Memorandum by the Commission for Architecture
and the Built Environment (CABE) (HIS 10)
CABE'S INTEREST IN THE ROLE OF HISTORIC BUILDINGS
IN URBAN REGENERATION
1. CABE is a non-departmental public body,
jointly funded by the Department for Culture, Media and Sport
(DCMS) and the Office of the Deputy Prime Minister (ODPM). We
are the champion for architecture in England, promoting high standards
in the design of buildings and the spaces between them. While
our remit primarily leads us to deal with new architecture and
urban design, we have an interest in the issues surrounding historic
buildings which arises from a number of areas of our work. Through
our Design Review programme, which offers free advice on the design
of selected projects, and our Enabling programme, which provides
support and advice to clients during the early stages of projects,
we have offered advice on a large variety of development schemes,
many of which involve the re-use, extension or refurbishment of
historic buildings, or which include proposals for new buildings
in sensitive historic contexts.
2. CABE has also produced a number of papers
and publications which discuss this and related subjects, including
a response to the consultation paper "Protecting our Historic
Environment—Making the System Work Better" and a response
to the quinquennial review of English Heritage. Our joint publication
with English Heritage, "Building in Context", highlights
examples of high quality new architecture in historic contexts;
our publication "Shifting Sands", again jointly produced
with English Heritage, examines regeneration in seaside towns;
and "Building Sustainable Communities: Actions for Housing
Market Renewal", produced in association with four other
partners, includes thoughts about the role of heritage in housing
market renewal areas.
THE CONTEXT:
THE CONTRIBUTION
OF HISTORIC
BUILDINGS TO
URBAN REGENERATION,
AND THE
ROLE OF
THE PLANNING
SYSTEM AND
LISTING OF
HISTORIC BUILDINGS
IN AIDING
OR HINDERING
URBAN REGENERATION
3. CABE starts from the position that historic
buildings can and should wherever possible make an important contribution
to urban regeneration. The historic environment should be an engine
of economic activity and social regeneration. The value of historic
buildings, and in particular the importance attributed to them
by local people, are often overlooked or misunderstood by professionals
involved in regeneration. These buildings can and should be put
to alternative uses where possible, and sometimes creative design
teams can reveal imaginative and unsuspected ways of using historic
buildings. Our joint publication with English Heritage, "Building
in Context", includes a number of cases where redevelopment
and/or extensions of existing buildings have contributed to the
regeneration of tired and run-down areas.
4. Good practice in planning and urban design
has increasingly recognised the importance of an understanding
of context in areas where change is to take place. The companion
guide to PPG1, "By Design", draws attention to the need
to understand and respond to the character of an area as a key
aspect of urban design. English Heritage are developing a methodology
of characterisation of historic areas. This will allow areas to
be understood in a holistic way, beyond the framework of statutory
designations. For this way of thinking to be effective, urban
design skills and expertise in the historic environment need to
be closely integrated within local authorities.
5. We believe that there should always be
strong encouragement for the best in contemporary design, including
new buildings within historic areas as well as in changing and
adapting historic buildings. Again, "Building in Context"
highlights examples of where this has been done to a high standard,
and with positive regenerative effects.
6. In our view, regeneration which makes
full use of historic buildings and assets has been helped by the
system of listing historic buildings. Prior to the creation of
English Heritage in 1983, the protection of historic assets was
piecemeal and lacked rigour. As a result, great damage was caused
to our historic environments throughout the 1960s and 1970s, diminishing
entire cities such as Bradford, Birmingham and Derby, as well
as many smaller settlements. Historic environments were damaged
by the ethos of the "white heat of technology" which,
it appears in retrospect, associated, in the minds of decision-makers,
the older buildings in our cities with the grime of a superseded
"smoke-stack" industrial past; and also by a technocratic
vision heavily influenced by considerations of highway engineering,
benefiting traffic at the expense of human beings.
7. Since then, we have seen a shift towards
a more sustainable model of regeneration in which, for the most
part, the importance of the historic environment has been harnessed
in taking forward the regeneration and growth of our villages,
towns and cities. Examples have included the Lace Market in Nottingham,
the Barbican in Plymouth and Aire riverside in Leeds.
8. However, we think that the way the designation
and planning processes work will need to change if they are to
operate effectively in a changing world. The process of economic
and social change, particularly within our towns and cities, is
growing increasingly complex and dynamic. Within the realities
of a global economy, the built environment has to respond swiftly
to the needs of a footloose business and investment community,
and to the needs of an increasingly mobile labour force.
