Memorandum submitted by Judith Martin
Judith Martin M.Sc. (Historic Conservation)
Industrial Buildings Preservation Trust (officer)
City of Winchester Trust (trustee)
Women's Environmental Network (director)
SE Association of Preservation Trusts (member)
SE Historic Environment Forum (member representing
SE APT)
SE Forum for Sustainability (ditto)
Although I represent the above bodies in various
forums, the following is my own opinion. The range of interests
shown above indicates my profound belief that the conservation
of the built environment is an essential part of the protection
of the wider, natural environment.
1. What the DCMS should identify as priorities
in the forthcoming Heritage White Paper
(i) The first priority is for the Department
to liaise with other government departments—Treasury and
ODPM perhaps above all—to ensure that policies made by DCMS
are not contradicted by other arms of government. The government
offices and regional assemblies equally should have a single approach.
This will be amplified in subsequent sections.
2. The remit and effectiveness of DCMS, English
Heritage and other relevant organisations in representing heritage
interests inside and outside Government
(i) English Heritage in particular has a very
high reputation which is in danger of being undermined by constant
budgetary constraints. Not only does it not have enough funds
for conservation grants that could put real clout behind its recommendations;
its lack of resources (and financial independence, perhaps, also)
mean that too often it is held hostage by developers threatening
legal challenges. Too much of its time and money is taken up with
Heritage Counts—which after all does not change much on
an annual basis. A biennial report would surely suffice.
(ii) There is great public confusion between
the roles of DCMS and ODPM on planning issues. This may be resolved
with regard to listing, but appeals and the planning process generally
continue to lack coherence. ODPM frequently seems to have an adverse
effect on the work of both DCMS and DEFRA, on built and natural
environmental conservation.
(iii) The listing procedure, far from being
streamlined, appears to have gone into terminal decline—spot-listing
especially. Again, one suspects financial constraints to be (at
least part of) the reason.
(iv) CABE, after issuing an excellent report
on Building In Context, does not always pay sufficient regard
to heritage but allows architects and developers rather to see
old buildings as standing in the way of sexy, cutting edge design.
(v) There does not appear to be an adequately
resourced planning department, with adequately trained conservation
officers, in the country. Government's insistence on digitising
planning applications makes scrutiny very difficult. Application
of PPG3 varies widely, and the legislation arising out of the
Nolan Report, at least as it is implemented at local level, makes
it very hard for planning committee members to be adequately informed.
Overarching guidance (from which department?) would be valuable.
3. The balance between heritage and development
needs in planning policy
(i) The "local heritage lobby" feels
overwhelmingly that developers are given preference. Councils
are afraid, for financial reasons, to reject a bad plan that developers
will take to appeal. The push for greater housing numbers in many
regions makes refusal harder than ever. The Deputy Prime Minister
has said that "mediocre is no longer good enough" in
design, but no government policy has backed that up.
(ii) In the large cities especially, industrial
sites have been allowed to decay for so long that, when redevelopment
is finally proposed, local communities are so grateful they are
willing to accept anything. Significant local heritage is lost
in this way, when it could be incorporated into the new plan.
There is no sanction against landowners who have deliberately
allowed the decay to happen, in order to obtain planning consent
and increased land values.
(iii) On brownfield sites, as above, the responsibility
for remediation of historic pollution is unclear. "The polluter
pays" is inadequately enforced, even when the polluter can
be found.
(iv) The PPG3 emphasis on brownfield sites is
welcome, but what constitutes a brownfield site is too wide a
definition. Gardens are lost, with greenery and wildlife, and
good older houses replaced by denser development, and the local
community often suffers. Real brownfield sites—derelict
industrial areas—are more expensive to develop, leading
to perhaps the most essential change of all:
(v) VAT MUST BE HARMONISED AT 5% ON ALL
DEVELOPMENT.
4. Access to heritage and the position of
heritage as a cultural asset in the community
(i) The Joseph Rowntree Foundation found in
1999 ("Social cohesion and urban inclusion for disadvantaged
neighbourhoods") that "older, historic buildings are
fundamental to residents' sense of place and the loss of such
`landmark' buildings led to an acute feeling of lost heritage,
pride, status and identity". Clearly this does not mean stately
homes or the architecture of the elite; rather it is the good,
ornate Victorian corner pub or the handsome board school, unlisted
and unregarded until it is too late that is referred to as giving
a sense of local belonging. Recognition of good, older, everyday
buildings would have more impact on a greater number of people
than all the visitors to National Trust houses.
(ii) Numerous reorganisations at different levels
of government have left great numbers of good solid buildings—town
halls, courts, even baths—without a use and without a dowry.
Some of these will be protected, many not, but all come in the
category above of significant community heritage. Often they have
no obvious use on the open market. Where they are used for "community"
purposes, all too often the community group/s concerned have little
understanding or ability to maintain them. Government bodies or
their representatives should recognise a continuing responsibility
to these buildings and their subsequent users.
