Memorandum by SAVE Britain's Heritage
(CAB 12)
INTRODUCTION
1. SAVE Britain's Heritage is a registered
charity. It was founded in European Architectural Heritage Year—1975—to
campaign publicly for the protection of threatened historic buildings
and areas. Through press releases, exhibitions and reports it
has championed the architectural heritage of this country. There
are many buildings now restored and in beneficial use that, had
it not been for SAVE, would have been destroyed.
2. SAVE has been at the forefront of the
conservation movement in the UK, pushing for changes in legislation
and in government policy to give greater protection to our built
heritage, and in raising awareness amongst politicians, professionals
and the public about the vital contribution made by historic places
and spaces to the quality of life in this country.
3. In particular, SAVE has championed historic
areas and building types that have been under-appreciated or which
have not previously been recognised or studied and which have
been threatened by redundancy, disuse and demolition. These have
included an enormous range of buildings, from Northern textile
mills through to railway architecture, from historic hospitals
and mental asylums being closed down, to historic military buildings
coming out of use. Most recently, SAVE has published (April 2004)
a book illustrating the large number of historic law courts, many
of them fine buildings with magnificent interiors, which currently
face an uncertain future.
4. SAVE has always sought to demonstrate
that old buildings can be put to new uses. On many occasions,
SAVE has worked with leading contemporary architects—for
example with Lord Rogers of Riverside at Billingsgate Market—to
show how buildings can be imaginatively converted. SAVE has championed
conservation in numerous historic towns. These have not been necessarily
the picture postcard historic towns and cities like York or Bath,
but more often the gritty Victorian cities of the industrial north
which in the 1970s and 80s were unloved, unappreciated and seriously
under threat from decay and misguided demolition. The town reports
prepared by SAVE during the 1980s on places such as Halifax, Huddersfield,
Leeds, Liverpool and Manchester identified threatened historic
buildings and areas. They opened the eyes of both the public and
the politicians in these towns to the potential these buildings
could have for regeneration, a potential that is currently being
realised
5. In SAVE's first report in 1975 we wrote
"it has become one of the clichés of political debate
that conservation is . . . the hobby of an elite determined to
fight against the inevitable overriding dictates of modern economic
growth". This cliché remains as untrue now as it was
then, with the popular concern for the historic environment finding
its voice most recently in the "Restoration" series
on television.
6. Conservation is not a backward looking
nostalgia for the past. It remains, in our opinion, a constructive
cause requiring vigorous championing in the face of intense pressure
for redevelopment pursued by powerful commercial interests. CABE
is the government's champion for good architecture. Its role is
to promote high quality design both in terms of individual buildings
and in terms of the built environment as a whole. It is thus at
the interface between the commercial interests promoting new developments
and the public interest. It is a position of great influence.
It is also a position with inherent dangers. We do not doubt that
CABE has an important, indeed vital role, but as an organisation
funded by government it must be clear that in terms of this interface
its objective must be to work in the public interest.
7. We are seriously concerned that as CABE
has evolved there has been a blurring of boundaries and the interface
has become too much skewed towards promoting development. Fascination
with the new can be beguiling and is too easy to write off the
past as mere history. Our concerns, which we outline below, focus
principally on this issue of balance and in ensuring balance in
the public interest. CABE may think it exists to champion the
new but it needs to realise that its agenda must recognise the
importance of context, and that the views of those who understand
and appreciate historic context must be heard.
8. A government body too closely aligned
to interests associated with commercial property will inevitably
have difficulty seeing the point of view of bodies such as SAVE.
It is easy to write off such bodies as being zealots or conservation
fanatics. SAVE's record and achievements over the past 30 years
resoundingly demonstrate that SAVE is not anti-modern architecture
nor is SAVE impractical or unrealistic in its thinking.
9. History does not stop at some arbitrary
point and SAVE is fully aware that the great buildings built today
are the heritage of tomorrow. The way in which CABE undertakes
its work must be fully accountable. It must take cognisance of
all stakeholders—including those that represent the historic
environment. In order to achieve this CABE must be broadly enough
based to fully understand all the issues on which it pronounces.
