O.D.P.M.
SELECT COMMITTEE INQUIRY INTO
THE ROLE OF HISTORIC BUILDINGS IN URBAN REGENERATION:
Submission
from the Civic Trust, 24.11.03.
INTRODUCTORY COMMENTS
The
Civic Trust is a charity with over 40 years’ experience of urban regeneration,
care for the historic environment, and of promoting partnership between
national and local government, the development profession, and the voluntary
sector. It also has an active Regeneration Unit which has advises local
authorities on regeneration initiatives. Its aim is achieve the best possible
living and working environment. We welcome the opportunity to submit comments
to the Committee, and will be happy to provide further views and evidence in
oral examination if required.
The
Trust's unique asset is its association with c.900 Civic Amenity Societies,
with a total membership of c.250,000 individuals, concerned with excellence in
public and private development. Many command a wide range of professional
skills and have unrivalled local knowledge. While the historic environment is a
major concern for them, they welcome innovative new development.
An
understanding of the historic environment is important for fostering civic
pride and national and local identity, and for promoting informed and engaged
citizens. The deterioration in the living and working environment, the
continued erosion of the historic environment, and increased public
indifference to "civic" affairs, cannot be unconnected.
A
revised definition of ‘historic’ is required; a selection of pos-1945 buildings
has been Listed, outstanding examples of post-WW2 planning should be protected,
and the whole historic environment is evidence of continual change.
Recent
research shows that the historic environment, and particularly listed
buildings, is not an obstacle to development or regeneration, and that the
historic environment is of fundamental importance to us, as a nation, as local
residents, as individuals and as informed citizens. Our responsibility, and
challenge, as a nation with a long and diverse history, is to ensure that the
old and the new can together contribute both to growth and well-being.
1. THE CONTRIBUTION OF
HISTORIC BUILDINGS TO URBAN REGENERATION
We
regret that 'public spaces' have been omitted from the revised brief; they are
integral elements of the historic environment.
The
Civic Trust has long experience of conservation-led regeneration and the focal
role which historic buildings and public spaces can play in it. Our
Regeneration Unit has conducted many
regeneration projects in a wide range of places including historic
market towns, seaside resorts and former mining communities. Historic buildings
are important to our membership and integral to their aspirations for their areas, and could even be regarded as
critical to the well-being of our townscapes.
The
nationally-known Civic Trust Awards give countless examples of both excellent
new development and of restoration of historic buildings which have contributed
to local regeneration. We can provide many examples.
Converting
a historic building for housing in a deteriorating district may provide the
impetus for people to start moving into, and restoring other buildings. To
attract business to a historic environment, a strong Local Authority-led vision
is important. To make it work economically, the challenge, and the creativity
needed, will be greater than sweeping away and replacing with new buildings,
but this can have greater advantages socially, environmentally and
economically.
Historic
buildings and public space can inspire regeneration through local pressure
groups using them as a rallying point. By contrast, a feeling by the public
that "they" are demolishing loved buildings, and its feeling of
powerlessness when the redevelopment process has no public involvement or support,
creates an indifferent and negative population who feel it is pointless to
vote; that they have no control over, and therefore no responsibility for,
their local environment; and come to see change as something to be fought
rather than encouraged. We believe that
the public will accept change more readily if they feel they have more control;
it is lack of trust in an apparently indifferent 'system', and in
decision-makers, which creates 'nimbys', who are people who have no other way
of showing their concern.
The
economic contribution of the Historic Environment to regeneration is shown by
English Heritage’s figures that every £10,000 of English Heritage investment
attracts £48,000 of matching funding, delivers 177 sq. ft. of improved
commercial floorspace, and delivers two new jobs. The Civic Trust welcomes RDAs
using their investment programmes to promote conservation-led regeneration;
though THE HISTORIC ENVIRONMENT - A FORCE
FOR OUR FUTURE (5.5) recognises
this, the mechanisms for achieving it need to be clearer.
Streets,
paths and squares are the unifying elements of a townscape from the public sees
it. The historic public domain in Chester occupies about one third of the total
built-up area; it is therefore an equally important element of the townscape
and can contribute enormously to the quality of life. In turn, improved quality
of living and working space will encourage more aware, and hence involved and
productive, citizens.
