SAVE'S RESPONSE TO
THE DCMS SPENDING REVIEWCOMPREHENSIVE SPENDING REVIEW:
A NEW APPROACH TO INVESTMENT IN CULTURE RESPONSE FROM SAVE BRITAIN'S HERITAGE"We now have a historic opportunity to establish the place of culture, sport, heritage and tourism at the heart of public life and public policy". The words of Chris Smith at the launch of his "investment for reform contract for Britain's cultural and creative world".
1.1 SAVE agrees with the Secretary of State that there is an historic opportunity to put the historic environment at the heart of public policy. The changes proposed in the paper for the historic environment have been described as the most important since the formation of the Historic Building Councils in 1953. But we believe that this paper fails to grasp sufficiently that opportunity. The conservation of the historic environment is not listed in the paper as one of the Department's core objectives. It should be.
1.2 Building conservation in England - and the UK - has been remarkably successful in the last twenty years, and attitudes towards our historic fabric have been transformed almost beyond recognition. There is much about the present system of which all should be proud. Now is the time to consider the wider picture. The paper talks a great deal about the need for strategic leadership from the Department. We believe that that leadership is needed to grasp a far wider and more fundamental range of issues than are addressed in the paper in order to establish building conservation "at the heart of public life and public policy".
1.3 Therefore, we present three different strands, the first two fundamental issues that we believe the Department ought to address, the third comments on specific elements of the document.
"THE SANE USE OF ALL OUR RESOURCES"
The first SAVE report, the AJ 17 & 24 December 19752.1 Conservation is sustainability in practice. In the first SAVE report, published in 1975, we recognised this and identified the cause of building conservation with the wider concern about our environment. Since then the building conservation movement in this country has been extremely successful. Support for building conservation remains high, though there is a danger that because of the successes of the last twenty five years public perception is that all the battles have been won. In fact there as many threats as ever, which need the most dynamic action to counter, lead by the Department. Too often conservation is a merely an appendix to the planning process rather than an integral part of it, but the change in attitudes has been enormous and we should be proud of those achievements.
2.2 However, the concept and practice of historic building conservation in the UK has yet to gain a full sense of its place in the wider environmental context. In the 1990's the environmental movement in the UK has grown in influence and acceptance: witness how diverse and widespread is the support for anti-road protesters. But building conservation is curiously divorced from this.
2.3 Yet, on some occasions we instinctively recognise links between the built and the natural environment. Many of our most treasured landscapes have been created by man. In the Pennine Dales the man made structures - the dry stone walls, field barns, and huddled valley bottom settlements - are as important to the landscape as the open fells, the peat stained rivers and the curlews overhead. But the Government and indeed the wider building conservation movement have yet to fully recognise how the conservation of the built environment is a part of the wider concern about our environment and our future. Conserving the built environment for future generations is as important as conserving the natural environment.
2.4 This is not just only because we have a responsibility to future generations as caretakers of our cultural inheritance. The historic environment is also important as a vital and continuing determinant of the uniqueness and local distinctiveness of a place. In other words, it is important in giving a community a sense of time and place, of where it is and how it got there.
2.5 If the Department is serious about wanting to take a strategic lead, then it should be taking the lead in countering the perception that conservation is backward looking. For the fact is that the historic environment is extremely relevant to future challenges.
2.6 The government is keen to talk about its is commitment to sustainable development. The fact that it must now underpin all government policy is clear in the Department's paper. A great deal of print is expended discussing sustainable planning; about designing communities for the future that provide us with an acceptable quality of life and rates of economic growth without doing irreversible damage to our environment. There is a vociferous debate about meeting projected future housing needs - the infamous figure of 4.4 million - by maximising brownfield development to limit damage to the countryside. And yet in all of this the role of building conservation is mute: we hear a great deal about transport strategies, the threat to the green belt, the need for urban renewal, but little about the role the historic environment can play. This is where the Department should be leading.
2.7 On one level, existing buildings represent a sum of embodied energy (the production and transportation of materials, craftsmanship and human energy, etc) that should not be destroyed if they can continue to serve society. This applies to all existing buildings, not just those that meet the art historical criteria of listing. Most existing buildings can be reused, and reused successfully. In the mid 1970s the GLC admitted that 60-75% of the housing it demolished between 1967 and 1971 was in a fair to good condition and could have been rehabilitated. Demolition of housing on such a vast scale (except perhaps for the very buildings that replaced these "slums") no longer occurs, but those same attitudes towards existing buildings remain.
2.8 It is conservation that has driven the regeneration of the inner cities, following the failure of comprehensive redevelopment - just compare Covent Garden with the Elephant and Castle.
