G2 Listed - New Roof + Heritage Statement

[Mr_Green]

Hi,

So we’ve instructed the roofers to go ahead with a new roof, all done to the proper spec for local listed buildings.

Breathable, expensive etc.

Initially the LBC/Planning/Building bods wanted drawings! Now they don’t.

But they do want a Heritage Statement which I’ve been quoted £3k for. I could honestly do without more expense.

But the roofers who are very well known for good work have said it’s the first time they’ve ever heard of having a statement needed for a roof replacement on a G2.

Is it usual to need a statement for a re-roof?

 

[Kearn]

It’s a mandatory requirement for every LBC application.

Not really your roofers’ area of focus, as I can’t see them submitting many applications. Strange that they have an opinion on such an element, but makes you start to wonder…

You will need Building Control involved, sure they’ve mentioned that?

And what was their take on bats?
Roofs get contentious because of bats, this will be a requirement. An expensive annoying one, as the net result of three visits at different times of year, is to add bat boxes.

I’m not quite sure what the ‘proper spec is for local listed buildings’, each roof can be quite different hence the normal request for drawing / method statement / material samples etc.

I can’t quite work out where you are in the process though - have you had your LBC app not validated due to the missing required documents?
Or is it a pre-app hence the mention of drawings being asked/not asked for as a dialogue with a CO is a rare thing?
It’s probably a bit soon to give trades the go ahead before you’ve got permission. Might not get it, might take close to a year in many counties as the conservation departments often don’t have a CO or if they do they’re very overworked….

In terms of the heritage statement, you can easily write your own. Heritage England provide a good guide on how to structure, and the level of detail has to be proportionate to and focussed on the works involved. Equally, look at other LBC apps on your LA portal and find a heritage statement that works for you and borrow the structure etc from it.
The underlying argument you need to present is that you understand the significance of your building across the four lenses, and any areas that are particularly of importance (or not) and that the work you’re doing is net positive to the building as a whole.

 

[Flyfisher]

I've made four successful applications for LBC on my G2* house over the past 17 years and each time the requirements have been slightly different and each time my initial application was not validated because of a missing document.

One application required a 'Design and Access Statement', which had not been previously required and had me somewhat worried until I found an online guide about what was required and it turned out that it was barely applicable to the proposed works so my D&AS consisted of 4 headings of essentially 'no impact' or 'not applicable' on a single sheet of paper. This was accepted for the validation process and the application was accepted and subsequently granted. My suspicion is that the person validating LBC applications works to a 'tick-list' of required items and doesn't actually read anything.
The D&AS was later superseded and replaced by the 'heritage statement' (may have been called something different some years ago). Again, there are online guides about what is required and Kearn has exactly described above how to create one. With a bit of care and attention is really isn't difficult and, in this case, should be an easy way to save £3k.

As for roof works, my house has three sections of roof and over the years each section has been stripped of all tiles, repairs carried out where necessary (surprisingly little as it turned out), a breathable membrane installed and the tiles replaced together with around 15% reclaimed tiles to replace the broken ones. All this was done with LBC but without building control being involved and without any complications concerning bats, so perhaps it all depends on the local council.

 

[Mr_Green]

Thanks for the comments, good to know from those with experience.

 

[Mr_Green]

I don't suppose anyone would share a heritage statement with me for a roof?

 

[Kearn]

I don't suppose anyone would share a heritage statement with me for a roof?

Happy to share ours, but it is a) extensive and b) roof is one thing not included, so probably not much help.

I’d search your planning portal for local similar applications, and borrow one of those - it’s all public info

 

[Kearn]

I've made four successful applications for LBC on my G2* house over the past 17 years and each time the requirements have been slightly different and each time my initial application was not validated because of a missing document.

One application required a 'Design and Access Statement', which had not been previously required and had me somewhat worried until I found an online guide about what was required and it turned out that it was barely applicable to the proposed works so my D&AS consisted of 4 headings of essentially 'no impact' or 'not applicable' on a single sheet of paper. This was accepted for the validation process and the application was accepted and subsequently granted. My suspicion is that the person validating LBC applications works to a 'tick-list' of required items and doesn't actually read anything.
The D&AS was later superseded and replaced by the 'heritage statement' (may have been called something different some years ago). Again, there are online guides about what is required and Kearn has exactly described above how to create one. With a bit of care and attention is really isn't difficult and, in this case, should be an easy way to save £3k.

As for roof works, my house has three sections of roof and over the years each section has been stripped of all tiles, repairs carried out where necessary (surprisingly little as it turned out), a breathable membrane installed and the tiles replaced together with around 15% reclaimed tiles to replace the broken ones. All this was done with LBC but without building control being involved and without any complications concerning bats, so perhaps it all depends on the local council.

As always, every experience varies… can’t remember the %age threshold , 25 possibly, of roof being replaced is meant to trigger the need for BC involvement. Grey area if taking all off but replacing… addition of insulation tends to also be a trigger. But informing is a different question entirely!

