Memorandum submitted by the Institute
of Historic Building Conservation
1. SUMMARY
1.1 Background
1.1.1 This is the evidence of The Institute
of Historic Building Conservation (IHBC) to the Culture Media
and Sport Committee Inquiry on Protecting, Preserving and Making
Accessible Our Nation's Heritage, 2006. It has been prepared
specifically for the Committee.
1.1.2 The IHBC would welcome the opportunity
to appear before the Committee.
1.2 Summary
1.2.1 Historic places are those places that
are valued by people for the way they embody our culture, both
today and for the future.
1.2.2 The forthcoming Heritage White Paper
must establish historic places as sustainable resources at the
heart of our communities. The White Paper is expected to concentrate
on reforms in the identification and management of our historic
places, in line with proposals identified under Heritage Protection
Review/Reform (HPR).
1.2.3 The IHBC enthusiastically welcomes
the thinking underpinning proposed reforms and strategies, especially:
— devolving more responsibilities for
historic places to local people;
— understanding that our historic places
are part of a seamless whole, and
— recognising that the future of historic
places must be supported by local government services that are
secure, properly resourced and fit-for-purpose.
1.2.4 The strategies expected in the Heritage
White Paper provide a real opportunity to re-invigorate local
community support for conservation through the planning process.
At the same time they should secure significant overall savings
when examined across the range of government priorities, including
economic, environmental and social interests.
1.2.5 Yet the IHBC is extremely concerned
that local authority services supporting our historic places are
already under huge pressures. Without significant additional support
they will not have the capacity to deliver under the proposals.
1.2.6 So the White Paper must underpin local
management of historic places by securing both delivery and capacity
at the heart of local government. Its priorities must be:
Legislation: introducing obligations
for local planning authorities to identify and care for their
historic places, and provide specified core services for their
conservation, and
Investment: providing new and
dedicated investment, in the fashion of the Planning Delivery
Grant, to support services and duties.
1.2.7 Legislation and resources must be
balanced by performance measures that will ensure that delivery
is effective and efficient, and in line with central government
targets.
1.2.8 The IHBC's close involvement with
the development the Heritage White Paper's proposals has encouraged
us to produce recommendations that are no less challenging than
those expected in the White Paper. Our proposals will help provide
a coherent strategy for government to secure sustainable communities
and conservation strategies for the 21st century.
2. THE INSTITUTE
OF HISTORIC
BUILDING CONSERVATION
(IHBC)
2.1 The Institute of Historic Building Conservation
(IHBC) is the UK's professional body for the conservation of historic
buildings and places. Our multi-disciplinary membership is active
across the public, private and voluntary sectors, and consists
of professionals working as, conservation officers, planners,
architects, regeneration professionals, project managers, historians,
archaeologists, surveyors, engineers and urban designers, among
others.
2.1.1 The Institute of Historic Building
Conservation (IHBC) supports professional activities in the sector
by:
— determining, defining and operating
professional conservation standards;
— delivering educational, information
and advisory services, for members & the wider public, and
— promoting professional development.
2.1.2 The IHBC operates a range of services,
including publications, both for its own membership and the public.
Our website averages 25,000 hits per day, with visitors from many
parts of the world. (See www.ihbc.org.uk)
2.2 The IHBC encourages participation in,
access to, and awareness and understanding of historic places,
both for their value to communities and as sustainable resources
for our own and for future generations. Historic places help underpin
our social, economic and cultural infrastructure, allowing society
to address key priorities, especially those supporting the creation
of sustainable communities. These can include:
— diversity, including minority needs—historic
places range from low-cost housing to integrated industrial complexes,
and can provide the physical and economic variety capable of addressing
the needs of many communities;
— providing one of most sustainable
resources—in contrast to demolition or replacement of historic
places, their conservation secures low waste (eg carbon emissions
and land-fill) and high-level construction skills;
— promoting genuine social inclusion—they
are especially useful in supporting deprived communities where,
as an alternative to mass housing, they promote an infrastructure
supporting communities with closer social links and more varied
economic bases;
— helping to make towns, cities and
regions secure and more economically competitive by providing
attractive and popular living places for key workers;
— through heritage-led regeneration,
shaping the cutting edge of modern practice in economic restructuring
and diversification;
— delivering education for all, as
our historic places provide the most public manifestation of our
cultural inheritance, including town & city centres, landscapes,
parks, gardens, arts, interiors and design;
— representing and conveying key human
needs and aspirations, from culture, citizenship and community
to a sense of place;
— embodying values and identities across
Britain in all their diversity and plurality, helping create a
national sense of pride and well-being;
— contributing a unique, accessible
and irreplaceable dimension to shaping the Quality of Life for
all.
2.2.1 The above principles are supported
by a wide body of research, publications and surveys and studies,
by a key sector stakeholders—including English Heritage,
Heritage Lottery Fund, Architectural Heritage Fund, and Heritage
Link among others. (See section 5.1 below) They are summarised
in our "Valuing Places" Statement (Appendix 1) (not
printed here).
2.3 Conserving and maintaining our historic
places for the benefit and enjoyment of people today, and for
future generations, is regarded by the IHBC as a core duty of
society.
3, WHAT THE
DCMS SHOULD IDENTIFY
AS PRIORITIES
IN THE
FORTHCOMING HERITAGE
WHITE PAPER
3.1 The forthcoming Heritage White Paper
is expected to focus on the implementation of the conclusions
from the Heritage Protection Review through Heritage Protection
Reform (HPR).
3.1.1 The IHBC has welcomed its close involvement
in examining how local communities in partnership with government
services can best benefit from and support our historic places,
and commends DCMS and English Heritage for their huge efforts
to establish a substantial basis for reform.
3.2 Subject to proper legislation and resources,
IHBC supports the principles behind HPR, including:
— Local Delivery—delivering
effective local management of historic places, which underpins
new procedures for
— New Designation Systems &
the Unified Register—improving procedures & access
to the process of designation
— New Consent Strategies—making
consent procedures simpler and more inclusive, and
— Heritage Partnership Agreements
(HPAs)—integrating management across certain classes
of historic places.
