Editorial:
Never mind the policy, where's the strategy?
Towards an Urban Renaissance - Enabling Development - April 1999 - February 1999























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Towards an Urban Renaissance - The findings of the Urban Task Force

The Urban Task Force, headed by Richard Rogers, was launched last year by the Deputy Prime minister John Prescott with this mission:
. . . to identify causes of urban decline in England and recommend practical solutions to bring people back into our cities, towns and urban neighbourhoods. It will establish a new vision for urban regeneration founded on the principles of design excellence, social well-being and environmental responsibility within a viable economic and legislative framework.

Its remit was difficult to fault. However its first prospectus created a ripple of unease in the conservation community because it barely mentioned historic buildings other than to declare that they could "effectively block" regeneration. This prompted SAVE to join forces with The Architectural Heritage Fund, the Institute of Historic Building Conservation and the United Kingdom Association of Preservation Trusts to produce Catalytic Conversion - Revive Historic Buildings to Regenerate Communities, a report highlighting how conservation can play a leading role in the government's housing, regeneration and sustainability policies. The report was endorsed by 17 other leading independent conservation bodies. Hot on the heels of Catalytic Conversion English Heritage launched another report, Conservation-led regeneration, outlining English Heritage's role as a regeneration agency.

The UTF launched its final report, Towards an Urban Renaissance, at the end of June this year. This time the message about conservation was more positive, and all the organisations behind Catalytic Conversion and Conservation-led Regeneration should take credit for changing the UTF's views of conservation. A chapter entitled Recycling the Buildings lays out the UTF's vision for historic buildings as well as covering the issues of empty properties and vacant space above shops. The major recommendations from this chapter are:

  • That local authorities should be given a statutory duty to maintain an empty property strategy with clear targets for reducing levels of vacant stock.
  • That a ten year £500m national program should be established - The Renaissance Fund - to help local groups repair our towns and cities by tackling derelict buildings and other eyesores.
Other recommendations include:
  • Introducing new measures to encourage the restoration and use of historic buildings which have been left empty by their owners. This should be done by revising planning guidance (PPG 15), including heritage issues in regional economic strategies, reviewing buildings regulations and ending the business rate exemption on empty listed buildings.
  • Facilitating the conversion of more empty space above shops to provide accommodation by providing additional public assistance including public equity stakes and business rate reductions.
  • Harmonising VAT at a zero rate to bring new build, conversion and restoration onto a level playing field. It is suggested that if harmonisation can only be achieved at 5% rate then a significant part of the proceeds should be reinvested in urban regeneration.
  • The liability for full payment of council tax should be extended to all owners of empty homes. Where properties have been empty for over a year the authority should have the discretion to impose a higher charge.
These recommendations are by and large sound and those about empty properties and VAT and the proposed Renaissance Fund are very welcome. However, the report still displays some ambivalence towards conservation. It claims that "blanket conservation" can stifle urban regeneration and undermine the long term futures of our historic urban areas and it recommended that more flexibly is built into PPG 15, the planning guidance document on the historic environment.

Whilst SAVE has always advocated adaptive reuse for historic buildings there is a clear and real danger that making guidance and legislation any more flexible will lead to unacceptable and irreversible loss of historic fabric. PPG15 already is a flexible document and used effectively allows the implementation of a healthy and dynamic balance between conservation and sympathetic development. For this reason we were delighted that the Minster for the Arts and Architecture, Alan Howarth, recently reiterated that the government has no intention of modifying PPG15 - the balance is already about right.

There were other indications that the Task Force views conservation as a barrier to the implementation of its vision. It recommends that the role of conservation bodies should be reviewed "to ensure that they are able to act as catalysts for local regeneration schemes" What this seems to mean, as was more apparent elsewhere, is that the Task Force saw the fact that 20% of listed building consents were refused as a deterrent "to ensuring quality solutions". We, of course, would argue exactly the opposite. SAVE believes their current critical standards help to secure high quality schemes. The question is, though, are conservation bodies being asked to lower their standards to achieve wider regeneration benefits?

On balance, however, the Urban Task Force has come up with a powerful set of proposals for regenerating our towns, cities and urban areas, that could signal a real change in the way we create and manage our urban areas. But they are only a set of recommendations. We will have to wait until the Government's white paper on urban policy is launched to see whether or not they will survive the Treasury and other old reactionaries to make it into government policy

Towards an Urban Renaissance costs £19.99 and can be ordered by calling 0870 0768853
For a copy of Catalytic Conversion send an A4 SAE (postage 60p first class, 45p second class) to SAVE, 70 Cowcross Street, London EC1M 6EJ
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Enabling Development - Ruination in the guise of salvation

This year has seen the publication of two reports on the controversial subject of enabling development. Enabling development is the practice by which permission for new buildings adjacent to or in the grounds of a decaying historic building is granted when otherwise it would not be permitted solely so that it can cross-subsidise the repair and restoration of a listed building that could not alone support its own restoration. The practice is most commonly associated with country houses, which as high calibre buildings designed to stand alone in planned grounds are most sensitive to ill considered new build, but it can be applied to any kind of building, and prove just as damaging.