If it is not, and given its influence, lasting damage will be
done to our towns and cities and the mistakes of the 1960s repeated.
10. Government spending on new public buildings
and on regeneration and renewal is at an all time high. Whilst
seeing great cities like Leeds, Manchester and Liverpool—particularly
with the City of Culture status to help it—turning the corner
is something we can all take pride in, there is a real danger
that the anti-heritage agenda which inevitably runs parallel to
substantial commercial interests is unduly influencing the government's
regeneration agenda and is being reflected in CABE's current attitude
to the historic built environment and to its views on cases where
new meets old.
CABE'S OVERALL
PRIORITIES FOR
INVESTMENT AND
DEVELOPMENT AND
ITS RELATIONSHIP
WITH OTHER
BODIES (NATIONAL
AND LOCAL)
11. As an organisation, CABE has grown remarkably
fast. The budget of the former Royal Fine Art Commission was less
than £1 million. Now, five years on, CABE has an annual budget
of some £12 million. From a handful of staff, it now has
over 70. It has a broad arena of work and on the whole we feel
that it has succeeded in raising the profile of the importance
of good design. This we applaud. However, with this meteoric expansion
in five years comes the challenge of ensuring that the budget
is spent wisely and of ensuring that priorities for investment
and development are carefully chosen and then sensibly pursued.
12. In our view, CABE needs to recognise
that it has to deal with a broader church in terms of its stakeholders
and give much greater weight and recognition to those concerned
with the historic environment. By this we do not just mean government
agencies such as English Heritage, or umbrella bodies such as
the Civic Trust. CABE needs to understand that national and local
civic societies have a vital and constructive role to play in
its area of business. It was illuminating to see such bodies virtually
absent from the list of stakeholders interviewed as part of CABE's
recent Stakeholder Review. Why was this, we ask?
13. We do not propose to address every area
of CABE's work in this submission but rather to single out one
area where CABE is focussing its efforts that gives us particular
cause for concern at the present time (our separate comments on
Design Review follow on in the next section). CABE's current Corporate
Strategy is based around the idea of "Neighbourhoods".
The concept of seeing the built environment in terms of local
areas and in terms of the way local people perceive and respond
to neighbourhoods is a laudable one. Yet CABE is currently engaged
in a major area of work which seems to us to fly in the face of
the underlying ethos of creating sustainable neighbourhoods.
14. This is CABE's current role in East
Lancashire as part of the Housing Market Renewal Initiative in
the Pathfinder Area. Whilst in some areas earmarked for Pathfinder
Schemes the quality of the urban environment and the quality of
the architecture within them is unquestionably poor, some of the
areas in East Lancashire where demolition is proposed are potentially
attractive nineteenth century stone built terraces which make
up a coherent townscape alongside the churches and other larger
buildings which give character to the area. Examples include Darwen
and Nelson. These terraces are likely to be demolished and CABE
appears to be supporting this initiative. These smaller towns
undoubtedly have serious economic and social problems but we seriously
question whether comprehensive clearance is the best answer. Before
embarking on this initiative, we feel that CABE should have sought
the advice of those with knowledge of conservation and adaptive
re-use. Areas of historic towns and cities have been abandoned
before and in the past 30 years transformed through conservation.
In 1975 a substantial area of Frome made up of weavers' cottages
known as Trinity was virtually wholly derelict. Now it has been
restored and the houses re-occupied. The saving of Spitalfields
east of the City of London is probably best known, but there are
many examples of areas of towns further away from commercial centres
which have been rescued from serious decay such as the Railway
Villages in Derby and Swindon, and parts of large Macclesfield,
all of which were threatened with clearance. Clearly lessons can
and must be drawn from these cases. It is not clear to us that
CABE has sought to do this or engage those with knowledge of conservation
into the debate about the future of these areas.
15. Large scale demolition in the past has
often involved appalling social disruption where not just the
fabric of the building but also families, businesses and communities
have been broken up. The pain and deprivation caused by the loss
of the personal heritage of home, cherished street or familiar
surroundings has been cruelly underestimated. This was the lesson
of the 1960s. We are faced with this situation again in the North
of England through HMRIs currently being enacted under the Pathfinder
initiative and CABE is actively engaged in the process. We suggest
that in many cases a more appropriate solution exists but failure
to engage more comprehensively with those concerned to protect
the historic environment will prevent a proper debate from taking
place with the result that an agreed strategy is unlikely to be
evolved. The saga of Nelson where CABE appeared to promote clearance
whilst English Heritage pressed for retention is a case in point.
