Submission from the Civic Trust, 24.11.03.





The Civic Trust is a charity with over 40 years’ experience of urban regeneration, care for the historic environment, and of promoting partnership between national and local government, the development profession, and the voluntary sector. It also has an active Regeneration Unit which has advises local authorities on regeneration initiatives. Its aim is achieve the best possible living and working environment. We welcome the opportunity to submit comments to the Committee, and will be happy to provide further views and evidence in oral examination if required.


The Trust's unique asset is its association with c.900 Civic Amenity Societies, with a total membership of c.250,000 individuals, concerned with excellence in public and private development. Many command a wide range of professional skills and have unrivalled local knowledge. While the historic environment is a major concern for them, they welcome innovative new development.


An understanding of the historic environment is important for fostering civic pride and national and local identity, and for promoting informed and engaged citizens. The deterioration in the living and working environment, the continued erosion of the historic environment, and increased public indifference to "civic" affairs, cannot be unconnected.


A revised definition of ‘historic’ is required; a selection of pos-1945 buildings has been Listed, outstanding examples of post-WW2 planning should be protected, and the whole historic environment is evidence of continual change.


Recent research shows that the historic environment, and particularly listed buildings, is not an obstacle to development or regeneration, and that the historic environment is of fundamental importance to us, as a nation, as local residents, as individuals and as informed citizens. Our responsibility, and challenge, as a nation with a long and diverse history, is to ensure that the old and the new can together contribute both to growth and well-being.





We regret that 'public spaces' have been omitted from the revised brief; they are integral elements of the historic environment.


The Civic Trust has long experience of conservation-led regeneration and the focal role which historic buildings and public spaces can play in it. Our Regeneration Unit has conducted many  regeneration projects in a wide range of places including historic market towns, seaside resorts and former mining communities. Historic buildings are important to our membership and integral to  their aspirations for their areas, and could even be regarded as critical to the well-being of our townscapes.


The nationally-known Civic Trust Awards give countless examples of both excellent new development and of restoration of historic buildings which have contributed to local regeneration. We can provide many examples.


Converting a historic building for housing in a deteriorating district may provide the impetus for people to start moving into, and restoring other buildings. To attract business to a historic environment, a strong Local Authority-led vision is important. To make it work economically, the challenge, and the creativity needed, will be greater than sweeping away and replacing with new buildings, but this can have greater advantages socially, environmentally and economically.


Historic buildings and public space can inspire regeneration through local pressure groups using them as a rallying point. By contrast, a feeling by the public that "they" are demolishing loved buildings, and its feeling of powerlessness when the redevelopment process has no public involvement or support, creates an indifferent and negative population who feel it is pointless to vote; that they have no control over, and therefore no responsibility for, their local environment; and come to see change as something to be fought rather than encouraged.  We believe that the public will accept change more readily if they feel they have more control; it is lack of trust in an apparently indifferent 'system', and in decision-makers, which creates 'nimbys', who are people who have no other way of showing their concern.


The economic contribution of the Historic Environment to regeneration is shown by English Heritage’s figures that every £10,000 of English Heritage investment attracts £48,000 of matching funding, delivers 177 sq. ft. of improved commercial floorspace, and delivers two new jobs. The Civic Trust welcomes RDAs using their investment programmes to promote conservation-led regeneration; though THE HISTORIC ENVIRONMENT - A FORCE FOR OUR FUTURE  (5.5) recognises this, the mechanisms for achieving it need to be clearer.


Streets, paths and squares are the unifying elements of a townscape from the public sees it. The historic public domain in Chester occupies about one third of the total built-up area; it is therefore an equally important element of the townscape and can contribute enormously to the quality of life. In turn, improved quality of living and working space will encourage more aware, and hence involved and productive, citizens.





·         English Heritage's Heritage Economic Regeneration Scheme has been successful and should be expanded, as has been the Heritage Lottery Fund's Townscape Heritage Initiative. English Heritage continue to support the Civic Trust's Access Awards (recognising projects which combine access provision with the conservation requirements of a historic building) and Urban Design Awards (Best improvement to the local built environment as a whole). 

·         We welcome the National Trust initiative in extending its brief to the more 'commonplace' and to urban areas (e.g. John Lennon's house, Sutton House in Hackney). This shows how buildings are, or could become, a focus of local pride and may also deliver significant regeneration and education benefits. We trust they will continue to expand their brief in this way.

·         The Civic Trust has wide experience of regeneration projects would welcome the opportunity to present examples.

