Memorandum by the Council for British
Archaeology (UWP 73)
THE PROPOSED URBAN WHITE PAPER
The Council for British Archaeology, which has
a membership of over 5,000 individuals and 500 organisations,
is the principal UK-wide non-government organisation that promotes
knowledge, appreciation and care of the historic environment as
a means of sustaining the quality of life of present and future
generations.
We very much welcome the Government's recent
endorsement of PPG15 and PPG16 given by Alan Howarth, speaking
to the Historic Towns Forum. These two documents establish much
of the framework within which the historical and archaeological
issues surrounding urban renaissance need to be considered.
The principles of sustainability are now well
established in national and local planning and conservation policy
(PPG7, PPG12, PPG15). National policy increasingly requires a
holistic approach to the "all pervasive" historic character
of the environment (PPG15 paragraphs 1.3, 2.26 and 6.40). As English
Heritage have noted, The pursuit of sustainability . . . calls
for a long-term view, certainly much longer than the 5- or 10-year
life of local development plans, in which the future consequences
as well as the immediate benefits of development and exploitation
are considered; we aim to ensure that our grandchildren will be
able to enjoy the heritage that we pass on to them, and to study
and appreciate for themselves their origins and culture at first
hand. (English Heritage 1997, Sustaining the Historic Environment:
New Perspectives on the Future p 2).
The fundamental policy requirement relevant
to this White Paper is to "ensure that the means are available
to identify what is special in the historic environment; to define
through the development plan system its capacity to change, and,
when proposals for new development come forward, to assess their
impact on the historic environment and give it full weight alongside
other considerations." (PPG15, paragraph 1.3).
The remainder of this memorandum is structured
in accordance with the issues on which the committee has sought
views.
1. WHICH OF
THE RECOMMENDATIONS
OF THE
REPORT OF
THE URBAN
TASK FORCE
SHOULD BE
A PRIORITY
FOR IMPLEMENTATION?DESIGN
Key Recommendation: Establish National Urban Design
Framework
CBA Comment: We believe that this should be
a high priority provided that such a framework very clearly establishes
strong principles for issues such as:
— how to sustain the local historic
character of the environment while pursuing change;
— when and how to respect historic
spatial patterns;
— how to make the most of imaginative
multi-use and adaptive reuse of historic buildings;
— how to integrate these with local
social and community needs;
— how to retain and reinforce local
distinctiveness through materials, scale, detailing etc.;
— how to avoid poor pastiche;
— how high quality well proportioned
modern design is usually much better than pastiche;
— how similar principles of design
can be established for urban transport and the public realm (improving
the environment in historically sensitive areas at both strategic
urban and neighbourhood/street level, sensitive design and placing
of signage, street furniture, etc.
Key Recommendation: Demonstration projects of
integrated design-led regeneration for different areas
CBA Comment: While this could be very helpful,
we believe that there are already a number of very good examples
that illustrate this, and we would draw attention to the numerous
examples quoted in Catalytic Conversion, (SAVE, 1998) and The
Heritage Dividend (English Heritage 1999) which show how high
quality environmentally led design can result in excellent, cost
effective and socially very successful schemes. The key priority
is to take existing high quality environmentally sustainable examples
and enable contacts to be made so that those responsible for them
can share their experience with new entrants to the field. This
does not necessarily need new pilot projects.
Key Recommendation: Regeneration schemes to be
dependant on spatial master plan
CBA Comment: This should be given a high priority,
but there should be a basic requirement that such plans should
only be acceptable where an assessment of the potential and opportunities
for any historic and archaeological conservation measures or mitigation
requirements are built in. Wrongly handled, master plans can be
too narrow in concept and outlook and then may fossilise poor
solutions. But more all-embracing, environmentally aware and imaginative
plans can provide very dynamic frameworks for arriving at high
quality, low cost, environmentally sound solutions. Master planning
should include fully integrated approaches to resolving environmental
issues (eg the complexities of dealing with archaeology in areas
of contamination) whether or not through formal Environmental
Impact Assessment. The programming of resolving such issues should
be part-and-parcel of the master plan process.