3.2.1 These new strategies are linked to
an ongoing withdrawal of English Heritage from active participation
at many levels of local conservation planning. To inform the implementation
of the strategies, including the more recent discussions of phased
introduction, studies commissioned by DCMS and English Heritage
are currently being undertaken and are projected. (See DCMS &
English Heritage, Local Delivery Research, unpublished drafts,
2006)
3.3 The Heritage White Paper is expected
to propose that local government will deliver new conservation
responsibilities and services, in accordance with the above "Local
Delivery" strategy, in large part through "stand-alone"
planning authorities. However effective "Local Delivery"
can only be achieved when conservation services, fit-for-purpose,
are secured at the heart of local government.
3.3.1 Local planning authorities require
two things to effectively manage their historic places:
— a properly skilled professional team
able to provide expert input into planning decisions, including
raising public awareness through outreach and education, and undertaking
pro-active enhancement, and
— adequate resources specifically supporting
conservation and design services and, through fiscal and funding
opportunities, providing market support where required.
3.3.2 It is generally recognised that the
reform of heritage protection is unlikely to be successful unless
both of these conditions are met.
3.4 We know that conservation services can,
in economic terms alone, draw significant additional investment.
For example in Lincolnshire, East Lindsey District Council Conservation
Team delivered a very successful programme of conservation-led
regeneration schemes attracting significant external funding.
The team invested £450,000 of Council money to secure a total
of £4.4 million of investment in the District, an impressive
return on investment of almost 1:10. (See Appendix 2) (not printed
here).
3.5 However conservation services today
are under serious threat across many parts of local government—including
that in East Lindsey—where they survive at all. At present
we understand that dedicated conservation services for Essex,
Norwich, and Devon County are among those that have been dropped
or are or are being phased out.
3.6 The huge pressures conservation services
in local planning authorities face has been publicly registered
most recently at the Annual General Meeting of Heritage Link on
7 December 2005. Here David Lammy, Minister for Culture, referred
to inconsistencies in the provision of conservation services in
different parts of the country.
3.6.1 Local authority conservation services
usually fail to deliver because of inadequate resources or support
mechanisms, or limited or absent expertise.
3.6.2 Research by English Heritage and the
IHBC in 2003, The Local Authority Conservation Provision Study,
(LACPS, 2003), describes a service surviving under severe pressure
(see Section 9 below). This described conservation services at
that time as follows:
"The overwhelming impression emerging
from the survey is of a conservation service that is often stretched,
under-resourced and operating without many of the necessary `building
blocks' that would ensure an effective, efficient and balanced
service".
3.6.3 Since then extensive local government
reform has only led to the further deterioration of services,
through:
— down-grading of conservation posts
following the low grading of conservation skills and roles;
— diminishing resources compounded
by lack of statutory duty and specific performance indicators;
— new duties & operations, including
those attached to e-government & new planning obligations;
— limited corporate recognition of
sector skills and training needs;
— reduction or cessation of conservation
investment in historic places (including central government allocations).
3.6.4 These organisational problems aggravate
related issues on the ground, encouraging
— a decrease in trainees and professionals
coming into local government conservation service, creating an
ageing profile (figures provided by IHBC for DCMS & English
Heritage research into Local Delivery);
— over-reliance on low-resource strategies,
such as control, to compensate for the lack of pro-active strategies
requiring investment;
— inconsistent regulatory standards,
and, following from these;
— poor public perceptions arising from
over-control in some areas and under-regulation in others.
3.6.5 The IHBC understands the current state
of conservation services across England will be captured in forthcoming
research to be undertaken for DCMS & EH as part of their investigation
of HPR strategies. This will allow for a more detailed understanding
of the present situation.
3.7 As well as bringing opportunities for
local decision-making, new proposals will involve English Heritage
devolving its responsibilities and reducing its scrutiny of local
conservation operations. Increased duty and reduced scrutiny of
local planning authorities must be balanced by the introduction
of clear duties and obligations for delivering conservation.
3.7.1 Ongoing research has identified that
local government structures and managers can be unclear about
their duties to local historic places, in particular as regards
perceived conflicts between preservation and enhancement. (DCMS
& English Heritage 2006, Local Delivery Research, unpublished
draft).
3.7.2 IHBC recognises that all local government
services are subject to significant pressures. However conservation
services are particularly threatened because of the long-term
strategies they require and the diverse cross-sector returns they
bring.
3.7.3 The IHBC notes that the recent proposal
by English Heritage to phase the introduction of local delivery
could help respond to some concerns over capacity, but only at
the expense of effective implementation of Local Delivery. Certainly,
without more clarity in the responsibilities of local government
under HPR, conservations services will always be susceptible to
disintegration.
3.8 KEY RECOMMENDATION
1
To secure local conservation services, the White
Paper must introduce a legal obligation on local planning authorities
to:
— care for their historic places, and
to
— deliver defined services supporting
their historic places, including Buildings at Risk registers,
technical advisory services, grant aid and current and relevant
information in the form of Historic Environment Records.
3.9 Any devolution of duties to local government,
or increase of responsibilities, must be accompanied by dedicated
investment in local authority services in the fashion of the Planning
Delivery Grants (PDG).
3.9.1 We do know that new duties expected
in the White Paper will bring new budgetary pressures, even if
the precise impacts are, at this time, unclear. For example, moving
consents for scheduled ancient monuments to local authority control
will require additional skills to be employed or bought in to
many services. Also, while we understand that there is no detailed
analysis of the financial impact of Heritage Partnership Agreements
(HPAs), they may have considerable resource implications for many
services. English Heritage has piloted a limited number of such
agreements but it has not to our knowledge calculated the cost
to the local authorities in terms of staffing and time required
to bring management agreements into effect. Proposals for Local
Lists, while still undergoing development, also will place new
burdens and additional duties on local services.
3.9.2 Any additional duties for planning
authorities not attached to additional resources will result in
current essential work being sidelined.
3.10 KEY RECOMMENDATION
2
The White Paper must secure an investment programme,
in the fashion of the Planning Delivery Grant, to:
— bring all local conservation services
to an operational standard in anticipation of the changes, and
— cover the impact of Heritage White
Paper proposals on internal budgets.