·         The Church (primarily, though not entirely, of England) possesses a unique national resource in historic buildings. Many are in decaying suburbs and are often the only historic building in the  area. Too often the option for redundant churches has been demolition or conversion to residential use, causing loss of a historic resource for public enjoyment, education and inspiration. The value of churches in this respect was ignored, for example, in the Draft Greater London Cultural Strategy. Despite the cost of maintenance and the decline of congregations, they can still have a role in regeneration, and the churches should see them as helping to fulfil their religious/social mission rather than as redundant encumbrances. We can cite examples of successful reuse by the churches of these underused or redundant buildings in a way which is both beneficial for local regeneration and in harmony with their religious purpose.

·         The Defence Estates are too often sold to maximise financial return but without regard to their historic value or to DCMS guidelines for disposal of historic sites. One of our members is undertaking a study of this problem.

·         British Waterways has a good record on restoration of historic assets, and is inclusive in its approach, especially in involving children.

·         We do not consider that Network Rail have the capability or the will to conserve their  substantial portfolio of historic railway monuments. If they cannot restore their historic properties in the context of urban regeneration, they should pass them to those who can.

·         Many of our members report that local authorities - and especially elected members - undervalue conservation and lack necessary skills or knowledge. Areas which do have adequate  Conservation staff are too often those which are well-resourced and not suffering from decline, and where the work of Conservation Officers is more related to the conservation of a well-kept historic environment than the regeneration of a depressed or decaying one; but levels of prosperity frequently bear no relation to the number of historic buildings in an area. Where local authorities have the will to take positive action to enhance the historic environment,  improved powers of compulsory purchase - or decaying buildings or small, neglected open spaces - would assist them in their aim.

·         Local authority commitment is essential, particularly in depressed areas where private owners have little incentive to take a lead, but they need adequate resources to be effective. In one case the Civic Trust urged the appointment of an assistant for an overworked Conservation Officer, but was told that this was not a priority in a deprived area and that money could not be put into conservation when the area had other social problems. This demonstrates an ignorance of the benefits of conservation-led regeneration. We would commend to you Conservation in Chester (Chester City Council, 1988) which shows the value of the historic environment in the economic regeneration of Chester.





As we made clear in our response to Protecting Our Historic Environment, we firmly believe that  Listing does not hinder regeneration.


Listing does not sterilise a site. Indeed, in reality, Listing does not even protect a site, and it certainly does not cover - nor is it intended to cover - all buildings meriting Listing. Its purpose is to flag up the fact that "There is historic environment here". It concentrates the minds of owners, developers and local authorities, obliging them to recognise the "Power of Place" and not to treat everywhere the same. The presence of historic environment can actually generate a more creative approach by obliging people to think beyond mere demolition and rebuilding.


As the lessons of the 1950s-80s show (section 4 below), it has an added value in enabling communities to safeguard derelict but historic buildings which may currently be unfashionable or unappreciated, but which can eventually be brought back into uses which may not have been foreseen; a well-known example is Saltaire.


The case has been made, and will no doubt continue to be made, by those less sympathetic to conservation-led regeneration, that "too much" has been listed. However, not all that is Listable is Listed. Further, the 'playing field' is not a level one. It is not a simple choice between preserving the historic or sweeping it away and starting again. Firstly, there is already a presumption in favour of development in most urban locations; secondly, the 'historic environment' does not survive intact as some major form of obstacle to development. Much was destroyed in redevelopment schemes of the past 50 years now recognised as mistaken, and if it is accepted that the historic environment is of cultural and spiritual value to the community - as we believe - it is essential to conserve what remains.


Thirdly, there is the impact of the Shimizu judgement. This created an anomalous situation in which listed buildings in Conservation Areas cannot be demolished or altered without consent, whilst identical buildings in CAs which are not listed can undergo near-total demolition without consent. If the historic environment is to play its proper role in regeneration, this must be remedied by reversing the Shimizu judgement.


Conservation is of public value in its own right. Conservationists welcome excellent new development, asking only that it respects and enhances the existing historic built environment and the public realm.






·         Our comments under (2) are also relevant to this section.

·         We believe that there has been a loss of public trust in architects, developers and planners, after the development 'excesses' of the 1950s-80s, when the hearts of so many historic towns and cities were destroyed in the name of 'progress', so many of which are now acknowledged as a mistake. As a result, there has been a significant loss of potentially imaginative and inspiring schemes. The Civic Trust aims to work as an intermediary between the development profession and the public, to restore that trust and to help them work together on innovative schemes which restore historic buildings to good use but also integrate new development sensitively into the local landscape.

