The IHBC has submitted its response to the consultation by Historic England (HE) on its draft ‘Advice Note on Climate Change and Historic Building Adaptations’ (HEAN), with IHBC Policy Chair Roy Lewis highlighting the main concerns.
… the Institute is very concerned at the numerous shortcomings in the draft HEAN…
IHBC Policy Chair Roy Lewis said: ‘The IHBC has made a detailed response to the draft HEAN. Whilst IHBC is keen to support well-considered adaptations to historic buildings to make them more sustainable, the Institute is very concerned at the numerous shortcomings in the draft HEAN, which would undermine other more detailed technical research and guidance on such adaptations by Historic England and other organisations and would be likely to result in ill-considered outcomes.’
‘The draft HEAN is simplistic and makes superficial generalised statements regarding the acceptability of specific adaptations. Furthermore, it attempts to dictate consideration of the need for listed building consent and the striking of the balance between harm to heritage significance and public benefit – issues that Historic England has always previously left to each local planning authority. The IHBC is particularly concerned that the draft document makes statements about the need for listed building consent which are inaccurate and that certain adaptations are ‘generally acceptable’, notwithstanding the need to balance any harm to heritage significance against public benefit set out in the NPPF.’
‘It is a major concern that the draft HEAN fails to highlight potential risks associated with certain adaptations and, astonishingly fails to make any cross-reference to the highly relevant key standards of PAS 2035 and PAS 2030, both updated in 2023, preferring instead to refer to the out-of-date Conservation Principles published in 2008.’
‘It also introduces enigmatic new terminology such as ‘buildings of monumental character’ and uses other terms such as ‘modern windows’ and ‘slim-profile double-glazing’ without definitions of what they mean.’
‘In view of the inaccuracies, omissions and inconsistency with the NPPF, the draft HEAN requires a major re-write if it is to be fit for purpose.’
The IHBC writes:
Responding to the consultation IHBC notes that ‘the advice given is superficial, insufficient and in many cases, incorrect. It also fails to highlight potential risks and disadvantages of specific adaptations……… The HEAN has missed a good opportunity to inform its audience about a great many ‘improvements’ that occupants can make which are benign and don’t need consent…. The HEAN gives examples where destructive change will be accepted without first raising the proviso of repair, maintenance or benign improvement. It would be better to update the existing documents relating to specific adaptations which provide more detailed and definitive advice, including risks, than provide a superficial overview document that undermines the more detailed documents.’
IHBC identifies a number of factual errors in the discussion of the need for Listed Building Consent and suggests ‘that all the references to the need for LBC relating to specific adaptations should be replaced with a single statement that the LPA should make its judgement on the need for LBC on the basis of whether the works constitute an alteration that would affect the building’s character as a building of special architectural or historic interest (s7, P(LB&CA) Act, 1990)…….. The guidance on specific works makes absolute statements on acceptability and departs from the essential process to determine significance, identify any harm to significance that would result from any retrofit proposal and to weigh the degree of harm against the potential sustainability public benefit that would flow from the proposal. This needs to be done on a case-by-case basis. It is not possible to generalise in the way the draft HEAN does. It is worrying that paragraph 5 states a different process to the NPPF approach whereby it is envisaged that ‘minimal environmental impact’ can ‘maintain the quality of the existing built environment’. The relevant issue is harm is to ‘significance’, not ‘quality’. There is no reference to ‘quality’ in the NPPF. Historic England should not publish guidance that is out of kilter with NPPF policy and terminology.’
Since the closure of the consultation on 24th December, the Government has published online ‘Adapting historic homes for energy efficiency: a review of the barriers’ which sees the HEAN as a key tool in overcoming such perceived barriers. The review states that ‘Providing greater clarity at the outset to those living in historic homes on their options and the associated planning requirements, and improved advice to decision-makers on taking balanced decisions, will facilitate consistent and faster decision-making.’ IHBC is concerned that the draft HEAN as published cannot fulfil these aims.
The IHBC’s Consultations Panel
The IHBC constantly monitors Government Departments and other national and regional organisations for relevant proposed changes to legislation, policy and guidance. The Consultations Panel formulates responses to these documents on behalf of the IHBC.
The IHBC may not necessarily comment on all these consultations, but we are glad to hear opinions on them from both members and non-members.