3.11 To ease pressures on local conservation
services under any White Paper proposals, ODPM must take a lead
in delivering support for the services, their resources and their
budgets, either directly through White Paper-related reforms,
or indirectly through other initiatives. These would be expected
to include delivering:
— Regulation of demolition through
planning controls;
— Performance indicators for local
authorities;
— Conservation Area controls;
— Interim revision of select parts
of PPG 15, and
— New development guidance.
3.12 Demolition: Demolition is not
regarded as development, so communities often look to conservation
controls to protect threatened buildings, regardless of their
historic value. This places a burden on the sector as a whole,
and undermines conservation principles. As un-managed demolition
itself is environmentally unsustainable, demolition should be
controlled within the wider planning system. This would then ease
the burden on conservation services under the new proposals.
3.13 Performance indicators: Corporate
support for conservation services within local government could
be enhanced or secured by using relevant performance indicators.
Such indicators shape wider management processes and, provided
they are fit-for-purpose, can help manage resources within local
authority priorities. Assessing over time the numbers of historic
Buildings At Risk, for example, would help focus attention on
their rescue.
3.14 VAT on repairs: As VAT is charged
on repair or refurbishment, but not on new-build, there is a key
financial incentive to replace old and historic fabric with new,
rather than repair it. The ODPM Committee report on The Role of
Historic Buildings in Urban Regeneration (2004) recommended that
that "The tax system needs to favour the preservation and
reuse of historic buildings rather than deter it. The imposition
of VAT on the repair of historic buildings whilst newbuild projects
are exempt deters developers from taking on complex projects involving
historic buildings and runs counter to the Government's sustainability
agenda and its policy on promoting the reuse of historic buildings".
(Recommendation 23).
3.14.1 The IHBC notes the Government's response
(November 2004), and urges the ODPM to identify a route that will
resolve the discrepancy, rather than present a reason why it should
not. There is an ongoing review of the impact of reduced VAT rates
that includes as an objective the "modernisation" of
the system in the context of labour-intensive activities. As
part of this, there was an experimental reduction of VAT on repairs
and renovations to private dwelling in The Isle of Man. Unfortunately
it was assessed only in basic fiscal terms, of employment and
prices, and not the wider environmental benefits such reductions
could bring. As of 2003, construction industry activities involving
repairs, maintenance and improvement—"RMI"—constituted
50% of the entire business of the construction sector, effectively
contributing to 4% of GDP (see Altogether stronger, Skills Needs
Analysis for construction (Sector Skills Council for Construction,
2004-05). The IHBC believes that, not least given the scale of
the activities, any study of the modernisation of VAT should include
a test of the impact on cultural and environmental resources of
reduced VAT on repairs.
3.15 Conservation Areas: Conservation Areas
are increasingly seen as effective tools for delivering economic
development and regeneration, but they are also complex and inconsistent
in their scope, convoluted in process and limited in impact. They
need to be simplified and clarified. To bring development in conservation
areas under more effective control, the Institute believes that
in this specific instance more regulation would equate to better
regulation in terms of comprehension and ease of administration.
3.15.1 Without supplementary controls (referred
to as "Article 4s") conservation areas do not provide
the protection and quality assurance that people expect of them.
Conservation Areas should become a designation with simple, robust
and consistent control of demolition and damaging change, and
require the retention of key cultural features such as doors and
windows, roofing and walling materials, chimneys etc.
3.16 PPG 15 update: The re-writing of a
consolidated policy statement for historic places must await new
legislation. However there is still an urgent need for interim
revisions and up-dates of parts of PPG 15.
3.17 New development guidance: The IHBC
is concerned over the low quality of much new development, including
that in and around conservation areas, or involving extensions
or adaptations to listed buildings. New development in historic
places does not need to imitate the original, it should be a creative
response to it. Legislation and guidance for new development in
historic places, and resources to ensure best practice, should
encourage quality.
3.17.1 The IHBC welcomes the strength of
recent guidance for planning authorities on design. This advises
that: "Design which fails to take the opportunities available
for improving the character and quality of an area should not
be accepted". (PPS1) This is now more rigorous than the special
requirements for listed buildings and conservation areas. New
guidance for historic places should ensure that:
— Conservation designations promote
creative solutions, not suppress them. Guidance should deal with
situations where new development seeks to complement general townscape
characteristics (not stylistic characteristics) and those where
bolder statements are appropriate;
— Guidance should also deal with the
relationship between planning and the procurement and construction
of development. At present, many local planning authorities and
designers leave important design decisions to building contractors,
when careful conditioning of planning consents can be used to
assure better design quality;
— Better design training for decision
makers in both urban design and architectural principles is essential.
This should lead to better understanding of the difference between
quality assurance, and subjective stylistic preferences;
— There should be a greater emphasis
on analysis and understanding of urban context in new design.
Conservation Area appraisals, area or building management plans,
and urban design frameworks are examples of good practice.
3.18 KEY RECOMMENDATION
3
ODPM must lead in delivering reforms to support
proposals in the Heritage White Paper, including:
— controlling demolition through the
planning system;
— pursuing a clear strategy for equitable
VAT on repairs, to include promoting in Europe an examination
of the cultural and environmental impacts of reduced VAT on repairs
given their labour-intensive nature;
— promoting management mechanisms,
such as performance indicators, to support delivery of local conservation
services, such as Buildings at Risk services;
— tightening Conservation Area control
and making it more consistent;
— completing an interim revision of
agreed parts of PPG 15;
— demanding quality new design in historic
places either though tightening current planning legislation or
through supporting guidance.
3.19 As the responsibility for implementing
new heritage legislation will fall primarily to local authorities,
the IHBC is concerned that the steering group overseeing the HPR
programme appears to have no representatives from the local government
sector. This is could undermine the value and delivery of White
Paper proposals.
3.20 KEY RECOMMENDATION
4
Local Government representation should be given
priority in the further development of the Heritage White Paper.