16. In these cases there has also been a
failure to take into account the views of those who live in and
use the buildings proposed for demolition. In many HMRIs these
communities are strongly in favour of retaining the buildings,
which in many cases they own or have lived in for decades. Neighbourhoods
are as much about people as they are about the buildings yet mechanisms
for listening to and properly taking on board their views are
not properly included in the HMRIs or indeed in CABE's Corporate
Strategy. Given the priority in CABE's strategic plan of investing
more resources in working with the HMRIs, consultation with communities
and stakeholders and taking on board their comments should be
a priority.
17. The relationship between CABE and English
Heritage remains one that appears fraught despite reassurances
to the contrary. For example, in spite of their joint guidance
on Tall Buildings, each organisation seems to interpret it differently.
English Heritage seems (rightly) nervous of CABE taking on issues
and areas that have traditionally been its territory. Given CABE's
record on conservation, English Heritage's fears would seem to
be well placed. The dilemma is of course that unless CABE does
engage properly with historic environment issues, it is likely
to continue to attract criticism on account of its one-sided approach.
18. One positive development has been the
emergence of the English Heritage Urban Panel as a joint CABE/EH
panel. This initiative, which we believe was encouraged by CABE,
is to be welcomed and there are lessons to be learnt here. The
relationship with other heritage bodies—such as national
and local amenity societies—is not currently one of mutual
understanding or trust. This is to be lamented and contrasts,
in our view, with the much more positive relationship bodies such
as ours had with the former Royal Fine Art Commission which, despite
its acknowledged faults, did work hard to listen to other points
of view and to be broad-minded in its approach. Whilst CABE has
hugely expanded its scope of work far beyond that of the RFAC,
there is certainly the perception on our part that attitudes to
what constitutes a quality built environment have narrowed, negating
or marginalizing heritage.
19. John Mansfield's recent article in The
Journal of Architectural Conservation highlighted the role
of CABE in conservation policy. He argues that having been recently
established and having evolved rapidly, CABE has begun to present
a more pervasive agenda that goes beyond mere guidance and may
threaten the potential introduction of a series of non-regulatory
requirements that need to be addressed by developers. The author
sets out at some length the problems with CABE's guidance, and
the Institute of Historic Buildings Conservation suggests that
his article should be required reading for all conservation professionals.
Particular reference is made to "Moving Towards Excellence
in Urban Design and Conservation" where CABE's 11th hour
involvement to skew the content led to IHBC's refusal to endorse
it.
20. Within CABE's Corporate Strategy there
is currently no recognition that the existing historic fabric
of towns and cities can be reused or adapted to meet its vision
for 2010. CABE states that the "acceptance that good design
contributes both to more functional and safer places, and also
to the well-being of society, generating economic, social and
environmental benefits". Yet it is widely acknowledged
that the preservation and reuse of existing historic environment
meets these same aims.
DESIGN REVIEW
21. We hold that with the conservation of
the built environment comes the civilising influence of visual
continuity in our surroundings. Here good design is essential
in the historic environment. SAVE firmly believes conservation
and good design can and should go hand in hand. It greatly saddens
us therefore to see that the historic environment seems to take
second place to new build in CABE's assessment of schemes.
22. It is well established that conservation
can effectively lead the regeneration of historic towns and areas
through the thoughtful re-use of historic buildings and intelligent
responses to these historic buildings by architects and planners.
Our experience of dealing with CABE has not shown us that the
organisation has a deep appreciation of the positive role the
historic environment has to play in the regeneration and renewal
of our towns and cities.
23. As the case studies below illustrate,
we are deeply concerned that there is insufficient expertise available
to CABE on the historic environment or, if that experience does
exist, it is not sufficiently represented or taken heed of. CABE's
record in terms of Design Review does not show it to be sympathetic
to the historic environment. Although SAVE only takes up a limited
number of key cases, in the last three years there have been a
number of occasions where we have been deeply concerned at the
position taken by CABE's Design Review Panel and the views expressed.
