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


Memorandum by SAVE Britain's Heritage (EMP 13)

INTRODUCTION

  1.  SAVE Britain's Heritage is a registered charity. It was founded in European Architectural Heritage Year—1975—to 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 central Government.

  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 areas—however, 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.

THE VULNERABILITY OF HERITAGE WITHIN PATHFINDER AREAS

  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.

THE ALTERNATIVES TO DEMOLITION

  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 developers.

  18.  There is evidence that some Pathfinders have strongly resisted refurbishment schemes for fear of setting precedents that would undermine the case for wider demolition—the 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 base.

PROBLEMS WITH THE EVIDENCE BASE

  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 question.

  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 context—a 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 practice.

WEAKNESSES AT THE LOCAL AUTHORITY LEVEL AND THE NEED FOR GUIDANCE FROM CENTRAL GOVERNMENT

  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 authority level.

  32.  The approach to change and demolition appears to be based on crude top down statistical view of neighbourhoods—voids, 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 for.

  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.

THE LESSONS OF THE PAST

  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 obsolescence.

CONCLUSIONS

  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.


 
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Prepared 8 February 2005