2.9 Today it is the reuse of redundant buildings such as warehouses, often not listed, which is spontaneously leading to the regeneration of areas such as Shoreditch in East London. In Birmingham, one can look at the Custard Factory, in Liverpool and Manchester the work of Urban Splash. These areas have flourished because the their historic fabric gives them a character you cannot recreate. Crudely put, people find them aesthetically and environmentally attractive places to live and work. The economic benefits of building conservation are outlined in SAVE's reports Preservation Pays and Preservation's Wider Economic Benefits.
2.10 The most successful conservation and regeneration story since World War II has been the regeneration of decayed inner-city housing by individuals, entrepreneurs and housing associations. The renewed vigour of areas such as London's Notting Hill, Clerkenwell and Islington are the result.
2.11 But this is still not acknowledged by some professionals. To take one example one can look at Richard Rogers' Urban Task Force, established by John Prescott to report next year on causes of urban decline and on practical solutions to bring people back into cities and towns. Its "Prospectus" hardly mentions the potential or importance of historic buildings and areas, aside from saying they could "effectively block" the kind of redevelopment that it hopes will regenerate towns and cities; its fourteen members include architects, planners, developers, engineers, academics, countryside campaigners, regeneration professionals - but no building conservationists.
2.12 One specific element of the UTF's remit is housing, "considering both new development and the potential for reuse of existing buildings". There are estimated to be some 20,000 - 30,000 listed buildings at risk in England. The vast majority are empty, or only partly occupied. Many could be viably and attractively repaired to create single or multiple homes. In addition, there are an unknown number of unoccupied unlisted buildings in conservation areas and possibly as many as 500,000 potential residential units in empty space above shops, or in empty shops themselves. There are also many other well constructed buildings that will never be listed, nor find themselves in conservation areas, that are under-utilised.
2.13 For example, large numbers of MoD and NHS properties are becoming vacant, some listed, many not. SAVE's report Mind over Matter identified the 98 out of a total of 121 mental hospitals that will close in the 1990s. Many of these are very large and could be converted, as Moorhaven near Plymouth has been, into a hundred or more houses and apartments. In this way 100,000 residential units could have been created, without including asylums in Wales or Scotland or any other type of hospital building. In our view, perhaps as many as one million of the 4.4 million said to be required could be provided in existing buildings. The more efficient use of existing buildings must be a central element of strategies to meet the future housing needs.
2.14 EH is moving towards embracing the ideas and processes of sustainability, most notably demonstrated in its discussion document, Sustaining the Historic Environment. EH, the Department and the wider conservation movement need to continue to explore what this could mean and how building conservation can be a part of the wider debate about our future. If the Department really want to seize an historic opportunity then it is here that it should be taking lead. The Urban Task Force is just one example of how the debate about our future is in danger of being conducted without the building conservation movement.
2.15 We were extremely disappointed that the Department did not consider the fundamental task of protecting, conserving and sustaining our historic environment to be one of its new objectives. From the beginning of listing in the 1940s, protection of the historic environment has been a part of the planning process, where in many ways it properly belongs. If the Department is not willing to be the champion of the historic environment, then there has to be a case for considering if responsibility for the historic environment should pass back to the Department for the Environment, Transport and the Regions. There it could take its place as an integrated part of public policy for planning, regeneration, housing and environmental protection and conservation.
"DRIPS COME SUDDENLY AND DO GREAT DAMAGE"
3.1 The words of Christopher Wren are all too familiar to owners of historic buildings and conservationists alike. In the vast majority of cases Wren's "great damage" is the result of the failure to carry out routine jobs - cleaning out gutters, unblocking drains, ventilating buildings. Every year tens of millions of pounds of government money is dispersed through organisations such as the Heritage Lottery Fund and English Heritage for major, and often vastly expensive, restoration projects to buildings at risk. Many of these projects would have been unnecessary if basic maintenance had been carried out; it takes only a few rotting leaves or a dead bird or a tennis ball to block the top of a downpipe, causing the gutter to overflow. The telltale sign is green mould, showing that a wall is damp. As walls become sodden, damp gets onto the roof timbers and rot begins. Many empty buildings are boarded up and left unventilated - and stale, damp air is the perfect breeding ground for dry rot. It is much better for windows to be flapping in the wind than to prevent pigeons roosting in the ballroom.
3.2 SAVE believes that if we are to solve the problem of decay, then we must master the chore of routine maintenance rather than exclusively financing high profile programmes of restoration. "Stave of decay by daily care", wrote William Morris.