In some circumstances the model works, and with restraint, enough space, convenient topography and high standards of design, sympathetic developments which provide a sustainable future for historic buildings are realised. The problem is that it is often little more than a mechanism used by developers to increase the amount of profitable new build housing. The refusal of developers to give full disclosure of the financial breakdown of a development, the lack of local authority resources and skills to asses enabling applications and inadequately constructed and weakly enforced planning agreements have all led to the most appalling and damaging developments. Far too frequently, the settings of houses have been destroyed by the construction of badly and unsympathetically designed housing up against the walls of the house or placed in the middle of their planned gardens and grounds. At the same time the houses themselves are left to rot, the victims of developers selling off the unrestored building without amenity, after finishing the "enabling" originally permitted to save the house from ruin. The problem can be compounded by the next owner of the house demanding further enabling to fund its restoration, or simply developers gaining permissions for far more enabling than the restoration actual requires.

The case studies illustrated in the report recently published by the national amenity societies - Rescued or ruined? - Dealing with enabling development say as much as one needs to know about the appalling damage done in the name of conservation. The three most important requirements in tackling inappropriate enabling are that all reasonable efforts are made to market the rotting building at a value that truly reflects its condition, that developers are required to give full disclosure to the local authority of the financial basis for their proposal and that planning permissions are tightly constructed by legal agreement and rigorously enforced. The burden of policing such proposals falls on local authorities, many of whom lack the resources and expertise and experience necessary.

In response to the issue, English Heritage has produced a policy statement on the subject (Enabling developments and the conservation of heritage assets). It contains many fine sentiments. However, as the IHBC has said, what conservation officers really need from EH is detailed guidance, similar to the excellent document Stop This Rot produced last year on buildings at risk policy, and professional and financial support. Without this, the practice of enabling development will continue to improve developers' bank balances at the expense of our historic environment.

Rescued or ruined? - Dealing with enabling development is available from the Georgian Group, 6 Fitzroy Square, London W1P 6DX at £6 (incl p&p)
Enabling developments and the conservation of heritage assets is available free of charge from English Heritage by phoning 0171 973 3434
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Never mind the policy, where's the strategy?

The Culture, Media and Sport Committee of the House of Commons is capable of demonstrating a staggering level of ignorance about historic buildings. However, in two recent investigations it has at least raised the very real question: is there a UK strategy for the historic environment?

The answer it concluded is, no. And that is something SAVE would firmly agree with. When Alan Howarth, the Minister for the Arts, was questioned by the Committee during its recent investigation into the Heritage Lottery Fund, he was asked if the Government has a strategy for the heritage. He replied: The Government does have a strategy; we certainly have a strategy. Our strategy is that it should be protected and enhanced, that it should be well presented, there should be good access to it and that the educational opportunities that the heritage provides should increasingly be taken advantage of. So of course we have strategy. Well up to a point. However, it is a bit like the Chairman of British Airways saying BA's strategy is to make a profit by flying planes to different countries and encouraging passengers to travel in them - hard to argue with, but hardly a meaningful strategy for future planning. Protection of the built environment does not even feature as one of the five core Departmental Objectives.

Not surprisingly, the Select Committee was not very impressed, and neither were many of the witnesses who complained about a lack of leadership from the Department. The issue was highlighted during the Committee's investigation of the HLF's strategy for funding the historic environment; it concluded that the HLF was responding to known heritage demands, but only on the basis of an incomplete and inadequate assessment of the full needs of the sector. This was endorsed by the HLF, which is already carrying out some of its own research into needs assessment of specific areas, such as urban parks.

A picture emerged of a sector without a detailed strategic vision, "led" by a Department providing little meaningful leadership and funded by a lottery distributor handicapped by patchy and incomplete information of heritage need. The Committee contrasted this with the natural environment sector, in which all organisations share a clear sense of purpose and priorities and a clear strategy, based around the Biodiversity Action Plan. This resulted in clear direction to and action from the HLF.

Therefore the Committee recommended the preparation of a comprehensive national audit of the heritage sector and its needs to inform future funding and policy and the formation of a national strategy for the heritage. And quite correctly, the Committee noted that neither of these tasks should be the responsibility of one organisation alone, be it EH, the HLF or the Department, but the responsibility of all interested parties, including voluntary ones.

