Heritage buildings: the need to take fear out of decarbonising

86% of members are keen to decarbonise their buildings according to the 2023 heritage survey from the CLA and Historic Houses, but an astonishing 87% think that the planning system is a barrier to that.

Part of the solution to this problem came in the December’s update of the National Planning Policy Framework (NPPF). This included, after much CLA lobbying, a new paragraph 164 which encourages the decarbonisation of heritage buildings. Members can quote this in applications and it should significantly increase the chances of getting consent.

In addition, following years of CLA lobbying, the UK Government promised to review consent barriers to decarbonising heritage buildings. Firstly in its 2021 Planning White Paper, and again in its April 2022 Energy Security Strategy. A cross-departmental project included roundtable consultations at which many people, including CLA members and staff, set out consent barriers to decarbonising heritage and other existing buildings, and what could be done to overcome these.

The reason consents are such a barrier to decarbonising appear to be:

• Great uncertainty as to whether planning and/or listed building consent (LBC) is needed in individual cases.
• The fear of draconian potential penalties: failure to get LBC if it was required is a criminal offence, which can lead to prosecution; and failure to get LBC or planning permission if required can lead to enforcement costing thousands of pounds. Those who go ahead without consent live with a fear that that the local authority may later threaten or take enforcement action, or that allegedly ‘illegal work’ could be reported by a neighbour with a grudge, or that a purchaser will allege that ‘illegal work’ justifies a price reduction.
• The costs, delays, and risks if you do decide to make consent application(s), and the reputation of the consent system. In the CLA/Historic Houses survey, 48% of owners thought the system was ‘poor’ or ‘very poor’ (while a 2022 Historic England survey found this to be a very similar 44%).

It is hardly surprising that many CLA members – perhaps most – abandon their proposals, usually before the stage of making an application.

The government has now published its report - Adapting historic homes for energy efficiency: a review of the barriers.

This, firstly, reconfirms the need to decarbonise historic buildings. Members can quote it (with NPPF paragraph 164 as above) in support of applications.

Secondly, the report’s long list of 55 actions contains several on the consent system. This includes consultations on introducing national listed building consent orders (LBCOs) and further permitted development, long advocated by the CLA and stakeholders at the roundtables.

Thirdly, the many other actions include longstanding CLA objectives such as fundamental reform of Energy Performance Certificates (EPCs).

Overall, this report is welcome, but as yet not focused. It has few timescales or deadlines, effectively saying ‘55 things the state could do’, not ‘three things which would get the market to address this problem effectively and quickly’. For example, it rightly says that owners not knowing what to do is a real barrier and calls for more guidance from Historic England and government, but it steers clear of suggesting that some interventions are better than others.

CLA guidance notes in contrast explain this, including ‘Reducing heating costs and decarbonising heritage buildings’ which lists things you can do in an approximate order with the most effective and least risky first, and less effective and more risky at the end.

The ‘Adapting historic homes’ report is a foundation on which successful policy could be built. The government could, by focusing on the most effective actions, help owners to deliver results quite rapidly.

The CLA has been encouraging government to identify and publish clear ‘low-hanging fruit’ measures like draughtproofing, loft insulation, and secondary glazing which are practical, cost-effective, and unlikely to harm heritage so that owners know what is most likely to work.

Crucially, it is essential to make careful use of LBCOs and permitted development to grant consent for these works so that owners can be sure that they will not face prosecution or enforcement, provided they stick to the LBCO and permitted development conditions.

Taking the fear out of decarbonisation is a vital first step if we are to see owners actually deciding to decarbonise their buildings, contractors recruiting and training staff, and a virtuous circle of effective and safe decarbonisation activity.

Explore our catalogue of helpful guidance notes on heritage here.