From 1 September 2017, any application for listed building or conservation area consent in Wales has to be accompanied by a heritage impact statement. This is just one of many recent changes to the heritage regime arising from the Historic Environment (Wales) Act 2016 (“The Act”).
The Act and its secondary legislation, and the suite of accompanying policy changes and guidance documents focus on the positive management of change in the historic environment. They recognise that through development, historic assets can be conserved and enhanced to increase their long-term sustainability and economic viability. The Act and its related requirements provide a clear and focused framework for historic assets in Wales.
The details of what must be included in a heritage impact statement are set out in The Planning (Listed Buildings and Conservation Areas) (Wales) (Amendment No. 2) Regulations 2017, which come into force today. There are slightly different requirements for listed building consent and conservation area consent applications and therefore reference to the regulations in advance of the preparation and submission of any assessment is important.
Cadw has also published best-practice guidance for preparing a heritage impact statement - “Heritage Impact Assessment in Wales” is explicit in its expectation that a heritage impact assessment will need to be carried out for proposals that require listed building consent or conservation area consent. The heritage impact statement summarises the heritage impact assessment process. The guidance notes that a heritage impact statement may also be required to accompany an application for scheduled monument consent and that the heritage impact assessment process is helpful for proposals affecting other historic assets too, such as registered historic parks and gardens, World Heritage Sites and historic assets of special local interest.
The guidance sets out five basic stages of a heritage impact assessment; these are summarised in the chart below.
Heritage impact assessment
Cadw’s published guidance makes clear that an understanding of an historic asset and its significance is the foundation for sound decision making. Once the significance of the heritage asset is understood, the potential impact of any proposed change can then be assessed. Proposals should evolve and adapt to ensure that any change sustains or enhances the significance of the historic asset.
Heritage impact statements
The heritage impact statement sets out the results of the heritage impact assessment and should be structured around the five main elements set out above. The heritage impact statement should also include detail of any measures required to offset unavoidable harm, and should also include an access statement, if the works proposed affect the access arrangements to, or within, any part of a listed building that is not used as a private dwelling.
The heritage impact statement replaces the design and access statement (DAS) in the application process for listed building consent, although a DAS will still have to be submitted as part of a planning application, where one is required. A heritage impact assessment is not required when applying for planning permission, for example when applying for development within the setting of a historic asset, although it is considered good practice to adopt the principles of the heritage impact assessment process in such circumstances.
A heritage impact statement should be proportionate both to the significance of the historic asset and to the degree of change proposed. In cases where a detailed assessment is required, the guidance advises that a qualified and competent expert should be engaged to conduct the heritage impact assessment, and to write the heritage impact statement.
As the Cadw guidance recognises:
positive, well-designed change can bring improvements to our understanding and appreciation of the historic environment, as well as social and economic benefits through increased regeneration and tourism.
It is our view that the heritage impact assessment process should be undertaken in this context. Moreover, at Lichfields, our experience of undertaking a range of projects that affect historic assets indicates clearly that the heritage impact assessment process must begin at the earliest stage, to ensure that the impact of any development can meet this objective while respecting the core principles of preservation and enhancement that are enshrined in legislation.
The Deptford Project has been announced as winner of the ‘Best Heritage Project’ in London at the London Planning Awards!
What a fabulous finale for Lichfields, for a project that has transformed a run-down part of Deptford, providing housing, commercial units and a new market, and bringing life back to a listed railway structure that was on Historic England’s buildings at risk register.
Working on behalf of U+I Group plc (formerly Cathedral Group), Lichfields has provided planning inputs into the Deptford Project from the start, securing the original planning permission, and conservation area and listed building consents, discharging conditions and then obtaining permissions and consents for the numerous subsequent details and changes needed to meet the evolving requirements of the development.
The Deptford Project comprises a number of very different elements of development that work together to create a successful regeneration area in the heart of Deptford.
Whilst the Rogers Stirk Harbour + Partners-designed 121-unit apartment building (now known as Tinderbox House) is an obvious key feature of the project, providing a modern and vibrant residential development with a roof-top garden, it is the Grade II Listed Carriage Ramp running proudly alongside the apartment building that makes this development unique.
The Carriage Ramp was built in 1832 for providing rolling stock and private carriage access to the Deptford Station and Railway Viaduct, which is itself the longest listed structure in the UK. It is hard to imagine that the Ramp was constructed in an open field, although in the subsequent 20-25 years it was enveloped by the expansion of London, with new terraced housing backing directly onto it.
The open arches, which reduce in height beneath and along the length of the Ramp, were originally used for storage in association with railway works, although they were later used by private companies for heavy goods storage. Over the years, a lack of investment in the up-keep of the Ramp and the removal of most of its east-west section saw it fall into disrepair. The Carriage Ramp was always important though, as the last remaining of three such ramps in London.
It was The Deptford Project that saved the structure, providing the investment and careful renovation needed to bring the Ramp back to life. This was not without its challenges but the end product, resulting in this award, speaks for itself. The Ramp and its new east-west section provide access to Deptford Rail Station whilst businesses occupy the arches once again.
In front of the Carriage Ramp is the new Deptford Market Yard, providing public realm and a new market area with new connectivity through the site and beneath the Carriage Ramp, and with improved legibility provided by the implementation of a comprehensive wayfinding strategy.
The development also includes St Paul’s House, which fronts Deptford High Street and provides 8 apartments, 3 town houses and 2 restaurants.
I may be biased but I do think that the Deptford Project is very deserving of its title of ‘Best Heritage Project in London’, given at the London Planning Awards. I will miss working on such an exciting development; however it is now time to let the development do the talking as it becomes a fully integrated part of Deptford.
Indeed it is already bringing benefits to the area by acting as a catalyst for further regeneration and investment. Whatever happens, the Grade II Listed Carriage Ramp will be around to see it.
Image credit: Deptford Market Yard