9. There is a balance to be struck as the
number of buildings and areas under protection has increased very
rapidly. There is a danger that, over time, the built environment
could become increasingly ossified, to the detriment of managing
economic and social change. As we have stated, historic buildings
should be given every chance to make a positive contribution to
the economic and social well being of the neighbourhoods in which
they are located. However, we do not think that their preservation
should be at the expense of the wider needs of society in terms
of health, education and employment.
10. We should also recognise that high quality
new buildings may become the heritage of the future. All that
is old and cherished was, after all, once brand new; and buildings
now loved were once vilified, the Palace of Westminster being
a notable example. We should not be afraid of replacing some of
the less valuable buildings of the past to make way for good new
architecture. CABE believes that our built environment is a continuum,
in that it is being added to and subtracted from all the time,
and any system of historic protection should, therefore, in essence
be a system of managing change.
11. While some parts of our historic environment
have responded well to the challenge of a changing economy and
society, the regeneration of Grainger Town in Newcastle being
just one case in point, other areas of the historic environment
may be constraining the ability of the UK economy to respond to
the global challenge:
— buildings and structures for which
there is no longer any discernible use but which are preventing
the assembly of meaningful development sites in parts of the country
in need of urgent regeneration and re-development
— housing in northern England that
is no longer fit for purpose
— Victorian schools, hospitals and
prisons that can no longer accommodate modern technology-led public
services fit for the start of the 21st century
— the need for retail and office buildings
that respond to today's business trends in terms of footplate
and technology requirements.
At the same time, the Government has established
policy objectives that require significant flexibility from our
built environment:
— the commitment to accommodate at
least 60% of additional households in new housing on brownfield
sites at densities exceeding 30 units per hectare
— the commitment to bring retail development
from out-of-town into town centre locations
— the commitment to promote mixed use
development in properly masterplanned townscapes
— the commitment to strengthen regional
governance and local decision-making to improve responsiveness
to the different needs of different parts of the country
— the commitment to sustainable buildings
that offer decent access for the whole population, including the
disabled.
12. Given this, there is a clear need for
the issue of heritage protection to be considered within the wider
context of the overall development of the built environment. At
present, the focus of the protection system is strictly on the
"architectural" and "historic" aspects of
a building or area, and we question whether this is adequate in
a process that should be concerned with managing wider change.
13. One notable aspect of conservation policy
in practice is that the amount of protection afforded to particular
areas has shown a strong correlation to patterns of relative wealth.
Most listed buildings and conservation areas are in prosperous
areas. In part, it could be argued that conservation policy has
strengthened certain local economies. It can also be argued that
the policy approach has helped to reinforce divides between richer
and poorer areas. We think that we need a system of historic protection
that places emphasis on identifying and managing historic assets
in deprived areas, rather than focusing resources and effort on
maintaining the prospects of immaculate conservation areas in
wealthy residential suburbs. This suggests that there are factors
beyond strict "architectural" and "historical"
significance that need to be taken into account.
14. An equitable land use planning and historic
designation system will avoid operating a two tier system of control,
whereby poorer areas of lower historic significance experience
a continued deterioration of the quality of their local environment
compared to more prosperous conservation areas. The Government's
planning guidance in PPG1 sets out its view that "good design
. . . should be encouraged everywhere" but experience of
development in practice—the evidence of our eyes as we look
at our cities—is that it is difficult for planning authorities
to assert this principle.
RECOMMENDATIONS
15. We think that all this points towards
a flexible approach, where the planning and listing systems recognise
the value and role of the historic environment, but keep under
continual review the contribution of individual buildings and
spaces to the needs of the local population in terms of their
economic and social welfare, and allow the flexibility required
for the imaginative re-use of existing buildings and for the insertion
of high quality new development in historic areas.
16. At present historic environment issues
can sometimes to be thought of as separate from the more general
challenges of urban regeneration and planning. This separation
may be reflected in the structure of local authority departments.
CABE believes that there is a need for greater availability of
professional skills in local authorities in the field of the historic
environment, as part of a wider picture relating to built environment
skills. It is important to avoid a "bunker" mentality.
17. The role of English Heritage in its
work with local authorities on historic buildings is also significant.
Here too there is a need for a more holistic approach where an
understanding of and concern for the historic environment are
related to the broader canvas of regeneration.
18. In commenting on the recent DCMS consultation
paper "Protecting our Historic Environment—Making the
System Work Better", CABE has identified a number of key
principles that should be at the heart of any changes to the system
for protecting the historic environment, and those that follow
are particularly relevant to the facilitation of regeneration.
Underlying these principles is recognition of the fact that historic
buildings and areas have always changed, and our expectation should
be that this would continue. The issue is how we manage that process.
