Memorandum by SAVE Britain's Heritage
1. SAVE Britain's Heritage is a registered
charity. It was founded in European Architectural Heritage Year1975to
campaign publicly for the protection of threatened historic buildings
and areas. Through press releases, exhibitions and reports it
has championed the architectural heritage of this country. There
are many buildings now restored and in beneficial use that, had
it not been for SAVE, would have been destroyed.
2. SAVE has been at the forefront of the
conservation movement in the UK, pushing for changes in legislation
and Government policy to give greater protection to our built
heritage, and in raising awareness amongst politicians, professionals
and the public about the vital contribution made by historic places
and spaces to the quality of life in this country.
3. In particular, SAVE has championed historic
areas and building types that have been under-appreciated or which
have not previously been recognised or studied and which have
been threatened with redundancy, disuse and demolition. The buildings
of the Pathfinder areas are a case in point.
4. SAVE's involvement with the HMRI/Pathfinder
began with the attempts by the residents of Whitefield, Nelson,
East Lancashire, to resist the demolition of their historic homes
and breaking up of their community by their local authority in
what appears to be a misguided attempt to halt the decline of
the housing market locally. We learned that this was not an isolated
case and were amazed that the figures being discussed for the
reduction of the housing stock were in the broad range of 75,000
houses to over 400,000 houses. This represents the elimination
of a layer of the country's cultural heritage: the majority of
buildings in these Pathfinder areas are pre-1919, and in most
cases, as at Whitefield, form parts of coherent townscapes. At
the time of writing we have visited two of the nine Pathfinder
areas, East Lancashire and Merseyside, at the request of local
residents in these areas. We intend to visit other Pathfinder
areas over the coming weeks.
5. We have read the report of the Transport,
Local Government and the Regions Committee from 2001 into Empty
Homes and understand the motives behind the HMRI/Pathfinder. We
understand the need for radical intervention in certain areas
due to a fundamental lack of demand. However, we strongly question
what sort of response is most appropriate and whether demolition
is either necessary or radical: while clearance may be the easiest
option we do not believe it represents either the most suitable
form of intervention or best value. This question has not been
adequately addressed by local authorities, Pathfinder bodies or
6. We firmly hold the view that the historic
environment represents a finite resource and that demolition should
only be a last resort once all other alternatives are exhausted.
This is the case as laid down in law and guidance with regard
to the elements of the historic environment that are covered through
statutory listing or conservation areashowever, this only
represents a fraction of the totality of the historic environment.
7. It is vital for those carrying out the
HMRIs to understand that the funding available is not purely for
demolition, and indeed that a Pathfinder area does not have to
include any demolition at all. Clearance may seemingly be the
easiest option in the short term and so it is often taken up by
local authorities. However, it flies in the face of best practice
in terms of conservation and sustainability, both of which are
recognised in Government policy, and neglects any resultant long
term problems, from social dislocation, homelessness (as recognised
in Shelter's recent report "On The Up") to the potential
to remove flexibility from the housing market.
8. Neighbourhood Renewal Assessments (NRAs)
and Area Development Frameworks (ADFs) do not give sufficient
weight to the regeneration value of heritage, meaning that local
historic assets and streetscape quality are being destroyed, as
it is only the statutorily listed buildings and conservation areas
that are offered any protection. Even so, in many of these areas
the statutory lists are very out of date leaving many worthy buildings
unprotected and vulnerable. For example, Liverpool only has one
red-brick conservation area, recently declared, which is of similar
character to many of the clearance areas.
9. Many of the areas subject to HMRIs have
great character. These call for a different approach, not clearance,
which while maintaining the integrity of appearance and consequent
architectural/historic character of area, allows for the radical
alteration of the interiors of buildings, creating the flexibility
and variation in housing types that is called for.
10. It is widely accepted that local distinctiveness,
character and sense of place help underpin healthy communities
and markets. Sophisticated local authorities now understand that
the distinctive qualities of their urban fabric, old and new,
are fundamental to their economic and cultural future. In Liverpool
for example, local character is key to driving the housing market
recovery already well underway. The desirability of the urban
form is a unique asset now fuelling house price growth across
the city, especially the Pathfinder areas. Market led restoration
in Canning, Princes Avenue, Ullet Road, Kensington, Sefton Park
and Newsham Park is powerful evidence of the regenerative power
of place and the historic environment.
