Memorandum by the Royal Institute of British
Architects (RIBA) (HIS 05)
1. INTRODUCTION
1.1 The Royal Institute of British Architects
is one of the most influential architectural institutions in the
world, and has been promoting architecture and architects since
being awarded its Royal Charter in 1837. The 30,000-strong professional
institute represents 85% of registered architects in the UK through
its regional structure as well as a significant number of international
members. Our mission statement is simple—to advance architecture
by demonstrating benefit to society and promoting excellence in
the profession.
1.2 The RIBA greatly welcomes the Committee's
inquiry and considers it extremely timely in the light of the
Government's own review of heritage protection legislation. George
Ferguson (President, RIBA) is a leading regeneration architect,
and would be very happy to appear as an oral witness to the Committee
to give both a personal perspective on the role of historic buildings
in urban regeneration as well addressing the inquiry's terms of
reference on behalf of the architectural profession.
2. THE CONTRIBUTION
OF HISTORIC
BUILDINGS TO
URBAN REGENERATION
2.1 Buildings, more than any other factor,
identify an urban community. Famous examples such as Liverpool's
Three Graces or Bath's terraces are testament to this. People
often have a particularly intense identity with the historic buildings
which surround them.
2.2 Historic buildings and structures can
lend value to more recent, appropriate, developments, such as
the highly successful Brindley Place in Birmingham, or more obviously,
the Temple Bar area of Dublin, which was saved by an architect-led
campaign. Conversely, our historic buildings can become devalued
by inappropriate development which "steals" their intrinsic
value, exemplified by the recently developed Temple Quay development
in Bristol adjacent to the historic Temple Meads Station. Urban
regeneration needs to be approached with a combination of architectural
and planning sensitivity and flair. Architects are very aware
that it is a much greater challenge for completely new places
to succeed in capturing peoples' imagination or engendering affection
to the same extent as those places that are based on historic
buildings and areas. This has much to do with the fact that many
old buildings and places break the planning and building regulation
rules as applied to new development, such as the proximity of
buildings and the width of streets, and the institutional requirements
of car parking provision etc.
2.3 In recent years the recognition and
definition of historic areas has changed. Victorian and Edwardian
industrial buildings have now become the focus for regeneration
efforts. This has become particularly noticeable in terms of the
recent regeneration of historic waterfronts—docks, canals
and riversides. It is a paradox that Britain has learned much
about the regenerative effect of developing such historic areas
from the relatively young United States. Organisations such as
the Rouse Corporation in cities including New York, Boston, Philadelphia
and San Francisco have produced important models that have led
to the dramatic regeneration of run-down urban centres, many of
whose lessons have been replicated here. Home-grown models such
as Clough Mills in Halifax are showing how the imaginative use
of historic buildings can become the anchor of regeneration in
previously depressed areas.
2.4 Bristol—fundamentally a medieval
city which has been added to in every subsequent age—serves
as a useful case study for urban regeneration. The architectural
historian and curator of the Soane Museum, Sir John Summerson
(1904-92), said of Bristol that if he were to take a foreigner
to a British city outside London which reflected everything that
had happened—he couldn't do better than take them to Bristol.
Bristol is also the adopted home of the current RIBA President
George Ferguson who has been very involved in its regeneration.
2.5 In Bristol, as in many other cities,
higher values for both commercial and residential property are
to be found in the historic areas, which have become the focus
for regeneration. The 18th century Clifton hillside led the way,
but the focus has now turned to the Bristol Harbourside—the
former Bristol Docks—which has been rescued from a lengthy
period of industrial decline and has become the focus of new mixed
uses. Alongside premium residential property, the area has become
a new and successful area for entertainment and cultural activity.
The Arnolfini Gallery has been joined by the At-Bristol science
and education complex: other cultural attractions and a large
number of bars and restaurants which have brought life to a previously
neglected part of the city. The success has been dependent upon
the creative re-use of abandoned industrial buildings and the
creation of new city spaces.
