In June 2022, together with Local Government Association and Parity Projects, we published a report on why some social homes are harder to decarbonise than others. One of the key findings was that retrofit work is restricted in many homes in England, particularly heritage homes, by planning barriers. Heritage homes are homes which have special considerations under the planning system, due to the character and historic interest attached to the building. According to research from LETI (originally the London Energy Transformation Initiative), this could be the case for up to a quarter of UK homes. With housing making up as much as a fifth of the UK’s carbon emissions, this presents a huge challenge.
Put simply, many homes are in areas with reduced permitted development rights, such as conservation areas. This restricts what housing associations who own or manage homes in these areas are allowed to do to them, preventing essential retrofit works such as installing air source heat pumps, solar panels, double-glazing or external wall insulation.
Added to this, many NHF members have reported inconsistencies across different local planning authorities, and sometimes even within the same authority. One planner told us they had received different planning decisions for two very similar houses on the same estate. Without consistency and assurances over decision-making, housing associations may scale back their retrofit adaptations, as they navigate a planning system which can become both time-consuming and expensive.
In December, I attended the launch of new research from the Architecture Climate Action Network (ACAN). The report examines the Islington Cross Street Conservation Area to appraise the status of protected buildings. This appraisal seeks to identify where there has been detrimental impact on heritage buildings and where they could be further developed.
ACAN found that 22% of buildings in this area have had alterations that have affected the character of the building in a way that threatens its heritage value. In these instances, thoughtful retrofit work that respects and complements the historic environment can serve to enhance the significance of the building. Guidance on how this may be carried out can be found in our climate and sustainability hub.
While many walls of homes in heritage buildings may not be suitable for external wall insulation, the report finds that actually, as many as 44% of buildings could be fitted with external wall insulation without issue. This will be reassuring for housing associations operating in conservation areas. ACAN suggests that Islington Council could supplement work like this with a Local Development Order providing guidance on materials and methods for the installation of external wall insulation.
At the heart of the issue is the need to balance the protection of heritage assets with and the need to adapt in the face of the climate emergency. As Islington Council’s 2021-2022 Local Plan puts it, ‘the historic environment must be reconciled with the environmental needs and aspirations of people.’
The Royal Borough of Kensington and Chelsea has shown that with sufficient political will, it is possible to make the necessary adaptations while also protecting the heritage of an area. Last year they became the first local authority to grant an order permitting the installation of solar panels on most Grade II listed buildings without applying for individual building consent (with some limitations on placement, positioning and visibility).
This important local work needs stronger national guidance. In recent months, we have engaged with the Department of Media, Culture and Sport and the Department for Housing, Levelling Up and Communities to discuss strengthening environmental links in the National Planning Policy Framework (NPPF).
While a great strength of the NPPF is the flexibility it affords local planning authorities, there is an urgent need for greater consistency in planning decisions.
The latest NPPF consultation was launched in December 2022. The draft text adds a paragraph that gives greater weight to the need to adapt existing buildings, with a specific focus on non-domestic properties. At this stage, there are no alterations to Chapter 16, which sets out the criteria for making decisions around adapting heritage assets. We would like to see greater consideration given to the environmental public benefits of green adaptations – the same justification given by the Royal Borough of Kensington and Chelsea when proposing their solar panel Local Listed Building Consent Order.
As we begin another year where climate change is likely to impact all our communities, it is vital that central and local government work to ensure that residents in heritage areas can live comfortably and safely in homes that are both historically significant and energy efficient.