Who should write a heritage statement, and what IHBC means
There is no rule about who writes a heritage statement, only a consequence. How to match the author's accreditation to the harm the works could cause.
For a modest extension to a Grade II house, a heritage statement can reasonably be written by an architect or agent who has done comparable work and understands the statutory duty. For works affecting historic fabric, a Grade I or II* building, or anything involving structural repair, the council will expect a conservation-accredited author, and IHBC after someone's name is one of the signals it looks for. The Institute of Historic Building Conservation is the professional body for conservation practitioners, and full membership is assessed against defined conservation competences rather than awarded on application.
There is no legal requirement that a particular person writes the statement. There is a practical one: a statement that does not identify significance correctly produces a refusal or a request for more information, and that costs more than the fee saved.
What the statement has to demonstrate
National policy expects applicants to describe the significance of any heritage assets affected, including any contribution made by their setting, to a level of detail proportionate to the asset's importance. That is the statement's first job.
Its second is to assess the effect of the proposal on that significance, element by element. Not "the works are sympathetic" but what each intervention does to which aspect of interest.
Behind both sits the statutory duty. Sections 16 and 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 require special regard to the desirability of preserving a listed building, its setting and any features of special architectural or historic interest. Section 72 requires special attention to preserving or enhancing the character or appearance of a conservation area. Those duties carry considerable weight in the decision, and a Heritage Statement that never mentions them has missed the framework the officer is working within.
Conservation accreditation in architecture and surveying
Several accreditation routes exist, and they do different things.
| Route | Who holds it | What it signals |
|---|---|---|
| IHBC full membership | Conservation officers, consultants, practitioners from several backgrounds | Assessed competence across conservation philosophy, practice, law and management |
| RIBA conservation register | Architects, at graded levels | Assessed conservation experience in architectural practice |
| RICS building conservation accreditation | Chartered surveyors | Assessed conservation competence in surveying and building pathology |
| Conservation accreditation for engineers | Structural engineers | Competence for structural intervention in historic fabric |
| Archaeology institute accreditation | Archaeologists, at graded levels | Competence in archaeological assessment and fieldwork |
For a householder the practical reading is simple. The question is not which letters are best, it is whether the author's accreditation matches the kind of harm the works could cause. An accredited architect is the right choice for fabric intervention. A heritage consultant with IHBC membership is often the better choice for a statement about setting, significance and policy.
The historic environment institute and its membership
IHBC membership is assessed against areas of competence covering the philosophy of conservation, practical conservation work, legislation and policy, and the management of the historic environment. Members come from architecture, planning, surveying, archaeology and local authority conservation work, which is why the designation appears alongside other qualifications rather than instead of them.
Most local authority conservation officers hold it, which matters for a reason people underestimate: a statement written in the language the conservation officer was trained in gets a quicker and more useful response.
When an archaeologist is the right author
Where the proposal affects below-ground deposits, the relevant document is an Archaeological Desk-Based Assessment rather than a heritage statement, and it needs an archaeologist. Common triggers are a site within an Archaeological Priority Area, a scheduled monument nearby, a basement or substantial groundworks, or a known historic settlement core.
Where historic fabric will be lost or substantially altered, Historic Building Recording to a stated level may be required by condition, and the level has to be specified. There is a related piece on what institute registration means for archaeological organisations.
A heritage statement and an archaeological assessment answer different questions. Submitting one in place of the other is a frequent validation problem.
Listed building consent and the level of expertise expected
Listed building consent is a separate application from planning permission, and the two are often needed together. The level of expertise an authority expects rises with the grade and with the depth of intervention.
Rough guide, and it is only a guide:
- Like-for-like repair to a Grade II building, using matching materials, with a clear photographic record. An experienced agent or architect can usually handle the statement.
- Internal alterations affecting plan form, or new openings in historic walls. A conservation-experienced author, with an accredited architect or surveyor involved in the design.
- Structural repair, underpinning, or works to a Grade I or II* building. An accredited conservation architect or surveyor, plus a structural engineer with conservation accreditation.
- Loss of historic fabric, or works where the public benefit has to outweigh harm. A heritage consultant who can write the balancing argument, and usually specialist input on the specific element.
Grade I and II* works also bring Historic England into the process as a consultee for certain categories, and its comments are written by specialists. A thin statement is more exposed there than anywhere else.
Pre-application discussion with the conservation officer is worth more on heritage work than on almost any other topic, because the officer will usually say which aspects of significance they consider sensitive. That one conversation often reshapes the design before any statement is written, which is the cheapest point to change it.
Reviewing a statement you have been given
If someone has written one for you, read it against this list before it is submitted.
- Does it name the asset, its designation, its grade and its list entry, and quote the relevant part of the list description?
- Does it assess significance by type of interest, rather than describing the building's appearance?
- Does it include a short development history with dated sources, not a general account of the period?
- Does it describe each element of the proposal and assess its effect separately?
- Does it reference the statutory duty and the national policy harm test, and reach a stated conclusion on the level of harm?
- Does it include a photographic record with a location plan for the viewpoints?
- Is the length proportionate, rather than padded with general history?
A statement that fails the second and fourth of those is the common type. It reads well, describes the building pleasantly, and never assesses anything.
Matching the author to the asset
Work backwards from the harm. Ask what aspect of significance the proposal could affect, then appoint someone whose accreditation covers that aspect. Setting and views point to a heritage consultant or landscape specialist. Fabric points to an accredited architect or surveyor. Structure points to an accredited engineer. Buried remains point to an archaeologist.
And ask for examples. Two comparable statements for buildings of a similar grade in a similar authority tell you more than any list of letters. PlanScope can produce an AI-assisted draft heritage statement structured to policy with flags where site facts are missing, and the professional directory is the route to review by a suitably accredited author.
This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Does a heritage statement have to be written by an accredited consultant?
No. There is no legal requirement about who writes it. For simple works to a Grade II building an experienced architect or agent is usually acceptable. For structural intervention, loss of fabric, or Grade I and II buildings, authorities expect a conservation-accredited author and will say so if the statement is thin.
What does IHBC mean after someone's name?
Full membership of the Institute of Historic Building Conservation, assessed against competences covering conservation philosophy, practical conservation, legislation and policy, and management of the historic environment. Members come from architecture, planning, surveying and archaeology, and most local authority conservation officers hold it.
What is the difference between a heritage statement and an archaeological assessment?
A heritage statement assesses significance and impact for built and designated heritage assets, including setting. An archaeological desk-based assessment deals with below-ground deposits and their potential. They answer different questions and need different authors, and submitting one in place of the other is a common reason an application is held at validation.
What should a heritage statement actually contain?
Identification of the asset with its designation, grade and list entry, an assessment of significance by type of interest, a short dated development history, an element-by-element assessment of the proposal's effect, reference to the statutory duty and the policy harm test, a stated conclusion on harm, and a photographic record with viewpoint locations.
When is Historic England consulted?
For certain categories of works affecting Grade I and Grade II buildings and other designated assets, under the statutory consultation arrangements. Its comments are written by specialists, so a statement that avoids assessing harm is more exposed in those cases than in a straightforward Grade II application decided by the local conservation officer.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.