LA's single strategy for public realm and open
space
CBA Comment: We believe that integrated approaches
to the public realm deserves a high priority, again provided that
it entails a clear recognition how important the public realm
is in determining key characteristics of local historic character
and distinctiveness that need to be conserved. We believe that
awareness of this could be enhanced by a more holistic approach
to the public realm, though there is obviously an equal danger
that the effect could be negative if the authority concerned was
less conscious of the historic environment than is the case at
present. We therefore believe that if this were pursued any legislation
or regulation would need to incorporate clear responsibilities
and objectives to enhance conservation of the historic environment
in the public realm.
Amend planning and funding to discourage low density
CBA Comment: While this could reduce impact
on the historic environment and for example buried archaeological
remains, it is equally true that high densities can be very damaging.
In our view it is essential if this were to be pursued, that any
regulations or guidance should establish a very clear principle
to allow lower densities where needed to achieve in situ preservation
of historic and archaeological remains, or sympathetic treatment
and massing of development to respect the setting and spatial
layout of historic buildings and structures.
Design competition
CBA Comment: We would support this only if competition
briefs had clear requirements to take account of historic character
and local distinctiveness.
MAKING CONNECTIONS
Key Recommendation: Home Zones
CBA Comment: We would support this idea again
with the proviso that they should enhance rather than detract
from the historic character of the area.
Key Recommendation: Statutory Local Transport
Plans
CBA Comment: We would support this idea, and
consider that they should incorporate full consideration of how
to improve conservation and amenity of the historic environment
and enhance rather than detract from the historic character of
the area (see above).
Key Recommendation: commit a minimum of 65 per
cent of transport public expenditure to walking, cycling and public
transport
CBA Comment: We would support this commitment
where it enhances conservation and public appreciation of the
historic character of their area (see above).
New bus franchise system if not improved in five
years
CBA Comment: We would support this idea and
recommend that any new system includes requirements to achieve
high numbers of passengers per journey and minimise duplication.
Some historic towns like Oxford, despite a new transport strategies
enhancing use of buses, remain disfigured by the number of empty
or near empty buses in a multiple provider franchises.
MANAGING THE
URBAN ENVIRONMENT
Key Recommendation: Strategic Role to local authorities
for managing whole urban environment
CBA Comment: We would support this idea provided
that it is used to establish much better integration of approaches
to conservation of the historic environment with other aspects
of urban renewal—for example holistic approaches to the
conserving and enhancing the historic character of the public
realm (see above). Part of this should be the introduction of
whole town historic character assessments (as recommended in the
principles established by PPG15 paragraph 1.3 quoted above) to
ensure that the capacity for different parts of town to absorb
change and the historic features and characteristics that make
them distinctive are recognised and discussed with local communities.
Such approach could help to take account of the character of past
rates of change in helping to determine the style and trajectory
of regeneration.
Increased funding to local authorities to support
urban environment
CBA Comment: We support this, provided that
due proportion is given to conservation of the historic environment.
There has been a significant loss of posts covering archaeological
and historic conservation in the last few years, and any additional
funding that at least in part could make up for such loss would
help to redress the trend. A significant level of development
on brownfield sites is likely to involve complex conservation
issues, and we believe that priority should be given to ensuring
that this is adequately covered. By reinforcing local authority
input on conservation issues very early in the process of identifying
land suitable for regeneration, significant later costs of redesign,
unnecessary and expensive mitigation or delays could be avoided,
resulting in better conservation and a higher quality solution.
Experience of heavily subsidised urban regeneration in Ireland
has shown that conservation authorities can be severely stretched
if such subsidy is not supported by concomitant provision for
environmental guidance and regulation. Ignoring this may well
either lead to environmentally very poor solutions or unnecessary
delays.