11. In effect the opportunities presented
by existing fabric and chance to respond to this are being missed.
The historic environment, far from being a barrier to the removal
of blight is a spur to the creative reuse of these areas, helping
retaining distinct identities and ensuring the civilising influence
of visual continuity. In placing excessive emphasis on demolition
instead of re-use, local distinctiveness, a key to the renaissance
of cities as sustainable communities, is squandered. In this light
we strongly believe some of the activities carried out under the
Pathfinders are self-defeating.
12. The drive for demolition appears to
over-ride innovation. There seems little desire in some places
to act as a genuine pathfinder and test different types of innovation
and proven means of reducing vacancies such as group repair schemes,
promotion of living above shops, "trickle transfers"
from RSL to owner occupation, environmental improvements and partnerships
with specialist developers. Furthermore, there is a paucity of
readily available evidence about what sorts of intervention have
previously been most effective, both in the UK and abroad. Importantly,
given the level of public funds involved, there is as yet no measure
of how successful the proposed interventions under the HMRIs are.
13. Key to the retention and reuse of the
threatened historic housing stock is how it is perceived. Some
work is being done to alter the perception of these buildings
and their areas, such as the workshops "rethinking the terraced
house" held by CABE, and the work currently being undertaken
by Urban Splash in Salford, illustrating an imaginative approach
to certain types of terraced houses. This also shows that it is
easier to tackle vacant buildings, which give a blank canvass,
than it is to tackle occupied buildings, such as with block repairs.
However, there appears to be little or no adoption of these policies
in some Pathfinder areas. Where buildings are knocked together
to provide larger units, the loss of one of these units must be
included in the statistics for the reduction of the housing stock.
This is not currently the case.
14. Pathfinder funds could equally be aimed
at stimulating improvements to existing homes. The experience
of English Heritage's HERS schemes shows how seed funding can
anchor in private investment in historic buildings, and there
are numerous successful examples of housing improvement grants
being used to upgrade older properties.
15. The assumption that consolidated land
ownerships and comprehensive area masterplans led by major corporate
development partners are the best way to deliver urban renaissance
may be an expedient means to secure "clearance and renewal",
but runs against much ODPM policy and best practice. Best practice
broadly promotes a fine-grained, mixed-use approach to creating
diverse, sustainable communities. Allowing private developers,
however well intentioned, to masterplan large areas is a great
threat to local diversity, inclusivity and character.
16. It is abhorrent that the maintenance,
repair and rehabilitation of the existing building stock attracts
a 17.5% tax in the form of VAT. This anomaly must be removed as
a matter of urgency. We commend your committee for having recognised
this in its report on the Role of Historic Buildings in Urban
Regeneration, and for having backed fiscal measures in the 2001
budget aimed at bringing long-term vacant residential properties
back in to use.
17. A radical alternative to demolition
is to mothball and seal off areas and keep the buildings weather-tight
to prevent deterioration. Blocks of buildings could then be gradually
released on to the market as demand picks up, either to be repaired
by individuals or to repaired and altered by commercial property
18. There is evidence that some Pathfinders
have strongly resisted refurbishment schemes for fear of setting
precedents that would undermine the case for wider demolitionthe
Granby Triangle area in Toxteth, Liverpool, is a classic exemplar
of this, where only tenacious community action finally halted
a decade long clearance programme in the teeth of opposition from
Liverpool City Council officers. The promised refurbishment of
substantial double fronted Victorian town houses in tree-lined
streets has yet to materialise some years into the Pathfinder
programme. Adjacent houses in private ownership have been refurbished.
This shows that the market is in a position to pick up many of
the buildings and indicates serious problems with the evidence
19. The assumption that there is "Low
demand" in market terms for existing terraced stock is only
partially true and relates more to specific (rented) tenures.
Evidence of low demand (such as voids and turnover) is largely
sourced from RSLs. Their figures refer to low demand from prospective
tenants, not from prospective owner-occupiers or private investors.
