Supplementary Memorandum by the Diocese
of Southwark (HIS 08(b))
APPENDIX B
Extracts from representations made by the
Diocese of Southwark in response to Protecting our Historic Environment:
Making the system work better
The following are the questions and answers
that relate to urban regeneration and which have been extracted
from our response to the Department for Culture, Media and Sport.
Q3. What criteria should be used to determine
what item should be placed on the List?
Buildings that are placed on the List should
be buildings of real merit, in terms of architectural design and
detailing, group value and historicity. Wider cultural issues
should not be a reason for listing buildings, neither should they
be included solely because a particular individual has designed
them. To list buildings solely for their historic connections
is often to condemn them to decay and eventual loss and listing
on these grounds should be made with great care. There is a strong
case for recording, as opposed to listing, in those cases where
listed buildings of lesser quality have outlived their purpose
and use for to do otherwise only increases the number of buildings
at risk in a way that is detrimental to the national economy.
When the use of a building has changed to the
point where its use generates no demand in the market place and
the building owner cannot afford to maintain the building, then
it must be accepted that the building is at risk until the fortunes
of the owner or the market change, a third party with adequate
funding is empowered to step in to maintain it for its original
purpose, the effects of listing are removed or an alternative
economic use is agreed.
To help resolve this challenge a compromise
needs to be found between a perceived sacrosanct requirement to
continue the uneconomic original use of the building on the one
hand and on the other hand the demise of the building that will
result from it falling into disrepair. At present Local Plan policies
often preclude this option. Indeed it is an area where mutually
exclusive policies conspire to aggravate the risks of potential
dereliction of listed buildings. Towards enabling such a compromise
an enabling policy for alternative uses should be generally accepted
and incorporated within PPG 15.
Using listing, as a means of providing time
to reflect is unhelpful, as matters do not work that way in practice.
The tendency is that once listed, it is likely to remain listed
(there is an inherent presumption against de-listing) and therefore
the desired pause for thought becomes a decision that is in effect
made by default, which is of benefit to no one. The position then
moves from one of doubt to a presumption for retaining the newly
listed status, regardless of merit, for to reverse the recently
taken decision will be seen as a considerable loss of face that
is to be avoided. The idea of using the system of listing as a
pause for thought is just the sort of process that will continue
to bring the system into disrepute.
It has been correctly identified that listing
per se does not secure a buildings future. Similarly it is recognised
that a building at risk can be saved with a concerted local enthusiasm
but this tends to be the exception rather than the norm, as is
evidenced by the length of the Buildings at Risk Register.
There is a repeated argument that economics
should not be taken into account when determining the future of
a building. Indeed Local Authorities and EH are often charged
with being highhanded and taking the view that their responsibility
is to the building and the environment regardless of costs. This
is a quite intolerable situation, usually advocated by those who
have no financial responsibility and can therefore ignore the
issue in its entirety. The building owner cannot insulate himself
from the issue and in many cases the repair liability of listed
buildings is well beyond the owners capability. This is echoed
by the general state of the nation's buildings that are mostly
under maintained. Where insufficient grants or no grants are available,
economics must be a determining factor in the retention of historic
buildings. If the nation considers it appropriate to retain uneconomic
properties, as part of its heritage, then the State cannot abrogate
a responsibility to financially assist in maintaining such buildings.
Ignoring economics is a luxury only available to those who exercise
no responsibility for a particular building and who see themselves
as controllers of other people's property.
Q4.1 Should the present gradings of I, II*
and III be retained?
At present there is a general understanding
of the existing grades and any change will inevitably tend to
cause some confusion. Nevertheless because little brings the system
more disrepute than contentious decisions that are reversed it
is important to list only buildings of real merit. For this reason
alone the grading of the List must be reviewed and whatever form
the List eventually takes it must be formed so as to avoid undue
confusion.
Q4.2 Should some of the items at grade II
move onto local lists? What safeguards would be needed?
There is a strong case for revising the List
into three new categories: Grade 1, 2 and 3. Grade 1 would echo
the existing grade I List of exceptional buildings, Grade 3 would
comprise those buildings currently in Grade II that are of real
merit with those failing to fall into this category being removed
from the List after a vigorous review. Those cases falling between
Grade 1 and 3 would be placed as Grade 2 as important buildings.
This would have the effect of reducing the overall size of the
list. We believe that the criteria for listing in PPG 15 paragraph
6.11 should be better defined so that only buildings of real merit
are included in the List as grade 3. We also consider that PPG
16 paragraph 6.13 should be revised so that other buildings of
similar quality elsewhere should become a material consideration.
It may well be that the List can be further reduced by removing
those cases where a listing relates purely to the façade
within Conservation Areas where the protection afforded by the
Conservation Area is adequate. To ease the changeover process
still further the initial work of determining whether or not a
building should be listed grade 3 could be done as a desktop process
with it being accepted that statements of significance
are placed on the List as part of a continuing process over a
predetermined term.
Q13. What planning guidance on protection
of the local historic environment would be of most value to local
residents, authorities and developers?
A clear understanding that all decisions will
be made on objective reasoning using informed opinion that relates
to the merits of the case, as opposed to uninformed subjective
opinion or decisions made out of expediency or for political advantage.
It is only in this way that clear parameters can be established
for the general good of society and the efficiency of the national
economy.
REGENERATION
Whilst generally concurring with the statements
made under paragraphs 69-72 there remains the underlying issue
of being able to find alternative uses for listed buildings. This
has already been mentioned under question 3 but it is still very
much an important issue within the parameters of regeneration.
Q17. What are the important skill gaps and what
action would be most effective to bring about swift change?
One of the most important skill gaps is the
need for more well trained planning officers and for the individual
posts that they hold to be sufficiently attractive to prevent
them changing jobs at frequent intervals. This may well have something
to do with promotion and salary structures in a field where there
is a considerable shortage of quality candidates for advertised
posts but whatever the cause it creates a substantial administrative
problem in the day to day running of property matters.
One of the quickest methods of bringing about
change is to reduce the burden of legislation by one means or
another thereby reducing the pressure on planning departments
and increasing the nations efficiency and improving its economy.
If only this is kept in sight and acted upon, whilst the revisions
engendered by this consultation document emerge, then the process
will to some extent have been worthwhile.
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