2.6 George Ferguson's own Tobacco Factory
Project is a fine example of heritage-led regeneration. The project
emerged from the threatened demolition of the 19th century former
Imperial Tobacco factories—over 800,000 square feet—designed
by Sir Frank Wills between 1900 and 1910 on the Raleigh Road estate
in South Bristol. In the face of resistance by the local authority
and English Heritage to seek listed building status for the factory
buildings, and following rejection of his proposal to develop
the complex as a "sustainable urban village" in the
early 1990s, George Ferguson bought one factory building from
the Receiver in an attempt to prevent total demolition, and encouraged
a manufacturer to occupy another.
2.7 Over the last seven years, George Ferguson
has developed the Tobacco Factory as a multi-use building housing
a theatre, restaurant, cafe bar, a "fame" school and
offices. This has been widely acknowledged as the principal driving
force for the remarkable regeneration of the area and is to be
the subject of a research project by the University of the West
of England into the regeneration result of the project. It was
necessarily an economic project that was carried out as an individual
initiative without any form of subsidy, and against all commercial
agency advice. It is telling that it has now become the prime
local example used by agents to demonstrate the benefits of such
historic building and mixed cultural and commercial use.
3. THE ROLE
AND EFFECTIVENESS
OF THE
PUBLIC AGENCIES
RESPONSIBLE FOR
THE BUILT
AND HISTORIC
ENVIRONMENT IN
ENCOURAGING URBAN
REGENERATION
3.1 English Heritage, while carrying out
its proper role of protecting and enhancing our built heritage,
should reduce the dominance of its more archaeology-led approach
to historic buildings and encourage the combination of respect
and design flair that is exemplified by such projects as the British
Museum Great Court or the creative re-use of Covent Garden's market
buildings. There needs to be a reduction of the bureaucratic processes
that have become such a disincentive to historic building grant
application, and a more liberal attitude to the accreditation
of architects for historic building work to create opportunites
for those who are brilliant designers as well as those who specialise
in careful repair. English Heritage nevertheless serve an important
purpose as grant-makers and as supporters of the many Building
Preservation Trusts that have a vital role to play in historic
building regeneration.
3.2 The Commission for Architecture and
the Built Environment are a great force for good in the field
of architecture which we regard as a crucial partner in the challenging
game of architecture and place-making.
3.3 The Regional Development Agencies are
playing a vital role in many regeneration schemes across the country.
It might be said that their role could and should be more enabling
than direct—using their influence and funding to attract
the appropriate developer and putting together appropriate partnerships
such as historic building trusts, housing associations and commercial
organisations, together with the necessary gap funding to ensure
delivery.
3.4 The Environment Agency is playing an
important role in discouraging inappropriate development on flood
plains. However it has applied similar stringency to the redevelopment
of some historic dockyards which are not worsening the situation
by their reuse and may be threatened by the economic and aesthetic
consequences of the measures advocated. It would seem that there
should be a more pragmatic approach to managing the risk in such
cases rather than imposing stringent physical conditions.
3.5 Many local authorities have realised
the regenerative potential of their heritage to breathe new life
into formerly run-down areas. Newcastle City Council and Gateshead
City Council are an excellent example of how traditional rival
local authorities can work together.
3.6 Little evidence remains of the River
Tyne's heavy industry which dominated their Quayside apart from
a number of former warehouse buildings. Many of these have become
anchors for regeneration—such as the former Baltic Flour
Mill in Gateshead and an old Co-operative Warehouse in Newcastle
which are now respectively the outstanding Baltic Centre for Contemporary
Art and a stylish modern hotel. They have been joined by imaginative
and brave modern interventions—including Norman Foster's
Sage music centre in Gateshead and Wilkinson Eyre's Millennium
Bridge which joins the two river banks and won the 2002 RIBA Stirling
Prize for Architecture. New and old are linked by a riverside
walk interspersed with bars, restaurants and public art. Culture
and recreation are used as a force for regeneration which in turn
has attracted new service-sector businesses to the area. It has
developed its own dynamic, based on the existing historic fabric.
4. WHETHER THOSE
ORGANISATIONS CARRYING
OUT REGENERATION
PROJECTS GIVE
SUFFICIENT REGARD
TO HISTORIC
BUILDINGS
4.1 Butlers Wharf in Southwark is an outstanding
example of a commercially- developed regeneration project which
benefited particularly from the imagination and flair of Terence
Conran. Much the same could be said of Castlefields in Manchester,
where local entrepreneurs Jim Ramsbottom and the renowned Urban
Splash have made such a spectacular difference with a mix of old
and new buildings. This has been one of the principal catalysts
for the regeneration of Manchester with similar efforts now being
applied to Liverpool and Salford.