4. THE REMIT
AND EFFECTIVENESS
OF DCMS, ENGLISH
HERITAGE AND
OTHER RELEVANT
ORGANISATIONS IN
REPRESENTING HERITAGE
INTERESTS INSIDE
AND OUTSIDE
GOVERNMENT
4.1 Joined-up government is essential to deliver
the cross-cutting benefits of historic places, and this is not
evident. Historic places, and their roles in creating sustainable
communities, are side-lined or overlooked in favour of more narrow
departmental agendas. Despite their best efforts DCMS, which is
responsible for historic places in central government, has not
been able to achieve cross-government support, for example:
4.1.1 As noted above, reduced VAT on repairs
would help promote the more environmentally and economically sound
principal of maintenance over replacement. Key development and
economic interests in government have failed to pursue this strategy
pro-actively, despite consolidated calls across the sector.
4.1.2 Similarly, the sequence of challenges
faced by English Heritage in recent years, including review, re-structuring,
re-organisation and, now, re-location, have been met only by an
overall reduction in investment from central government (See section
7.1 below).
4.1.3 The remarkable returns the HLF has
brought through its cross-cutting investment in the social benefits
of conservation have been fully and effectively documented in
their publications. Yet now its fund is threatened by a multiple-whammy
of re-distribution of reserves, reduced income from lottery sales,
and threatened reductions due to the forthcoming 2012 Olympics.
4.1.4 Again, the extra capacity and coordination
Heritage Link brings to the sector is achieved in the face of
minimal investment by central government, despite the huge added
value it brings in voluntary contributions from member organisations.
Similar problems are faced by the national amenity societies,
despite their capacity to promote informed engagement in development
issues.
4.1.5 The IHBC's long-standing advocacy
of the importance of local government services delivering support
for historic places—an agenda supported by many partners
across the sector—has been met only by the deterioration
of services referred to in section 3 above.
4.1.6 The positive initiatives of DEFRA's
invaluable involvement in the improvement of historic places through
agri-environment schemes is extremely welcome, but represents
an exceptional situation, spurred on by European funding, rather
than the ordinary practice it should.
4.2 As the management and guidance of change
takes place through the planning process, the lead department
for planning, currently ODPM, should also be the lead department
for the protection of the historic environment.
4.3 KEY RECOMMENDATION
5
Government reform at Cabinet level is required
to deliver joined-up support for historic places at the most strategic
level, including re-locating DCMS interests in historic places
inside the planning portfolio currently held by ODPM.
4.4 It is essential that Government takes
full advantage of the ways it can directly support historic places.
4.4.1 In particular Regional Development Agencies
(RDAs) have a key role in determining regeneration strategies
and priorities for different areas. Yet unless there is a strong
qualitative basis to their activities, regeneration is unlikely
capitalise on community and cultural resources and to be sustainable.
IHBC would like to see a greater emphasis on the quality of regeneration,
especially through recognition of the capacity for heritage-led
regeneration, supported by quality design, to deliver higher value
and more sustainable benefits. Greater public involvement, including
meaningful community participation, would help incorporate in
the development of RDA priorities genuine local interest in historic
places.
4.4.2 The Commission for Architecture and
the Built Environment (CABE) helps to provide guidance on best
practice in new architectural and urban design. Closer and more
integrated working between CABE and English Heritage, supported
through ODPM, would enable a more effective holistic approach
to the quality of the built environment, old and new.
4.4.3 Government must support inter-departmental
communication by promoting participation by heritage bodies with
cross-sector interests, such as IHBC and Heritage Link.
4.4 KEY RECOMMENDATION
6
Government must deliver its support for historic
places through all its activities and partners, including:
— ensuring that every RDA employ special
advisers with skills in conservation and design, and responsibility
for quality assurance;
— encouraging links between English
Heritage and CABE;
— actively promoting participation
by heritage organisations with cross-sector agendas, such as IHBC
and Heritage Link, in the development of inter-departmental agendas.
4.5 Faced by a wider agenda and diminished
resources, lack of government support for English Heritage has
undermined its capacity to deliver. For the future it must be
encouraged to focus on two key priorities, casework support—both
for today and under any HPR strategies—and investment in
historic places through grants. IHBC is especially concerned that
English Heritage caseworkers are overstretched at present and
that funding for partnerships in conservation areas grant schemes
is being squeezed. Property management and visitor site functions
should not distract from the need for effective partnership with
local government.
4.5.1 English Heritage must continue to
develop its focus on the ways area grant schemes and other heritage
initiatives contribute to sustainability and social inclusion,
and actively pursue closer working with regional development agencies,
English Partnerships and other investment, funding and regeneration
agencies.
4.6 KEY RECOMMENDATION
7
English Heritage should give priority to:
— working in partnership with local
authorities to support local conservation delivery, and working
with regional development agencies and other agencies to promote
awareness of the importance heritage plays in regeneration and
the creation of sustainable communities;
— securing, delivering and promoting
investment in conservation area-based schemes;
— developing its casework function
to ensure that proper support is given to local authorities when
dealing with planning proposals and regeneration projects, both
for today and in line with any HPR proposals.
5. THE BALANCE
BETWEEN HERITAGE
AND DEVELOPMENT
NEEDS IN
PLANNING POLICY.
(THE ROLE
OF HERITAGE
IN DELIVERING
SUSTAINABLE DEVELOPMENT)
5.1 There is no necessary conflict between
heritage and development interests. Already progressive development
practices are seeing historic places as positive catalysts for
regeneration, diversity and economic growth, and for promoting
quality new design.
5.1.1 In fact the role of heritage in the
delivery of wider economic benefits, including especially heritage-led
regeneration, is well established in a range of reports. Some
of the main ones are:
— Regeneration and the Historic Environment,
English Heritage, 2005;
— New Life—Heritage and Regeneration,
The Heritage Lottery Fund, 2004;
— The Role of Historic Buildings in
Urban Regeneration, ODPM Housing, Planning, Local Government and
the Regions Committee, 2004;
— The Heritage Dynamo, Heritage Link,
2004;
— Heritage Counts, English Heritage,
2003;
— Heritage Dividend, English Heritage,
2003;
— The Economic Power of Restoration,
D Rypkema, 2001.
5.1.2 Schemes based on the conversion and
reuse of historic buildings and areas are amongst the most sustainable
forms of development and are crucial tools in the delivery of
sustainable communities. As identified in the publications cited
in 5.1.1, there are numerous dimensions to this:
— Energy and landfill—Demolition
of existing building stock contributes to landfill and involves
the loss of the embodied energy used in the manufacture of materials
and construction. Further energy is then invested in the replacement
development, usually at the expense of high carbon emissions.
