It is likely that we will see further revisions to the National Planning Policy Framework in early 2022. As far as heritage is concerned, this will present an ideal opportunity to iron out some of the many inconsistencies that surrounding listed building status.

In working with a number of national clients with extensive heritage portfolios, I regularly experience, and hear from clients, about a lack of consistency when dealing with conservation issues, even within the same local authority.

With precedent being key to planning, it is interesting to consider what has previously been consented as alteration works to listed buildings, compared to today.

It was the introduction of English Heritage’s Conservation Principles Policies and Guidance Note in 2008, which resulted in a significant change in how listed building consent applications are addressed. The guidance was brought in partly to address a perceived harm inflicted on listed buildings in the 1960s and the loss of, in some cases, considerable amounts of historic fabric.

But there appear to be many differences between the approach taken by conservation officers within urban local authorities and their rural counterparts. There is also a perception that alterations to listed buildings within an urban setting are more straightforward than those in a more rural context.

There is some credence to this, but the reality is much more complex. The greater scarcity of historic fabric within some urban properties, usually the result of stripping out and removal and the extensive regeneration of the immediate area, maintained heritage in urban buildings is more scarce. The result is that urban areas are all too often treated with undue sensitivity.

The same is true of the English National Parks. Here, the approach is generally more stringent than other rural areas, due to a myriad of factors including the heritage values that the building provides to the wider community and how much of the historic fabric has been retained. These complexities make it extremely difficult to provide consistency in issuing a listed building consent for alterations and repairs.

Ultimately, every development proposal is unique and so while there is considerable guidance available, it is impossible to compare and contrast. The planning system should prevent subjectivity, but it does not do so in this case.

I often find that clients run into difficulties with listed building applications because of a lack of understanding of the history, construction and development of the building and its significance. The recent changes to the NPPF have not included any amendments to the guidance on heritage assets, and given the complexities and unique nature of these buildings and structures, there is unlikely to be a move towards a more consistent approach. This only highlights the need to ensure that a property owner has the right team, with the necessary experience of heritage buildings, in place at an early stage. A sense of pragmatism is also necessary, as it is unlikely that all proposed changes will receive consent and elements of the scheme may need to be reconsidered. Without a significantly strong and well supported argument, what may have been achieved 20 to 30 years ago is much less likely to be consented today, and there is no guarantee of success.

I hope that a more objective approach to heritage, as heralded by the ‘beauty’ agenda, will finally create some much needed consistency.