4.2 George Ferguson's own practice is currently
working on the regeneration of Royal William Yard in Plymouth
with Urban Splash, who were invited in by the South West RDA after
many of the more conventional national developers had bowed out.
This is proving to generate values considerably above prevailing
local prices because of the marketing strength of the historic
site itself and the appealing combination of new and old. The
Phoenix Trust is also involved with the site and can be said to
have lit the touch paper that has enabled development to proceed
on a site that has lain fallow for many years.
4.3 There are too many cases where development
has had insufficient or scant regard for the historic environment.
This has too often applied to town centre retail development,
with some particularly poor examples being the Fleet Street Development
in Torquay Old Town and the Eastgate Centre in Inverness. Both
of these failed to utilise the historic environment in a positive
manner that would have given greater economic sustainability.
5. WHETHER THE
PLANNING SYSTEM
AND THE
LISTING OF
HISTORIC BUILDINGS
AID OR
HINDER URBAN
REGENERATION
5.1 We consider English Heritage to be the
appropriate body to be responsible for designation of buildings
and monuments of historic importance. We believe, however, that
the RIBA can make an informed contribution to the process and
would like to make a case for the architectural profession, through
the RIBA, to be directly represented on English Heritage.
5.2 The RIBA believes that the sole criterial
for listing should be those of architectural, cultural and historic
importance and that matters of viability and economy—in
other words the potential to contribute to urban regeneration—should
continue to be dealt with through the Listed Building Consent
process. However we would propose that a structure that has deteriorated
to the extent that it has lost its architectural, cultural or
historic integrity chould be justed to have lost the criterial
that might otherwise have justified listing.
5.3 We support the Government's current
proposal to bring together the different heritage protection regimes.
We see no good reason to change the well established grades of
listing.
5.4 Expertise within the planning system
is an important issue and can hinder proper consideration of heritage
and urban regeneration issues. While there may be a case for the
establishment of local lists for planning guidance only—as
suggested by the Government, we advise that "the List"
should continue to be held and maintained centrally where greater
expertise lies. English Heritage is best able to judge when it
can delegate individual listed building consent decisions to the
relevant local authority, dependent on a combination of the importance
of the case and the extent of local expertise. It should have
the power to do so, but, with some notable exceptions there is
a lamentable lack of conservation and historic building experience
within many local authorities.
5.5 The listing and listed building consent
process must be more transparent. The RIBA encourages the notion
of greater transparency, including a requirement for summary "statements
of significance" with new listings that give outline guidance
to stakeholders of relative importance. Statements would require
review at the time of listed building consent, to include the
signficance of new discoveries and contemporary changes, which
become part of the history of the structure or complex, and are
sometimes of great significance themselves. Guidance in favour
of structure and brevity should be clear and statutory to avoid
a medley of different forms of statement and over-zealous demands
on owners.
5.6 The listing system—in particular
spot-listing—has major implications for individuals' property
rights and owners' ability to bring about regenerative change.
We would therefore expect full explanation of the process and
consequences to be attached to every listing proposal. To prevent
the possibility of abuse of an open consultative/decision period,
it is accepted that the structure or complext concerned should
be deemed to be fully protected as listed until a designation
order is made. We suggest that might be limited to a guidance
period of four weeks with a maximum of 12 weeks from the announcement
that listing is to be considered.
5.7 The RIBA supports the right of appeal
to the Secretary of State, both for and against listing. The Secretary
of State should judge as to the level of inquiry appropriate to
each case. Clear criterial should be set down as to the case for
appeal. Cost should be awarded against those seen to be bringing
a vexatious or time-wasting case. The right to appeal should be
restricted to owners and relevant third parties, such as the individual
or group or authority thaty had instigated the listing process.
6. WHETHER ALL
GOVERNMENT DEPARTMENTS
TAKE ADEQUATE
ACCOUNT OF
THE HISTORIC
ENVIRONMENT
6.1 Whitehall's reputation is patchy. Although
the Department for Culture, Media and Sport tries its best to
be a good champion for the historic environment within Whitehall,
it remains the poor relation in terms of departmental funding
and the concerns of its sectors are often overlooked.
