, is supporting regeneration with strong social involvement, and in Italy the vacancy of historic buildings is being challenged through 'meanwhile uses', drawing on legal rights and traditions of civic activism, and regulation around urban commons.

Group 3. Adaptive Heritage Reuse: Difficult
In these countries adaptive heritage reuse is often happening despite the system. Though the idea of adaptive reuse is becoming more common and popular, it is not structurally facilitated or funded. The institutional capacity to support projects is weak or absent, and there is little sign of this improving quickly. All the difficulties experienced in group 2 are present and more pronounced, as well as combined with a structural lack of resources. Heritage and planning decision making are undertaken at different governance levels or by separate authorities (e.g., local government and devolved regional offices). The heritage system in these countries is typically inflexible, with a focus on material conservation and avoiding change. The possibilities for change tend to increase with economic/ development pressures or needs, increasingly using heritage for economic development, but typically through ad-hoc decision-making rather than coherent policy. If there is public investment for adaptive reuse, it often comes from external funding or policy steers (e.g., tourism and/or regeneration schemes, EU or other funds). Heritage funding, if available at all, usually applies strictly to material conservation of nationally listed buildings. A general lack of funding and resources and a lack of paid experts and capacity in the institutional frameworks make adaptive reuse hard, even where local government has the discretion and willingness to support adaptive reuse. A lack of institutional capacity also leads to long procedural times. Moreover, unstable policy contexts can make navigating the system difficult, with outdated or rapidly changing regulations, a lack of transparency and access, and uneven and opaque decision-making when making exceptions for political or economic reasons. There are inadequate mechanisms for supporting bottomup practices, and while volunteers fill some gaps, this doesn't address the absence of structural support. Support for adaptive heritage reuse is weakest in Hungary, Romania and the Ukraine. The situation in Slovakia is not quite as stark, as there is support in principle for pursuing adaptive reuse and a degree of flexibility towards projects of adaptive heritage reuse that is positive. However, a chronic lack of paid expertise and financial resources ultimately makes projects difficult to realise.

Discussion: Facilitating Adaptive Heritage Reuse
Direct policy support exists in some countries for adaptive reuse. In the Netherlands, the explicit use of the term adaptive reuse (herbestemming) in policy contributes to the active stimulation of the practice by the government through planning, culture, design, and heritage agencies, in terms of resources, sharing knowledge and supporting pilots. Adaptive reuse is encouraged in policy and seen as a useful means to achieve regeneration, develop regional and local identity and solve building vacancy. In England, while the term 'adaptive reuse' is not found in policy, it is normalised as a practice. For example, the English National Planning Policy Framework (2021) 33 explicitly aims to conserve and enhance heritage through putting it to new use, where appropriate.
While such explicit policy underpinning is unusual, this does lead us to the first of the four key axes for understanding the institutional context of adaptive heritage reuse that we identified. Key to the operationalisation of such policy, is support for discretion in decision-making at the local level, enabling the most suitable solutions which benefit the social and economic development of the area and, at the same time, preserve and promote the heritage values of the site. Equally, the policy examples we describe occur within the context of a robust, consistent, and well-resourced heritage systems. The outcomes of adaptive reuse projects are not inevitably desirable and there can be a fine line between discretion and an imbalance of interests, with undue influence by politically and economically powerful actors. Flexibility and discretion too generously used, risk heritage being reduced to being entirely a commodity and a tool for gentrification and touristification, with the marginalisation or skewed exploitation of heritage sites not easily monetised. At its most extreme, flexibility and discretion can be linked with corruption. Local discretion may thus run counter to effective heritage conservation and instead open the way for demolition and redevelopment. Therefore, linked to this variable, we saw that adaptive heritage reuse was supported better when the local level was well-integrated into a multilevel governance system, with each level connected both vertically and horizontally, and heritage and planning issues are managed via an integrative approach, leading to our second axis. This often connects with heritage being considered as a resource for development -broadly conceived -and development is understood as a means of preserving heritage.