This can be avoided by working to retain and convert historic
or other existing building stock rather than replace it.
— Historic buildings and areas better
support mixed use and mixed communities due to the wider range
of types of floorspace and rental levels.
— This factor also allows community
uses to be more easily accommodated. It also provides for minority
needs and demands and promotes social inclusion. For example,
older areas can provide a focus for specialist retail such as
charity shops, affordable IT, alternative music and youth culture,
and ethnic foods and fashions.
— The variation in rental levels is
also crucial to accommodate small businesses, creative and high
tech industries and fostering innovation. Historic buildings can
provide for economic diversification and increased job opportunities.
— Historic places are also important
for cultural development, both by catering for minority tastes
and also often having a past associated with local industries
and specialisms. Historic buildings often form a focus for the
arts and craft based skills.
— Older housing areas are often high
density in nature and for many people are a preferred choice to
"soulless" off-the-peg new housing.
— Historic buildings have also helped
to increase diversity of housing stock, including the repopulation
of inner city areas. Often such schemes incorporate a range of
tenures including affordable housing and starter homes.
— Historic areas often incorporate
good urban design principles, such as legibility and good pedestrian
permeability. Historic buildings and spaces are often adaptable
to changing demands. Pedestrian interests can be a strong feature
of historic places.
5.1.3 In addition heritage-led regeneration
has been a key element in the transformation of inner cities all
around the UK in the past decade, prominent examples including
Grainger Town and the Baltic Flour Mill in Newcastle, Ropewalks
in Liverpool, the canal corridors and City Centre in Manchester,
the Jewellery Quarter in Birmingham and the Lace Market area of
Nottingham.
5.2 At the same time, environmental and
economic interests have become more closely integrated, not least
in response to issues such as Global Warming and bio-diversity.
As carbon trading is increasingly factored into key economic decisions,
conservation is, compared to new development, a low-carbon emission
strategy by definition. The cross-sector BEFS response to the
DEFRA consultation on sustainability, Taking it on, noted that
`historic fabric is intrinsically "sustainable".
5.2.1 Conservation strategies help to manage
development in a more sustainable way, and are associated with
reduced waste & landfill, recycling, lower carbon emissions,
more advanced skills, tourism, and more attractive working and
living environments, all of which have clear economic impacts.
(See 2.4 above and 6 below).
5.3 Similarly the sustainable conservation
of historic places requires specialised skills and competences
capable of informed professional operations, such as those required
for IHBC membership. The sector's recognition of the principle
of inter-disciplinary skills is represented by key publications,
including the Egan Report, the ODPM's Evidence base review of
skills for sustainable communities (2004), the cross-cutting interests
of the Academy for Sustainable Communities (ASC), and the Construction
sector's analysis of needs in skills, Altogether stronger, Skills
Needs Analysis for construction (see above). This last has noted
that "There is a lack of understanding of the impact of the
Government's wide-ranging sustainability agenda on what and how
the industry builds". Clearly the sector as a whole fails
to understand the contribution conservation can make to the sustainability
agenda.
5.3.1 To deliver support for historic places
effectively and efficiently, it must be shaped by skilled conservation
professionals who are fully informed of its priorities and principles.
Membership of relevant professional institutes, including the
IHBC, helps confirm standards, not least as most institutes usually
require ongoing professional development programmes. Increasingly
informed developers are looking to employ this type of expertise.
Planning authorities and English Heritage can play an important
role here by insisting on appropriate professional qualifications.
5.3.2 English Heritage initiatives to enhance
the skills of professionals operating in conservation and related
disciplines are particularly welcome, and have the full support
of relevant professional bodies such as the IHBC.
5.4 However, at the local planning level,
conservation benefits are generally not valued for their contribution
to wider sustainability-related targets, and so the opportunity
to promote sustainable development at the local level is compromised,
even under-mined. In the absence of a suitable indicator, it is
impossible to include these conservation-related benefits in wider
sustainable strategies.
5.5 KEY RECOMMENDATION
8
Establish a new sustainability indicator covering
conservation and historic places so they can be managed within
wider planning strategies, including Local Development Frameworks.
6. ACCESS TO
HERITAGE AND
THE POSITION
OF HERITAGE
AS A
CULTURAL ASSET
IN THE
COMMUNITY
6.1 The IHBC encourages physical and intellectual
access to the built heritage for all people.
6.1.1 Projects that are partially or completely
funded from public sources provide opportunities to require and
develop such access. IHBC members are involved in sensitively
adapting buildings to provide access for people of limited mobility,
all in accordance with statutory and best-practice requirements.
6.2 Heritage has a fundamental role in defining
national, regional and local cultural identity (See section 2
above).
6.2.1 Industrial heritage in places like
Birmingham, Nottingham, Liverpool and the Potteries provide locally
distinctive townscapes, sometimes still accommodating the original
manufacturing activities, but also often accommodating new businesses,
creative industries and other activities.
6.2.2 The Ropewalks area of Liverpool became
a focus for creative industries. Places like Birmingham's Jewellery
Quarter or Nottingham's Lace Market have adapted and contribute
to modernisation and diversification. Market towns, canals, historic
city and town centres, traditional housing areas, post-war planned
development, villages, parks, gardens, cultural landscapes, and
a range of other historic places all contribute to creating balanced,
sustainable and well functioning places.
6.3 Historic areas are often better at catering
for the needs of local communities and minority groups. The diverse
needs of small communities will often correspond more closely
to those uses that historic places originally addressed, including
the provision of flexible living and working spaces. (See section
5.1.2 above)
6.3.1 Shops and businesses catering for
specialist markets are rarely to be found in areas that have been
comprehensively redeveloped, but are often found in older buildings
and areas which offer more viable rental levels.
6.4 The destruction of historic areas has
often resulted in the loss of community facilities, break-up and
fragmentation of communities, narrowing of economic and employment
choices and opportunities, and loss of distinctive local identity.
6.4.1 While more rare than in previous decades,
such mistakes are still being made. The public outcry against
recent plans to demolish large areas of terraced housing in Housing
Pathfinder areas illustrates this. This is not to say that the
worst housing shouldn't be demolished, but it is crucial to look
beyond crude supply and demand economic factors and consider the
more complex human interactions of communities, as well as the
environmental impacts, such as waste generation and carbon emissions.