6.2 A current example is VAT on construction
work. The European Commission has recently published a proposal
to amend the current Council Directive permitting reduced rates
of VAT. For many years the architecture and heritage sectors have
been calling for VAT rates to be harmonised in respect of new
building, conversions and refurbishment. The Government's own
Urban Task Force (chaired by the Lord Rogers of Riverside) also
called for this measure in its its Report in 1999.
6.3 All have argued that that the current
VAT regime—where VAT is chargable on repair of existing
dwellings but not on new buildings—creates anomalies that
both discourage against the re-use or repair of existing buildings,
and encourage urban sprawl. The Government seemingly remains reluctant
to take up the case for harmonisation—even in the face of
its own continued commitments to promoting greater brownfield
development and urban regeneration. In our inner cities, where
many different kinds of buildings lie disused or in poor repair,
regeneration can make a huge difference. Yet developers face disincentives
through the current VAT regime to breathe new life into declining
neighbourhoods. Harmonised VAT could help to arrest this continuing
decline.
6.4 The Government has a rare opportunity
to secure a VAT regime that is both coherent among different building
categories, and consistent with its wider planning objectives.
DCMS should be fighting hard within Government to make the case
for harmonised VAT as the sponsoring department for both architecture
and the historic environment. We remain to be convinced that they
are doing all they can.
6.5 Under the current heritage protection
regime, DCMS and ODPM both share oversight of English Heritage.
DCMS, until recently the sole sponsor of the Commission for Architecture
and the Built Environment, has persuaded ODPM to generously fund
parts of CABE's activity. We are encouraged that this framework
for co-operation exists and it appears to work well.
6.6 We are concerned, however, that DCMS
may lack sufficient policy input into the work of the ODPM. While
we warmly welcomed and we pleased to contribute to the current
review of heritage protection legislation by DCMS, we are nevertheless
worried that its timescale is out of synch with the thinking behind
the Planning and Compulsory Purchase Bill and the Bill's current
progress through Parliament. It seems to us that the Bill would
be an ideal legislative opportunity to make many of the changes
envisaged in the heritage protection review. Yet we fear that
the DCMS's stately progress of the review may mean we have "missed
the boat". It may be some time before we have another similar
legislative opportunity.
7. WHETHER FISCAL
AND LEGISLATIVE
CHANGES SHOULD
BE MADE
7.1 We consider the harmonisation of VAT
on all forms of construction to be a priority. We have rehearsed
the case for harmonisation in section 6 of this memorandum.
7.2 The RIBA would like to make a specific
new proposal. We suggest that a pilot study is carried out into
the encouragement of the removal or radical remodelling of buildings
or structures that are perceived to be particularly detrimental
to the appearance and character of conservation areas. This would
entail the identification of such buildings and structures on
a statutory "hit list"—Grade X listing. Grade
X listed buildings and structures would be eligible for demolition/alteration
grants where it helps to tip the economic balance and is seen
to help with positive and appropriate regeneration.
7.3 As mentioned in paragraph 5.4 of this
memorandum, there are lamentable gaps within local authorities
who have historically been weak in this area, but have in recent
years lost yet more of their most able people to the private sector.
It is the intention of the RIBA to build on conservation and historic
building skills within the architectural profession through the
education system and through continuing professional development.
But swift change can only be brought about through substantial
additional investment in training of both the profession and trades,
and the definition of thresholds that should be reached by every
planning authority.
7.4 As we have already stated, the Department
for Culture, Media and Sport remains a poor relation in Whitehall.
Within that Department, the heritage sector has seemed for some
time like a neglected child—often overlooked in favour of
more vociferous sectors such as sport or the arts. During previous
Comprehensive Spending Reviews—where substantial additional
funding has been lavished upon the sports and arts sectors—the
heritage sector has had to make do with the promise of "jam
tomorrow". But we now face the tightest Comprehensive Spending
Review since the Government came into office in 1997. Already
there is word of frozen budgets and, in some cases, even cuts.
We hope that the Department for Culture, Media and Sport will
not give up on the heritage sector and will begin to treat it
as a funding priority.
| 