19. CABE considers that a "community
worth" or "regeneration" criterion should be added
to the broad statutory criteria for listing historic buildings,
alongside architectural and historic significance. This would
mean that designation decisions could take place within a regeneration
context which considers the "community worth" of the
buildings, structures or spaces under consideration, reflecting
the needs of both existing and future communities and taking regeneration
circumstances into account. We feel that this would lift the designation
process out of the ivory towers of academic scrutiny and into
the realities of people's lives and their sense of communal identity.
20. Applying such a test could lead to a
situation, which we would welcome, of a building which on strict
architectural and historic significance grounds would not justify
listing being designated because of its clear worth in its communal
context. This would be particularly valuable in deprived communities
where there are few historic buildings and those that do exist
may merit protection, even though they would not usually be considered
of sufficient worth in terms of architectural or historic value.
21. We acknowledge that there may be dangers
in introducing such a test in that it increases the potential
for value judgements and therefore, potentially, the number of
appeals. However, we think that the process of designation is
already as much an art as a science and any risks created by including
this new test would, in our view, be outweighed by making designation
a process that understands and reflects the needs and views of
communities as an intrinsic part of that process.
22. As mentioned previously, there will
conversely be occasions where a building might be marginal in
terms of its architectural or historic merit and the pressing
need for re-development to improve economic and social conditions
is of greater value than preserving the building.
23. CABE believes that the new PPS15 should
reflect the holistic view outlined above. It should make the case
that historic environment issues are integral to planning and
regeneration generally.
24. We would like to see the new PPS15 emphasise
to local authorities the potential for the imaginative use of
conservation area status in assisting the regeneration of more
deprived neighbourhoods where the architectural and historical
significance may not be so overt, but where proper recognition
of the historic assets of the area could help to generate a greater
appreciation of the underlying economic and social value within
the locality.
25. We think that the criteria for selecting
a building to become listed should change over time as architectural
and historic rationale become reconsidered; in this context, de-designation
should be as significant a part of any revised system as designation.
26. Of particular relevance in the coming
years will be the role of heritage in the those areas marked for
housing market renewal. It will be important not to sweep away
places that are intrinsically of great value or have the potential
for imaginative renewal. The legacy of the past can be used as
the driver for recovery, particularly where there are buildings,
public spaces or urban layouts of heritage value.
27. The designated housing growth areas
also contain areas and buildings of historic significance. If
urban coding is to be used as a mechanism for simplifying the
planning of these areas, then it will need to be informed by an
understanding of the existing local fabric. Characterisation will
have a role to play in achieving the goal of new neighbourhoods
that become recognisably "somewhere" rather than "anywhere';
the historic buildings and areas should be seen positively as
assets that can inspire the best of new housing rather than becoming
an excuse for lowest common denominator solutions.
28. It may be possible in many cases to
use the historic environment and local landmarks as an asset to
attract potential investors, residents and tourists, due to the
distinctive qualities and identity that they can bring to a neighbourhood.
29. The importance of the historic environment
to tourism in particular is evident. Tourism makes an important
contribution to the economy; and the quality of the built environment
in general and the historic environment in particular are clearly
important factors in the choices that tourists make. If urban
regeneration is at least in part about reinventing our cities
for a post-industrial age, then we neglect the spending power
associated with, say, the European long weekend break, at our
peril. If cities such as Liverpool are to compete with success
stories such as Bilbao for this trade, then this consideration
needs to be a central part of their thinking; the nomination of
Liverpool's waterfront as a World Heritage Site in the same year
as the city is chosen as European Capital of Culture is a neat
illustration of the point.
30. The historic environment should be at
the centre of considerations when planning for new developments
in these areas, and thought should be given to this as early in
the process as possible. It will be important to carry out analysis
to understand the historic fabric of the area, through the preparation
of characterisation studies which will help determine what is
historically and culturally significant, vulnerable to change
or in need of protection, enhancement or celebration.
31. However, there will be circumstances
where demolition may have to be considered. As we have previously
stated, we do not believe in reaching a situation where the preservation
of historic buildings is at the expense of wider social and economic
aims. We would recommend that the above processes be carried out
to ensure that any proposals for demolition are based on sound
information.
32. CABE believes that the present VAT system,
with VAT chargeable on repairs to existing properties but not
on the cost of new-build, and on repairs to listed buildings but
not on alterations to them, acts as perverse disincentive to the
beneficial re-use of historic buildings. We believe that VAT should
be harmonised for all building work in order to encourage the
sustainable re-use of existing building stock.
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