What a conservation officer checks in a heritage statement

A conservation officer reads a heritage statement looking for four things in order: which heritage assets are affected, where the significance of each lies, what the proposal does to that significance, and how the statutory duties and policy tests have been applied to the answer. A statement that describes the building at length and then asserts no harm fails on the third and fourth of those. The drafting problem is almost always the same: significance described in general terms, then a conclusion that does not follow from it.

Write the statement so that each element of significance is tracked through to an effect. That is the discipline the officer is testing.

Identifying the heritage assets affected

The first page should list every asset, designated and not. Listed buildings on and adjoining the site with their grade and list entry number. Structures within the curtilage of a listed building, which can be protected even though they are not separately listed. The conservation area, by name, with the part of it the site sits in. Scheduled monuments, registered parks and gardens, and any locally listed or non-designated asset identified in the local plan or the historic environment record.

Officers routinely find omissions here. The most common is the building next door, where the works affect its setting rather than the application site itself, and the second most common is a curtilage structure such as a wall, gate pier or outbuilding.

A statement that gets the grade wrong, or quotes a list entry as though it defines the whole of the building's interest, starts badly. The list description identifies the building; it does not limit the significance of it.

Describing significance and its components

Significance is described by interest, and the recognised components are archaeological, architectural, artistic and historic interest, which Historic England's guidance expands into evidential, historical, aesthetic and communal value. The useful form is element by element rather than building by building.

For a Georgian townhouse that means: the street elevation and its proportions, the plan form and stair, original joinery and plaster, the rear elevation with its later additions, the roof structure, the rear yard and wall, and the contribution the building makes to the terrace. Each with a statement of how much it matters, and why.

Do it on a drawing as well as in words. A colour-coded plan showing high, medium, low and negative significance by element is the single most useful thing you can give a conservation officer, because every later judgement can be read against it. Negative significance matters too: identifying the 1970s rear extension as harmful to the asset is what justifies removing it.

Assessing the effect of the proposal

This is the section that fails most often. The test is what the proposal does to the significance you have just described, element by element, and the assessment has to be specific about fabric.

• which historic fabric is removed, and how much of it
• which spaces are altered, and whether the plan form remains legible
• what is concealed, and whether the change is reversible
• what is added, and how it relates to the asset
• what happens to the setting, including views into and out of the site
• what the cumulative effect of earlier changes plus this one amounts to

Then state the conclusion in the language the policy uses. Either the proposal preserves significance, or it causes harm, and if it causes harm you say whether that harm is less than substantial or substantial. Not stating a level of harm is the commonest single weakness in submitted statements, because it leaves the officer to do the applicant's work and they will do it less generously.

Applying the statutory duties, not just the policy

Officers check for the statutory duties by name, and their absence is noticed.

These duties sit above the policy balance and the courts have held that considerable importance and weight attaches to them. National policy then requires great weight to be given to the conservation of a designated heritage asset, with the weight increasing with the importance of the asset, and sets out the balance where harm arises. Cite the Framework by its edition, because it has been re-issued twice in recent years and the numbering has changed.

Public benefits and the balance

Where harm is identified, the case turns on public benefits. Officers test these hard, and the recurring error is offering private benefit as public.

Benefits that count: securing the optimum viable use of a building at risk, repairs to historic fabric, removal of harmful later additions, reinstatement of lost features, public access or interpretation, delivery of housing where the development plan needs it, environmental improvement to the wider area.

Benefits that do not: the applicant's return, the convenience of the occupier, a larger kitchen, or the fact that the works are needed to make the building comfortable. Those may be relevant to viability. They are not public benefits.

The balance has to be written out, not implied. Name the harm, name the benefits, and explain why one outweighs the other in this case.

Evidence and illustration expected

A statement with no illustrations is hard to accept. What officers expect: historic maps in sequence showing the development of the site, archive material where it exists, annotated photographs of the fabric affected keyed to a plan, existing and proposed drawings at matching scales, and photographs of the setting from the viewpoints that matter.

Where fabric is being removed, a record may be required. Historic Building Recording to the appropriate level is often secured by condition, and councils expect a suitably qualified author. Where below-ground archaeology is in play, an Archaeological Desk-Based Assessment is the separate document, and the county archaeologist reads that one.

Where drafted text most often falls short

A drafted Heritage Statement gets the structure right, pulls in the statutory framework and produces a coherent significance section. Four things it cannot do without you.

1. Observe the fabric. Nobody has been inside the building. Skirtings, sash horns, lath and plaster, a blocked opening, a cut-away beam: these are the details that make an assessment convincing, and they come from a site visit.
2. Reach the harm conclusion on this proposal. The level of harm is a judgement about specific fabric and specific loss.
3. Supply the archive. Historic maps and records have to be obtained and read.
4. Avoid plausible but unverified history. A date, an architect's name or a building phase asserted without a source is the error that destroys the document's credibility, and PlanScope flags missing facts rather than filling them, which is a safeguard to use rather than paper over.

Search for unresolved flags before you export, and read our note on factual errors to look for in a drafted document. For applications where the heritage argument is finely balanced, send the draft for review through the professional directory before submission.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.