Bats just seems a licence to delay and steal your money!

 

[Flyfisher]

Yes, it does seem that owner's experiences can vary across the country, just as the quality and helpfulness of CO's can vary, as evidenced by many posts here.

I've read about the (possibly mythical) % threshold for works triggering BC involvement, such as re-plastering a whole room etc, but I've never seen any formal written guidelines. That's not to say they don't exist and I may have been negligent in not seeking them out, but how is the amateur DIYer supposed to know all this stuff? I wonder if 'wilful ignorance' is an offence?

One of our roof sections was over some attic rooms so I wanted to add insulation but that involved increasing the height of the roof, which affected the gable details and other things. So, with CO input, we decided to use multi-foil insulation. It didn't fully comply with the U-value requirements but it did limit the increase in roof height to about 50mm, which was deemed important by the CO given the G2* status, plus it was, of course, a big improvement on not having any insulation at all. So basically a pragmatic tradeoff. But at no time was BC involvement ever discussed.

As for bats, none of my LBC or planning consents have imposed special conditions or surveys before the consented works could begin. Yet, when an architect friend drew up plans for a kitchen extension he warned me that the planning consent would likely require conditions such as newt protection fences around the site because of our close proximity to ponds and a river. This warning was based on his experience in Hertfordshire but it clearly wasn't the same in Norfolk as no such conditions were imposed (and this was a project involving LBC, planning and BC consents).

Another inconsistency in the planning rules that has always bugged me is the issue of sign-off. 'Normal' works require planning permission before the work can (legally) begin and then the work itself is carried out under the supervision of building control to ensure it meets the relevant requirements and when finished it is signed off with a certificate of compliance. All sensible stuff. But for listed buildings, things seem to start and end with LBC - you get consent for the works but there is no 'control' element or final sign-off to prove the consented works have been implemented correctly.

It sometimes seems to me that the preservation of our built heritage is better protected by responsible owners who actively care enough to do the right things than the various regulatory bodies who are formally charged with protecting them. But that's enough grumpiness for one day!

 

[Kearn]

Yes, it does seem that owner's experiences can vary across the country, just as the quality and helpfulness of CO's can vary, as evidenced by many posts here.

I've read about the (possibly mythical) % threshold for works triggering BC involvement, such as re-plastering a whole room etc, but I've never seen any formal written guidelines. That's not to say they don't exist and I may have been negligent in not seeking them out, but how is the amateur DIYer supposed to know all this stuff? I wonder if 'wilful ignorance' is an offence?

One of our roof sections was over some attic rooms so I wanted to add insulation but that involved increasing the height of the roof, which affected the gable details and other things. So, with CO input, we decided to use multi-foil insulation. It didn't fully comply with the U-value requirements but it did limit the increase in roof height to about 50mm, which was deemed important by the CO given the G2* status, plus it was, of course, a big improvement on not having any insulation at all. So basically a pragmatic tradeoff. But at no time was BC involvement ever discussed.

As for bats, none of my LBC or planning consents have imposed special conditions or surveys before the consented works could begin. Yet, when an architect friend drew up plans for a kitchen extension he warned me that the planning consent would likely require conditions such as newt protection fences around the site because of our close proximity to ponds and a river. This warning was based on his experience in Hertfordshire but it clearly wasn't the same in Norfolk as no such conditions were imposed (and this was a project involving LBC, planning and BC consents).

Another inconsistency in the planning rules that has always bugged me is the issue of sign-off. 'Normal' works require planning permission before the work can (legally) begin and then the work itself is carried out under the supervision of building control to ensure it meets the relevant requirements and when finished it is signed off with a certificate of compliance. All sensible stuff. But for listed buildings, things seem to start and end with LBC - you get consent for the works but there is no 'control' element or final sign-off to prove the consented works have been implemented correctly.

It sometimes seems to me that the preservation of our built heritage is better protected by responsible owners who actively care enough to do the right things than the various regulatory bodies who are formally charged with protecting them. But that's enough grumpiness for one day!

Well, careful or you’ll really get me started…! I get the system, honestly I do. It was the right intention when our built heritage was being pulled down at an alarming rate for new builds, infrastructure and the like. And catching some crud in the drive by net was acceptable on balance as it meant good buildings were protected. I feel there should be some sensible way of weeding out that crap now though via delisting stuff that should never have been listed. But that’s an impossible task by all accounts. And I get it could drive the wrong behaviours for people doing damage in order to delist. But then, that will happen regardless.

