Heritage consultant competence and the significance test

Nothing in planning law says who may write a statement of heritage significance. The National Planning Policy Framework asks the applicant to describe the significance of any heritage assets affected, at a level of detail proportionate to the asset's importance and no more than is sufficient to understand the potential impact, and leaves authorship to the applicant. Historic England Advice Note 12 then sets out what such a statement should contain, and reading it alongside a weak statement is the quickest way to see where competence was missing.

So the competence question is answered by the document, not by a letter after a name. A chartered planner with twenty years of listed building work may produce a better assessment than an accredited architect who has never written one. The reverse is also true.

What Advice Note 12 expects of an author

The advice note asks for significance to be analysed rather than asserted. In practice that means identifying what the asset is, how it came to be that way, which parts of it carry which values, and which attributes are vulnerable to the proposal. Historic England's conservation principles supply the vocabulary for the values themselves: evidential, historical, aesthetic and communal.

An author who can do that needs four skills. Documentary research, to establish development phases from maps, deeds, archives and the listing description. Fabric analysis, to read the building itself and date what the documents do not cover. Comparative judgement, to place the asset against others of its type. And the ability to write a conclusion that survives cross-examination.

Few individuals hold all four at the level a Grade I case needs. A statement produced by a researcher working with a building archaeologist is often stronger than one written by a generalist alone, and it is reasonable to ask who did which part.

Conservation accreditation routes

The recognised routes signal different things. The Institute of Historic Building Conservation offers full membership for conservation practitioners across disciplines, including local authority conservation officers. The Royal Institute of British Architects maintains a conservation register with graded levels of accreditation. The Royal Institution of Chartered Surveyors operates a building conservation accreditation for surveyors. Separately, the register of architects accredited in building conservation covers architects working on historic fabric.

Those are competence signals for work on buildings. They are not, by themselves, evidence of competence in writing significance assessments, which is a research and analysis task rather than a design or repair task. An accredited architect is the right person to detail a repair and may not be the right person to establish the building's phasing.

For archaeology the position is clearer, because the Chartered Institute for Archaeologists publishes standards and guidance and maintains registered organisations, and councils routinely require work to be carried out to those standards. There is no equivalent single standard for heritage statements on buildings.

Where art historical and building archaeology skills differ

Architectural history works outward from style, type, documentary record and attribution. Building archaeology works inward from the fabric: mortar joints, reused timbers, blocked openings, tool marks, the sequence of what was built against what.

The two methods reach different kinds of conclusion. An art historical assessment will tell you the building is a competent example of a regional vernacular type of around 1760. A building archaeology assessment will tell you the north range is earlier than the listing suggests, that the roof structure has been raised once, and that the apparently original staircase is a nineteenth century insertion.

That second kind of finding changes schemes. It is also the kind most often absent from a statement, because it requires access, scaffolding or at least a ladder, and a careful look at parts of the building nobody has examined for decades. Where significant fabric will be removed, Historic Building Recording to the appropriate Historic England level is the related discipline, and the person who can do the recording can usually do the analysis.

Assessing significance against justifying harm

These are two separate exercises and they belong in that order. First establish what the asset's significance consists of. Then assess what the proposal does to it. Then, if there is harm, make the case under the policy tests.

The statutory duties frame the whole exercise. Section 16 of the Planning (Listed Buildings and Conservation Areas) Act 1990 applies to listed building consent, section 66 to planning applications affecting a listed building or its setting, and section 72 to conservation areas. The courts have held that those duties require considerable importance and weight to be given to any harm, a point confirmed by the Court of Appeal in the Barnwell Manor case in 2014, so a statement that concludes harm is minor without identifying what it falls on has not done its job.

Who should write a listed building consent application

A listed building consent application needs three things: an assessment of significance, a design and justification for the works, and enough drawn and specified detail to understand the intervention. One person can rarely supply all three.

The pattern that works on most domestic and small commercial cases is a conservation-experienced architect or surveyor producing the design and the specification, with a heritage specialist producing the Heritage Statement and the significance analysis. On larger cases add a building archaeologist for fabric analysis and, where below-ground deposits are involved, an archaeologist to the institute's standards.

On a straightforward case the same person often does everything, and that is fine where the works are modest and reversible. The judgement to make is whether the works touch anything the statement would need to analyse carefully.

Evidence an inspector expects at appeal

Inspectors read heritage statements closely because the statutory duty forces them to. What they look for is traceable reasoning: a described asset, identified attributes of significance, a stated effect on named attributes, a characterised level of harm, and public benefits evidenced rather than asserted.

What tends to fail is the statement whose significance section is short and whose justification section is long. If the assessment never establishes that the rear wing is of limited interest, the conclusion that removing it causes less than substantial harm has nothing underneath it.

Bring the author to the appeal, or have them write the heritage evidence. A planning witness presenting someone else's heritage conclusions cannot defend the analysis under questioning.

Checking a heritage statement for circular reasoning

Four tests catch most of it. Does the significance section describe anything the proposal does not affect? A statement that only discusses the parts being altered has been written backwards. Does the harm conclusion name the attributes it relies on? Does the public benefit section identify benefits to the public rather than to the applicant? And is recording offered as mitigation for the loss of fabric, which Historic England guidance treats as a means of capturing information rather than as a reduction in harm?

Reading a statement for those four things takes twenty minutes and tells you more about the author than their CV will. The wider question of how to read competence from a CV is covered in reading a consultant CV for real competence, and the register checks are set out in checking a professional institute register.

PlanScope drafts heritage statements structured to the policy framework, with the significance analysis flagged for completion from site evidence rather than invented. The analysis itself needs an author who has looked at the building, and councils usually expect that author to be named. Reviewers who sign off drafts are listed in the professional directory. Reports should be reviewed before submission and PlanScope does not guarantee planning approval. Verify the current National Planning Policy Framework edition and its historic environment policies on gov.uk, because the Framework was reissued on 17 August 2026 with policy-coded chapters in place of paragraph numbers.