IHBC Chair David McDonald has registered with England’s Ministry of Housing, Communities and Local Government the Institute’s serious concerns over how ‘some of the recently announced proposals relating to permitted development rights in planning (PD) may have unforeseen and detrimental effects on the historic environment’.
David McDonald writes:
I write on behalf of the Institute of Historic Building Conservation (IHBC), the professional body of the United Kingdom representing conservation specialists and historic environment practitioners in the public and private sectors. The Institute exists to establish the highest standards of conservation practice, to support the effective protection and enhancement of the historic environment, and to promote heritage-led regeneration and access to the historic environment for all.
Whilst we support the Government’s aims to boost the economy post-Covid by encouraging the building industry, we are concerned that some of the recently announced proposals relating to permitted development rights in planning (PD) may have unforeseen and detrimental effects on the historic environment. We note that listed buildings, conservation areas and world heritage sites are excluded from the proposed changes, but nevertheless, there are serious concerns, as outlined in detail below.
Two-storey extensions on detached, purpose-building flat-blocks
Our concerns here relate to the potential effect on the setting of designated heritage assets, such as listed buildings or conservation areas, of such potentially high and bulky extensions to existing buildings. We are also concerned that there is no exemption for locally listed buildings. Many local planning authorities (LPAs) include in their local lists 1930s blocks of flats which might not meet the high standards required for statutory listing or are in conservation areas, but nevertheless contribute to local distinctiveness. A two-storey extension of poor design could be extremely harmful. If this new PD measure is to take place, we would urge that it includes some form of prior-notification to enable the LPA to intervene.
Upward extensions on commercial and residential buildings
The issues and concerns listed above would also apply to the upward extension of other buildings. Roofscapes and skylines make a strong contribution to the character and quality of areas. Ill-considered, bulky additions to the roofs of buildings that were not designed to accommodate them could have a serious adverse impact on the character, appearance and amenity of such areas and could cause serious concern to existing owners and residents. The harm caused by a relatively small number of inappropriate, prominent additions could soon outweigh the benefits.
Demolition of redundant buildings and rebuilding on same footprint
This is problematic on three counts. First, in terms of current thinking on climate change, and the value of embodied energy, the re-use rather than demolition of existing buildings is considered to be a more sustainable approach to the environment. In the case of locally listed buildings, this could also lead to their loss without detailed assessment of their architectural or historic interest and contribution to local character. Second, and in terms of urban design, rebuilding on the same footprint of a building of little character could perpetuate a poor layout and relationship to the street and adjacent buildings. Third, without a height limit, this PD right could lead to new buildings totally out of scale with their surroundings.
Changes of Use
Whilst we recognise that there is some value in allowing flexibility in changes of use between commercial uses to improve the viability of town centres, the same cannot be said for uncontrolled change of use to residential in high streets. Such changes of use at ground floor level can lead to ‘dead’ frontages in shopping parades. The introduction of residential uses in areas of otherwise commercial and bustling character may lead to complaints from new residents and closing down of those commercial uses which provide activity and vibrancy in a town centre. This potentially could run contrary to recent Government initiatives to revive our high streets.
We would ask you to bring these issues to the attention relevant Ministers and consider changing or abandoning these potentially damaging proposals….
Form more on the background see the NewsBlog