Applications Affecting Heritage Assets
In light of paragraph 128 of the National Planning Policy Framework applications affecting heritage assets or their setting require descriptions of significance to accompany the submitted drawings/plans. These statements will form part of the justification for the proposal and should demonstrate that consideration has been given to the protection of the heritage asset and/or its setting.
A heritage asset will either be a Designated Heritage Asset (Listed buildings, Historic Park or Garden of National Importance, Conservation Area, Scheduled Ancient Monument) or a Non-Designated Heritage Asset (Locally Listed Park, Garden Building or Feature, Area of Archaeological Importance, Known site on the Historic Environment Record (HER). In essence it makes little difference whether the heritage asset is designated or not because the statement required for each should contain similar information to ensure the application can be registered, irrespective of whether it is a planning permission (including the demolition of a building in a Conservation Area), Listed Building or Advertisement Consent.
Finally, it is important to entitle the document as a heritage statement for both designated or non-designated assets, making it clearly identifiable as part of the application.
An overview of how to write a Heritage Statement
- Explain why the heritage asset is significant. (Significance is defined as: The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic). The ‘heritage asset’ may be the building itself and/or the conservation area it’s located in or adjacent to. Documents that will help you may be the conservation area appraisal, possibly the list description if the building is listed and the Historic Environment Record held by the council's Archaeological team (firstname.lastname@example.org).
- Provide clear details of the proposal i.e. what works you intend to do.
- Assess how these works will/may affect the significance of the building. A conclusion may be reached that there would be no impact or that there would be an impact but it is acceptable or that there may be some harm but suggest some form of mitigation (other works or ways to reduce the harm to an acceptable level). The assessment should include the justification for the works i.e. why it is required.
Detailed guidance on what a Heritage Statement should contain
Applications affecting a heritage asset (designated or non-designated) require an applicant to provide a description of the significance of the heritage assets affected and the contribution of their setting to that significance. The level of detail should be proportionate to the importance of the heritage asset and no more than is sufficient to understand the potential impact of the proposal on the significance of the heritage asset. As a minimum the Council’s Historic Environment Record (HER) should have been consulted and the heritage assets themselves should have been assessed using appropriate expertise where necessary given the application’s impact.
In simple terms, an applicant will need to undertake an assessment of significance to an extent necessary to understand the potential impact (positive or negative) of the proposal and to a level of thoroughness proportionate to the relative importance of the asset whose fabric or setting is affected. The following first three steps should therefore be undertaken in almost every case:
- Check the council’s Historic Environment Record by clicking here for known archaeological and historic environment sites. This initial research should collate necessary information on statutory and local lists via the Conservation and Design area of the site or the Heritage Gateway, the NMR, and other relevant sources of information that would provide an understanding of the history of the place and the value the asset holds for society.
- Examine the asset and its setting.
- Consider whether the nature of the affected significance requires an expert assessment to gain the necessary level of understanding.
It may be helpful to consider that an acceptable application, where it relates to a heritage asset, whether designated or not (i.e. known archaeological sites and features on the Historic Environment Record, locally listed structures and parks, nationally listed parks and buildings and conservation areas) should include several or all of the following terms:
- HER (Historic Environment Record, also called Sites and Monuments Record).
Guidance on what a Heritage Statement should contain
The purpose of a Heritage Statement is to identify the important characteristics/significance of the existing heritage asset and to explain how the proposals would affect these and justify why this is necessary or desirable. If appropriate the Heritage Statement can be incorporated as part of a Planning or Design and Access Statement as long as it is clearly identified within the overall document.
A Heritage Statement must include:
- Statement of significance of the heritage asset.
- Details of the proposal.
- Analysis of the impact of the proposal on the significance (including a statement of need and statement of impact).
Applicants are expected to assess and justify the likely impact of their proposals on the special interest of the site or structure in question and to provide such written information or drawings as may be required to understand the significance of the site or structure.
The scope and degree of detail necessary in a Heritage Statement will vary according to the particular circumstances of each application. Applicants are advised to discuss proposals with either a planning officer or a conservation officer and the planning archaeologist before any application is made. The following is a guide to the sort of information that may be required for different types of application and is based on guidance provided by the Department of Communities and Local Government (January 2008).
For applications for listed building consent, a written statement that includes a schedule of works to the listed building(s), an analysis of the significance of archaeology, history and character of the building/structure, the principles of and justification for the proposed works and their impact on the special character of the listed building or structure, its setting and the setting of adjacent listed buildings may be required. A structural survey may be required in support of an application for listed building consent. Statements can include supplementary photographs and reports if appropriate.
For applications for planning permission for the demolition of a building or structure in a conservation area, a written statement that includes a structural and condition survey, an analysis of the architectural and historic character of the building/structure, the principles of and justification for the proposed demolition and its impact on the special character of the area will be required. This may include information about the use and viability of the building and evidence that alternative uses or ownership have been fully considered. In addition, the following information should be included:
- The condition of the building, the cost of repairing and maintaining it in relation to its importance and to the value derived from continued use.
- The adequacy of efforts made to retain the building in use, including evidence that the building has been offered on the open market at a realistic price.
- The architectural and historic merit of the building and the contribution that it makes to the conservation area.
- The merits of alternative proposals for the site.
Any proposal for demolition would normally be considered in conjunction with a detailed application for a proposed redevelopment.
For planning applications either related to, or impacting on the setting of heritage assets, a written statement that includes plans and photographs showing historic features that may exist on, or adjacent to the application site, including historic buildings and structures, historic parks and gardens and scheduled ancient monuments will be required. This should include an analysis of the significance of archaeology, history and character of the building/structure, the principles of and justification for the proposed works and their impact on the special character of the historic building or structure, its setting and the setting of adjacent historic buildings.
For applications within or adjacent to a conservation area, an assessment of the impact of the development on the character and appearance of the area will be required. This would include an analysis of the important characteristics of the area including significant buildings or features as well as views into or out from the proposed development.
For all applications involving the disturbance of ground within an Area of Archaeological Potential as defined by the planning archaeologist or in other areas in the case of a major development proposal or significant infrastructure works, an applicant may need to commission an assessment of existing archaeological information and submit the results as part of the Heritage Statement. Applicants are advised to contact the planning archaeologist at Seaclose offices regarding these matters.
Designated Heritage Asset: World Heritage Site, Scheduled Monument, Listed Building, Wreck, Registered Park and Garden, Conservation Area.
Heritage Asset: A building, monument, site, place, area or landscape positively identified as having a degree of significance meriting consideration in planning decisions. Heritage assets are the valued components of the historic environment. They include designated heritage assets and non-designated assets identified by the local planning authority during the process of decision-making or through the plan-making process (including local listing).
Setting: The surroundings in which a heritage asset is experienced. Its extent is not fixed and may change as the asset and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral.
Significance: The value of a heritage asset to this and future generations because of its heritage interest. That interest may be archaeological, architectural, artistic or historic.