A Heritage Statement is a mandatory required document as part of all applications for Listed Building Consent.
Please refer to my Blog post about Listed Building Consents and whether you might need it or not, and what to do.
It is perfectly possible for a homeowner to do it without professional input, if the application is reasonably straightforward. However, for anything that is complicated or requires a rather detailed approach, perhaps where there are potential differences of opinion involved, then seeking out an experienced heritage advisor will avoid wasted time.
Historic England has published a very useful document – Historic England Advice Note 16 Listed Building Consent – which you should refer to for information and guidance.
Historic England has also published a document on writing Statements of Significance. – Historic England Advice Note 12 Statements of Heritage Significance – which you should refer to for information and guidance.
Historic England has also published a useful document on making changes to heritage assets, which you should read too – Historic England Advice Note 2 Making Changes to Heritage Assets
There are no rules for what a Heritage Statement look like or for what they should contain. However, I can give you some ‘top tips’ which will serve you well and help you produce a Heritage Statement that is useful to supporting your application.
Significance
This is the most important part. Your local Conservation Officer won’t be expected to automatically or magically know your house or building. You know about it better than anyone and you need to carefully and accurately describe it. Use simple words and include photos. Saying something like “we want to take out the fireplace in bedroom 3, move the door, block up the arch and create an ensuite bathroom in the corner” means nothing without some context and descriptive narrative . You know what you mean, no one else will. You must, therefore, provide a document that provides a statement of the understanding of the significance of the heritage asset. Whether you are asking to put a cat flap in a back door, or build a substantial addition to the house is not relevant. The rules apply equally. You must explain the significance of the heritage asset as a whole and also of the specific part that you intend to alter. To do this, you will first need to do a thorough analysis and research project of the building. It is highly likely that it will have changed many times and will have evolved over time. Explain this. Use colour coded floor plans to show the different phases of the evolution. This is important. If your proposal only impacts part of the house that dates from the 1970’s it is very different conversation to one whereby the impact is on part that dates from 1570. Tell the story of your house, explain what you want to and then explain how that will impact on the heritage. Be honest.
The amount of analysis and research should be proportional to the application request, the significance of the heritage asset and the part of the building that is impacted. The cumulative impact and consideration of previous alterations should also be mentioned and taken into consideration.
An alteration is likely to have both positive and negative consequences. Be honest and open and explain this. The removal of a wall is a negative, but if that then allows a positive improvement to take place explain what it would be like. This is where the use of good photos of the existing building and good drawings of what you are proposing will have value. Modern computer generated graphics are really useful for this. Keep them as realistic as possible though.
It is important that you consider investing into using professional advisors who are trained and have specialist skills in conservation. Using a Conservation Accredited professional will make a huge difference and will probably be the difference between getting your application Granted rather than Refused. Each of the professions has specialists. Refer to my earlier Blog posts about Listed Building Consents and I have given you the links to where you can find suitable professional experts. Don’t assume that all Architects, Surveyors, Structural Engineers are the same. They might have the same qualifications, but this is all about experience and professional judgement.
You must provide sufficient information for the Conservation Officer to be able to make a judgement and decision. If you submit a poor document it might tick a box on a checklist but it won’t help you. If you don’t provide sufficient information, your application will simply be Refused, or will take so much longer as they will keep coming back and asking for more details. Provide the details at the start and it will help you progress much quicker.
Materials
Not all building materials are the same. Bricks are not all the same throughout history. Roof tiles, windows, roof slates, timbers and the many other parts are not all the same. Make sure you provide explicit details of your building and fully explain the materials used in the construction. It is essential that you provide details of the materials that will be impacted by your proposals. If you want to knock an opening into the wall, don’t just say that and show it on a drawing. Explain what the wall is built from. What plaster is used? Does the removal of the section of wall impact on the significance of the building or the architecture of the room at all..? Be detailed and be specific. If you don’t provide this information, you will be asked for it and then incur a delay.