One-stop-shops in local authorities
CBA Comment: We doubt that this would necessarily
be a good investment. While superficially attractive, the key
is not a one-stop-shop in terms of staff structure, but a one-stop
service, which provides direct access to the necessary expertise.
A one-stop-shop that was based on what was perceived to be the
advice most in demand could merely mean that other issues, that
on some sites might be more important, would be neglected. A system
by which local authorities undertook surveys and prepared dossiers
of all relevant information about sites highlighting all issues
needing to be addressed and arranging flexible, multi-disciplinary
meetings and subsequent contact points would be better than a
more rigid structure.
Town Improvement Zones on statutory footing
CBA Comment: We are not convinced of the need
for statutory Zones. In particular we oppose any definition that
would diminish the environmental protection applicable to brownfield
sites. However, there might be a need for such designation if
it would provide definition of areas where enhanced environmental
advice and expenditure for environmental protection were available
to make the treatment of complex conservation issues more efficient.
Public authorities responsible for sites blighted
by infrastructure projects
CBA Comment: We believe that there is a need
for much better provision to deal with blight, particularly where
historic sites and buildings or areas are concerned. There are
many lessons that still have to be learned from cases such as
the Channel Tunnel Rail Link where numerous listed buildings were
blighted before the final route was chosen.
Strengthen enforcement powers on planning conditions
and nuisance
CBA Comment: We would support strengthening
powers of enforcement for planning conditions; however, we believe
that over-reliance on this can be counterproductive in creating
adversarial solutions to dealing with issues. In general we favour
putting much more effort and resources into early consultations,
so that conditions are fully agreed and built into designs and
contracts from the start. This would then give added strength
to the case when enforcement is necessary.
DELIVERING URBAN
REGENERATION
Key Recommendation: Urban Priority Areas with
package of powers
CBA Comment: We are not in favour of "streamlined
planning consents." This tends to lead to neglect of issues
and short-termism in a situation where long-term environmental
sustainability is crucial to achieving satisfactory, high quality
solutions. In our view, rather than altering the system, much
more effort should be expended on improving the effectiveness
and resources available to deal with early consultations to get
schemes right from the outset. We believe that tax incentives
should include equalisation of VAT for repair and maintenance
of historic buildings with new build, but this needs to be a general
provision as recently implemented in France, not limited to urban
priority areas or just urban renaissance. We support the need
for some incentives for investment in effective urban regeneration,
and in particular would support substantial expansion of the funds
that English Heritage have made available through their incentive
schemes.
Strengthen New Commitment to Regeneration
CBA Comment: We support the idea of regeneration
where it makes sensible use of sites that have been developed
before, especially where this can be done in ways that allow sensible
and sensitive adaptive re-use of historic buildings, and provide
ways of using reinforcing the historic character and local distinctiveness
of places as positive ways of promoting high quality sustainable
solutions. We are also in favour of individual and locally distinctive
new development that will create a lasting legacy that people
will be proud of in the future.
Enable Urban Regeneration Companies to deliver
area projects
CBA Comment: We would support this idea with
the proviso that such organisations would need to be directly
accountable to the communities which they serve, and that their
activities would need to be carefully integrated with those of
the LPA and other key players within the regeneration process.
Establish Housing Regeneration Companies to undertake
regeneration of deteriorated and vacant housing stock
CBA Comment: We strongly believe that the regeneration
of existing deteriorated and vacant housing stock is essential
to the sustainable regeneration of urban areas. We therefore believe
that the establishment of such companies could be very beneficial,
although again with the proviso that such organisations would
need to be directly accountable to the communities within the
areas which they serve, and that their activities would need to
be carefully integrated with those of the LPA and other key players
in the regeneration process. Like the privatised water companies,
any such companies set up by legislation should have statutory
obligations towards conservation of the historic environment.