·         One of our members' most consistent complaints is of frustration at their inability to persuade local authorities to include good design of the public realm in their remit. There are excellent guidelines, from, e.g., English Heritage, but they have no force and so are often disregarded, particularly by those responsible for maintenance of the public realm - e.g. highway engineers who work 'by the book'. The Government must take a lead in setting minimum best practice standards and requiring sensitivity to local conditions (the recent change in the Traffic Signs Regulations, enabling signs on poles to be dispensed with where yellow lines are installed, is a positive, if  small example; Nottingham has already removed large numbers). Good design must be a specific remit of planners. We understand that in York, the installation of pink tactile paving  was authorised by Members who did not regard it as an aesthetic issue, and in the Highgate Conservation Area, London, old stone paving was replaced by pink tactile paving despite advice from English Heritage that better alternatives were acceptable.

·         A major source of concern revealed by the Power of Place consultation was poor skills levels in planning and conservation departments, and the lack of priority and resources allocated to conservation and design. This is compounded when faced by developers with the legal and financial resources to wear them down; our members report  local authorities giving inappropriate planning permissions for fear of incurring costs on appeal. This can be a major  obstacle to conservation of the historic environment.

·         For similar resource reasons, planning enforcement is often ineffective, for example, when historic shopfronts are deliberately destroyed by their owners - e.g. Tottenham High Road, London, where the problem is exacerbated by owners' ignorance of the historic, social and economic value of the properties they occupy.

·         Restoration of historic buildings is made more difficult by a dearth of skills in traditional building crafts. Promoting these could provide local employment, broaden the national skills base, aid public appreciation of the historic living environment, and provide a high-value specialist skills resource which could be exported to other countries.

·         The EU should specifically refer to the desirability of encouraging conservation-led regeneration.

·         The Government’s commitment to 'encourage' Local Planning Authorities, when preparing community strategies, to consider the role of the historic environment in promoting economic, employment and education opportunities, must go beyond mere encouragement. Our members complain of indifference or even hostility from local authorities who equate the historic environment with elitism and irrelevant to the problems of deprived and derelict areas.





Our comments under (2) relate also to this question. Members express concern  about Government departments' failure to follow DCMS advice on the sale of redundant historic assets - an example was the Listed College Farm, Finchley, only saved after a long fight by local people against the Highways Agency's determination to sell it for redevelopment; Rudi Vis, MP could elucidate. There are particular concerns over redundant Defence estates.





·         4.6 of HE-FF affirms a commitment to an effective statutory framework for protecting 'all elements of the historic environment'. We hope the Committee will recommend measures to achieve this.

·         Equalisation of VAT at 5% for new build and repairs to existing buildings could be the single most important fiscal change. The current differential, which places VAT of 17.5% on repairs and refurbishment, while new building and even demolition are zero-rated, is a major obstacle to restoring the historic environment. We regret that the Government, in the Planning Green Paper, committed themselves only "to take this... into account carefully when considering the future VAT treatment of building work", but are more encouraged by its recent efforts to address the issue at EEC level.

·         We deplore the EU ruling against Gap Funding. The reasons given, that it would restrict fair competition across the EU, are unconvincing. The money would be returned to the public sector, and we fail to see how subsidising a development scheme in Liverpool would deprive anyone in Lisbon, Livorno or Lipari. Gap Funding would meet EU cultural objectives to bring historic buildings back into reuse. We hope the Committee will recommend the Government to press the matter with the EU.

·         Restrictions which make it impossible for local authorities to prevent the demolition of buildings within Conservation Areas should be removed.

·         As stated under Q.3, failure to remedy the anomalous situation created by the Shimizu situation will diminish Local Authorities' ability to achieve sensitive regeneration of historic areas.

·         The development of Lottery and English Heritage Funding for voluntary groups was mentioned in HE-FF, but did not feature in the action points. Many local groups are anxious to save and restore historic buildings, but cannot compete with professional financial and development interests. English Heritage's current budget makes it impossible for it to assist financially. We are disturbed at indications that the remit of the Heritage Lottery Fund in regard to the built heritage may be restricted; in our view, heritage projects - funded, e.g., through the HLF's Local Heritage Initiative - are surely the ideal medium for Lottery Funding, which should be geared towards making it easier for local groups to pursue them. It could help materially in enable the backlog of repairs to buildings at risk, etc., to be cleared.

·         HE-FF is very positive in wanting to ensure that local policymaking takes proper account of the value a community places on particular aspects of its environment, but less so in that it is only in the context of 'character assessment'; it proposes no mechanism for greater public involvement in the protection of its own historic environment. Public bodies should be required to take full account of the historic environment, and community aspirations for it, in preparing strategies.