(See section 5 above)
6.5 Conservation strategies shaped through
HLF and EH funding increasingly remind us that the profile of
people who live, work and spend leisure time in historic buildings
and places is extremely diverse.
6.5.1 Indeed many under-privileged, minority
and `hard to reach' groups are key stakeholders in managing heritage
assets, and only need access to the resources to become caring
and constructive. Innovative and creative approaches are required
support and empower local communities and minority groups. These
include area grant schemes, individual projects and educational
initiatives aimed at both schools and communities, such as those
being undertaken in various regions by Planning Aid England.
6.6 Local historic environments also have
an educational role, helping people to understand how their area
developed and grew. Such understanding is often crucial to managing
and planning the future of an area in partnership, informed by
the wishes of the community.
6.6.1 Local schools' `Citizenship projects'
on the history and potential of their own surroundings involve
the wider community, as children take the ideas home to their
parents. Cutbacks in English Heritage mean that despite excellent
generic publications the organisation has had to concentrate on
its own sites or immediate policies, rather than a wider agenda,
and this is a missed opportunity. Partnership with the DfES could
secure funding to provide schools with local resource material
for such projects.
6.6.2 As is well known, historic places
can also form the basis of tourism and the visitor economy is
increasingly significant in many areas.
6.7 The contributions of the HLF—and
its strategy for allocating funding within access-related priorities—have
significantly enhanced access to the heritage while also promoting
its conservation. However recent reductions in funding for heritage
projects reduces the scope for such activities. This will leave
more of our historic places inaccessible to many members of the
public. Also, by failing to implement conservation strategies
today, it will also compromise access by future generations.
6.8 Historic places
represent the cultural legacy of different places and communities,
but also help them to adapt and provide for ongoing cultural development.
The destruction or neglect of historic buildings and areas destroys
cultural diversity and increases social exclusion. A properly
resourced heritage sector is a crucial part of an inclusive and
diverse society.
6.9 Key Recommendation 9
In order to secure access, understanding and
enjoyment of our historic places for all communities, for today
and for future generations, proposals expected in the forthcoming
Heritage White Paper must be properly resourced and implemented.
7. FUNDING, WITH
PARTICULAR REFERENCE
TO THE
ADEQUACY OF
THE BUDGET
FOR ENGLISH
HERITAGE AND
FOR MUSEUMS
AND GALLERIES,
THE IMPACT
OF THE
LONDON 2012 OLYMPICS
ON LOTTERY
FUNDING FOR
HERITAGE PROJECTS,
AND FORTHCOMING
DECISIONS ON
THE SHARING
OF FUNDS
FROM LOTTERY
SOURCES BETWEEN
GOOD CAUSES
7.1 Government investment in historic places
has diminished rapidly in recent years. The IHBC is appalled by
the relative decline in funding for English Heritage at a time
when DCMS commitment to the arts and sport has seen large increases.
English Heritage has, by its own figures, been subject to a £9.7
million reduction in funding over the past five years. This marks
a stark contrast with other players in the culture sector (See
DCMS Annual Reports). HLF's rightly celebrated contributions to
the sector—with £3 billion invested in the heritage
since 1995—have been a key safety line for the sector. However
these are masking huge reductions in core government funding.
7.2 Notwithstanding
the poverty of government investment, English Heritage, the HLF
and other investment bodies and charities, have achieved exceptional
value for their investments by securing sustainable futures for
many of the nation's historic places, in some of the most challenging
fiscal and social circumstances. (See for example Annual Reports
of English Heritage, Heritage Lottery Fund, Architectural Heritage
Fund)
7.3 The current low priority for heritage
and freeze on investment in historic places will not support sustainable
development as it actually ignores the wide social, cultural and
environmental returns these places bring. (see section 2 above)
The consequences are:
— English Heritage has reduced casework
support for local authorities and building owners, without compensatory
increase in local authority capacity. This can only bring about
a drop in the quality and substance of decisions
— Funding for area grant schemes is
being lost. Such schemes have a significant role to play in delivering
regeneration and social inclusion
— The potential of the built heritage
is not being realised in terms of accessibility, education, economic
development, and delivery of a range of beneficial new uses, a
problem aggravated by the difficulty of measuring this failure
— Buildings at risk problems of under
use, poor condition, dereliction and environmental degradation
cannot be adequately addressed, which will give rise to an increase
in demolitions
— The regeneration of inner city areas,
industrial areas, towns and villages, and rural areas can be compromised,
especially in areas of significant market failure
— Skills in the sector are not being
adequately maintained or developed
— Lack of certainty over future funding
is undermining pro-active project development activities
— There is a huge loss of other public
and private sector funding that could be levered by heritage funding
7.4 Key Recommendation 10
Given central government failure to maintain
overall budgets for bodies investing in historic places, there
should be a formal commitment to redress recent funding imbalances
in the sector, in particular for English Heritage.
7.5 Pressures on budgets of heritage bodies,
especially the HLF, from the 2012 Olympics, ignore the wide-ranging
social contribution achieved through strategic investment in historic
places. The Olympics is a remarkable national opportunity to show
the international community our best-practice in regeneration,
including heritage-led regeneration. Indeed area regeneration
was the centrepiece of the successful bid. Heritage bodies have
key roles to play for 2012, and, not least to avoid the international
criticisms faced in previous Olympics-related development programmes,
they should have access to additional dedicated funding.
7.5.1 However as the regeneration for 2012
will be necessarily largely localised, any investment there should
not result in an overall reduction in regional investment in heritage
programmes.
7.6 Key Recommendation 11
Additional budgets should be made available
to key funding bodies such as English Heritage and HLF for 2012,
as investment in heritage programmes, especially area grants,
is the key to securing sustainable development for many parts
of the Olympics' regeneration programme.
7.7 The Heritage Lottery Fund provides funding
for individual building projects and for historic areas through
the Townscape Heritage Initiative (THI) programme, while also
supporting diversity in and access to the sector through educational,
policy, research and related strategies.