In some areas the now buoyant housing market shows there is far
less of an issue of "low demand" than when the research
was prepared. The causal chain of "abandonment" may
stem from a collapse of local authority or RSL services which
only then undermines tenant confidence.
20. Much of this data is now half a decade
old and predates the house price boom that has seen prices in
some HMRI areas rise by 50% and more per annum. In short, the
ambition to balance the market and control supply already appears
in places to have been overtaken by events even before adoption.
This increase in value has made re-use of existing buildings and
infrastructure more financially viable. This must cast doubt on
the future flexibility of the whole approach to market restructuring.
21. Furthermore, the assumption that a market
has failed implies one has been allowed to operate. Across the
Pathfinder areas in Liverpool for example, the market has been
short-circuited for many years by large tracts of public and RSL
property ownership. These holdings preclude the healthy operation
of a housing market in Liverpool's inner core.
22. Given the step change in market values
over the last two years, SAVE would like to see these assumptions
on which Pathfinder is based rigorously questioned before being
embedded in policy: the diagnosis has thus far been accepted without
23. The Campaign to Protect Rural England's
North West Regional Group commissioned a study, "Useless
Old Houses?" (March 2004) to look at the extent to which
the causes of low demand are related to the region's high-density
heritage. The report found that the type of housing was not central
to low demand problems; rather that deprivation related factors
cause residential environments to decline and more affluent occupiers
to move on. It recommended that where increased housing stock
is desired, it can be managed most efficiently and with least
social disruption by refurbishment and alterations to existing
buildings to provide larger and smaller residential units.
24. The study is based on qualitative research
with estate agents in Merseyside and East Lancashire. The key
factors in low demand were seen to be the bad image and reputation
of an area, crime and antisocial behaviour, empty housing and
litter and vandalism. However, most estate agents did not feel
that the lack of a garden, room sizes and layouts, density, poor
public transport, type of housing or poor road links were factors
contributing to low demand. This indicates that it is not the
housing that is the problem, but the social conditions that surround
the housing. The report strongly makes the point that it is "perfectly
possible that housing refurbishment and measures to tackle the
social conditions of the area is all that is needed to overcome
at least some of the problems of low demand". Clearly this
approach should be tried first before resorting to demolition.
25. Likewise both English Heritage and CABE
have produced research illustrating the enduring popularity of
terraced housing as well as English Heritage's work showing the
comparative running costs of terraced houses and their modern
equivalents (Heritage Counts 2003). However, this and the CPRE's
research appears to have been overlooked in some Pathfinders.
The assumption that a primary cause of market failure is an "obsolete"
housing form, specifically the pre-1919 terraced house, has little
evidential basis and collapses at the slightest scrutiny. We strongly
question the concept of obsolescence in this contexta term
widely used during the 1960s and 70s to justify clearance of hundreds
of Georgian streets and squares that would now be popular.
26. Remarkably, terraced housing, as the
most prevalent form of urban housing in the country, has not been
subject to serious published architectural study. Demolition without
understanding what is to be lost is against best conservation
27. Many smaller local authorities in Pathfinder
areas are without sufficient expertise to deal with the scale
of the challenge posed by the HMRIs. This is particularly so regarding
historic buildings and areas, with some of the authorities in
the area covered by the East Lancashire Pathfinder, for example,
lacking conservation officers. These authorities cannot rely on
an already hard-pressed English Heritage for advice.
28. A key issue that has arisen in the cases
we have dealt with is that of consultation of communities in Pathfinder
areas by their local authorities over the options presented by
Pathfinders. For example terminology is not clearly explained
to residents, the options available to them are unclear and before
they understand what is going on or why they receive letters telling
them that their houses are to be compulsorily purchased and demolished.
This is traumatic and unnecessary. We understand that a number
of residents groups and civic societies are submitting Memoranda
outlining their experiences.
29. There is a need for a consistent, clear
and fair form of consultation to ensure that the needs and aspirations
of these residents are represented. Alternative forms of consultation,
such as enquiry by design (as carried out by the Prince's Foundation
at Whitefield) should be employed and guidance produced by central
Government on how best to consult, with a series of performance
targets to ensure consistency and fairness in the application
of the policy.