3.3 This need was clearly recognised when the three Historic Buildings Councils for England, Scotland and Wales were set up in 1953 in the wake of the Gowers report. Gowers recognised how much damage accumulated from simple failures to replace slipped slates, and the three HBCs were given the power to aid both maintenance and repair. But the new bodies had limited funds, and these were concentrated on what was considered the more pressing concerns of repairs. In many ways this was exactly the right thing to do, and the system of grant based repairs has helped to reverse the effects of half a century of neglect, particularly with country houses. Now the challenge is to prevent all that being thrown away for a lack of maintenance. We need to move from crisis management to crisis prevention, to ensure that the great strides of the last decades are sustainable. But how?
3.4 In Holland conservationists have established an organisation called the Monumentumwacht (Monument Watch), as important and inspiring a preservation model as our National Trust. The Monument Watch has a branch, run by a pair of operatives in each Dutch province. Each pair has a van stocked with slates, tiles and roof lead, a tool kit and a set of ladders.
3.5 The cost is funded 50% by owners and 50% by the state: this pays for regular inspection visits on an hourly basis. While at the building, the Watch carry out basic maintenance tasks, climbing ladders to clean gutters, going into the roof space to look for damp, worm, beetle or rot, and searching the roof leads and gutters. Having bagged up the debris, they leave a list of essential tasks. If the owner repeatedly fails, year on year, then the Watch may refuse to return, but most owners are delighted with the system.
3.6 In winter, when bad weather makes it difficult to work outside, they make roof access ladders that they leave in the lofts of churches and large houses. Some roofs are too high to reach by ladders and rather than erect expensive scaffolding, the Watch have developed an alternative system of harness hooks to enable them to work their way along roofs with climbing equipment.
3.7 If all this sounds like elementary common sense that is because it is. Small sums spent on regular maintenance will save huge sums spent on future repair bills, sums which are often picked up by the tax payer. SAVE is not advocating the abolition of grant aid for repair: clearly there will always be a need to have substantial sums available for repair works. Rather, we are advocating an integrated approach that recognises that repair alone is meaningless without programmes of proper maintenance. English Heritage grants include maintenance agreements, but these are rarely, if ever, followed up. If we invested half as much effort, time and capital on promoting maintenance as we do on repair, then we will be tackling many of the problems of the future at root cause.
3.8 The challenge is to turn the tide of an entrenched conservation culture of repair in this country, and develop systems of Monument Watch that are sustainable in the different structural conditions of England, where Monumentenwacht's heavy state subsidy is unlikely to be replicated, and where the size of the country and the problem is so much greater. Perhaps we should offer tax incentives in return for proper maintenance and public access? We need pilot studies to explore the different ways in which fiscal incentives, voluntary labour, local authorities, the amenity societies, BPTs, the Heritage Lottery Fund, English Heritage, and possibly new organisations, could work in partnership to put maintenance into practice. Hand in hand with these practical programmes, we need leadership from the Department, demonstrating a political commitment to the philosophy of maintenance as the only truly sustainable way to care for our historic environment.
THE PAPER
Regionalisation4.1 In principal, SAVE welcomes the greater emphasis throughout the paper on regionalisation, be it within the Department, EH, or the HLF. SAVE advocated regional offices for EH when it was established fifteen years ago. We welcome the idea of DCMS officers in each regional government office as a way of promoting the DCMS's brief and furthering co-ordination between government departments and national, regional and local agencies. All such regionalisation should make the built environment more relevant to people's lives by making policy and practice more responsive to local needs and local concerns.
4.2 However, it is absolutely critical that all three bodies retain a national strategic outlook. EH must remain able target resources nationally, as its sees the greatest priorities lie and not have policy constrained by the need to treat each region equally. The conservation of textile mills is an issue of concern and deserves the continued concentration of resources, but the geographical spread of such need is limited. EH must retain a national framework for the dissemination of expertise, policy, advice and funding, as well as the ability to fund major projects beyond the scope of individual regions and co-ordinate projects that cross regional boundaries. A good example of this is the way in which EH has responded to the challenges set by the sale of hundreds of redundant hospitals and military buildings. Only a body with a national overview can tackle such issues. For these reasons we believe it is vital that EH retains its national strategic role - including grant giving powers -with regard to the historic environment and of rat reason it should remain separate, and such responsibilities remain apart, from the proposed Regional Cultural Agencies.
4.3 Similarly, although benefits would stem from greater regionalisation of the HLF, we would oppose the complete transfer of grant giving powers to any form of regional executives. As with EH, the HLF must retain the ability to assess need nationally, and target resources accordingly. Equally, many of its most successful programmes are national. We think particularly of the Urban Parks Funds. Its benefits have been enormous, though not geographically even. The outstanding potential of such programmes must not be squashed by a rigid policy of regional equity.
