Memorandum by the Diocese of Southwark
(HIS 08)
1. INTRODUCTION
1.1 We are the fourth largest Diocese in
the Church of England in terms of buildings and people and cover
a geographical area of about 312 square miles that includes most
of the South of London. Within the Care of Churches & Ecclesiastical
Jurisdiction Measure 1991 we are responsible for some 364 churches
(of which 184 are listed buildings). We also have direct responsibility
for some 370 houses for clergy (a proportion of which are listed
buildings) and indirect responsibility, as custodian trustees,
for in excess of 300 church halls. The Diocese stretches across
17 different Local Authorities and is actively involved in the
review of Unitary Development and Local Plans as they are placed
on deposit. We should perhaps state that we do not speak for the
Church Commissioners or the individual parishes within the Diocese.
Neither do we speak for any other Diocese although we believe
that we express the concerns of many who are unfamiliar with the
current Inquiry into the role of Historic Buildings in Urban Regeneration
and others who, not being familiar with the planning system and
its supporting legislation, might find it difficult to express
similar concerns.
1.2 We very much welcome the opportunity
to give evidence to the Select Committee, which we set out below.
1.3 Over the last few months we have read
with great interest the consultation documents issued by English
Heritage (The State of the Historic Environment Report)
and the Department of Media Culture and Sport (Protecting our
Historic Environment: Making the system work better) and have
welcomed the opportunity of responding to those documents as we
firmly believe that the system relating to listed buildings and
the Planning process is in considerable need of improvement.
1.4 So far as they relate directly to the
issue of urban regeneration, we are attaching as Annex A &
Annex B, extracts of our responses to The State of the Historic
Environment Report and Protecting our Historic Environment:
Making the system work better.
1.5 The evidence within this paper has been
collated and written by Roger Pickett, FRICS who has been directly
involved over the last 43 years, initially within Private Practice,
with the design of new buildings of Civic Trust Award quality
in Conservation Areas, with the extension and repair listed buildings
and who, during the last 21 years, has also accumulated direct
experience in the appointment of able consultants to facilitate
small scale urban regeneration schemes that enhance the urban
townscape and relate to listed buildings. This evidence is built
on the experience of the Diocese of Southwark and incorporates
the philosophy that it has developed, based on many years experience
of development schemes within the built environment. The evidence
has been prepared in consultation with Mr Simon Parton, and Mr
Andrew Lane, who are respectively the General Secretary to the
Diocese of Southwark and the Secretary to the Diocesan Advisory
Committee for the Care of Churches.
2. THE CONTRIBUTION
OF HISTORIC
BUILDINGS TO
URBAN REGENERATION
2.1 This representation starts from the
belief that there is an overwhelming case for selective retention
and care of the best of the nation's historic buildings but we
also believe that many Grade II buildings are less than second
rate and do not merit listing. It is our belief that many such
buildings only have their listed status through tenuous reasoning
and a desire to secure the known and acceptable in preference
to the fear of an unknown alternative. In our representations
on Protecting our Historic Environment: Making the system work
better we have argued that the poorer examples of listed buildings
should be removed from the List.
2.2 We believe that the contribution of
historic buildings to urban regeneration can be immense when regeneration
takes place around high quality listed buildings such as those
listed as Grade I or II*. Regeneration provides the opportunity
to review and change the setting of a group or single building
of listed status in a way that can enhance and draw attention
to particular characteristics. It can also provide the catalyst
for funding to improve/repair the listed building itself although
the current use, the ownership and the long term perceived future
of the building can all militate against such a successful outcome.
2.3 When high quality listed buildings fall
within areas of urban regeneration then the overall design hand
needs to be of considerable ability. When this is so the results
can be spectacular but when the general scheme is of a lesser
quality and becomes detrimentally influenced by Local Authority
planning officers and others, who have little or no professional
design training, then the resulting scheme often becomes mundane.