7.7.1 The HLF has built a highly effective
policy and public relations resource supporting heritage interests
across the sector directly out of its investment strategy. The
integration of its funding strategy and its policy development
has been an important development in the representation of the
heritage interests at all levels of government.
7.7.2 The HLF area programmes are particularly
effective in under-pinning this strategy. THI's have helped to
deliver dramatic transformations of town centres, traditional
industrial cores, and other failing or under-performing areas.
7.8 Key Recommendation 12
The individual grant-based investments and Townscape
Heritage Initiative programme of HLF should be consolidated and
expanded. Care is required to ensure that resources are not drained
from the programme by the Olympics or from the transfer of funds
to other lottery operators.
7.9 At least two separate area grant schemes
for historic places, as currently operated through English Heritage
and the Heritage Lottery Fund, must be maintained, to provide
match funding under Treasury guidelines.
7.9.1 It is essential that both English
Heritage's area partnership schemes and the Heritage Lottery Fund's
Townscape Heritage Initiatives continue to operate independently.
They have differing criteria and are used in different circumstances.
It is especially crucial that at least two independent heritage-specific
funding bodies exist, for match-funding purposes as it is not
always possible to obtain match funding from mainstream regeneration
sources.
7.10 Key Recommendation 13
Individual grant investments and Townscape Heritage
Initiative programmes should be maintained and expanded, with
a particular focus on the need for the retention of two separate
funding streams, as is currently available from English Heritage
and HLF.
7.11 There is a lack of understanding and
application of principles of investment and return in the sector.
There is an urgent need for fiscal perspectives on:
— Heritage Protection Reform proposals,
including a full cost-benefit analysis of its impacts across government
services and priorities
— the role of the historic environment
in delivering social, economic and sustainability objectives,
including the Government's Sustainable Communities policy
— the benefits of expanding skills
in the sector, including craft-based, technical and professional
skills
— the advantages of promoting pro-active
strategies such as project-based investment, rather than just
reactive control work
— the benefits arising from better
integration with other Government departments, including the education,
planning and regeneration ministries
— environmental returns, and associated
budgetary gains, from conservation
7.12 The IHBC, based on its knowledge of the
state of our historic places, suggest the following priorities
for investment:
— better investment local government
specialist design and conservation services
— an expanded English Heritage casework
and funding capacity
— expansion of area grant schemes,
especially in areas of market failure
— grants for buildings at risk
— development of sector skills, across
the public, private and voluntary sectors. These should include
practical building skills, design and conservation training, and
generic skills such as project management
— improved access to heritage
— education and capacity building initiatives
aimed at both local communities and the visitor economy
7.13 Key Recommendation 14
The IHBC urges a comprehensive reassessment
of investment in our historic places, including grant and funding
programmes, to gain a better understanding of the returns this
can bring, with a view to redressing reduced allocations to the
sector over recent years.
8. WHAT THE
ROLES AND
RESPONSIBILITIES SHOULD
BE FOR
ENGLISH HERITAGE,
THE HERITAGE
LOTTERY FUND,
LOCAL AUTHORITIES,
MUSEUMS AND
GALLERIES, CHARITABLE
AND OTHER
NON-GOVERNMENTAL
ORGANISATIONS IN
MAINTAINING THE
NATION'S
HERITAGE
8.1 The IHBC commends the wide spectrum of
active players in our sector as a sign of its vigour, inclusiveness,
diversity and accessibility. However we do also recognise that
this breadth of interest can limit clarity in policy and strategy,
both inside and outside the sector. In response, the IHBC is committed
to promoting stronger partnership between the sector's stakeholders,
including developing inclusion and diversity agendas.
8.2 As a multi-disciplinary
organisation, IHBC especially welcomes co-ordinating bodies such
as Heritage Link and The Joint Committee of National Amenity Societies,
in particular for the extra capacity they bring to the sector.
Such consolidation, whether of policy or resources, does not undermine
the inclusion and diversity inherent in the sector.
8.2.1 The roles and responsibilities of
English Heritage, HLF and local authorities are considered in
sections 3 and 4 above, and in section 9 below.
8.3 Each of the bodies referred to in this
section's title plays a variety of roles in the sector, again
representing its capacity to deliver. Any formal classification
necessarily under-estimates their contribution. However key activities
may include any of the following, all of which are crucial to
delivering futures for our historic places:
— Funding—providing and directing
investment in historic places, typically through grants and funding,
ranging from strategic investment provided by English Heritage
and HLF, through the activities of the Architectural Heritage
Fund, to small charities supporting individual building preservation
programmes
— Preservation & Regeneration—often
project-based organisations, such as building preservation trusts
(BPTs) generally constituted as charities, that develop, manage
and operate conservation programmes invariably benefiting from
high voluntary and community inputs
— Advice—again ranging from national
bodies such as English Heritage to the informed specialised activities
of national amenity societies or institutes such as the IHBC,
to local amenity interests represented by civic trusts
— Advocacy—issues-based support
for historic places, operating at strategic levels (such as through
policy development by professional institutes like IHBC) as well
as specific project-oriented advocacy in the informed casework
of the national amenity societies
— Stewardship—providing strategies
for caring for specific parts of the nation's historic places,
either direct, through ownership & maintenance, or indirect,
through supporting the informed guardianship that the planning
system can provide
— Education—promoting understanding
and awareness, an activity to which all organisations will contribute
— Community support & inclusion—Adding
capacity to the community, through promoting voluntary activities,
engagement with and mediation in public interests, and promoting
access, diversity and inclusion
— Professional support—professional
institutes, such as the IHBC, that provide quality assurance through
promoting and regulating professional activities
8.4 Types of bodies may be best classified
according to scale, focus and remit:
— Large-scale dedicated national heritage
bodies such as English Heritage and HLF bring a wide-ranging experience
and understanding of the nation's heritage in all its manifestations—from
technical conservation of objects to policies for places—that
is particularly valuable to the wider sector
— Smaller scale national heritage bodies
such as the national amenity societies play key roles in building
capacity in the community and informing planning strategies through
informed advocacy
— Professional institutes—Promote
and support professional activities, while also encouraging voluntary
activities and development within the profession
— Link organisations, such as Heritage
Link and the Joint Committee of National Amenity Societies, that
help build capacity, communications and partnership
— Voluntary organisations (including
amenity bodies)—play a central role in delivering support
for and information on the sector through community interests.
