To our privilege, an increasing share of our work involves a heritage element – we frequently deal with applications for Conservation Areas and listed buildings, often in constrained urban settings. These make for challenging but rewarding projects. Jules sits on Bristol’s Conservation Advisory Panel so is already pretty au-fait with heritage principles, but as per our manifesto pledges for 2020, we know there’s always more to learn.
On this note, we recently signed up to one of Historic England’s HELM training courses (pre-lockdown) for a really informative session on Statements of Heritage Significance. Led by Dr. Richard Morrice of the HE Planning and Reform team, we were taken through the updated Historic England Advice Note (HEAN) 12, released in October last year to support the NPPF’s requirement for applicants to describe the ‘heritage significance’ of their proposals to assist LPA’s in making decisions on impact. Followed up with some opinion-dividing case studies (we all concluded there’s no absolute right answer!), it was a useful refresher in the discipline of analysis.
So, should you be about to take on a project that involves a heritage asset, of whatever scale or context, here are a few basics that we took away with us for assessing and expressing ‘Significance’:
- NPPF Para 189 is the starting point. This requires a description of the significance of any heritage assets affected, this includes the contribution made by its setting.
The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum, the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary.
Where there is the potential for archaeological interest on a site then an application should be supported by an archaeological desk-based assessment and, if necessary, a field evaluation. Any investigation should be carried out under the CIfA Standards and Guidance (whether desk-based assessment, field evaluation or recording of buildings and structures) and it’s good practice to agree on the scope of this with the LPA beforehand.
- Significance is defined by the NPPF as ‘the value of a heritage asset to this and future generations because of its heritage interest’.
Interest can be archaeological, architectural, artistic or historic, and can be derived from the physical presence of an asset, but also from its setting. So an understanding of significance stems from these 4 interests, or a combination thereof.
- A Staged Approach is recommended for decision-making in applications affecting heritage assets.
The first stage requires an understanding of the form, materials, and history of the heritage asset. The second, an understanding of the significance itself – the onus being on the applicant to complete these stages (this being the ‘Statement’). The third stage demands an understanding of the impact of the proposal on significance. Whilst the fourth stage seeks to avoid, minimise or mitigate negative impacts, in a way that meets the objectives of the NPPF. Finally, the fifth looks for opportunities to better reveal or enhance significance.
Whilst these latter stages are all covered by the LPA’s assessment, it’s useful to address these as part of your Heritage Assessment in an up-front bid to assist a positive assessment of impact.
- Analyse and describe
For the staged approach to be effective, it’s crucial that the analysis is carried out appropriately (ie in full), regardless of the level of significance or scope of the proposal.
The level of detail, however, needs only be proportionate to the importance of the asset. Although the description must be sufficient for the LPA to come to a judgement about the level of impact. Grasping the scope of the document is therefore important – too panoramic and it misses the point, too microscopic and it’s not comprehensive enough.
- The Sequence of the staged approach is also key.
Significance should really be analysed before a proposal is designed, not the other way around. The Statement is the opportunity for you to demonstrate their understanding of an asset, not to justify an oven-ready scheme. It’s about objectively expressing ‘what matters and why’ about the asset, before any development is planned.
- Provide an expert narrative
Where the significance of a heritage asset is not obvious, pull in a specialist to help. We rely on the skill and expertise of many heritage consultants including archaeologists, historic building surveyors, garden historians and Conservation architects, who can describe significance in a way that is acceptable to the LPA and will give your application the best chances of success.
For simple sites a basic checklist approach may be appropriate, whilst multiple heritage assets could involve sophisticated matrices and scoring systems. There is no set formula or systematic answer – what matters most is that your narrative clearly describes ‘what matters and why’ about the asset, and how the proposals impact upon this.
- Consultation is always helpful.
Early engagement and pre-application discussions with LPA’s, Historic England (where appropriate) and statutory consultees will ensure that your Statement is fit for purpose and will avoid abortive work. Whilst resources don’t always permit, it’s good practice to agree the precise scope and nature of your Statement with the LPA before commissioning any analysis. It will save you time and costs in the long run, particularly on complex sites.
- Check your Sources
The NPPF requires that, as a minimum, the relevant Historic Environmental Record is consulted for your analysis. However there are numerous other information sources which might inform your Statement, including local, county and national records, statutory designations, the thematically-arranged HE guides (for listed buildings, archaeological sites and historic parks and gardens), the Pevsner Architectural Guides, amenity society records and historic Ordnance Survey maps, to name but a few. Reference your sources clearly within your document, so all parties can understand the information you have consulted. Or alternatively employ someone with specialist knowledge to help with this.
- Splice with your Design and Access Statement
Your Statement of Significance may form part of your Design and Access Statement (DAS). This can be a useful analytical tool in demonstrating how a scheme has been designed to avoid/mitigate adverse impacts on significance.
However, the DAS is not a substitute for the Statement of Significance and the function of each document should not be confused.
- Remember Proportionality
And finally, if all this work sounds excessive, remember again that your Statement only needs to be proportionate to the impact of your proposal. It’s important that your analysis is full and that the LPA has sufficient information to make their assessment. But it’s equally important that the detail you provide is no more than sufficient to understand the potential impact of your proposal. So, if your scope of works is restricted to just part of a heritage asset, your analysis should define its significance as a whole, but your Statement need only describe the affected part in detail.
Phew – it’s quite an involved, disciplined process and possibly more than a little daunting for non-heritage specialists. But if you keep reverting to the NPPF wording and follow the staged approach of HEAN 12, you should be able to produce a robust Statement of Significance (of whatever scope and scale) that meets the requirements of the Planning (Listed buildings and Conservation Areas) Act 1990, and provides a sound basis for LPA decision making.
If you don’t know where to start, check out HEAN 12 for a suggested template and lots of helpful prompts to help your Statement take shape. If this all seems a bit too much then drop us a line and we are more than happy to recommend some specialist heritage consultants to help you. And please do share your successful documents with us, we’re always keen to learn from good practice.