If your planning application affects a listed building, a conservation area, a scheduled monument, or any other designated heritage asset, you will almost certainly need to submit a heritage statement. Getting this document right — in terms of how significance is assessed and how harm is characterised — is one of the most important factors in securing consent for heritage applications.
This guide explains what a heritage statement is, when one is required, what it must include, and how the NPPF test for harm works in practice.
A heritage statement (sometimes called a heritage impact assessment or conservation statement) is a planning document that:
It is an assessment document, not an advocacy document. A well-written heritage statement should acknowledge harm where the works cause it and address the public benefits test honestly — rather than trying to argue that there is no harm where harm clearly exists. Planning officers and Historic England will scrutinise heritage statements carefully, and a statement that understates harm is more likely to generate objections than one that addresses it directly.
Key policy: Paragraph 195 of the NPPF 2023 requires local planning authorities to identify and assess the significance of any heritage asset that may be affected by a proposal, using available evidence and, where necessary, the applicant's own heritage statement.
A heritage statement is required for the following types of application:
| Application type | Heritage statement required? |
|---|---|
| Listed building consent | Always |
| Planning application for works to a listed building or within its curtilage | Always |
| Planning application within a conservation area | Usually — where works affect the character or appearance of the area |
| Works affecting the setting of a listed building | Usually |
| Works affecting a scheduled monument | Always (also requires Scheduled Monument Consent) |
| Works affecting a Registered Historic Park or Garden | Usually |
| Works affecting a non-designated heritage asset | Depends on LPA validation requirements |
| Standard householder extension (no heritage designations) | Not required |
Always check the local planning authority's validation checklist before submitting. Many LPAs publish a heritage statement pro forma or a list of required sources — failing to follow this can result in an application being declared invalid.
The heart of any heritage statement is the significance assessment. Historic England's Conservation Principles, Policies and Guidance (2008) identifies four types of heritage value that together constitute the significance of an asset:
The potential of the asset to yield evidence about past human activity. This is primarily about the physical fabric of the building — its construction materials, structural form, and any surviving archaeological deposits beneath it. An unaltered Victorian terrace house has high evidential value; a building that has been heavily modernised internally has lower evidential value.
The ways in which past people, events, and aspects of life can be connected to the asset. This includes associations with notable individuals or events, and the role of the building in illustrating broader historical patterns — for example, as evidence of nineteenth-century speculative development or wartime requisitioning. Historic value is often intangible and does not depend on the physical fabric being unaltered.
The ways in which people draw sensory and intellectual stimulation from the asset. For buildings, aesthetic value is closely related to architectural quality — the design, proportions, materials, and craftsmanship of the structure. Group value (the contribution of a building to a coherent ensemble of buildings) is an important component of aesthetic value for terraced houses and formal set-pieces.
The meanings of an asset for the communities that have a relationship with it. This includes commemorative, symbolic, and social values — the role of the building in local identity, memory, and civic life. A village church, a market hall, or a memorial garden may have high communal value that does not necessarily correspond to high evidential or aesthetic value.
Tip: Not all four values will be equally relevant to every asset. Focus your assessment on the values that are genuinely significant, and be honest where significance is limited — it is not necessary to claim high significance across all four values for every heritage asset.
Once significance has been assessed, the heritage statement must evaluate the impact of the proposed works on that significance. NPPF 2023 Chapter 16 sets out a tiered system of harm tests that apply depending on the level and type of harm identified.
Paragraphs 200 and 201 of the NPPF address substantial harm. This is a high threshold — it applies where the works would fundamentally undermine or destroy the significance of the asset, not merely cause some impact on it. Where substantial harm to a Grade I or Grade II* listed building or World Heritage Site is identified, the NPPF states that consent should be refused unless there are exceptional circumstances. For Grade II listed buildings and other designated assets, substantial harm should be refused unless there are compelling public benefits that outweigh the harm.
Substantial harm is comparatively rare. Most proposals that affect listed buildings and conservation areas fall into the less than substantial harm category.
Paragraph 201 of the NPPF requires that less than substantial harm be weighed against the public benefits of the proposal. Public benefits can include economic benefits (jobs, housing delivery, investment), social benefits (improved community facilities, accessible housing), and heritage benefits (the removal of later accretions, improved maintenance, a sustainable new use for a redundant building).
Less than substantial harm covers a very wide spectrum — from negligible impact that barely warrants the label, to considerable harm that falls just short of the substantial threshold. Heritage statements should characterise the level of harm with precision and honesty, rather than simply stating "less than substantial harm" without further analysis of where on that spectrum the impact falls.
Common mistake: Claiming there is no harm where harm clearly exists. This is the most frequent error in heritage statements and the most likely reason for a planning officer to request further information or issue a refusal. If the works affect any fabric or setting that contributes to significance — even modestly — that impact should be assessed, not dismissed.
Paragraph 209 of the NPPF requires a balanced judgement to be made when assessing the impact of proposals on non-designated heritage assets, having regard to the scale of any harm and the significance of the asset. The bar for refusal is lower than for designated assets, but the same principle applies: harm must be acknowledged and weighed against benefits.
In addition to the NPPF policy tests, heritage applications engage a number of statutory duties that must be referenced in the heritage statement:
These are statutory duties, not merely policy tests — they carry greater legal weight than NPPF policies and must be addressed directly in the heritage statement.
A robust heritage statement should be informed by the following sources, where relevant:
For applications involving heritage assets, both documents are often required:
| Document | Purpose | Focus |
|---|---|---|
| Heritage statement | Assess significance and impact on heritage assets | Historic England values, NPPF Chapter 16, statutory duties |
| Planning supporting statement | Demonstrate overall policy compliance | NPPF, local plan, design, amenity, highways |
| Design and Access Statement | Explain design process and access arrangements | Design principles, context, access for all users |
For major applications involving listed buildings, all three documents may be required simultaneously.
Planabl drafts a policy-referenced Heritage Statement assessing significance across Historic England's four values and applying the NPPF Chapter 16 harm tests to your specific proposal.
Try Planabl free →It depends on the nature and scale of the works and the LPA's validation requirements. For a modest rear extension that is not visible from the public realm, some LPAs will not require a formal heritage statement. For works that affect the principal elevation, roof form, or any features that contribute to the character of the conservation area, a heritage statement is strongly advisable and is often required. Always check the local validation checklist.
For complex applications involving Grade I or II* listed buildings, scheduled monuments, or contentious conservation area proposals, a heritage statement should be prepared by a qualified heritage professional — typically an architect with conservation accreditation (RIBA Conservation Architect), a member of the Chartered Institute for Archaeologists (CIfA), or an RTPI-accredited planning consultant specialising in heritage. For more straightforward Grade II listed building applications, a well-researched statement prepared by the applicant or their architect may be acceptable, provided it engages properly with significance and the NPPF tests. Planabl generates a well-structured first draft that can then be reviewed and refined.
The listed building consent application form is the statutory form used to make the application. The heritage statement is a supporting document submitted with the application that provides the substantive assessment of significance and impact. The form cannot substitute for the heritage statement — they serve different purposes.
Historic England is a statutory consultee for applications affecting Grade I and II* listed buildings, scheduled monuments, registered parks and gardens, and World Heritage Sites. For Grade II listed buildings, the LPA's own conservation officer is typically the primary consultee. Historic England does not have a veto over planning decisions, but its objections carry significant weight and a refusal that goes against Historic England's advice is unusual.
Fill in your asset type, significance, and proposed works — Planabl generates a structured, policy-referenced first draft in under a minute.
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