Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by SAVE Britain's Heritage (CAB 12)


  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.


  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.


  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.

previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2004
Prepared 27 October 2004