Windows
If your proposal involves any new windows, you will be asked for detailed construction drawings. This will need to the very specific joinery details of the frame, glazing bars and construction. Include a comment about your choice of glass. Try to avoid using modern plate glass. You can use heritage glass with a much better finished impact. Make sure that you include the joinery details as otherwise you will be delayed later when it is requested. Most joiners are able to provide the detailed drawings that are required for the application and will be used to the request for them to be provided. Sometimes, the window joinery details may be Conditioned as part of the Consent. However, this then risks the Condition being rejected later when you seek to Discharge the Conditions (at an additional cost) if the details are unacceptable. By including all the Information at the start you can reduce your costs and can also avoid delays later.
Pre-Application (Pre-App) Advice
You are encouraged to have informal preliminary discussions with your local Conservation Officer. It is not mandatory, but it is a sensible way forward. Most Local Planning Authorities will charge a small fee of about £200 or thereabouts. Some are more expensive and some will do it for free. Do use this service. It will save you a lot of time later. Some will do the Pre-App on-site but most are only doing it remotely via video calls. A site visit is best, but you can still achieve a lot through a video call. Whatever happens, it is best that you do it than not do it. Include the reference number of the Pre-App in your document and a brief summary of the conversation and the conclusions reached.
Views of the Neighbours
If your proposal is likely to impact on your neighbours in some way, even if it is simply that they can see it, then do talk to them first. You can’t avoid them knowing about your application as they will be sent a letter by the Local Planning Authority when your application is submitted and they will be invited to provide a response. If your neighbours are likely to object, then be honest and cover this in your document. Explain what your neighbours are objecting to, what you have done to consider and mitigate those objections and how you feel that the objections are not as important as it might seem. Don’t just hope that it will go away. Some projects attract considerable opposition from immediate neighbours and the larger community. Deal with this upfront. Listen to the objections and show a rational and professional approach to your consideration. Don’t just ignore them entirely.
Archaeology
If your building is located on or near an Ancient Scheduled Monument you will need to provide a report from an archaeological expert. You may also be required to do this in other situations where it is possible that hidden archeology may be present. This can be expensive and also very time consuming. Give this thought and consideration at the earliest opportunity. Whether it is needed or not, include a statement to that effect in your document. It will demonstrate that you have at least considered it.
Preliminary Bat Roost Assessment for Bats (PBRA)
If your application is for roofing works, you will need to obtain a PBRA report. This is an on-site visual assessment looking for bats and bat roosts within your roof. It is done by a licensed ecologist. You can either submit this as a separate report or you can include within your Heritage Statement. If you submit a separate report, do at least refer to it within the Heritage Statement and the conclusions, just in case the documents get separated.
Review the Local Planning Policies
Your Local Planning Authority will have published its Local Plan policies and local rules and requirements. Make sure that you review them and take them into account. There might be area-wide policies which will relevant to your request. You should specifically refer to any Policies which are directly relevant to your application. You ideally want to find Policies which support your application. If you find a Policy which specifically prohibits your application then you will at least know in advance that you face a challenge and possibly face your application being refused.
National Planning Policy Framework (NPPF) 2021
The NPPF is a very important document. It provides a framework for all Planning applications. You can download it for free here..: NPPF download
You need to read the whole document, but the specific parts which relate to heritage can be found from Sec. 16, Para. 189 onwards. Make sure that you carefully review each of these paragraphs and follow the underlying guidance. It will help you if you can refer to specific paragraphs in support of what you are doing or what your application is for.
Demolition
If your proposals include the demolition of a Listed Building you will be faced with an immediate challenge.
This is referred to in Para. 201 of the NPPF. You must read this section and directly justify your request. An inadequate justification and non-compliance with Para.201 will result in your application being refused.
Justify WHY
This is often overlooked. Why do you need to make the alteration? The justification for what you want to do is important. You need to explain why you want (need) to make the alteration, what the consequences of that change will be, what the harm caused will be and what the benefits gained will be. Try to anticipate any objections and try to find an argument to justify what you want to do. Include this discussion within the Heritage Statement.
Photographs
You know your building, but you shouldn’t assume that anyone else will too. Photos can help to place your ideas into context. Include general images as well as close-ups. Make them big enough to see and be helpful. Thumbnail images are pointless. Images without a caption are pointless. Don’t just include 50 photos and expect the reader to know why or what they for.
Disclaimer: Anything posted in this Blog is for general information only and it is not in any way intended to provide any advice, legal or otherwise, on any general or specific matter that you can rely on. You should always seek your own legal and professional advice.