The opportunity of improving the urban townscape around an accepted
architectural jewel is lost for the foreseeable future and the
resultant poor scheme provides fuel for the lobby against change.[1]
2.4 We are convinced that the presumption
in favour of the retention of poor quality listed or locally listed
buildings within urban regeneration programmes more often than
not stultifies and inhibits the best possible result.[2]
More often than not the listed building[3]in
question is not of sufficient quality to generate grants for repair
funding and the resultant scheme, if it is to be economically
viable, is a cramped and generally unsatisfactory scheme, very
much poorer than would be the case if demolition were embraced.
3. THE ROLE
AND EFFECTIVENESS
OF THE
PUBLIC AGENCIES
RESPONSIBLE FOR
THE BUILT
AND HISTORIC
ENVIRONMENT IN
ENCOURAGING URBAN
REGENERATION
3.1 We believe that all the public agencies
should be encouraged to respond with a common clearly defined
set of guidelines as this will lead to a more efficient system
that will be to the benefit of the national economy. Balance and
flexibility need to be injected into all parts of the existing
system to enable regeneration to reach its full potential. Far
too much time is taken up within the existing system, particularly
the planning system, in attempting to reconcile the irreconcilable
thus incurring unnecessary costs and delay.[4]
Whilst we recognise the contribution of public opinion and wish
to encourage an informed debate, as part of the democratic process,
we also recognise that general public opinion is subjective and
very often not well informed when it comes to architecture and
aesthetics; the dictum seems to be "I know what I like",
regardless of any understanding of the accepted tenets of design
and aesthetics.
3.2 It is less than helpful that the initial
reaction of many local authorities, when faced with complex or
difficult schemes involving regeneration or listed buildings,
is to react negatively.[5]
This, we believe, reflects public thinking and the thinking in
many amenity societies. This thinking seems to result from a reaction
to the poor quality work done in the 1960s and cultivates the
mindset that all change is bad per se. We contend that the culture
needs to be changed to encourage urban regeneration rather that
seeing it as a threat. We also believe that English Heritage should
be encouraged to respond to schemes in a much more positive and
imaginative way than is enabled by the current philosophy. For
the wider benefit of local communities, as well as the nation,
they should be encouraged to think and support what initially
seems to be the unthinkable and the insupportable, as it is only
this way that the nation's environment stands a chance of becoming
more vibrant; enhancing the best of the past with the best of
what this generation can leave for posterity. We do not wish to
loose that which is a fundamental part of our built inheritance
but argue for a shift in thinking that will more readily release
us from the desire to preserve our past at the expense of the
present.
3.3 Small-scale urban regeneration is also
at times hindered by the contents of national Planning Policy
Guidance, Unitary Development and Local Plans when the adopted
policies militate against or thwart alternative economically feasible
uses for listed buildings thereby condemning them to potential
dereliction and the Buildings at Risk Register. Were it possible
to pursue the economically viable alternative this in turn could
assist in helping to produce the funds to assist with regeneration.
A much greater degree of flexibility in the implementation of
policies at both national and local authority level is necessary
if the full potential of urban regeneration is to be achieved.[6]
We are convinced that the way in which national policy guidance
and the shift to plan-led decision making adversely influences
urban regeneration. A greater degree of flexibility is required.
4. WHETHER THOSE
ORGANISATIONS CARRYING
OUT REGENERATION
PROJECTS GIVE
SUFFICIENT REGARD
TO HISTORIC
BUILDINGS
4.1 We do not seek to comment in connection
with large-scale regeneration projects, as we have no direct experience
to bring to the issue, but we are well aware that for many small-scale
regeneration projects much time is devoted to listed buildings
and the degree to which it is very often counter productive is
already set out in our earlier comments.
5. WHETHER THE
PLANNING SYSTEM
AND THE
LISTING OF
HISTORIC BUILDINGS
AID OR
HINDER URBAN
REGENERATION
5.1 In our experience there is a tendency
for historic buildings to be listed specifically to hinder urban
regeneration. This is partially to do with the system itself and
partially to do with the desire to hinder regeneration schemes.