For example, in England local planning and conservation officers have considerable discretion to make decisions when it comes to adaptive reuse, and heritage and planning are integrated within the same planning policy framework. Their job is to weigh community benefits of a project proposal against the potential harm to the significance of the asset or area. Building regulations are (within limits) adjustable for listed buildings. In contrast, in Flanders, while there is also a flexible understanding of heritage, this is combined with a stricter institutional context of rules and regulations, and a planning system that the region is currently aiming -but struggling -to make more coherent and transparent, in relation to the co-creation of policies and plans between different levels of government. In further contrast, Romania has a multilevel planning system, where all plans are required to adjust to plans further up the hierarchy. However, this does not integrate with the system of heritage protection, which remains highly centralised. Interventions to protected monuments, including those connected to change of use, need approval by the ministry in each case. Similarly, Hungary has centralised and complex planning and heritage protection systems, where many different levels of government are responsible for various parts of planning, heritage, and building control. Heritage and planning might meet at the local level, though not necessarily, as this relies on the approach taken by each municipality. 34 These are structural issues, which can be mitigated but not solved by, for example, providing free access to expertise on how to navigate bureaucratic procedures, procedural fees, and funding issues. This is why effective governance is linked to our fourth axis, resourcing, including technical expertise to support adaptive heritage reuse projects, financial resources to facilitate projects and specific project management expertise to effectively assemble and deploy these resources. On occasion professional resource is directly deployed to support a programme of adaptive reuse. For example, mapping vacant and dilapidated heritage assets can document the extent of the issue and stimulate further thinking about reuse and urban regeneration, helping set priority reuse actions for certain areas and assets. The Netherlands puts designated 'matchmakers' in place, with knowledge of vacancy in the locality to match vacant heritage assets and potential users. As discussed, a good level of resourcing can help mediate other potential blockages in the process. For example, a governance context that channels sufficient resources towards the institutional system in terms of staff, support, and funding, will create capacity to make adaptive reuse possible despite an inflexible regulatory context; something we observed in Germany and Austria. Thus, the question of 'resources' is fundamental to maintaining a functioning and integrated planning and heritage protection system. If there are resources, conflicts between scales or among authorities can be mediated, civic initiatives can be supported, participatory processes can be initiated and substantiated, court cases can be fought, etc. Without such resources, conflicts are generally dominated by those with the biggest political or economic power. Thus, if we return to the issue of discretion, if development is prioritised one-sidedly by the state power, experts in the heritage institutional system necessarily fight for conservation of heritage, reluctant to cede any flexibility without the agency to influence development; something we observed in Hungary for example. For heritage experts to take a more open approach and negotiate confidently, they must be empowered through access to sufficient resources and decision-making must be integrated with other governance processes.
The difference that good levels of resource can make was most evident for the countries sitting between the extremes in our classification. Austria and Germany were included in our first group, despite relatively inflexible heritage protection regimes. In Austria expertise has been channelled into a national Building Culture policy programme which aims for a holistic (regulatory) approach to the built environment by supporting reuse, high quality architecture, and reducing the use of greenfield sites. The reuse of heritage buildings is promoted through culture and heritage programmes, and the Ministry of Digital and Economic Affairs provides funds for locating businesses in old or post-industrial buildings or areas. Conversely, Slovakia and Poland illustrate the importance of lack of resources. In common with the other Central-Eastern European countries, neither has a specific legal basis for addressing adaptive heritage re-use and both have a relatively inflexible heritage system focusing on conservation, only moderately integrated with planning. At the same time, the idea of heritage as a resource in economic development is increasingly recognised in both countries, especially in tourism, and in Poland also in the revitalisation of degraded areas. Consequently, in these two countries the direction of travel is towards more flexibility compared with the other Central-Eastern European countries in our typology. However, in Slovakia especially, the lack of resources to facilitate adaptive heritage reuse is preventing the potential of this transformation to be fully realised. Almost the opposite situation exists in Portugal, Italy, and Spain. Support exists for heritage projects, and sometimes adaptive reuse specifically, in terms of funding, tax incentives, and project grants and heritage identified as a resource for cultural, social and economic gain. However, the complexities and contradictions in governance frameworks between regions, levels, and departments, means making heritage reuse happen can still be very challenging.
Perhaps the most 'variable' variable was how countries support (or not) bottom-up initiatives, our third axis. Even in well-resourced countries reduced capacity and austerity in local government, in particular post financial crisis, has led to an increase in local groups taking up roles and projects in the context of adaptive heritage reuse, for example, by occupying or temporarily using vacant buildings (sometimes illegally), mapping vacant and at-risk heritage and organising (pop-up) events, tours, or cleaning events. Some countries have strong traditions of civic engagement that also translate into heritage and reuse practices. Austria uses its strong regional identities to underpin a tradition of civic engagement and activity, generally in cooperation with public actors. There are policy programmes and funding infrastructure in place to support civic participation and localism in urban and rural areas, partly funded through EU money. Some countries focus on creating space for participatory governance, e.g., through 'commoning' principles in Italy, where this process is embedded into a strong history of public support and private involvement, and civic participation is encouraged in the management of public goods at every governance level. Other countries, such as England, have historically had a large 'other-than-public' sector of voluntary or third sector organisations. 35 Their importance as delivery vehicles has developed further as the state has contracted, and, while funding exists, it is competitive and relies on capacity to self-organise and fund raise. The impact of international policy documents can create a formalised context in which bottom-up processes become easier, as in Flanders, where there is an emphasis on implementing the Faro convention (2005), 36 by focusing resources together with expert advice and funding. Bottom-up initiatives can, for example, be facilitated by land use or change-ofuse policies that enable temporary uses and changes of use. 'Meanwhile use' can help make projects more viable, although they can also exacerbate gentrification and speculation. For this to be feasible, temporary (change of) use needs to be proportional to property taxes, business rates, and other use-based levies. For example, such uses can be more viable if taxes are based on actual use (e.g., based on the square metreage or number of days) rather than a binary system of full pay or no use.