Special regeneration committees to speed up decisions
CBA Comment: We believe that the establishment
of such committees would be very beneficial in reducing unnecessary
delays in planning decisions, although we feel that the White
Paper should very strongly reinforce the need for the supporting
details for planning applications to be sufficient to provide
the LPA with all the necessary information on which to base an
informed decision. We strongly believe that delays in arriving
at planning decisions can be avoided by ensuring that early consultations
take place between applicants and LPA's so that applicants are
fully informed of the key planning issues, and so that applicants
submit sufficiently detailed applications.
Training
CBA Comment: We strongly support the need to
provide training, particularly to:
— enhance understanding of the opportunities
and potential presented by adaptive re-use and multiple use of
historic buildings as a catalyst of conservation-led regeneration;
— to establish clear understanding
of the fundamental importance of early analysis and recognition
of archaeological and historical conservation issues; and
— to inculcate the need to develop
a clear programme for dealing with conservation issues with often
complex relationships to other issues of design and environmental
mitigation.
We believe that cross-disciplinary training
in general would help different players within the urban renewal
process understand each other's positions and the benefits that
can arise from greater awareness of opportunities to achieve high
quality solutions for complex problems.
2. How policies for employment, competitiveness,
housing, transport and public services should be integrated to
foster urban regeneration and the role of other Government agencies
and the Regional Development Agencies.
We support the idea of integrating a range of
public policy areas which have a bearing on urban renaissance,
and would recommend that conservation of the historic environment
should be included.
Work by both the voluntary sector (Catalytic
Conversion, SAVE, 1998) and English Heritage (The Heritage Dividend
1999) have shown how the historic environment can act as a catalyst
for several different aspects of public policy to be brought together
within a very positive and high quality regeneration that has
lasting value and considerable economic and social benefit.
We suggest that where the historic environment
has the potential to act as a key factor schemes should be developed
in a similar way to the mechanisms well piloted by English Heritage
and others over the last few years. This may provide a model for
other kinds of focus for quality.
3. The future of urban areas suffering from
low demand for housing and social decline
Many such areas are those where too little regard
was paid to the historical and social context of regeneration
in the past—a lesson that needs to be learnt for future
policy. Community-based projects in such areas have been shown
to be beneficial and there is scope for better integration of
historical character of such areas where this has potential to
establish a better sense of local identity. On a much wider scale
there is an imbalance in demand for housing between north and
south, which has established and threatens to exacerbate pressure
on the historic environment in many areas. We believe that the
present policy of demand-led supply of housing may well be increasing
the problems of areas where there is low demand. The review of
demand-led highways provision carried out a few years ago showed
up the flaws of this approach, and within a development context
the change of policy on out-of-town shopping centres has demonstrated
that tighter geographical control of supply can be helpful in
steering demand to more acceptable areas. We believe that this
whole area needs more scrutiny, and that issues such as conservation
of broad historic patterns of settlement should be examined as
part of this.
4. The consequences of the urban renaissance
of housing and business development on greenfield sites
As a general principle we consider that a largely
seamless approach should be adopted to the greenfield/brownfield
debate, so that real pros and cons of alternative strategies can
be weighed up in the allocation of land for housing in development
plans. We are concerned that there has been serious over-simplification
of the issues, such that there is now almost a reversal of the
greenfield-clean—brownfield/dirty formula, into an attitude
of brownfield/good—greenfield/bad mantra. There has tended
to be a failure to recognise the significant conservation value
of brownfield sites—many of these contain important archaeological
remains, historic buildings and structures, and have become havens
for urban wildlife. Equally there has been a failure to recognise
the very degraded character of some "greenfield" areas
that have been under very intensive agriculture and peripheral
development.
The considerable historic value of brownfield
areas for industrial archaeology and the built heritage, and the
potential complexity of important buried archaeology and the added
difficulties of dealing with it in areas of contamination are
matters that must be properly faced, and seen within the wider
context of other environmental issues. These issues are even more
relevant in historic town centres. Exactly the same principles
apply to greenfield sites. The choice is not black and white and
in many cases so-called greenfield sites may be much less environmentally
sensitive than brownfield ones.