We have already dealt with our principal concerns over the way
in which the present planning system adversely impinges upon small-scale
regeneration but we are well aware that it is a common tactic
of local residents, local authorities and amenity associations
to attempt to hinder or preclude possible regeneration schemes
by doing all in their power to "list" what they see
as strategic buildings or groups of buildings. It is not always
clear what motivates such a reaction but very often it seems as
though there is an alliance of local politics and fear of the
unknown coupled with an overwhelming desire to prevent change.
Whilst the present system permits and tacitly encourages such
action it would seem that there is overall more hindrance than
aid. Again our earlier comments on adopted local planning policies
and the need to expand upon the possible alternative uses of listed
buildings are pertinent.
5.2 We take the view that the current national
planning framework, coupled with the plan-led rigidity of adopted
Local and Unitary Development Plans, is often too rigid to accommodate
some of the nuances needed to foster regeneration projects and
for this reason we would argue for some degree of flexibility
to be introduced into the system that will help to provide much
needed balance.
6. WHETHER ALL
GOVERNMENT DEPARTMENTS
TAKE ADEQUATE
ACCOUNT OF
THE HISTORIC
ENVIRONMENT
6.1 We do not have sufficient experience
across Government Departments to be able to comment.
7. WHETHER FISCAL
AND LEGISLATIVE
CHANGES SHOULD
BE MADE
7.1 As a Diocese within the Church of England
and a registered Charity we have a number of concerns relating
to both VAT and grants to listed buildings currently used for
worship as they relate to urban regeneration projects.
7.2 Although the current grant scheme on
listed places of worship alleviates a greater part of the VAT
burden when places of worship are incorporated into an urban regeneration
scheme there remains a substantial tax burden that impinges directly
upon charities whose listed buildings may impinge upon urban regeneration.
Because of the scale of the works that are likely to be needed
to historic buildings, within a regeneration scheme, the burden
of even reduced taxation remains a substantial extra burden upon
building owners who are unable to recover VAT. This tax militates
against the repair of listed buildings that inherently possess
a greater repair liability than similar non-listed buildings and
this in turn makes regeneration schemes that involve listed buildings
that much harder to deliver. There is a fundamental inequality
to this burden of taxation and we urge all those who may be involved
with this issue to press for extending a reduced rate of VAT to
the repair of all listed buildings.
7.3 A further difficulty with the incorporation
of listed churches into urban regeneration schemes is the way
that Lottery Grants for community purposes are conditional upon
terms that are precluded by the Ecclesiastical Measures.[7]
To address these issues to accommodate the Measures will enable
more regeneration schemes to succeed as many now fall at feasibility
stage because of the irreconcilable terms of any grant that might
become available.
7.4 We believe that more urban regeneration
schemes involving listed buildings can be brought on stream if
the planning process and the relevant legislation is revised to
take account of the previously cited issues. We are also convinced
that to achieve the best out of regeneration schemes it is necessary
for there to be an eventual change to the philosophy and culture
that currently surrounds regeneration and turns fear of what is
not fully understood into a deep-seated desire to maintain the
status quo. Moreover we believe that a radical overhaul of the
listing process and a sensible review of the buildings considered
worthy of listing along the lines of our representations to the
Protecting our Historic Environment: Making the system work
better consultation will go a long way in assisting with the
provision of improved local environments and an increase in affordable
homes that a well conceived substantial urban regeneration programme
will provide.
8. BRIEF SUMMARY
8.1 We are convinced that it is possible
to encourage high quality urban regeneration schemes around the
best of the nation's listed buildings in a way that mutually enhance
both the existing heritage and the proposals of the present generation.
However for he benefit of the national economy and the benefit
of the owners of listed buildings the planning system needs to
be modified to produce better balanced decisions much more quickly
than is currently the case. The system needs to quickly recognise
what is really important, to set on one side what is not, to devise
prudent criteria that lead to open minded consultations and speedily
implemented schemes.
