Updated: Nov 30, 2022
Currently a bit of a thorny topic within planning, today we are looking at the level of protection and treatment afforded to non-designated heritage assets which is a bit of a minefield for both developers and planning professionals alike. Often, the criteria for what constitutes a non-designated heritage asset and what protection they are afforded varies between local councils and even the conservation officers.
What is a non-designated heritage asset?
Non-designated heritage assets are buildings, monuments, sites, places, areas or landscapes identified by plan-making bodies as having a degree of heritage significance meriting consideration in planning decisions but which do not meet the criteria for designated heritage assets.
How do you identify a non-designated heritage asset?
The criteria for the identification of non-designated heritage assets are composed of four assessed categories:
Many of the non-designated heritage assets that meet the criteria above are recorded within the local Historic Environment Record (HER). However, frequently within our work we come across structures and features which are not recorded within the local HER but would be considered a non-designated heritage asset by your local council if you were to develop/alter the asset.
Having your building classed as a non-designated heritage asset would then mean that you may require a different approach when undertaking any alterations and/or seeking permissions. Therefore, if you are unsure if the property you are developing is a non-designated heritage asset, it is always best to seek the opinion of a heritage professional first.
What protections do they have?
Should you have your property identified as a non-designated heritage asset, it is now considered to hold a degree of significance that merits consideration within planning decisions.
The national policy within the NPPF states that:
‘The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that directly or indirectly affect non-designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset’ (Paragraph 203).
However, local planning policy on non-designated heritage assets varies from district to district. Some areas have specific policies providing guidance on non-designated heritage assets and some fail to mention them at all, in turn, creating a somewhat grey area within planning that is often left to the Conservation Officer’s discretion. This frequently creates uncertainty and inconsistency across the board.
Guidance provided by Historic England within Local Heritage Listing: Identifying and Conserving Local Heritage (2021) provides supplementary guidance for the treatment of non-designated heritage assets; however, this guidance is somewhat brief and is left open to interpretation. Within this document it is noted that:
‘Non-designated heritage assets may also be identified by the local planning authority during the decision-making process on planning applications, as evidence emerges.’
‘Any such decisions to identify non-designated heritage assets need to be made in a way that is consistent with the identification of non-designated heritage assets for inclusion in a local heritage list, properly recorded, and made publicly available’.
Consequently, this limited policy and guidance has created an inconsistent system in which non-designated heritage assets are assessed differently depending on the local authority. Furthermore, this approach also has the potential to overemphasise the legitimate protection and significance attached to each asset as they are often assessed in line with a potential development.
At Blue Willow Heritage, we provide expert advice on how to identify, manage and best develop non-designated heritage assets in a mode sympathetic with their significances. If you need support managing your non-designated heritage assets Blue Willow Heritage can help. If you would like to discuss your project or simply need some impartial, no-obligation advice, then please do not hesitate to get in touch.