5. How planning authorities should be encouraged
to bring about the speedy release of brownfield sites and foster
creative urban designs.
We believe that speedy release of sites and
encouragement of good environmental design could be supported
by a number of strategic actions to ensure proper assessment of
environmental issues prior to release of land. The uncertainties
and expense of archaeological risk and needs of conservation of
buildings can be seen as disincentives to development and "burdens"
on land development. If local authorities did more to minimise
such risks and identify likely environmental mitigation requirements
as part of site assembly and release processes much of this disincentive
would be avoided. This would require additional resources for
local authorities, whether or not they carried out such assessments
in-house. Measures would include.
— Environmental appraisal of carrying
capacity of land potentially available to be released.
— Strategic enhancement of historical
and archaeological records as part of or prior to identification
of areas designated for regeneration.
— Full studies of historical archaeological
and other environmental issues before or during land assembly
and prior to its release.
— Provision of free packages of environmental
information to support appraisals of potential constraints and
opportunities prior to release of land.
— Forewarning of problems and integrated
planning of scheme development.
— Issuing Development briefs and conservation
plans based on desk assessments with land release.
6. Policies relevant to towns and suburbs
as well as cities, including their boundaries
This historic environment of our market towns
is equally important as that of our cities, and many suburban
areas are of historical merit in their own right or contain remains
of archaeological or historic interest, which have been subsumed
through urban expansion. We believe that the key principles set
out elsewhere is this responsible also hold true for such areas.
7. The role of historic parks and buildings
in urban regeneration
Historic buildings made an invaluable contribution
to local urban character and identity and are critical assets
in relation to the quality of the urban environment. We advocate
that the Urban White Paper should recognise the opportunities
for regeneration that the historic environment presents. In particular
we believe that the Urban White Paper should promote and provide
incentives for conservation-led regeneration, fostered through
a Catalytic or Heritage Dividend approach, to ensure the intelligent
and careful adaptive reuse of historic buildings and enhancement
of the wider historic environment of our towns and cities. We
believe such an approach is vital to:
— achieve regeneration that is inherently
grounded on the principles of sustainability;
— improve social and cultural well-being
of urban communities through reawakening a sense of "civic
pride" and "sense of place" in communities where
this is lacking.
Historic parks and gardens can also make a very
significant contribution to urban regeneration. They are essential
to successful urban communities as many of these provide green
open-spaces vital for recreation and relaxation and are in themselves
often of significance in terms of local ecology and urban wildlife.
This is clear from the success of the Heritage Lottery urban parks
programme.
8. What added value a Government White Paper
should provide in addition to other Government announcements on
urban policy
We believe that a White Paper could be of particular
value in helping to establish cross-departmental commitments to
conservation within the context of urban renewal and the particular
benefits to be drawn from the Catalyst and Heritage Dividend approach.
This would help do away with the idea of a "heritage burden"
which has been and to some extent remains a negative, unhelpful
and adversarial concept, entirely unsuited to modern ideas of
sustainable change building on the quality of life that conservation
helps to promote.
We would also like to see any White Paper ensure
that conservation of the historic environment is fully integrated
into every aspect of urban renewal, with a commitment to establish
statutory obligations in this respect for any new semi-private
or state-supported companies and organisations that might be formed
to carry through implementation of policy for urban renaissance.
9. Other matters which may arise in the course
of questioning
Renaissance Fund—whilst we broadly support
the establishment of such Renaissance Funds, as recommended in
the final report of the Urban Task Force, we feel that their use
could be used to remove elements of the urban environment perceived
as "eyesores" which may in fact be of archaeological
or historical significance. We feel that it is important to challenge
perceptions of some of the less-loved and understood parts of
the historic environment rather than just clearing them away.
To this end we recommend that it would be more beneficial to target
such funds to produce high quality sustainable solutions centred
on the Heritage Dividend approach.
January 2000
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