Written evidence submitted by
Urban Vision Enterprise and D2H Land Planning Development

Introduction

Dave Chetwyn is Managing Director/ and Partner of Urban Vision Enterprise and Director/Partner of D2H Land Planning Development. He specialises in planning, regeneration, mediation, heritage, leadership and governance. Former roles include Chair of the Board of the National Planning Forum, Head of Planning Aid England, Chair of the Institute of Historic Building Conservation, Chair of the Historic Towns Forum, High Street Task Force Expert, and Associate of the Consultation Institute.

Urban Vision Enterprise and D2H Land Planning Development deal with a range of private, public and voluntary sector clients, including statutory planning bodies, professional bodies, local councils, developers, housebuilders and landowners. This provides a balanced perspective based on experience of the planning system from both sides of the fence.

Question 1

What are the most significant challenges facing owners and operators of built heritage assets, and how are they affecting what those sites can offer?

• What interventions are needed to prevent the managed decline of heritage assets on publicly-owned land?
• What can the Government do to make it easier for communities or local businesses to take ownership of historic buildings?

Challenges facing owners vary, but can include the following:

Use: Most heritage is in productive use, forming part of the infrastructure of cities, towns and villages. This includes use as housing, commercial space, recreation and entertainment, transport infrastructure and a diverse range of other uses. Productive use supports a sustainable future for commercial and other buildings, based on sustainable business models. Residential use supports the upkeep of housing. Conservation is about finding creative solutions to using and adapting buildings, to realise their social and economic potential, whilst maintaining their heritage value.

Viability: Where there are problems of vacancy and deterioration, it is often due to a lack of financial means for occupiers and/or the absence of a sustainable business model. Local economic circumstances are a major factor and can include:

• Inflationary pressures and lack of affordability, for example in London and high growth areas;
• Viability challenges, manifested in supressed land and property values, low incomes and lack of local economic opportunities. Building vacancy is often due to there being a viability gap, where capital and running costs exceed value and income potential over a reasonable period.

High street transition: In town and city centres, changes in live/work patterns have real implications for viability, sometimes involving large-scale changes of use. For example, in many centres there is now less demand for corporate office space, but greater demand for flexible workspace. Building owners need a flexible approach to respond to changing use trends and to adapt to new demands.

Infrastructure: Deficiencies in infrastructure can be a limiting factor in the continuing use or refurbishment and reuse of historic buildings, for example poor transport connections in older commercial and industrial areas.

Sector skills and capacity: Talented and experienced heritage teams are required to ensure that the planning system supports and does not impede heritage schemes. At present such skills are often deficient and this can be a barrier to finding practical solutions to the continuing use or reuse of historic buildings and areas. For building owners proposing works to historic buildings, there can be difficulties in identifying people with heritage skills and experience to undertake design works and carry out construction (see Question 5).

For publicly owned heritage buildings, there should be greater requirements and incentives for finding solutions to secure their reuse and conservation, including finding private-sector buyers or partners and also taking a positive approach to community asset transfer. The sale price of heritage assets should be realistic, taking account of viability challenges.

Businesses can sometimes provide the capital funds required for building refurbishments and conversions, whilst community organisations can sometimes obtain capital funding from public sources or community fund raising.

Clear and accessible information for building owners would be beneficial. Historic building protection is often flexible and allows for change, but there are common misconceptions over this. Often the barrier to gaining consents is a failure to use professional teams with the necessary skills, or local authorities that lack conservation skills and capacity.

Question 2

How effective are the current funding and finance models for built heritage?

• What should long-term public funding for the sector look like?

Most funding for historic buildings is provided by building owners, such as householders, businesses and developers. This can include commercial borrowing.

Community organisations can often access heritage funding. This can include funding from specific heritage funders, such as national heritage bodies, the National Lottery Heritage Fund and the Architectural Heritage Fund. Heritage is also funded through mainstream (not heritage specific) regeneration and development funding programmes, and these are in continual transition. Some funding streams exclude Town and Parish Councils, which is unhelpful.

Heritage is often a key part of regenerating industrial and commercial areas and in supporting town centre viability and high street recovery. Over the past decade or two, there has been a tendency for national programmes to focus on the needs of high growth areas, where the challenges are related to housing supply and affordability. This has resulted in public funding being injected into areas which already suffer from land and property price inflation, with predictable consequences.

In many areas, the challenges are development viability (viability gaps) and the need to create local economic opportunity. National programmes and national planning policies have been less effective in targeting such areas. It would be useful for future regeneration programme to shift emphasis to address the challenges in areas of deprivation. By channelling funding into areas of deprivation, the trend of a widening gap between over-heating and underperforming areas could be slowed or reversed.
 

Heritage has proved to be a particularly powerful tool in helping to deliver physical and economic regeneration in under-performing areas. This is especially apparent in the dramatic regeneration of many northern towns and cities over the past few decades. This has often involved the regeneration of peripheral commercial and industrial areas, which have initially offered lower rentals (for example, various peripheral commercial and industrial areas around Liverpool City Centre).

Question 3

What role does built heritage play in the regeneration of local areas and in contributing to economic growth and community identity?

• How can heritage buildings be supported to increase energy efficiency and contribute to the Government’s net zero targets?

