Memorandum by the Joint Committee of National
Amenity Societies (CAB 38)
INTRODUCTION
1. The Joint Committee of National Amenity
Societies is a standing committee of the seven statutory amenity
societies, The Society for the Protection of Ancient Buildings,
The Council for British Archaeology, The Ancient Monuments Society,
The Twentieth Century Society, The Garden History Society, The
Victorian Society and the Georgian Group as well as the Civic
Trust.
2. This submission relates only to CABE's
design review function.
SUMMARY
3. CABE has a valuable role in reviewing
the design of new development. The presence of an expert body
whose remit is to scrutinise development proposals from an architectural
perspective and to promote excellence in new building and urban
design is key to the creation of truly sustainable communities.
The Joint Committee believes that the design review work undertaken
by CABE is on the whole undertaken intelligently and has an effect
that is broadly positive.
4. However, we would stress that development
decisions affecting the built environment need to be balanced,
well-considered and well-rounded. They need to take into account
all the issues, most particularly that of physical context. It
is important that CABE demonstrates that it has a wide appreciation
of what constitutes a high-quality built environment. As an organisation
it can appear to take the view that new development is beneficial
per se, the implication being that older buildings are
dispensable.
5. There is a particular danger of CABE
pronouncing on the design of proposed new development in historic
settings before development has been shown to be acceptable in
principle. Examples are given in the memorandum of evidence of
SAVE Britain's Heritage and we will not repeat them here. For
CABE to encourage new development and commend its design before
it has been established whether any development, of whatever design
quality, is acceptable would be premature. It can help create
a pro-development bias in the decision-making process that is
not in the public interest.
6. In some instances, particularly in dense
urban settings, a new development may be highly desirable in principle
but its scale may be contentious. If CABE lends support at an
early stage of the planning process to an over-intensive scheme
because that is what those promoting the scheme are putting forward,
this very encouragement can make it difficult for the planning
authority—or bodies such as the national amenity societies—to
achieve a more appropriate and sensitive solution that better
serves the public interest.
7. As a rule, CABE should give its views
on proposed new designs in historic settings only when new development
has been deemed to be acceptable in principle and it is understood
what scale of development is likely to be appropriate, having
regard to all the relevant issues. At that stage, CABE's involvement
is to be warmly welcomed in the interests of creating a well-designed
development.
THE PURPOSE
OF DESIGN
REVIEW
8. CABE's role is the promotion of excellence
in architecture and the built environment throughout England.
In the letter dated 15 May 2001 from DETR to all planning authorities
in England, this role is described and the purpose of Design Review
is set out. It is clear that the key objective of Design Review
is to help achieve the best possible quality of the holistic built
environment: "Design Review can be used to help raise the
quality of proposals for buildings and structures because they
have the potential to enhance the quality of people's everyday
lives and promote social inclusion".
9. DETR was clear in its letter that the
role of CABE's Design Review function was to promote the public
interest. The implication is that local authorities—also
acting in the public interest—will be the principal bodies
seeking CABE's advice on schemes. The letter states that CABE
will seek to help "clients, designers and local authorities
to achieve the best possible quality". CABE "will contribute
to the quality of urban areas in the widest sense and therefore
welcomes approaches from local authorities and others at the earliest
possible stage . . . The views and advice of the [Design Review]
Committee are made known by letter to interested parties".
10. Unlike its predecessor the Royal Fine
Art Commission (RFAC), which, whatever its limitations, did focus
its efforts and direction on the public interest and devote its
attention to pursuing the critical issue of design quality, CABE
has developed into an organisation that can appear to be prejudiced
in favour of development. This may on occasion contradict the
requirement to advance the public interest and social inclusion,
both of which may be better served by limited development or retention
of the existing built fabric. The contribution made by historic
buildings in urban regeneration was recognised by the ODPM Committee
in its report on this subject published in July 2004.
11. We recommend that the ODPM Committee
studies the RFAC's Final Report 1998-99 (HMSO 1999). A glance
at the headings in the section entitled Themes, Issues and
Policy 1924-1999 points to the inclusive and comprehensive
approach adopted by CABE's predecessor: Good Architecture, Fitting
In, The Wider Context, The Urban Environment, Conservation &
Preservation, Public Amenity and, lastly, Creating Good Architecture.
These issues are of universal and eternal importance and provide
a benchmark against which to judge the performance of Design Review
as currently undertaken by CABE.
12. CABE has published some excellent guidance
and advice: the CABE/English Heritage booklet Building in Context
(2001) has clear guidance on how to appraise a proposal in a sensitive
location. Design Review (2002) likewise sets out CABE's
policy in reviewing schemes clearly and concisely. The CABE/EH
advice note on Tall Buildings is also to be commended.
It is important that CABE should have regard to its own guidance
when assessing new development schemes.
ASSESSING PROPOSALS
IN THE
ROUND
13. A deficiency in CABE's current design
review arrangements is that designs are not as a rule reviewed
in the round. They cannot be, because CABE currently does not
have the requisite expertise. There is a shortage of planning
and conservation expertise available to the Design Review Committee.
