Memorandum by the Regent's Park Conservation
Area Advisory Committee (CAB 17)
1. The Regent's Park Conservation Area Advisory
Committee resolved at its meeting on 4 October that the following
statement be submitted to the Inquiry.
2. The Regent's Park Conservation Area Advisory
Committee was established in 1983 by the London Borough of Camden
to advise on all matters relating to the conservation area. The
Advisory Committee brings together local community interests with
professional and other experts, to produce advice based on an
informed dialogue between as wide and inclusive a range of interested
parties as possible. All Committee members are volunteers, and
the Committee consists of nominees from local groups, professional
bodies (RIBA), and local and national amenity societies (Victorian
Society, Georgian Group). Although established by Camden, the
Committee includes nominees from the City of Westminster to ensure
that the Park is considered as a whole. The Committee meets every
month and considers all planning and other applications affecting
the conservation area.
3. The Advisory Committee's comments here
are based on our experience of the working of CABE on a scheme
of development at St Katharine's Precinct, within the Regent's
Park Conservation Area in Camden, on which CABE commented on 25
July 2002.
4. The proposal, by the Crown Estate, involved
the development of a site immediately adjacent to several Listed
Buildings, including St Katharine's Church. All parties agreed
that the planning application raised major issues relating to
the preservation or enhancement of the character and appearance
of the Regent's Park Conservation Area, and to the setting of
the neighbouring Listed Buildings.
5. The Advisory Committee wishes to raise
the following points.
6. CABE can review applications without
making a site visit. We understand that in the St Katharine's
case CABE's advice was made without a site visit.
7. In our view it is fundamentally unacceptable
for advice on a planning application to be made in the absence
of a good knowledge and understanding of the application site:
normally this would involve a site visit.
8. It is an accepted and fundamental principle
of architectural design that a scheme should respond to the site:
it is clearly very questionable whether a scheme can be properly
assessed in the absence of a good knowledge and understanding
of the site.
9. In a case where the main considerations
are the effect of a proposal on the character and appearance of
a conservation area, and on the setting of neighbouring Listed
Buildings, a detailed knowledge of the site is an essential element
of the process of development control, to which CABE's comments
are supposed to contribute.
10. CABE's review process, without a sound
basis in site specific consideration, profoundly undermines the
planning process and public confidence in that process.
11. It is not clear to us that CABE has
adequate knowledge or understanding of the historic environment
to undertake the effective review of schemes affecting the historic
environment. The relation of CABE to English Heritage appears
to us to be lacking in clarity, and to provide a source of conflict
between the two bodies, diminishing the authority of both.
12. Again, this conflict undermines the
planning process and public confidence.
13. It is not clear to us that CABE took
any account of community views and local considerations in undertaking
its review.
14. This again undermines policy which seeks
to empower local communities, and further diminishes confidence
in the decision making process.
15. CABE's accountability is unclear to
us as local people. CABE appears to us to be an unaccountable
body, using inappropriate processes to give advice not clearly
based in the necessary knowledge of specialist historic matters
or local community concerns.
16. While the Committee has always welcomed
high-quality modern design, in our view CABE's approach has undermined
confidence that the much-loved and highly valued historic environment
is properly protected—a condition we see as essential for
wide public acceptance of high-quality modern design in historic
areas.
17. Please do not hesitate to contact me
if I can clarify or expand upon any of these points.
Yours sincerely,
Richard Simpson
Chair.
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