A New Watchdog
4.4 We great the news of a proposed new watchdog with some wariness. The National Audit Office and the Culture, Media and Sport Select Committee of the Commons are already active in monitoring standards of efficiency and financial management. In addition, the new organisation will not achieve sufficient levels of expertise in the many vastly different sectors covered by its brief without a very large staff. SAVE believes that the new "Offcult" will simply be another layer of bureaucracy. The half a million pounds a year allocated for its budget would be better spent directly on the arts, sports and built heritage where it is desperately needed.
Amalgamation of EH and RCHME
4.5 In principle we strongly support this proposal. In numerous areas, from buildings at risk to the recording of ancient monuments the work of EH and the RCHMS overlap and as the green paper observes the moment has come for them to amalgamate.
4.6 SAVE advocated this very measure at the time EH was being set up. At the time it was fought off by the RCHME which argued that EH was a new body and might not last. One tragic result of this was that the Survey of London and all its resources was transferred to the RCHME, with the result that the Survey, which was in full spate, producing some of the finest urban history in the western world, has entered a steep decline in productivity.
4.7 The RCHME has long defended its independence by arguing that its status as a purely a recording body, without powers of control, helps gain access to many buildings which might otherwise be refused. This argument may have been valid in the past, but now many more buildings are listed, it is of less significance and Statute anyway provides a legal right for recording of any listed building that is to be demolished.
4.8 Increasingly the work of EH and the RCHME overlaps. For example, the recent historical survey of barracks (EH) and Hospitals (RCHME) are similar in character and the barracks volume is not inferior to the hospital one despite more limited resources.
4.9 EH will greatly benefit from having an enlarged researching and recording arm. However, it is absolutely essential that the recording work and the research work of the newly enlarged EH is ringfenced. The RCHME's work is vital and often superb. Its emergency recording teams are vastly overstretched already. Treasury demands for further cuts in the EH budget are never likely to cease. If EH has to look for further savings in its budget, the "last in first out" must not be allowed to prevail. Of course it is important to protect EH's ability to perform its regulatory functions, but the research and recording work of the RCHME must not be sacrificed in order to do so. They must be given a statutory basis underpinning in the new organisation.
4.10 Whilst SAVE is conscious from daily enquiries that many people are looking for historic buildings to restore, ownership of listed buildings is often portrayed in the press as a burden. EH has in recent years placed a welcome new emphasis on helping owners. It needs to go further. The absorption of the RCHME and the NMR would enable EH to develop a one stop shop approach to queries about historic buildings, areas and structures: providing information on a building's history and architecture, advice on repairs and maintenance, lists of suitable professionals, builders and craftsman, advice on planning law and tax issues and historical and survey information This should include an electronic reference library drawing on not only the existing material of the NMR, but also the unrivalled scholarship locked up in the unpublished RCHME survey reports, the reports of the Council for the Care of Churches, the conservation plans now demanded by the HLF and other similar sources. These could be the first building blocks in what would be a unique and valuable resource for the study of the built environment. EH would become a useful and essential first stop for the owners of listed buildings and their advisers and not be seen as purely a regulatory body.
4.11 EH continues to suffer from the perception that it is a negative force: willing to say what not to do, but reluctant to give positive advice to problems and queries. To its credit, the organisation has recognised this and is working hard to correct it. The vast majority of our cultural inheritance is in the hands of private owners and so EH must continue and increase its efforts to offer help and advice, to encourage owners to see listed buildings as assets and not liabilities. Education must be as important as regulation.
Architectural Heritage Fund
4.12 We also greatly welcome the proposal that EH should take responsibility for determining the annual grant to the AHF. Building Preservation Trusts have a key role in securing action on buildings at risk but the system is not always working. Many BPTs are struggling to put together workable - that is fundable - projects; many of today's challenges, such as redundant hospitals, are simply too large to be tackled by local BPTs. Despite the great generosity of ministers who have regularly added to the AHF's funds, we believe that too small a proportion of AHF funds at any one time is loaned out on building projects. In our experience the AHF can be even more cautious than banks or building societies in offering loans requiring even greater security.
4.13 It must be recognised that risks are involved in saving buildings at risk. In our view a much higher proportion of AHF money should be spent on grant aiding first aid operations on buildings at risk: funding emergency repairs and more feasibility studies and underwriting the costs of emergency works notices, repairs notices and compulsory purchase orders in order to encourage local authorities to exercise their statutory powers. Such work would complement the policies announced in the recent English Heritage Buildings at Risk Initiative, perhaps by concentrating on Grade II buildings outside conservation areas and unlisted buildings within them, categories of buildings that do not benefit from many of EH's new grant programmes. It could also grant aid local projects established to implement the ideas of proper maintenance discussed earlier.
