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The IHBC has submitted its response to the consultation by Historic England (HE) on its draft \u2018Advice Note on Climate Change and Historic Building Adaptations\u2019 (HEAN), with IHBC Policy Chair Roy Lewis highlighting the main concerns.<\/h3>\n<\/p>\n
IHBC Policy Chair Roy Lewis said: \u2018The IHBC has made a detailed response to the draft HEAN.\u00a0 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.\u2019<\/p>\n
\u2018The draft HEAN is simplistic and makes superficial generalised statements regarding the acceptability of specific adaptations.\u00a0 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 \u2013 issues that Historic England has always previously left to each local planning authority.\u00a0 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 \u2018generally acceptable\u2019, notwithstanding the need to balance any harm to heritage significance against public benefit set out in the NPPF.\u2019<\/p>\n
\u2018It 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to the highly relevant key standards of PAS 2035 and PAS 2030, both updated in 2023, preferring instead to refer to the out-of-date Conservation Principles published in 2008.\u2019<\/p>\n
\u2018It also introduces enigmatic new terminology such as \u2018buildings of monumental character\u2019 and uses other terms such as \u2018modern windows\u2019 and \u2018slim-profile double-glazing\u2019 without definitions of what they mean.\u2019<\/p>\n
\u2018In 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.\u2019<\/p>\n
The IHBC writes:<\/p>\n
Responding to the consultation IHBC notes that \u2018the advice given is superficial, insufficient and in many cases, incorrect. It also fails to highlight potential risks and disadvantages of specific adaptations\u2026\u2026\u2026\u00a0 The HEAN has missed a good opportunity to inform its audience about a great many \u2018improvements\u2019 that occupants can make which are benign and don\u2019t need consent\u2026. The HEAN gives examples where destructive change will be accepted without first raising the proviso of repair, maintenance or benign improvement.\u00a0 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.\u2019<\/p>\n
IHBC identifies a number of factual errors in the discussion of the need for Listed Building Consent and suggests \u2018that 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\u2019s character as a building of special architectural or historic interest (s7, P(LB&CA) Act, 1990)\u2026\u2026..\u00a0 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 \u2018minimal environmental impact\u2019 can \u2018maintain the quality of the existing built environment\u2019. The relevant issue is harm is to \u2018significance\u2019, not \u2018quality\u2019. There is no reference to \u2018quality\u2019 in the NPPF. Historic England should not publish guidance that is out of kilter with NPPF policy and terminology.\u2019<\/p>\n
Since the closure of the consultation on 24th December, the Government has published online \u2018Adapting historic homes for energy efficiency: a review of the barriers\u2019 which sees the HEAN as a key tool in overcoming such perceived barriers.\u00a0 The review states that \u2018Providing 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.\u2019\u00a0 IHBC is concerned that the draft HEAN as published cannot fulfil these aims.<\/p>\n
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