Heritage & listed buildings
Works to a listed building are subject to a significantly higher level of scrutiny than ordinary planning applications. The statutory presumption in favour of preserving listed buildings means your supporting statement must do more than simply argue that the works are acceptable — it must demonstrate a thorough understanding of the building's significance and show that any harm to that significance is justified and minimised. This guide explains what is required.
Most works to a listed building require two separate consents:
A planning supporting statement is typically submitted in support of the planning application. A Heritage Statement — sometimes called a Design and Access Statement or a Statement of Significance — is submitted in support of the LBC application. In practice, many applicants combine these into a single document submitted with both applications.
Note: Carrying out works to a listed building without consent is a criminal offence under Section 9 of the Planning (Listed Buildings and Conservation Areas) Act 1990. There is no time limit on prosecution.
The primary legislation is the Planning (Listed Buildings and Conservation Areas) Act 1990. Section 16(2) requires the LPA to have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses when determining an LBC application.
National policy is set out in Chapter 16 of the NPPF 2023. The key paragraphs your statement must engage with are:
Para 185 — When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset's conservation (and the more important the asset, the greater the weight should be).
Para 189 — In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting.
Para 196 — Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.
Para 200 — Local planning authorities should not permit the loss of the whole or part of a heritage asset's significance unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits.
Before you can argue that your proposals preserve significance, you must first establish what that significance is. Historic England's guidance document Conservation Principles (2008) identifies four types of heritage value:
Your statement should identify the principal sources of significance for the building — what makes it special — and then assess the impact of the proposed works on each relevant type of value.
Describe the building's listing grade (Grade I, II* or II), the date of listing, and the key features identified in the list description. Supplement this with your own assessment of what makes the building architecturally and historically significant — original fabric, plan form, materials, craftsmanship, historical associations, and setting.
Set out clearly what is proposed, which parts of the building are affected, and what existing fabric will be removed, altered, or obscured. Be precise — vague descriptions of "internal alterations" are insufficient.
This is the core of the statement. For each element of the works, assess whether it causes harm to significance — and if so, whether that harm is less than substantial or substantial. Harm should be characterised by reference to the NPPF paragraphs above.
Where harm is identified, the statement must explain why it is justified — either because it is necessary to secure a viable use for the building, or because the public benefits of the proposal outweigh the harm.
Explain why the works are necessary — the functional need that drives the proposal. Then explain what steps have been taken to minimise harm: have alternative approaches been considered? Have reversible methods been used in preference to permanent ones? Have original materials been retained and reused where possible?
Planabl generates a policy-referenced first draft for listed building applications in under 60 seconds, including the relevant NPPF heritage paragraphs. First draft free — no account needed.
Try Planabl free →