24. Design Review is an important function
and we can well see the merit of it. Encouraging high quality
design is exactly what CABE should be doing and Design Review,
objectively carried out, can be a truly positive influence. However,
many of the schemes approved have a strong, frequently unsympathetic,
impact on the historic environment in spite of the quality of
the design in its own right. CABE's endorsement of a scheme's
design is often then used by developers as a reason to negate
the heritage-based arguments put forward against a scheme. The
result is that heritage concerns are over-ridden (in spite of
the presumption in favour of preservation in planning guidance)
and local authority officers are forced into a position whereby
they are not able to advise their planning committees to turn
down what would be a hugely inappropriate scheme with a lasting
negative impact on the wider historic environment. Whilst CABE's
advice is non-statutory, it carries enormous weight and influence
within the planning system. This is exacerbated by the advice
so often being given pre-planning and in camera before a scheme
has entered the public domain. Were advice purely to focus on
issues of design, consultation pre-planning might be acceptable.
What is not acceptable however is for CABE as a publicly funded
body to actively promote development schemes being put forward
by commercial developers whilst the public and other stakeholders
are kept in the dark. Not only do we feel that CABE lacks appropriate
expertise in conservation and historic buildings matters but we
are concerned too that the increasingly large number of schemes
coming to Design Review means that CABE is unable to give sufficient
consideration to the complex issues raised by most large schemes.
25. In a country as densely developed as
England it is almost inevitable that new development will take
place next to or near to historic buildings and areas. For this
reason it is essential that design is looked at in terms of the
context of the wider historic environment, and so there is a clear
need for expert input into CABE's design review process from those
actively involved in the conservation and preservation of the
built environment. Likewise, where cases do not go to the design
review panel, but are dealt with by officers, there is a need
for expertise within the staff of CABE on the historic built environment.
We are concerned that at present this expertise does not exist
within CABE. CABE has produced two publications, Building in
Context and Design Review. The former contains very
clearly laid out guidance on how a proposal for a new building
in a historic area should be assessed. The latter document sets
out the criteria by which CABE assessing schemes during the Design
Review process. Yet, as will be seen from the case studies below,
it seems to us that CABE does not apply its own guidance when
assessing schemes. If it did we cannot see how it could have arrived
at some of the views it did.
23(a). Kingston Mills, Bradford on Avon
Bradford upon Avon is one of England's finest
historic towns. At the centre of the town lies an old factory
site, clearly ripe for redevelopment. Proposals put forward by
Taywood Homes for a large Docklands style development in this
most sensitive of locations were approved by CABE, although the
plans conflicted with the local authority's development brief
for the site. We remain entirely at a loss as to how the scheme
could have been endorsed without proper reference to the setting
of the development, at the focus of the natural amphitheatre around
which the town is built, and to the built form of the town. The
scheme was strongly opposed at a local and national level by numerous
independent bodies and has been withdrawn.
23(b) The Governor's Garden, Berwick
Upon Tweed
The Governor's Garden in Berwick Upon Tweed
forms the setting of the Grade II* listed Governor's House and
is next to the Grade I listed Scheduled Ancient Monuments of the
town's bastion walls. Developers put forward proposals for a block
of 40 flats in the garden, in line with one of the garden walls.
The design was loosely based on one of the massive quayside warehouses,
which are outside the town walls and entirely different in character
to the rest of the historic town. The scheme also went against
the development brief prepared by the local authority for the
site. CABE endorsed the scheme, and our questioning of this was
met with a sharp rebuttal that development could easily have happened
there at some point in history. Given the importance of the site
in the history of the town, this is simply not the case. At appeal,
the Inspector agreed with this and the appeal was rejected.
