Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence


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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