Active civic involvement can also be stimulated by a lack of sectoral coordination and resources, and a weak institutional capacity, but this leads to a case-by-case approach which tends to limit wider knowledge sharing and learning. Moreover, in a highly inflexible system, it can be difficult for those excluded from the system as 'non-experts' to have a voice in what happens to heritage, and for 'first-time' re-users the navigation of these systems is often very challenging. Ukraine and Romania are countries where some bottom-up organised networks exist, without any state support in terms of policy or funding. Heritage protection in Ukraine is dominated by professionals and an expert discourse, whereas heritage reuse is advocated by NGOs and businesses. After the 2014 Ukrainian Revolution, civil society became more active, and adaptive reuse became fashionable among some activists, sometimes with international support. As a result, some policies and projects to promote bottom-up processes are emerging at the local level. In Romania, the heritage system is weakly resourced, highly centralised, and expert based. NGOs have an important role in mitigating the effects of this. They help lobby for minority heritages and guide restoration and reuse processes, mostly on a voluntary basis. In Hungary, civic engagement and the activity of NGOs is explicitly discouraged by the state, and it is extremely hard to undertake bottom-up projects or mitigate the lack of capacity within the system.

Policy Change in the EU Context
It is evident that EU programmes and policies have a significant influence on heritage adaptive reuse in some countries. Especially since the European Year of Cultural Heritage 2018 (EYCH), the practice has become more prominent in EU agendas relating to heritage and culture (e.g., Creative Europe, Agenda for Culture). 37 It is also emerging in agendas on economic growth, urban and regional development, the quality of the built environment and architecture, (e.g., Interreg, Urbact, Urban Innovative Action, Leader, New European Bauhaus), as well as agendas on greening and circular economies, material sustainability, recycling, and waste reduction. 38 Furthermore, EU integration has had a significant influence shaping the planning system in some of the more recent EU member states, as territorial development and planning are to some extent part of the process of EU integration. Changes to planning systems are also influencing adaptive reuse practice. The EU suggests an integrated approach to cultural heritage as a key aspect of sustainable development. This is more successful in countries where a longer-term cultural shift towards embracing adaptive reuse over new construction is visible (e.g., Portugal, Spain) but it is harder to achieve change with highly centralised heritage protection systems where all decisions are made at national level, such as in Romania. In either case, the integration of planning and heritage is complex and slow. Not only does it require an overhaul of existing systems, but capacity-building may also be needed for those who were working in the 'old' system and become tasked with new roles and responsibilities. Moreover, while significant EU funding goes to sectors such as regional development, rural and urban regeneration, culture, sustainability, youth, and tourism that can easily integrate adaptive reuse as a practice, the latter is generally not a specific requirement, neither by the EU nor at national level. Moreover, projects tend to focus on heritage that is easy to capitalise, and minority heritage or bottom-up initiatives remain invisible and un(der)financed.

Conclusion: Learning from Other Countries
Adaptive reuse as a practice has been with us since time immemorial, and as a more explicitly acknowledged and promoted urbanist and urban design strategy for managing the environment, for the last half century or so. But adaptive heritage reuse has only emerged as an explicit sphere of urban policy in recent years. As we have outlined, policy makers have become interested in adaptive reuse as a means of achieving diverse goals, including urban regeneration, tourist development, social cohesion, and environmental sustainability. This is prompted by the specific characteristics of buildings and placessuch as the historical value, aesthetics, size, character of the space on offer -as well as more structural reasons. The latter include managing ever-expanding lists of heritage buildings with a lack of subsequent resources to protect and restore these with public funds, utilising adaptive reuse as part of a wider climate emergency programme and reducing CO 2 emissions and material waste. The EU is also explicitly addressing adaptive reuse through various policies and programmes ranging from climate to regeneration to tourism development, and various countries are putting effort into integrating and streamlining policies and regulations to make adaptive reuse less complicated. In this context, it becomes a matter of acute interest to understand the conditions in which adaptive heritage reuse can flourish.