2. THE ROLE AND
EFFECTIVENESS OF THOSE ORGANISATIONS RESPONSIBLE FOR THE BUILT ENVIRONMENT IN
ENCOURAGING URBAN REGENERATION
·
English
Heritage's Heritage Economic Regeneration
Scheme has been successful and should be expanded, as has been the Heritage
Lottery Fund's Townscape Heritage Initiative. English Heritage continue to
support the Civic Trust's Access Awards
(recognising projects which combine access provision with the conservation
requirements of a historic building) and Urban
Design Awards (Best improvement to the local built environment as a
whole).
·
We
welcome the National Trust initiative in extending its brief to the more
'commonplace' and to urban areas (e.g. John Lennon's house, Sutton House in
Hackney). This shows how buildings are, or could become, a focus of local pride
and may also deliver significant regeneration and education benefits. We trust
they will continue to expand their brief in this way.
·
The
Civic Trust has wide experience of regeneration projects would welcome the
opportunity to present examples.
·
The
Church (primarily, though not entirely, of England) possesses a unique national
resource in historic buildings. Many are in decaying suburbs and are often the
only historic building in the area. Too
often the option for redundant churches has been demolition or conversion to
residential use, causing loss of a historic resource for public enjoyment,
education and inspiration. The value of churches in this respect was ignored,
for example, in the Draft Greater London Cultural Strategy. Despite the cost of
maintenance and the decline of congregations, they can still have a role in
regeneration, and the churches should see them as helping to fulfil their
religious/social mission rather than as redundant encumbrances. We can cite
examples of successful reuse by the churches of these underused or redundant
buildings in a way which is both beneficial for local regeneration and in
harmony with their religious purpose.
·
The
Defence Estates are too often sold to maximise financial return but without
regard to their historic value or to DCMS guidelines for disposal of historic
sites. One of our members is undertaking a study of this problem.
·
British
Waterways has a good record on restoration of historic assets, and is inclusive
in its approach, especially in involving children.
·
We
do not consider that Network Rail have the capability or the will to conserve
their substantial portfolio of historic
railway monuments. If they cannot restore their historic properties in the
context of urban regeneration, they should pass them to those who can.
·
Many
of our members report that local authorities - and especially elected members -
undervalue conservation and lack necessary skills or knowledge. Areas which do
have adequate Conservation staff are
too often those which are well-resourced and not suffering from decline, and
where the work of Conservation Officers is more related to the conservation of
a well-kept historic environment than the regeneration of a depressed or
decaying one; but levels of prosperity frequently bear no relation to the
number of historic buildings in an area. Where local authorities have the will
to take positive action to enhance the historic environment, improved powers of compulsory purchase - or
decaying buildings or small, neglected open spaces - would assist them in their
aim.
·
Local
authority commitment is essential, particularly in depressed areas where
private owners have little incentive to take a lead, but they need adequate
resources to be effective. In one case the Civic Trust urged the appointment of
an assistant for an overworked Conservation Officer, but was told that this was
not a priority in a deprived area and that money could not be put into
conservation when the area had other social problems. This demonstrates an
ignorance of the benefits of conservation-led regeneration. We would commend to
you Conservation in Chester (Chester
City Council, 1988) which shows the value of the historic environment in the
economic regeneration of Chester.
3. DOES THE SYSTEM OF
LISTING AID OR HINDER URBAN REGENERATION?
As
we made clear in our response to Protecting
Our Historic Environment, we firmly believe that Listing does not hinder regeneration.
Listing
does not sterilise a site. Indeed, in reality, Listing does not even protect a
site, and it certainly does not cover - nor is it intended to cover - all
buildings meriting Listing. Its purpose is to flag up the fact that "There
is historic environment here". It concentrates the minds of owners,
developers and local authorities, obliging them to recognise the "Power of
Place" and not to treat everywhere the same. The presence of historic
environment can actually generate a more creative approach by obliging people
to think beyond mere demolition and rebuilding.