This theme was developed in a second investigation, this time into the relationship between the Department and its quangos. The Committee was unhappy with the existing relationship between the DCMS and EH. As it had already discovered, the Department did not have a clearly defined strategy for the heritage, and therefore could not lay down a series of clearly defined goals for EH to achieve in pursuit of this. Second, the Committee was dissatisfied with the range and meaningfulness of the targets EH is set as part of its funding agreement with the Department (currently £114m pa). Again this stemmed from the lack of a comprehensive heritage conservation audit. Without one, how can you effectively and meaningfully measure EH's performance in conserving the historic environment?

The Committee recommended the creation of a "Heritage Forum" to a develop a new national heritage strategy. Its conclusions would inform the Department's heritage objectives, which in turn will inform English Heritage policy. The committee also recommended a joint DCMS, DETR and EH study of the factors affecting the effectiveness of the maintenance of Grade I and Grade II* listed buildings with particular reference to buildings at risk, to inform future funding and target setting.

All of this is important because:

  • As the example of the natural environment sector has highlighted, currently the conservation movement is sorely lacking a comprehensive, widely endorsed and detailed strategy, and relies instead on broad concerns and widely held assumptions. We need something far more sophisticated than this to ensure the scarce resources available are put to the best use and to ensure that we can argue our case coherently and in unison at a strategic level so that the importance of our concerns are recognised and supported at all levels of government.

  • Any strategic review must be carried out by all conservation bodies and not be dominated by EH. This is particularly important because the DCMS no longer has any real capacity to make conservation policy and increasingly relies on EH as the lead sector quango. The fact that it has no clear strategy is evidence of this. EH does a sterling job, but as the lead conservation body is influence is already extremely powerful. Any essential element of any heritage strategy review must be an independent re-evaluation of EH policies. That must come from EH's peers, the many other highly experience conservation organisations in England.

  • SAVE is concerned by the way in which the EH register of buildings at risk is increasingly seen as the principal measure of the state of the health of the historic environment. Both the HLF and the DCMS use it as a key measure, one of need, the other of EH success in meeting conservation's objectives. Our concern is first that relying on this as a measure of the health of the heritage produces a distorting picture - Grade I and II* buildings account for less than 10% of all listed buildings, and they tell us little about the state of landscapes and gardens and conservation areas. EH chooses them because it funds their repair. Additionally, we are concerned that EH appears less and less interested in the conservation of isolated Grade II buildings, the bulk of our historic environment. Finally, as the only measure of the effectiveness of EH's conservation policies (as opposed to access, response times etc) it not only paints a distorted picture but encourages the inclusion on the register of buildings that many would not consider to be at risk for the simple fact that they are under repair. The cynical may suggest that these are only included so that when EH's funding agreement is up for renegotiation it can demonstrate how effective it has been in removing buildings from the register.

    Out of the audit and Heritage Forum should come imaginative new ways of measuring the health of the built environment. Aerial photography to measure the degradation of settlement patterns has been suggested for example. In this way more sophisticated and comprehensive means of directing funding and measuring HLF and EH performance can be established.

  • And finally, and perhaps most significantly, the process of review and formulation will provide the opportunity to argue for a new direction for conservation. Elsewhere on this site we are advertising for a Project Director to lead the formation of a new organisation that will launch an annual, independent and expert maintenance inspection service for owners of historic buildings. This has been a pet project of SAVE for a number of years and takes its inspiration from a long established Dutch project called Monumentenwacht. The objective is very simple - the prevention of decay by maintenance is cheaper, more sustainable and less destructive than treatment of resultant damage by repair. More information on this concept and the new organisation can be found via the SAVE home page. We believe that any conservation strategy emerging from the Heritage Forum must be maintenance not repair led, and we believe that a study of the effectiveness of the existing repair grant system for buildings at risk would demonstrate that a maintenance based approach would be more cost effective and sustainable.
A Heritage Forum to formulate a national strategy linked to a comprehensive audit are very welcome suggestions. However, if they are to prove meaningful exercises, first, they must be fully integrated, so that one can inform the other. It would be absurd for the HLF to carry out an audit for its own purposes independent of the formulation of a national strategy. Second, neither EH or HLF should be allowed to dominate the two processes. In other words they should not be allowed to set their own agendas for the next 5-10 years - both exercises must embrace the views of all conservation bodies. Third, of course, the Heritage Forum must be more than a talking shop - its recommendations must be adopted by Government. Then, perhaps, the conservation movement might find itself a new direction and a renewed sense of purpose.

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