The economic, community and other values of heritage are set out in detail in Chapter 2 of Conservation Professional Practice Principles, published by the Institute of Historic Building Conservation, Historic Towns and Villages Forum and Civic Voice (2017). This is available here:

https://ihbc.org.uk/Conservation-Professional-Practice-Principles/

Economic and community values of heritage include:

• Utility value for owners and occupiers (most heritage is in productive use);
• Investment value for owners and developers;
• Historic areas can act as a catalyst for sometimes transformational area-based regeneration;
• Peripheral historic areas can provide low rentals, which help to support small business development, enterprise and creative industries, in addition to independent businesses;
• Supporting choice and diversity through uses that are not viable in higher rental new development;
• Helping to make city and town centres, high streets and village centres more attractive and competitive;
• Creating visitor magnets and supporting tourism;
• Creating distinctive local identity and pride;
• Providing opportunities for volunteering and community activity;
• Supporting local skilled employment and associated higher levels of pay;
• Maintaining mixed use and pedestrian permeable environments;
• Protecting green spaces and green infrastructure, which support active lifestyles and health.

In terms of net zero targets, conservation and reuse of buildings retains the massive carbon investment associated with their materials and construction (embodied energy). Also, traditional buildings tend to be more durable, sometimes lasting for centuries. This avoids landfill and further carbon use associated with a cycle of demolition and redevelopment. The continuing use and conservation of buildings is clearly key in terms of reducing carbon use.

The heritage sector should focus more on place, not just individual building performance. Many historic areas have intrinsically sustainable characteristics including:

• Mixed use, arising from incremental change and the need for different facilities to be in easy walking distance;
• In established centres, good accessibility and concentration of community and other facilities;
• Pedestrian permeable environments, especially in places that developed before motorised road transport;
• Historic parks, routes and other green spaces provide health and well-being benefits.

Together, these reduce the need for travel, by maintaining ‘walkable’ neighbourhoods.

In terms of energy efficiency, most historic buildings are capable of being upgraded. The nature and extent of such upgrades depends on the specific building. There are concerns over poor advice on upgrading of buildings, especially where ill-conceived alterations have harmed properties due to a failure to understand the need for traditional buildings to ‘breath’. This can cause substantial damage to building fabric, which can be costly to rectify, in terms of financial implications and environmental impacts.

Question 4

What are the financial, regulatory and practical barriers to preserving built heritage?

• What policy changes are needed to make restoring historic buildings easier and less expensive?

Financial barriers to preserving heritage include:

Viability: Viability challenges in many parts of the country, where the costs of asset acquisition and refurbishment/adaptation are greater than the projected value or income. Regeneration policies and programmes should focus on areas with viability challenges, but avoid pumping money into high growth areas where it can stoke land and property price inflation.

VAT: VAT costs on refurbishment widens the viability gap, especially in areas of deprivation. VAT is a significant barrier to regeneration and investment in the areas that need it most. It is an anti-growth and anti-regeneration tax. VAT should be reduced on building refurbishment projects.

Fees: Fees have been suggested for listed building consent applications. These would clearly be unfair and would act as a disincentive to regeneration and to responsible owners wanting to reinstate their properties.

Regulatory barriers to preserving heritage include:

Planning policy: The National Planning Policy Framework chapter on the historic environment uses different terminology than that in legislation, so creates ambiguity and causes confusion. The NPPF historic environment chapter should be rewritten to remove such discrepancies. The NPPF and planning practice guidance should recognise the role of heritage in achieving growth, including high street recovery and the role of peripheral areas (often declining commercial or industrial historic areas) in terms of offering cheap and affordable floorspace for small businesses, start-ups, creative and knowledge-based industries;

Negative and passive guidance: Guidance produced by some heritage bodies is narrow in scope (narrow focus on significance) and passive and negative in approach. For example, some guidance on housing site allocations assumes that impacts are negative and focuses on mitigation. A more positive approach would be to actively seek positive impacts for heritage. For example, focusing housing growth in and around historic town centres, with good pedestrian connectivity, helps to create more sustainable live work patterns, easy access to facilities and infrastructure, enhancement of the vitality of high streets and regeneration of the historic centre. Guidance should be rewritten to promote positive planning for heritage as an integral part of the wider social, economic and environmental planning of an area. There should be far greater emphasis on the economic values of heritage and an assessment of viability should form part of heritage evidence bases for planning policies. The correlation between conservation of historic and natural environments should be emphasised.

Local government: There is a lack of design and heritage skills and capacity in some local authorities, in addition to lack of awareness of the economic values of heritage and culture. Heritage and culture have had a transformational impact in many towns and city centres. But there is little awareness of the economic value of culture and heritage in some other areas. Clear requirements should be set for local authorities in terms of design, heritage, culture and placemaking skills and capacity. This includes specialist skills to apply heritage statutory duties, including Section 16, 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990.

Owners: There is often a lack of awareness by building owners of heritage protection legislation. There should be clear and accessible information for owners.

Practical barriers to preserving heritage include:

Infrastructure: Infrastructure deficiencies, including highway access. Investment in improving infrastructure is often a key part of enabling regeneration.

Skills and capacity: Limited skills and capacity in the construction industry. There needs to be a much greater emphasis on training and skills development (see Question 5).

Question 5

What policies would ensure the UK workforce has the right skills to maintain our heritage assets?

Programmes and training should focus on the following skills to support heritage protection:

• Traditional construction skills, including repair, maintenance and conversion of historic buildings;
• Professional skills among built environment professionals;
• Project development and management skills for heritage projects;
• Raising of awareness in decision makers of the economic values of heritage and its role in achieving more effective and sustainable forms of economic and physical regeneration.

Skills and capacity deficiencies are a barrier to growth. Government should work with professional, membership and other sector bodies and training providers to ensure that these deficiencies are being addressed. Funding support should be provided where necessary to address skills gaps.

Evidence of Dave Chetwyn MA, MRTPI, IHBC, FIoL, FRSA

On behalf of Urban Vision Enterprise and D2H Land Planning Development