30. The condemnation of buildings by local
authorities can appear entirely spurious. In the case of Darwen,
Lancashire, buildings were declared unfit under the Housing Act
following very brief surveys. These were later proved to be wholly
inaccurate by a surveyor with great experience of this building
type. This whiffs of desperation to demolish and leads local communities
to believe that they are being presented with a fait accompli.
31. The reasons behind the choice of areas
for demolition can seem unclear, such as in Liverpool where the
some of the areas correspond to patterns of ownership rather than
need. The attitude is to cut out the rot rather than let the positive
influence of neighbouring areas continue to spread and positively
influence regeneration. Site assembly to facilitate comprehensive
redevelopment seems to be key. This ignores both the possibilities
of finer grained interventions and the problems caused by more
difficult to acquire sites. Such cases and interventions often
require a greater degree of expertise than is available at a local
32. The approach to change and demolition
appears to be based on crude top down statistical view of neighbourhoodsvoids,
turnover, ownership, value etc. This fails to see beyond the problems
that may have little to do with the houses themselves. It also
fails to obtain active community input until consultation exercises
are carried out late in the day. A better method of taking account
of potential urban quality and market sustainability is called
33. CABE and English Heritage have produced
some guidance which is extremely helpful. However, this was in
reality too little too late for this first tranche of Pathfinder
and so has not yet had any real impact in many areas. Consultants
must be obliged to demonstrate that they have followed this guidance
when preparing masterplans or NRAs. Given the potential scale
of the changes to the urban environment through the HMRIs, the
involvement of English Heritage and CABE as major Government agencies
concerned with urban regeneration has been insufficient, nor do
they appear to be working together in practice. We suggest that
some of the funding available through the HMRIs is used to support
and co-ordinate officers within these organisations dedicated
to advising on Pathfinders.
34. The language used in relation to the
Pathfinders (such as "to secure clearance and regeneration")
conflates two very different concepts. Indeed the truth is that
clearance has often resulted in the very opposite of regeneration.
The urban landscape of many towns within the Pathfinder areas
bears witness to this, and in the case of Liverpool the areas
that historically suffered the most clearance are those now in
most need of regeneration. Expanding clearance risks repeating
the same mistakes.
35. History shows what great lengths local
authorities will go to to destroy traditional streets which, even
if in poor condition, could be brought up to modern standards.
For example in 1975 SAVE discovered that 60-75% of housing demolished
by the Greater London Council was in fair to good condition and
could have been rehabilitated. Then as now houses were condemned
as "at the end of their useful lives" when people were
living in them and wanted to stay.
36. Many of the current proposals under
Pathfinder echo this attitude and the mistakes made in this period,
when comprehensive demolition and renewal destroyed the qualities
of existing communities and their historic urban fabric on the
false prospectus that "new" meant "improved".
37. It is where the desirability of traditional
streets has been compromised by past clearances, poor new build
development, neglected public environments and a preponderance
of badly managed social and private rented tenures that owner
occupation is held back. The blighting of traditional streets
by such failures of public policy must not be characterised as
38. Pathfinder is resulting in great damage
to the historic environment. It conflicts with national policies
on conservation, with regional guidance on the re-use of existing
buildings and infrastructure, from streets to parks. It is characterised
by a top down approach that excludes local communities living
in historic areas and is in our view in need of a firm central
Governmental hand on the tiller, rather than the being left purely
in the hands of local authorities, many of which do not have the
necessary skills to achieve the objectives of the policy in a
transparent and trustworthy manner. In terms of the integrity
of the evidence base, Pathfinder is based on assumptions and research
that we challenge as being skewed and out of date. The assumption
that clearance and renewal are effective regeneration tools needs
more scrutiny in the light of past experience, and the alternatives
to demolition must be urgently tested and put to the market as
a means of ruling in or out re-use of these irreplaceable assets.
39. Most damaging of all is that people
are thrown out of their homes against their will, often when they
have invested considerable sums in their improvement and love
and value the homes and streets they live in and the sense of
community they enjoy and share with other residents. During our
research we have encountered numerous homes, condemned as unfit,
usually without an internal inspection, which suffer only trifling
faults and which often have been modernised to a high standard.
For such homes to be condemned and demolished is simply Orwellian.