Grade I and II applications and national consultation

Historic England consultation on a listed building application is not discretionary. Where the works affect a Grade I or Grade II* building, the local planning authority has to refer the application to Historic England before it determines it, under the Secretary of State's direction on the handling of heritage applications. Grade II buildings come into it where demolition of the whole or a substantial part is proposed.

For a consultant, the practical consequences are three. The determination period is longer than the statutory eight weeks in almost every case. A second professional audience reads the submission, with different priorities from the conservation officer. And if the authority wants to approve something Historic England has objected to on a high grade asset, it cannot simply do so.

Which applications must be notified nationally

Work through the categories rather than relying on grade alone:

• Listed building consent for any works to a Grade I or Grade II* building.
• Listed building consent for a Grade II building where demolition of the building or a substantial part is proposed.
• Applications involving demolition, which additionally trigger notification to the national amenity societies.
• Planning applications affecting a World Heritage Site, a scheduled monument, or a registered park, garden or battlefield of the higher grades. The interaction with World Heritage Site buffer zones is worth checking separately, because the buffer is a policy construct rather than a designation.
• Applications made by the local planning authority itself in relation to its own listed buildings, which have their own procedure.

Check the National Heritage List for England for the grade and read the list entry in full. Two things come out of it: what was recorded as of interest at designation, and whether the listing includes structures within the curtilage, which decides whether a boundary wall or outbuilding is caught.

The grades and the works that trigger a response

Grade is a proxy for significance, not a description of what matters within a building. A Grade II* church may have an interior of the first importance and a much altered exterior. A Grade I country house may have a service wing rebuilt in 1960 where intervention is straightforward.

That distinction is what a good submission exploits. Historic England responds to what the works do to the significance of the asset, so an application that identifies the high significance elements and keeps away from them attracts a different response from one that proposes uniform treatment across the building.

The works that reliably generate a substantive response are loss of historic fabric, changes to plan form and circulation, removal of original joinery or plasterwork, new openings in principal elevations, alterations to roof structures, insertion of lifts and services through historic floors, and anything affecting a principal room or staircase.

What the national adviser comments on

Expect the response to address significance first, then harm, then justification, and to test each against the statutory duty in section 16 of the Planning (Listed Buildings and Conservation Areas) Act 1990 and current national policy. National policy in the Framework published 17 August 2026 continues to treat substantial harm to, or loss of, a Grade I or II* building as acceptable only in wholly exceptional circumstances.

In practice the comments group into a handful of themes:

1. Whether the assessment of significance is adequate and evidence based.
2. Whether the harm has been correctly characterised, and whether the applicant's label of less than substantial harm is right.
3. Whether the public benefits said to outweigh the harm are real, deliverable and public.
4. Whether alternatives that would cause less harm were tested.
5. Whether the level of information is sufficient to understand the effects, which is the most common reason for a holding objection.
6. Whether recording, mitigation and conditions are appropriate where harm is accepted.

Point five is the one applicants control. A response that asks for an opening-up survey, a condition survey or a structural appraisal is a delay caused by the submission rather than by the consultee.

Timescales and how they affect determination

The standard consultation period is 21 days. On a complex case the adviser will often ask for more time, and refusing that request buys nothing, because a rushed objection is harder to unwind than a considered response.

Then there is the notification stage. Where the authority proposes to grant consent contrary to Historic England's advice on a Grade I or II* building, it has to notify the Secretary of State and hold off issuing the decision while the referral is considered. The Secretary of State may do nothing, in which case the authority proceeds, or may direct that the application be referred for decision, which moves it to a different process entirely.

The realistic programme for a significant scheme is therefore three to six months from validation, secured by an agreed extension of time. Build that into the client's expectations at the outset, because a client who has been told eight weeks will spend the difference complaining rather than resolving the issues.

Local authority obligations after a response

The authority must take the advice into account and give reasons for its decision. Where it disagrees, it has to explain why, and that explanation appears in the officer report. A well argued applicant response to a consultee objection gives the officer the material to write that paragraph, which is a more useful piece of work than a general restatement of the scheme's merits.

Where the response is a holding objection pending further information, supply the information as an addendum rather than as a revised application. Where it is an objection in principle, the options are amendment, a negotiated position, or a decision to proceed and accept the referral risk.

Objections and the referral route

Two escalation routes exist and they are often confused. For listed building consent, the 1990 Act allows the Secretary of State to direct that an application be referred for determination. For planning permission, the call-in power under section 77 of the Town and Country Planning Act 1990 does the same job.

A referral is not a judgement on the merits. It reflects the national interest in the asset, and the case is then determined by the Secretary of State, usually after an inquiry or hearing. That is a serious commitment of time and cost, which is why a negotiated scheme is almost always the better outcome on a high grade asset.

Preparing a submission that survives notification

The pack for a Grade I or II* application is heavier than the one for a Grade II extension, and the extra weight is mostly evidence rather than argument.

1. A Heritage Statement that assesses significance element by element, following Historic England's published approach to assessing significance in heritage assets, with archival research, historic plans and a phasing analysis.
2. A condition survey and, where structure is part of the argument, a Structural Survey by an engineer with conservation experience.
3. A schedule of works item by item, cross referenced to drawings, so each intervention can be assessed on its own.
4. Drawings at a scale that shows the detail, with existing and proposed as matched pairs, and large scale details of each intervention.
5. Method statements and specifications for repairs, including mortar mixes and finishes.
6. An offer of Historic Building Recording at a level proportionate to the significance of what is lost, with the level stated.
7. A clear statement of the public benefits relied on, with evidence for each.
8. Where the building is at risk, the case for the works as part of securing its future, which connects to the powers behind repairs notices and urgent works.

Use pre-application engagement. Historic England offers a pre-application advice service, and a regional team that has seen the scheme in outline will tell you which elements will attract objection while the design can still change. That conversation is worth more than any amount of drafting after submission.

One honest uncertainty: how much weight an authority gives to a Historic England position varies, and a consultee objection is not the end of an application any more than its support guarantees consent. The decision remains the authority's, on the statutory duty and the policy balance.

PlanScope drafts the Heritage Statement and the supporting narrative from the listed building and conservation area data it detects for the site, and inserts a flag wherever archival or survey evidence has to be supplied. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required, and a Grade I or II* submission should be reviewed by a conservation professional before it is lodged.

This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.

Draft your Heritage Statement on PlanScope, then send it for professional review before the application goes in.