As
the lessons of the 1950s-80s show (section 4 below), it has an added value in enabling
communities to safeguard derelict but historic buildings which may currently be
unfashionable or unappreciated, but which can eventually be brought back into
uses which may not have been foreseen; a well-known example is Saltaire.
The
case has been made, and will no doubt continue to be made, by those less
sympathetic to conservation-led regeneration, that "too much" has
been listed. However, not all that is Listable is Listed. Further, the 'playing
field' is not a level one. It is not a simple choice between preserving the
historic or sweeping it away and starting again. Firstly, there is already a
presumption in favour of development in most urban locations; secondly, the
'historic environment' does not survive intact as some major form of obstacle
to development. Much was destroyed in redevelopment schemes of the past 50
years now recognised as mistaken, and if it is accepted that the historic
environment is of cultural and spiritual value to the community - as we believe
- it is essential to conserve what
remains.
Thirdly, there is the impact of the Shimizu judgement. This created an
anomalous situation in which listed buildings in Conservation Areas cannot be
demolished or altered without consent, whilst identical buildings in CAs which
are not listed can undergo near-total demolition without consent. If the
historic environment is to play its proper role in regeneration, this must be
remedied by reversing the Shimizu judgement.
Conservation is of public value in its own right.
Conservationists welcome excellent new development, asking only that it
respects and enhances the existing historic built environment and the public
realm.
4. DO THOSE ORGANISATIONS
RESPONSIBLE FOR URBAN REGENERATION GIVE SUFFICIENT REGARD TO HISTORIC BUILDINGS
AND PUBLIC SPACES?
·
Our
comments under (2) are also relevant to this section.
·
We
believe that there has been a loss of public trust in architects, developers
and planners, after the development 'excesses' of the 1950s-80s, when the
hearts of so many historic towns and cities were destroyed in the name of
'progress', so many of which are now acknowledged as a mistake. As a result,
there has been a significant loss of potentially imaginative and inspiring
schemes. The Civic Trust aims to work as an intermediary between the
development profession and the public, to restore that trust and to help them
work together on innovative schemes which restore historic buildings to good
use but also integrate new development sensitively into the local landscape.
·
One
of our members' most consistent complaints is of frustration at their inability
to persuade local authorities to include good design of the public realm in
their remit. There are excellent guidelines, from, e.g., English Heritage, but
they have no force and so are often disregarded, particularly by those
responsible for maintenance of the public realm - e.g. highway engineers who
work 'by the book'. The Government must take a lead in setting minimum best
practice standards and requiring sensitivity to local conditions (the recent
change in the Traffic Signs Regulations, enabling signs on poles to be
dispensed with where yellow lines are installed, is a positive, if small example; Nottingham has already
removed large numbers). Good design must be a specific remit of planners. We
understand that in York, the installation of pink tactile paving was authorised by Members who did not regard
it as an aesthetic issue, and in the Highgate Conservation Area, London, old
stone paving was replaced by pink tactile paving despite advice from English
Heritage that better alternatives were acceptable.
·
A
major source of concern revealed by the Power
of Place consultation was poor skills levels in planning and conservation
departments, and the lack of priority and resources allocated to conservation
and design. This is compounded when faced by developers with the legal and
financial resources to wear them down; our members report local authorities giving inappropriate
planning permissions for fear of incurring costs on appeal. This can be a
major obstacle to conservation of the
historic environment.
·
For
similar resource reasons, planning enforcement is often ineffective, for
example, when historic shopfronts are deliberately destroyed by their owners -
e.g. Tottenham High Road, London, where the problem is exacerbated by owners'
ignorance of the historic, social and economic value of the properties they
occupy.
·
Restoration
of historic buildings is made more difficult by a dearth of skills in
traditional building crafts. Promoting these could provide local employment,
broaden the national skills base, aid public appreciation of the historic
living environment, and provide a high-value specialist skills resource which
could be exported to other countries.
·
The
EU should specifically refer to the desirability of encouraging
conservation-led regeneration.
·
The
Government’s commitment to 'encourage' Local Planning Authorities, when
preparing community strategies, to consider the role of the historic
environment in promoting economic, employment and education opportunities, must
go beyond mere encouragement. Our members complain of indifference or even
hostility from local authorities who equate the historic environment with
elitism and irrelevant to the problems of deprived and derelict areas.
