Supplementary Memorandum submitted by
Westminster City Council
I refer to the evidence given by Robert Ayton
of Westminster City Council on 1 July 2008 and that given by Dr
Thurley of English Heritage on 2 July 2008. The City Council would
like to make the following comments with respect to Heritage Partnership
Agreements (HPAs) and Dr Thurley's evidence.
Dr Thurley stated:
"The important thing about Heritage Partnership
Agreements is that they are only really useful where you are dealing
with large estates where you have a single owner with multiple
buildings. Westminster, I think I am right in saying, has the
highest number of listed buildings of any borough in England and
so I can understand that there might be some concern there but
it does not have lots of estates of the sort of nature that we
are thinking of".
"I must say I do think that it is unlikely
and I think that as the word gets around and as we go on the road
and explain to local authorities the significant benefits there
can be from this, more and more local authorities will encourage
the big estate owners who make multiple, repetitious, slightly
pointless sometimes, listed building consent applications to get
on and make an agreement".
DCMS states at paragraph 41 of the Impact Assessment:
It is hoped that take-up of these new management
arrangements will be high among owners of sites that require repetitive
consent applications each year. As an indication, English Heritage
note that there are currently around 250 listed building sites
in England that have made six or more consent applications in
the last three years. There are, in addition, an unknown number
of applications made by owners of multiple sites which would be
helped.
In his evidence Dr Thurley suggests that he
is thinking of country estates but the City Council is concerned
that there are many urban estates in Central London comprising
large numbers of historic buildings, such as the Grosvenor, Howard
de Walden, Eyre, Pollen and Portman, who may wish to pursue an
HPA. These estates could fall within the definition given by Dr
Thurley; that is they are single owners with multiple buildings.
If urban estates are not considered suitable for HPAs then this
would need to be spelt out clearly.
The comment by DCMS suggests that owners with
dispersed property holdings could also benefit from HPAs. This
could include major landowners and developers, such as Great Portland
Estates and Land Securities, who own significant numbers of diverse
properties across Westminster. Again, if these types of owners
are not considered suitable for HPAs then this should be made
explicit.
The City Council draws the conclusion that,
unless there are clear definitions of who is suitable for an HPA,
there could be considerable demand for Heritage Partnership Agreements
from a significant number of property owners, and that this would
involve considerable local planning authority resources, especially
at the initial stages, but also later on. The draft Heritage Partnership
Agreement for Piccadilly Circus Underground Station proposed a
system of dealing with submissions pursuant to the pilot HPA which
could have meant significant on-going work, for the City Council
had it been implemented.
The City Council does not receive many of what
Dr Thurley refers to as "repetitious, slightly pointless
sometimes, listed building consent applications". The City
Council receives around 2,000 applications for listed building
consent each year but does not receive more than a handful of
unnecessary applications.
In the case of Piccadilly Circus underground
station, in the last 24 years the City Council has received a
total of less than 50 listed building consent applications, an
average of less than two per year. Some of these may have been
for relatively minor proposals, but the applications were not
pointless. Even under the draft HPA, listed building consent would
still have been required for these works. Dealing with this small
number of applications has not been an onerous burden.
DCMS suggest that HPAs might be appropriate
for sites submitting 6 or more applications in a three year period.
Again, it is questionable whether a rate of two applications per
year would justify the work required in setting up an HPA.
CONCLUSION
The City Council recognises that HPAs may offer
some benefits, especially to land owners, and is not opposed to
their use in special cases. But the City Council is yet to be
convinced about the extent of their benefits compared with the
extensive work required initially. It vital that local planning
authorities can resist participating in them if they consider
them unnecessary or too onerous.
July 2008
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