They are invariably among the most fully informed players within
their own remit, and add huge value to the sector through their
voluntary activities
— Others—the many other bodies
that play roles outlined in section 8.3 above, with varying degrees
of responsibility, interest and success, including national advisory
bodies such as CABE, professional institutes such as RIBA and
RTPI and many others.
8.5 The forthcoming Heritage White Paper heralds
significant change in the sector, particularly for core conservation
service providers, such as English Heritage and local planning
authorities. The IHBC considers that, beyond dedicated investment,
there should be no major changes in roles and responsibilities
for bodies in the wider sector until there is a better understanding
of the impact any changes will bring.
9. WHETHER THERE
IS AN
ADEQUATE SUPPLY
OF PROFESSIONALS
WITH CONSERVATION
SKILLS; THE
PRIORITY PLACED
BY PLANNING
AUTHORITIES ON
CONSERVATION; AND
MEANS OF
MAKING CONSERVATION
EXPERTISE MORE
ACCESSIBLE TO
PLANNING OFFICERS,
COUNCILLORS AND
THE GENERAL
PUBLIC
9.1 Much of the evidence presented in section
3 and after confirms that there is not an adequate supply of professionals
with suitable cross-sector skills, that conservation is a low
priority in many planning services, and that conservation expertise
can only be made more accessible by framing suitable and specific
legislation, and providing core resources.
9.2 The Local Authority
Conservation Provision Study (LACPS) of 2003, commissioned jointly
by English Heritage and IHBC, comprised data and analysis of conservation
staffing resources in England (LACPS, 2003). It remains the most
substantial publicly available survey able to inform the current
debate on capacity in local government. The main findings of the
study were:
— On average, local authorities employ
an average of 1.7 specialist staff—a very modest figure
for the extensiveness of the resource they need to manage
— Provision is very inconsistent, with
some authorities employing a single isolated officer or no specialist
staff
— Conservation specialists display
a wide range of skills to carry out their work effectively
— Salary and grades levels are low
to modest
— Because of limited capacity, workloads
tend to be focused on short-term reactive matters rather than
long-term proactive initiatives
9.3 Extensive data collected by IHBC as part
of the LACPS study, monitoring of over 950 conservation officer
posts since 1998 and local authority Best Value studies has demonstrated
a very consistent pattern to conservation officer workload priorities
over most types of local authorities (the main exception being
county councils). Skills required are reflected in the composition
of the workload that the study described:
— specialist Advice on planning, policy
and other technical issues
— schemes of Grant Aid (HERS, THIs
etc.)
— evaluation of Conservation Areas
— enforcement & Buildings at Risk
9.3.1 Priorities in the workload demonstrated
that that short-term high pressure workload takes precedence over
long-term large-scale and complex workload such as enforcement
and quality assurance.
9.4 The survey included the following conclusions:
The overwhelming impression emerging from the
survey is of a conservation service that is often stretched, under-resourced
and operating without many of the necessary `building blocks'
that would ensure an effective, efficient and balanced service.
Too many authorities hold inadequate information about the extent,
character and condition of the historic resource to be managed.
This is likely to lead to a failure on the part of authorities
to match resources with the scale of the challenge they face.
Staffing levels are often modest in relation to the size of the
resource to be managed and the workloads faced. Whilst it is clear
that the majority of conservation specialists would claim to be
covering a very wide range of activities, development control
tasks invariably predominate at the expense of other important
work. Consequently much of what might be regarded as essential
best practice, such as buildings at risk work, conservation area
appraisals, enforcement, monitoring and other proactive tasks,
inevitably receives comparatively low priority in many authorities.
In the context of rising development pressures,
it seems unlikely that local authorities will be able to properly
address their responsibilities for managing the historic environment
without more resources, a national framework of standards and
associated performance indicators.
9.5 Feedback from IHBC members indicates that
the above situation has continued to decline since 2003.
9.6 The ODPM report
by Ernst & Young on Evidence base review of skills for sustainable
communities (2004) confirms that `Quantitative and qualitative
evidence indicates that supply shortages are emerging' in the
supply of Conservation Officers. It also notes that `average [Local
Authority] spending on built environment conservation has remained
constant over the past 5 years, which translates as a decline
in real terms'.
9.7 There is a clear need to address the inter-related
problems of supply, service, resources and capacity in the sector.
This is especially important if the full potential of the historic
environment is to be realised, especially through proactive work
such as undertaking buildings at risk surveys, action planning,
project formulation, bidding, project delivery, formulating area
masterplans, regeneration strategies and design frameworks, etc.
9.8 The IHBC considers
that the effective implementation of the recommendations listed
in section 3 will help secure delivery by local conservation and
planning services of the support that is essential to the survival
of our historic places.
10 CONCLUSIONS
10.1 Historic places have a key role in delivering
a range of social, economic and sustainability objectives. However,
these roles have not been fully appreciated, even in the Government's
own sustainable communities policy. Progressive erosion of core
services has been accompanied by their under-valuing and over-criticism,
not least within the sector itself. Cabinet initiatives appear
essential to provide the cross-sector agenda that historic places
need for their survival.
10.2 The initiatives
that must accompany the proposals in the Heritage White Paper,
including specifying obligations to local authorities, PDG-style
investment, and fiscal and planning reform, provide a real opportunity
for government departments together to ensure that heritage is
firmly integrated with the wider economic, education, social,
sustainability and community agendas.
10.3 Pursuit of VAT reform on refurbishment
works, and securing the control of demolition in planning, would
provide the sector with a early votes of confidence in its future.
There is also a need to simplify heritage protection and make
it more robust. In particular, conservation areas need to be comprehensively
reviewed to make the designation process simpler and more consistent.
Again the proposals expected inside the White Paper should help
address issues.
10.4 There is also
a desperate and urgent need to review investment in the heritage
sector to ensure that the full potential of historic environment
resources can be realised. The reduced funding for pro-active
initiatives, such as area grant schemes, must be reversed as a
matter of urgency. Again the Heritage White Paper proposals, which
will bring a significant additional burden on a failing sector,
provide both a framework and an opportunity to address these issues.
6 February 2006
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