But now the process is just not fit for purpose. So many people do get hung up on all the upfront stuff and getting permission to start. I’ve heard of folks sitting there with a hole in the roof leaking water for over a year because COs couldn’t agree on roof coverings etc . Makes you question some people’s common sense… but I digress!
I’m with you, it’s odd. A totally front loaded process. Even conditions, their chance to add some extra control instead of just saying yes, get signed off in advance based on theory, not once the work is actually done and can be seen. It’s part of the reason I don’t stress too much about the finer details upfront. Get the massive stuff in and agreed, ensure you demonstrate an understanding and care for the building and it’s most important bits, and then they leave you alone worrying about others who don’t know what they’re doing and will sap time.
However, if it were by the book, COs would get fed up of seeing emails come in with further findings, changes, amendments etc…

Yes you do need LBC to remove concrete render/tanking and replace with lime, but really… and the ability to actually back track what incorrect changes were down when historically, either side of the listing date is silly too. “Yes I know it has impervious materials killing its structure, but that was done before listing, so it’s now protected and you have to justify changes to go back to how it should be.” Well, was it, rarely can anyone document enough evidence to prove either way.

As long as you keep your neighbours sweet and don’t have some busybody who calls the enforcement officer, then there is no real further engagement. That’s said, there’s a CO notorious for being in the details of everything throughout the process, too much knowledge rather than the usual other end of the scale. Then their colleagues just sign off and move on. It’s so varied.
Wiltshire is an oddity, in having a conservation team, yes, team - totalling 5 COs I believe. Most LAs are lucky to share one with neighbours. The others outsource to private entities and try to charge.

I think some pragmatism needs to be applied otherwise nothing would ever get done. BUT that does require the right custodians to be in place for it to work. Those fretting about whether they need permission to put a TV aerial up/down maybe shouldn’t be holding the keys. Equally, those who are intent to plough on with ‘modernisation’ and ‘insta house renos’ because they think they know best, will plod on blindly and do damage.

There’s a few groups / forums I lurk in where the first question is often are you listed / what does your CO suggest… in response to very specific request for experience about a material / approach etc. I constantly bite my tongue thinking most COs are not all knowledgable in every facet of building permutations and solutions, they’re not there to educate and advise on the whole, they have little time to sign off mountains of paperwork. The onus needs to be on the owners to be informed and researched and present a sensible option or two with rationale.

It’s a funny one - we’re here simply as housekeepers for the nations buildings, but no longer do you get any financial incentives to do so, in fact it will cost you more and take longer to do the right thing, while jumping through hoops as if you’re trying to pull a fast one!

Personally, I think the originally well meaning system has got to the point where it’s now reversing its original intention and causing more harm than good.

 

[Kearn]

I've read about the (possibly mythical) % threshold for works triggering BC involvement, such as re-plastering a whole room etc, but I've never seen any formal written guidelines. That's not to say they don't exist and I may have been negligent in not seeking them out, but how is the amateur DIYer supposed to know all this stuff? I wonder if 'wilful ignorance' is an offence?

But at no time was BC involvement ever discussed.

I believe getting BC involved is on us… therefore a need to understand when they’re needed and actively engage them.

We only have a private BCO right now as we were doing ambit structural work and adding an extension. No hiding that. But replacing windows, roof insulation…. That sort of stuff should fall into the bracket. Yet all the ancient crappy windows don’t meet any standards, but that fine as they’re not new.

A full rewire, mandates that heat and smoke sensors must be hardwired. Yet if it wasn’t a full rewire, then the battery powered ones would be fine. Safety is safety surely, shouldn’t matter how many sockets and switches are being moved.

 

[Flyfisher]

It’s a funny one - we’re here simply as housekeepers for the nations buildings, but no longer do you get any financial incentives to do so, in fact it will cost you more and take longer to do the right thing, while jumping through hoops as if you’re trying to pull a fast one!

Even when there was VAT exemption for listed properties, it was only for alterations and not for repairs. This always seemed odd to me given that listing is (I thought) intended to help preserve our built heritage yet the VAT rules back then actively encouraged alterations rather than repairs - though it was perhaps unsurprising how many like-for-like repairs became classified as 'alterations' Of course, when they finally got around to rationalising the rules they just removed the VAT exemption entirely! Still, while it was in place it did save me quite a bit so I suppose I shouldn't grumble.

Incidentally, I once asked our CO how it was that he was so accessible and helpful when I'd heard of so many other listed building owners having all manner of problems with their COs and he told me that he felt it was his job to actively help owners precisely because they get no financial assistance for helping to maintain and preserve the nation's listed buildings, which I thought was a very refreshing outlook.

 

[Oldschool]

I've submitted at least three successful LBC apps, two involving roofing works the latest requirements here in Cornwall at any rate for application involving a re roof would be bat survey which will include a survey and emergence survey(s) often carried out at dusk, Heritage Asset Statement I looked into this at length and decided rather than cobble together my own and have my app stall I paid for it but I did write the Design and Access Statement myself which was pretty straightforward, you'll need to speak to your roofer to obtain details of methodology and materials - our bat survey stipulated roofing felt and not membrane...bats get their claws caught in the membrane apparently. Frustratingly pre app advice is not free here in Cornwall and it's nigh on impossible to actually speak to a CO I guess they are stretched more and more, it might be sensible to bite the bullet and pay for those things in order to get your application through smoothly.