4.14 Recently the policy of certain Armed Forces' charities in using donations to build up reserves and only spending the income rather than the capital has been criticised by the Charity Commission which held that the charities had a duty to pass on donations to those in immediate need.
4.15 Whilst we appreciate that the AHF must operate to a considerable extent as a revolving fund, its overriding duty should be to help save buildings at risk, and not simply to protect its capital. If the latter is deemed to be the case, we suggest that further capital grants should be discontinued until need is proven.
National Amenity Society funding
4.16 We are opposed to the transfer of funding of the national amenity society funding from the Department to English Heritage. The seven societies have each been given a statutory status within the planning regime by the Secretary of State. We believe that there would be an inevitable diminution in their status if they were supported financially by a quango rather than central government.
4.17 In addition, the paper refers to the earmarking of funds within the EH budget. What does this mean? Will they be guaranteed, in principle alone, or in amount? They have already been frozen at their current levels for three years.
4.18 Finally, we are concerned that financial dependence on EH might potentially compromise the independence of the societies' views on listed building consent applications. The societies' willingness to criticise the stance of English Heritage on occasions is an essential part of our historic buildings developement control regime.
Listing
4.19 SAVE supports the view that the current arrangements should remain in place, particularly because as the paper rightly recognises if listing became the responsibility of EH, then there would have to be a formal right appeal. We believe that this would open the gates to a cascade of challenges and severely weaken the effectiveness of listing.
4.20 However, current listing policy does need to be reconsidered. First, greater transparency in the decision making process ought to be introduced. We ought to know what EH recommends, and why the Minister decides to disregard that advice if he or she chooses to do so.
4.21 Second, in the last few years EH has moved more and more to thematic listing - studies of types of buildings, not geographical areas. This has been a worthwhile exercise when applied to post war buildings and types of buildings that have been little studied or undervalued but which now face uncertain futures: such as military buildings and mental hospitals.
4.22 However, thematic listing is being pursued at the expense of updating the regional statutory lists - the "greenbacks" - 30% have yet to been revised, and some are now nearly thirty years old. As a result buildings, particularly in large northern urban centres such as Halifax, Derby and Bradford, are being damaged or destroyed for a lack of statutory protection. These are buildings, particularly Victorian and Edwardian buildings, which did not feature on earlier surveys but which are now valued and whose significance is understood. And the northern conurbations with the highest concentrations of such buildings are also the areas least able to contribute towards the costs of resurvey.
4.23 There is also a question mark about how efficient a use of resources thematic listing is - how good a return in terms of buildings added to the lists for the manpower expended.
4.24 It is vital that resources are directed back into the regional resurveys to complete the task started under the then Secretary of State for the Environment, Michael Heseltine, in the 1980s.
4.25 In a number of cases, the revised lists - the "bluebacks" - are ready in draft form, but are awaiting approval on the desks of civil servants at the DCMS, in some cases for five years. All this time buildings that have been identified for listing are denied rightful protection and fall victim to the vicissitudes of planning and development. The waste of resources and time generated by the second guessing of civil servants could simply be erased if EH's expert advice was provided to the Minister direct. This, surely, would be a more efficient and much speedier system.
Architecture - a new champion
4.26 SAVE supports the idea of a new champion for architecture. This must be an independent body, free from ministerial interference or from the waxing and waning interests of the Arts Council. The new body should play an important role in promoting good design and best practice, and increasing awareness and understanding of the built environment. But most importantly, it must be a body able to comment on all aspects of new development, including its impact on the historic environment.
4.27 An example of how perverse the current remit of the RFAC can be seen at the moment with a development proposal on the edge of Stamford, Lincs. The scheme involves both new build and conversion of existing buildings, and has run into a great deal of opposition. The RFAC has expressed its concern, but it feels constrained by its remit to comment only on the new build elements. When a development such as this consists of integral elements of both old and new build, surely the champion of good architecture must be able to comment on both, on its entirety. This will equally apply to many urban design and regeneration proposals, featuring complex patchworks of existing fabric and new insertions. The built environment must be considered in its totality, and the new independent champion of "architecture" must do so too.
5 We welcome the intention of the Secretary of State in issuing this paper and most appreciate the opportunity to comment on a wide range of issues. In our view the next ten years offer the chance to initiate a wide range of conservation initiatives, breathing new life into many historic buildings and helping to regenerate communities all over England.