The Design Review staff team, highly competent though it is, does
not have hands-on experience of development control; neither do
members of the Committee. Commissioners with appropriate experience
are not always able to be present at Design Review meetings and
from what we can gather are seldom asked for advice by CABE staff
on Design Review cases, even informally. Opting out of addressing
issues concerning the historic environment on the basis that English
Heritage and others will address these issues when a scheme finally
enters the public domain—as CABE did recently at Smithfield—is
no substitute for proper rounded consideration of all the issues
at the outset.
14. There is a concern, which may be justified,
that Design Review Committee members are selected more or less
at random for meetings, which again militates against there being
a proper and representative balance of views and experience. It
is this imbalance which, in our view, means that the nature of
a place or the context in which a new scheme is being proposed
is often ignored. What is needed is a Design Review body that
can consider schemes in a genuinely contextual way. Issues such
as townscape, an area's history, character, style and "feel"
are all ones that need to be considered when a new development
is proposed.
15. A problem with CABE's current approach
is that the visual material submitted to the Design Review Committee
is prepared by those who are promoting the scheme. Textual material
is likewise supplied by the promoters, then reframed by CABE staff
to fit within a consistent format. Meetings are generally held
in camera and even if there is a representative present from the
local planning authority (or English Heritage), he or she may
be seeing a proposal for the first time and being asked for a
view "on the hoof". In most instances, members of the
Design Review Committee will not have been to the site and may
well be unfamiliar with the locality. They will not be familiar
with all the local circumstances or issues and because the majority
of the members of CABE's committee are architects or people with
an interest in development, their views are likely, on balance,
to be in favour of development. This is scarcely inclusive or
democratic, or for that matter economically efficient; there is
abundant evidence, published for example in Heritage Counts
(English Heritage 2003) that conservation and reuse of historic
buildings act as an engine of economic regeneration at least as
effectively as brand new development.
16. To compound the problem, the throughput
of cases coming before CABE's Design Review team, whether at officer
or committee level, is far too great to allow for sufficiently
detailed consideration to be given in all instances. The 2001
DETR letter referred to 30-40 projects coming to CABE annually.
In the publication Design Reviewed, published by CABE in
February 2004, the number is recorded as around 500 projects a
year. Those which do not go to a full Design Review Committee
meeting are viewed by a staff and the committee chairman at a
"pin-up" meeting. Thus views are given about developments
in important locations on the basis of cursory consideration by
a handful of people. This is questionable practice, given the
influence a letter from CABE can have with local planning authorities.
THE NEED
FOR EVEN-HANDEDNESS
17. It would be revealing to know how many
schemes (excluding masterplans) coming before CABE's Design Review
Committee are submitted pre-planning by their promoters—the
developers or the architects who have a commercial interest in
seeing the scheme realised—as opposed to being brought by
the local planning authority or others who are not commercially
involved. CABE's own assessment is that it is "increasingly
approached direct by applicants at an early stage". It goes
on to state that its goal "is a productive, collaborative
three-way discussion between applicant, planning authority and
CABE". This is all very well, but it is clear that the public,
except insofar as their views are represented by the democratically-accountable
planning authority, are excluded from this process. This is a
particular problem where the historic built environment is concerned
because the issues raised by new development in historic settings
will normally be more complex than those raised new development
in a less sensitive area.
18. The DETR letter refers to approaches
from local authorities and from "others". These "others"
must be seen to encompass more than simply developers and their
professional advisers. They must for example embrace amenity groups,
but it is not apparent that CABE has ever sought, or accepted
an approach, from a national or local amenity society concerned
about new proposals or that it has ever invited representatives
of such groups to attend its Design Review meetings so that their
voice is heard.
19. Amenity societies—and in particular
the statutory amenity societies represented by the Joint Committee—have
an important role within the planning process; and in the interests
of achieving a balanced conclusion on the likely contribution
of new development to the creation of sustainable and inclusive
communities, CABE should consider their views alongside those
who are promoting their own schemes. HM Government is plainly
committed to encouraging local participation in the planning process
as a way of building communities of responsible citizens. Notwithstanding
its essential role in acting in the public interest (which is
not necessarily the same as acting in the Government's interest)
CABE, as a Government-funded body, should be party to that encouragement.
20. CABE currently gives the impression
that it regards local amenity societies as being conservative
and automatically representative of an anti-development point
of view. Yet it is these groups, with strong local networks and
detailed knowledge of their localities, that care perhaps most
deeply about what happens to their town, village or city. Since
they have to live daily with the tangible consequences, good or
ill, of new development, they are genuinely interested in promoting
high-quality, sustainable environments. Moreover, their interest
is, as it were, disinterested. They have no axe to grind commercially.
They operate on a voluntary basis with minimal funds, giving their
time free to comment on proposals affecting their areas. In our
experience, most local planning authorities value their input
and the contribution they make to forums such as Conservation
Area Advisory Committees.
21. The national amenity societies, equally,
are served by highly-qualified, public-spirited individuals with
years of professional experience of the issues and challenges
that face those seeking to improve the urban environment. We have
a great deal to offer and CABE needs explicitly to recognise that
those with an interest in and knowledge of the historic environment—beyond
the confines of English Heritage—are stakeholders in its
agenda.
| 