5. DO ALL GOVERNMENT
DEPARTMENTS TAKE ADEQUATE ACCOUNT OF THE HISTORIC ENVIRONMENT?
Our
comments under (2) relate also to this question. Members express concern about Government departments' failure to
follow DCMS advice on the sale of redundant historic assets - an example was
the Listed College Farm, Finchley, only saved after a long fight by local
people against the Highways Agency's determination to sell it for
redevelopment; Rudi Vis, MP could elucidate. There are particular concerns over
redundant Defence estates.
6. WHAT FISCAL AND
LEGISLATIVE CHANGES SHOULD BE MADE?
·
4.6
of HE-FF affirms a commitment to an effective statutory framework for
protecting 'all elements of the historic environment'. We hope the Committee
will recommend measures to achieve this.
·
Equalisation
of VAT at 5% for new build and repairs to existing buildings could be the
single most important fiscal change. The current differential, which places VAT
of 17.5% on repairs and refurbishment, while new building and even demolition
are zero-rated, is a major obstacle to restoring the historic environment. We
regret that the Government, in the Planning Green Paper, committed themselves
only "to take this... into account carefully when considering the future
VAT treatment of building work", but are more encouraged by its recent
efforts to address the issue at EEC level.
·
We
deplore the EU ruling against Gap Funding. The reasons given, that it would
restrict fair competition across the EU, are unconvincing. The money would be
returned to the public sector, and we fail to see how subsidising a development
scheme in Liverpool would deprive anyone in Lisbon, Livorno or Lipari. Gap
Funding would meet EU cultural objectives to bring historic buildings back into
reuse. We hope the Committee will recommend the Government to press the matter
with the EU.
·
Restrictions
which make it impossible for local authorities to prevent the demolition of
buildings within Conservation Areas should be removed.
·
As
stated under Q.3, failure to remedy the anomalous situation created by the Shimizu situation will diminish Local
Authorities' ability to achieve sensitive regeneration of historic areas.
·
The
development of Lottery and English Heritage Funding for voluntary groups was
mentioned in HE-FF, but did not feature in the action points. Many local groups
are anxious to save and restore historic buildings, but cannot compete with
professional financial and development interests. English Heritage's current
budget makes it impossible for it to assist financially. We are disturbed at
indications that the remit of the Heritage Lottery Fund in regard to the built
heritage may be restricted; in our view, heritage projects - funded, e.g.,
through the HLF's Local Heritage Initiative - are surely the ideal medium for
Lottery Funding, which should be geared towards making it easier for local
groups to pursue them. It could help materially in enable the backlog of
repairs to buildings at risk, etc., to be cleared.
·
HE-FF
is very positive in wanting to ensure that local policymaking takes proper
account of the value a community places on particular aspects of its
environment, but less so in that it is only in the context of 'character
assessment'; it proposes no mechanism for greater public involvement in the
protection of its own historic environment. Public bodies should be required to
take full account of the historic environment, and community aspirations
for it, in preparing strategies.
·
We
sought a commitment to working with local business to secure improvements to
the public realm. HE-FF is silent on
this.
· The use of S.106 Agreements should be extended to permit improvements to the public realm.
APPENDIX 1
==========
ARE THE MEASURES PROPOSED BY
THE GOVERNMENT IN THE HISTORIC
ENVIRONMENT: A FORCE FOR OUR FUTURE [HE-FF] ADEQUATE? WHAT OTHER MEASURES SHOULD BE INTRODUCED?
We
regret that this question, which appeared in the original 2002 Brief, was
dropped from the revised brief. The conclusions, and promises, made in HE-FF are, we consider, integral to the
remit of this investigation - possibly more so, following the appearance of the
Planning and Compensation Bill and DCMS's Protecting
Our Historic Environment consultation which expired on 31st October, 2003.
We therefore include our comments on this question, drafted with our original
response to the Select Committee's 2002 notification, in the hope that it will
be given due consideration as a part of the inquiry process.