23(c) Toddington Manor, Gloucestershire
At Toddington Manor in Gloucestershire we were
surprised to learn that CABE had endorsed one of the most controversial
enabling development schemes we have come across. CABE's advice
was that the principle of massive development on the site was
acceptable in spite of the Grade I listing of the house, the inclusion
of the surrounding land in English Heritage's Register of Historic
Parks and Gardens, and designation as an area of outstanding natural
beauty. The historic house is of the highest importance in terms
of architecture and design, designed by the chairman of the committee
for the rebuilding of the Houses of Parliament. It remains externally
unaltered since completion in 1835 and there have been no radical
alterations of its setting since then. The reasoning behind CABE's
acceptance of the principle remains unclear and seems to demonstrate
a lack of understanding of the law and guidance that exists for
listed buildings and conservation areas. A letter of complaint
from SAVE to CABE was again met with a sharp rebuttal and our
complaint was not accepted as such the grounds that no fault could
be found in the process that led to this conclusion. We cannot
accept this explanation. Once again, there was strong local opposition
to the proposals.
23(d) Span 4 of Paddington Station
This carefully designed Edwardian extension
to Brunel's Paddington Station was dismissed as `pastiche' and
unimportant by CABE in spite of the fact that it is an integral
part of a Grade I listed building. The internal space has been
hidden from public view for over 10 years—indeed longer
than CABE has existed. The comprehensive dismissal of the importance
and interest of Span 4 formed the basis for Westminster City Council's
decision to permit demolition, tipping the balance between community
benefits and the benefits of retaining part of a Grade I listed
building in favour of demolition. We are at a loss as to why CABE
took it upon itself to judge the quality of the existing building
(which it could not have seen) and then publicly state this position
and express its judgement that the proposals would be more appropriate
to Brunel's trainsheds. Images of the replacement building's interior
are minimal and inadequate. Given CABE's remit of commenting on
new design alone, it is strange that it felt compelled to make
this judgement.
23(e) The General Market Buildings at
Smithfield, London
The General Market buildings, which date from
1888, are currently the subject of controversial redevelopment
plans that would see the demolition of these 2½ storey buildings
and their replacement with 9 storey office block totalling over
750,000 square feet. The buildings currently sit in a conservation
area specifically extended to include them and form part of a
cohesive group of market buildings which are simply the grandest
in the UK. CABE's comments on the proposals ignored the quality
of the existing buildings and barely took into account the effects
of the proposals on the conservation area and surrounding historic
buildings.
26. The issues raised by the above cases
inevitably lead us to question of the accountability of CABE.
It is important that a publicly funded body as influential in
the formation of public policy as CABE is properly accountable
and is run to the very highest standards of objectivity. We cannot
help but conclude that the pro-development stance that is invariably
adopted is the result not just of having insufficient conservation
expertise available but of having too many professionals connected
directly with the development industry either as Commissioners
or as Design Review Panel members. There is in our view a lack
of balance.
27. There is a need to understand what conservation
advice is contributed from members of the Design Review Panel
or in the cases where schemes are dealt with by officers to see
what advice is sought with reference to the historic environment
and what weight is attached to it. At present this is entirely
unclear yet in order to inspire confidence in the process, ensure
accountability and limit future controversy, clarity is needed
and proper records should be kept.
28. We are concerned over who refers cases
to CABE. Early in its existence it would appear that the DETR
expected local authorities to seek CABE's advice on schemes. However
in the case of pre-application consultations the DETR stated in
a letter of 15 May 2001 to Chief Planning Officers that "[CABE]
therefore welcomes approaches from local authorities and others
at the earliest possible stage". It does not make it clear
whether "others" meant all other planning authorities
such as national parks authorities or developers. It would appear
that this has been interpreted in the widest sense, with promoters
of schemes seeking the blessing of CABE for their schemes as a
means of helping them through the planning process. This leaves
CABE open to the accusation levelled at its predecessor, the RFAC,
of being an architect's club.
29. We feel that the difficulties faced
recently by CABE over charges of conflict of interest were inevitable
given the way CABE has evolved its procedures for Design Review
in recent years. To sum up: CABE needs to develop a greater sense
of openness and a greater willingness to engage with those concerned
with the historic environment. It needs to develop mechanisms
for looking at projects in the round giving adequate weight to
historic environment issues. Most significantly, it needs to have
at the forefront in all matters a clear understanding that it
is not there to promote development but to act in the public interest.
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