(iii) English Heritage and other organisations
do their utmost to ensure historic buildings are accessible to
all parts of the community but, without appropriate education,
too many groups continue to feel excluded. Aesthetic and environmental
awareness, as well as history, should be part of every child's
schooling. The production of building design addresses all areas
of the curriculum, yet unless it is deliberately encouraged to
happen will continue to be ignored or squeezed out.
5. 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
(i) For English Heritage funding, see 2(i) above.
(ii) For museums and galleries, too many Lottery
funded projects have seen exciting new buildings with little thought
for what should go into them. At local government level, museums
and galleries are too often an afterthought as overall budgets
are invariably tight. The programme to turn libraries into "discovery
centres" or similar is too fast, as it is still largely untested.
(iii) While architects and the country at large
celebrated the Olympic bid, most conservationists, I imagine,
groaned, and not only because of the financial implications. If
it is not already too late, an audit of existing buildings in
the Lea Valley area—mostly in the "local landmark"
category in 4(i) above—should be made, as landowners are
scenting large profits and sweeping away all they can in advance.
Important heritage is being lost.
(iv) Funds for the Olympics from the Lottery
should come only from the Sports Fund, or perhaps where the benefits
are more widely social, from the Big Lottery Fund if it is to
continue to breach the initial "additionality" principle.
The one-third-of-half (16.6% of a dwindling pot) that is already
all that remains to each of Heritage and Arts must be sacrosanct.
The last 10 years has seen the only real investment in Heritage
and Arts since 1945; their share has already been eroded and must
be protected. The possibility that some of the new Olympic buildings
may come to be regarded as heritage in the future does not mean
they should be allowed any heritage funding now.
(v) Wider consultation on future sharing of
Lottery funds is underway; I trust all the various heritage bodies
will be making the case for the funding of the historic built
environment.
6. 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
(i) Responsibility divides in two parts: financial
and educational. All the above bodies can and should have an educational
role, from the involvement of the next generation in school, as
in 4(iii) above, via college and university training and teaching
of architects and craftsmen, to the education of the wider public
every time they encounter some part of the heritage. Of course
the bodies cannot do that without financial support; financial
responsibility has to rest ultimately with government.
(ii) Better education on the subject in its
widest sense would allow government to implement tax policies
to fund what would no longer be seen as an elitist add-on but
which could be viewed as an Italian-style bene culturale—something
in its own right that improves the quality of everyone's life.
Currently there is a real risk that, if Lottery players are allowed
a say as to where their money should go, the popular media would
ensure it did not go to the arts or heritage.
(iii) Specifically on maintenance, Lottery funds
for existing buildings make arguably a greater contribution to
social and environmental good than funds used for new buildings.
(iv) Clearly in the private sector, the provision
of a new building is a matter for the developer and the planner,
but in the public sector—for example headquarters for the
RDAs—there should be a presumption in favour of the reuse
of a good historic building before the creation of a new one.
Leeds with its plethora of wonderful, redundant, old industrial
buildings, and its new offices for Yorkshire Forward, comes to
mind.
7. 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
(i) Research carried out last year by the National
Heritage Training Group (Traditional Building Craft Skills; Skills
Needs Analysis of the Built Heritage Sector in England 2005) said
very clearly that there is nowhere near sufficient expertise.
(ii) At a time when universities are encouraged
to expand and more and more young people urged to take degrees,
craft skills taught in colleges are seen as less desirable. Not
only is this harmful, I believe, for the individual—it is
better to work with hand and brain—but it continues the
inadequate supply of conservation skills mapped so clearly above.
One or two universities—Kingston for example—teach
conservation at degree level, but there is no reason why such
training should not be integrated into architecture schools. Indeed,
all architects should have experience of practical conservation.
(iii) For those young people who will never
want or be able to go to university, more crafts teaching at school
would be valuable, with the opportunity to work in a (funded)
apprenticeship from the age of 14. There is an idea for an artisan
school on this basis being mooted in London; it should be grasped
and expanded across the country. This is another example of the
need for cross-departmental co-operation stated at the outset.
(iv) As in 3(i), local authorities—planners
and elected members—are frightened to take on developers
for fear of financial penalty. If a bad plan is to be challenged
the professionals and the councillors must be thoroughly educated
not just in the legal aspects but in the wider issues of conservation.
Planning departments are over-stretched and are unable to give
proper attention to conservation, while the legal requirements
with regard to conservation are few. No authority should be without
a conservation officer (department, indeed), reliant on consultants
to carry out their sole obligation to review their conservation
areas if any. CPD is essential, with frequent workshops for councillors.
(v) Many local authorities are unwilling to
create Article 4 Directions because of the financial implications.
Removing the need to recompense owners for the lack of ability
to alter their houses would be a great improvement. Education
would allow those owners to realise that their properties would
in fact be worth more unspoilt.
(vi) Non-vocational adult education has been
cut to the bone; easily affordable evening classes would seem
the ideal format for educating the general public in conservation.
18 January 2006
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