·         We sought a commitment to working with local business to secure improvements to the public realm.  HE-FF is silent on this.

·         The use of S.106 Agreements should be extended to permit improvements to the public realm.






We regret that this question, which appeared in the original 2002 Brief, was dropped from the revised brief. The conclusions, and promises, made in HE-FF are, we consider, integral to the remit of this investigation - possibly more so, following the appearance of the Planning and Compensation Bill and DCMS's Protecting Our Historic Environment consultation which expired on 31st October, 2003. We therefore include our comments on this question, drafted with our original response to the Select Committee's 2002 notification, in the hope that it will be given due consideration as a part of the inquiry process.


HE-FF and Protecting Our Historic Environment are the Government's most recent statements on the historic environment. HE-FF made many positive statements about the importance of the historic environment, but was weak on proposals for implementation, and we hope the Committee will hold the Government to its stated intentions. MORI's 2001 poll for English Heritage on public attitudes showed that the historic environment is important to the great majority of people (although regrettably HE-FF understated this, merely observing that "most people acknowledge the significance of the historic environment", and misrepresented the poll's conclusions by taking its statement, "a substantial number do not see it as having any relevance to them", out of context.


A major concern at the consultation stage was the deplorable lack of conservation skills and staff both in local authorities and private practice, and the poor levels of training of Councillors responsible for planning decisions. This must be resolved by making care for the historic environment, and improved levels of training, a statutory duty, and that Government departments be required to follow DCMS advice on the sale of redundant historic assets (see above).


If the historic environment is to play an effective role in regeneration, planners, developers and the public must be educated to understand and appreciate it. Public involvement will aid social inclusion, as, for example, has been done by the Hackney Society. It is therefore regrettable that HE-FF's proposals for widening the nationally popular Heritage Open Days, administered by the Civic Trust, into a Heritage Week have been dropped.


We commend HE-FF's suggestion that historic environment organisations, including voluntary organisations, be encouraged to get involved in the Creative Partnerships programme aimed at schools in deprived areas. It underlines the importance attached to the historic environment by the Government by stating that it "wants to see more regeneration projects, large and small, going forward on the basis of a clear understanding of the historic environment…”; this linking of educational, social and economic values is fundamental.


We therefore urge the Committee to emphasise to government that it already has a massive, and internationally unique, resource already in existence to help promote the regeneration, social and educational (not to mention economic) benefits of the Historic environment - namely, the Civic Society movement, comprising nearly 1,000 groups nationally with a membership comprising close to a third of a million of those citizens most actively concerned about, and active in, the improvement of all aspects of the living and working environment. In addition, there are bodies such as local history and archaeological societies. There are, of course, areas where these do not yet exist - often those areas of greatest deprivation - and this national voluntary resource would be willing and anxious to lend their expertise to those communities where it does not yet exist. We would be delighted, and anxious, to work with the Government to realise the potential of this active citizen body - for example, in the context of the Government's stated aim of introducing Statements of Community Involvement in the current Planning and Compensation Bill.


On economic potential, Chapter 5 of HE-FF looks at valuing the historic environment for the millions of tourists it attracts. However, it fails to recognise either the regeneration potential of a cared-for historic environment, or its potential for spreading the economic benefits of tourism more widely. For example, Greater London comprises a large number of historic towns and villages which retain much of their historic character and buildings, yet tourism in London places an overwhelming emphasis on the centre. Empowering local authorities to take greater care of these historic local centres, many of them in declining suburbs, could bring tourist revenue to local businesses. In the case of Greater London, for example, with its many deteriorating suburbs surrounding the cores of attractive historic villages, a "London Village Tourist Trail" could be a powerful factor for economic, social and educational regeneration.







We likewise regret that this was omitted from the revised brief. Public parks and open spaces can be a force for regeneration. Neglected parks, as Finsbury Park, London and many others have been, drag down the appearance and economy of a neighbourhood (the Select Committee's own excellent report into Parks covered these aspects in great detail). Restored public parks, equipped with new facilities, as in Southwark Park, Heaton Park, Manchester and Leazes park, Newcastle, have the opposite effect.






Our response to English Heritage's Review of Policies relating to the Historic Environment (2000) contained items of relevance to this inquiry, on such issues as the value and maintenance of the historic environment. A copy is attached as Appendix 3.






Similarly, we believe that our response to the recent DCMS Consultation Protecting our Historic Environment contains comments on a number of issues relating to attitudes towards, legislation affecting, and care of the Historic Environment, at local, regional and national level, which will impact materially on the ability to implement the present Committee's recommendations. We therefore attach a copy as Appendix 4.