8.2 We also believe that urban regeneration
can best be encouraged by:
(i) reviewing the lower grading of listed
buildings and removing from the list those buildings that are
not worthy of listing;
(ii) removing national and local planning
policies that preclude or hinder alternative uses for listed buildings;
(iii) introducing within the current planning
system the pursuit of flexibility, leading to balance, that encourages
and enables imaginative alternative uses of listed buildings that
no longer meet the purpose for which they were built;
(iv) encouraging English Heritage's philosophy
to more readily recognise the need for imaginative adaptation
of the existing heritage;
(v) encouraging, within the planning system,
an a much more ready acceptance of the role that economics inevitably
play in any attempt to revitalise buildings that are no longer
suitable for the purpose for which they were designed;
(vi) enabling the planning system to respond
much more quickly than it does at present thereby saving considerable
costs;
(vii) amending the taxation so that all listed
buildings pay a reduced level of tax.
8.3 We believe that that if high quality
urban regeneration schemes are to be progressed expeditiously
and cost effectively there needs to be a cultural change in public
thinking. The current thinking seems to be that almost all regeneration
schemes are a bad thing per se, may eventually need to be tolerated
(because the current planning system is perceived as favouring
developers and big business) but must be resisted at all cost
for as long as possible. The change in public thinking is only
likely to emerge long after many good schemes are seen as enhancing
the urban environment for good and if history is any guidance
each generation in its turn tends to find the new unacceptable.
However until there is public acceptance that change, when well
handled, can result in well-designed schemes that are beneficial
to all, many of the current difficulties will remain.
1 An example of such a scheme is the way that the setting
of Alexander Thompson's St Vincent Street church, Glasgow was
badly affected by unsympathetic development in the latter half
of the twentieth century. Back
2
An interesting historic example of the way in which arguably many
lesser and some more important buildings were demolished (some
765 houses) in order to enhance the setting of an important building,
incorporate other important areas and provide a grandly conceived
scheme is John Nash's development of Regent Street. Under the
current planning legislation, regardless of the difficulties that
any listed buildings would present, such a grand scheme of town
planning would stand little, if any, chance of success, even presupposing
that the funding and political will existed. This might or might
not be considered to be a good example but it does illustrate
that high quality urban regeneration is unlikely to succeed whilst
poorer historic buildings are considered to be sacrosanct. Similarly
in Paris, much of the grand town planning would not now enhance
that city if Baron Haussmann had not sacrificed many buildings
that would rate Grade II or better by UK current judgements. Back
3
We have set out in our response to The State of the Historic
Environment Report and Protecting our Historic Environment:
Making the system work better our concerns about too many
undistinguished buildings possessing listed and local listed status.
We believe that the philosophy behind the retention of such buildings
is ultimately detrimental to both the environment and the economy
of the era in which we live; it militates against the balance
that is needed to reflect the best that the present generation
has to offer. Back
4
An example of this was St George's Church, Perry Hill (listed
Grade II) where in 1998 after many years of misplaced hope and
considerable investigatory work it was finally accepted that the
building could not be saved from the subsidence from which it
was suffering. After many years of attempting to save the church
English Heritage finally agreed that they could not justify to
the Heritage Lottery Fund the grant needed to enable a £1,500,000
underpinning and repair programme. Demolition eventually ensued
and a new place of worship is currently under construction but
not before many hopes had been raised, only to be dashed, considerable
abortive costs incurred and years of delay endured. This is also
a case where it was thought that the key to saving the building
was List it. Back
5
An example of this was St Andrew's church, Lower Streatham (listed
Grade II*) where after a fire that gutted the building both the
Local Authority and English Heritage sort to prevent the demolition
of the residual structure. For some three years or so the demolition
of the church was resisted. Eventually new homes were constructed
on the site but not before much money had been wasted on keeping
the unstable structure in place and abortive costs and delays
incurred. Back
6
An example of where inappropriate policies have militated against
regeneration can be seen in a case in the North Downs where the
Green Belt had been inadvertently drawn in an illogical position
and a poor quality historic building (not listed) was considered
to be sacrosanct. Some four or five years were needed under the
current system to resolve the issue and the site now provides
some nine new homes. Back
7
Ecclesiastical Measures have the same force as statutes. Back
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