HE-FF
and Protecting Our Historic Environment
are the Government's most recent statements on the historic environment. HE-FF
made many positive statements about the importance of the historic environment,
but was weak on proposals for implementation, and we hope the Committee will
hold the Government to its stated intentions. MORI's 2001 poll for English Heritage on public attitudes showed that the
historic environment is important to the great majority of people (although
regrettably HE-FF understated this, merely observing that "most people
acknowledge the significance of the historic environment", and misrepresented
the poll's conclusions by taking its statement, "a substantial number do
not see it as having any relevance to them", out of context.
A
major concern at the consultation stage was the deplorable lack of conservation
skills and staff both in local authorities and private practice, and the poor
levels of training of Councillors responsible for planning decisions. This must
be resolved by making care for the historic environment, and improved levels of
training, a statutory duty, and that Government departments be required to
follow DCMS advice on the sale of redundant historic assets (see above).
If
the historic environment is to play an effective role in regeneration,
planners, developers and the public must be educated to understand and appreciate
it. Public involvement will aid social inclusion, as, for example, has been
done by the Hackney Society. It is therefore regrettable that HE-FF's proposals
for widening the nationally popular Heritage Open Days, administered by the
Civic Trust, into a Heritage Week have been dropped.
We
commend HE-FF's suggestion that historic environment organisations, including
voluntary organisations, be encouraged to get involved in the Creative
Partnerships programme aimed at schools in deprived areas. It underlines the
importance attached to the historic environment by the Government by stating
that it "wants to see more regeneration projects, large and small, going
forward on the basis of a clear understanding of the historic environment…”;
this linking of educational, social and economic values is fundamental.
We
therefore urge the Committee to emphasise to government that it already has a
massive, and internationally unique, resource already in existence to help
promote the regeneration, social and educational (not to mention economic)
benefits of the Historic environment - namely, the Civic Society movement,
comprising nearly 1,000 groups nationally with a membership comprising close to
a third of a million of those citizens most actively concerned about, and
active in, the improvement of all aspects of the living and working
environment. In addition, there are bodies such as local history and
archaeological societies. There are, of course, areas where these do not yet
exist - often those areas of greatest deprivation - and this national voluntary
resource would be willing and anxious to lend their expertise to those
communities where it does not yet exist. We would be delighted, and anxious, to
work with the Government to realise the potential of this active citizen body -
for example, in the context of the Government's stated aim of introducing
Statements of Community Involvement in the current Planning and Compensation
Bill.
On
economic potential, Chapter 5 of HE-FF looks at valuing the historic
environment for the millions of tourists it attracts. However, it fails to
recognise either the regeneration potential of a cared-for historic
environment, or its potential for spreading the economic benefits of tourism
more widely. For example, Greater London comprises a large number of historic
towns and villages which retain much of their historic character and buildings,
yet tourism in London places an overwhelming emphasis on the centre. Empowering
local authorities to take greater care of these historic local centres, many of
them in declining suburbs, could bring tourist revenue to local businesses. In
the case of Greater London, for example, with its many deteriorating suburbs
surrounding the cores of attractive historic villages, a "London Village
Tourist Trail" could be a powerful factor for economic, social and
educational regeneration.
APPENDIX 2
==========
PARKS AND PUBLIC OPEN
SPACES:
We
likewise regret that this was omitted from the revised brief. Public parks and
open spaces can be a force for regeneration. Neglected parks, as Finsbury Park,
London and many others have been, drag down the appearance and economy of a
neighbourhood (the Select Committee's own excellent report into Parks covered
these aspects in great detail). Restored public parks, equipped with new
facilities, as in Southwark Park, Heaton Park, Manchester and Leazes park,
Newcastle, have the opposite effect.
APPENDIX 3
=========
Our response to English Heritage's Review of Policies relating to the Historic Environment (2000) contained items of relevance to this inquiry, on such issues as the value and maintenance of the historic environment. A copy is attached as Appendix 3.
APPENDIX 4
=========
Similarly, we believe that our response to the recent DCMS Consultation Protecting our Historic Environment contains comments on a number of issues relating to attitudes towards, legislation affecting, and care of the Historic Environment, at local, regional and national level, which will impact materially on the ability to implement the present Committee's recommendations. We therefore attach a copy as Appendix 4.