In this paper we have considered how a range of institutional factors facilitate or impede adaptive heritage reuse across fifteen European countries, that is, the balance between discretion and protection, integrated governance, appropriate human and financial resources and the potential for citizen participation. Importantly these factors should not be considered in isolation but as an assemblage of factors that combine to create favourable or unfavourable conditions for adaptive heritage reuse projects. We have used these factors to generate a typology of institutional circumstances in our selected countries.
From our analysis, it is evident that the main structural issues that create barriers to adaptive reuse are to do with complexity and contradictions within and between planning and heritage systems and overlapping responsibilities. In addition to underresourcing, a lack of integrated procedures, policies, and organisational decisions can slow down processes and make adaptive heritage reuse projects complicated and risky. It becomes even more difficult when decision-makers don't have authority or discretion to deviate from a general set of regulatory standards, or their actions are circumscribed by land use restrictions, building codes, and fiscal, funding, and procurement structures, which are often developed with either new construction or strict heritage protection in mind.
We propose a typology in the form of the three groups -countries where adaptive heritage reuse is common and facilitated, where it is a somewhat established or developing practice, and where it is difficult. The typology proposed should not be considered as rigid or definitive, nor is this intended as a ranking system of countries. The groups were created by a thematic analysis of the institutional context in the specific countries, and are characterised by the trends observed, but countries do not have a fixed place in the typology. No grouping of policy systems should be considered static, because whilst there might be considerable inertia around some variables that are rooted in stable legal systems, discursive traditions (e.g., planning traditions or heritage discourse), or institutional path-dependence, other variables such as access to funding, can change quickly, and consequently influence the whole assemblage.
Indeed, there have been significant structural changes in the last two decades, with implications for most, if not all, countries. In the east of the continent, the end of the Soviet-backed socialist regimes and, for most of our cases, accession to the EU, was a major transforming factor. All our countries developed policy responses to the economic crisis in 2007/8 and all are having to respond to the consequences of the COVID-19 pandemic; the response strategies of various countries will almost certainly influence the policy and resourcing environment for adaptive reuse, albeit in highly variable ways across the fifteen countries.
Our typology is a way to conceptualise the similarities and differences in institutional and policy-contexts that facilitate or restrict adaptive reuse and to help to identify groupings that can offer the most suitable models for adaptive heritage reuse projects applicable in a specific context. Sometimes this is about understanding the formal institutional arrangements, sometimes about understanding how such arrangements maybe 'worked around'. The typology contributes to more informed insights in, and to the possibilities of learning from other policy contexts. Cross-national learning about adaptive reuse can occur both within the proposed groupings of countries and possibly between groupings too. The complexity of the assemblage of people, policies, resources, and institutional differences means that any comparison or idea of transferability needs to be approached with criticality, nuance, and care. To some extent, clusters map onto historical geographic regions, along the 'West', 'East', 'North' and 'South' of Europe. Countries have historically different legal-administrative traditions, with respect to discretionary policy-based systems vs. legally binding approaches and approaches to heritage protection, citizen participation, and the level of integration and discretion in governance, which all influence any transferability of policies and practices. The countries considered also vary significantly in terms of wealth and the scale and role of the public sector. A next step -beyond our scope here -will be to test and develop this typology against case studies of adaptive reuse projects, each with their own specificities and complexities. Equally, we would like to see greater reflection in the literature on adaptive reuse on the institutional circumstances surrounding the implementation of adaptive reuse in project accounts.
Comparative study of institutional context helps illustrate what is possible as well as make the barriers to action visible. It reveals which measures have been explored to make adaptive reuse more achievable and common, but also how to mitigate some of the constraints that exist. For example, good levels of resource appropriately targeted can mitigate inflexibility and bending the aims of urban regeneration or sustainable development policy programmes to achieve adaptive reuse can be very influential. This also means that the role of the EU is significant, even though it has no established remit when it comes to heritage. Its investment programmes can stimulate, favour, and celebrate adaptive reuse as part of developing other sectors such as tourism and the creative industries, but also to address topics such as wellbeing and social cohesion, and of course, climate emergency.
Comparative institutional learning is critical to facilitating future practice. Systems are often path dependent and slow to change. In this context, learning the art of the possible, despite current institutional barriers becomes vital. Education at all levels, peer-to-peer networks, peer-learning schemes, and showcasing example projects can all help with the sharing of practices, knowledge, and experiences. How heritage is conceptualised has undergone profound shifts over the last century and more. From being a tool to valorise the idea of the nation state, to a repository of local identity to be fiercely defended from uncaring growth coalitions, as authors of this paper, we advocate a move to a holistic understanding of heritage as care for our local environment. Adaptive heritage reuse, the positive use of heritage in our daily lives, could and should be integral to this vision.