Statements of Significance
Applications Affecting Heritage Assets, both Designated and Non-Designated
Guidance on Statements of Significance and Impact Assessment
The Dover District Heritage Strategy (2013), recognises the important role that heritage assets have in place-making and guiding and stimulating the regeneration of the district. It also recognises that heritage assets are an irreplaceable resource and that we should conserve them in a manner appropriate to their significance.
In line with this, applicants need to describe the significance of any heritage asset, including any contribution made by its setting, when making an application. This should be used to inform their proposals and should therefore be carried out at an early stage in the design process. Once a scheme has been produced then it should be evaluated against its impact on the significance of the asset, or specific part of the asset. The Dover District Heritage Strategy provides a good starting point for this evaluation, which will ultimately form a very important part of any application. This guidance note has been produced in order to assist applicants to provide the level of information required by Government to accompany applications that will have an impact on a heritage asset. In most cases this should take the form of a ‘statement of significance’ to accompany the general ‘design and access’ statement, and could be an integral part of it. However with large complicated proposals it may be more appropriate to have two separate statements.
The National Planning Policy Framework, (NPPF) highlights the importance of protecting and enhancing the historic environment, and this forms an integral part of achieving ‘sustainable development’. One of the twelve core principles of the NPPF is to ‘conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations’.
The NPPF also states that ‘In determining applications, local planning authorities should require an applicant to describe the significance of any heritage asset affected, including any contribution made by their setting’. An understanding and appreciation of the significance of a heritage asset should then be used to inform any proposals affecting it.
Designated heritage assets include Listed Buildings, Conservation Areas, Registered Parks and Gardens, Scheduled Monuments, Protected Wreck Sites, Registered Battlefields and World Heritage Sites.
Some sites or buildings, whilst having no formal designation, may also be classed as a heritage asset, and it may also be appropriate to provide a ‘statement of significance’ for applications affecting them. This can be clarified with the local planning authority before an application is made, or during the planning process.
Preparation of Statement of Significance and Impact Assessment
There is no set format to the production of such a statement, however the NPPF states that ‘the level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance’. So, for example, if an application includes substantial demolition of a heritage asset, it is reasonable to expect the applicant to provide a thorough and detailed understanding of the asset as a whole, and a detailed explanation of how the proposals will impact on the significance of the building. Whereas an application for a very minor alteration to part of the asset, is likely to only require a brief overview of the significance of the asset as a whole, with more detailed analysis on the part to be altered.
The ‘statement of significance’ can be written by anyone who is competent to do so, and this may be the owner of the heritage asset. However for a complex heritage asset, with high levels of significance, it is advisable to employ a heritage professional (conservation architect/planner, architectural historian, archaeologist, chartered surveyor, conservation structural engineer etc). If the applicant is using an architect/agent to submit an application on their behalf, they may be capable of producing the statement, or they may know someone who is.
Where an application site includes, or has potential to include heritage assets with an archaeological interest, an appropriate desk based assessment or field evaluation may also be required. It is advisable to discuss any archaeological implications of the site with the Heritage Conservation team at Kent County Council. (tel: 01622 221541, email email@example.com)
The following stages should be considered when producing a ‘statement of significance’.
Stage 1: Research required in order to assess significance.
Existing Documentary Evidence
Check the main local and national records, including the Kent Historic Environment Record (HER) - statutory lists, for example all listed buildings have a Statutory List Description as do Registered Parks and Gardens and Scheduled Monuments; the National Monuments Record (NMR); the Heritage Gateway and other relevant sources of information that would provide an understanding of the history of the place (building/site), and the value the asset holds for society.
(See Sources of Information).
Maps can reveal historic layouts of sites and buildings, their relationship with other buildings or structures and surrounding landscapes or gardens. An examination of historic maps will often reveal how a site has changed or developed, providing time periods for different building phases. This may be very influential in determining the relative significance of different parts of a building, or site. (See Sources of Information).
There are many sources of historic photographs of buildings within the district. They can often reveal information about how a building has changed and can provide a justification for proposed alterations or inform the design of an alteration or extension. (See Sources of Information).
Many buildings and areas in the district are referred to in other sources of information, for example in the studies produced by the local authority or the County Council, or by local museums, historians, parish councils etc.
Stage 2 Statement of Significance
Using the information obtained from stage 1, a written Statement of Significance should then be produced, which may include historic maps, photographs and other historic documentation. The amount and type of information will depend on the nature of the heritage asset itself and the nature of the proposals. A listed building application for a minor internal alteration will clearly not require as much information as an application for part demolition and extension of a listed building, or alterations to a site of archaeological importance. It is suggested that the following issues, to a greater or lesser extent, should be addressed for all applications affecting heritage assets.
The development of the site or building. How the development, form and appearance of a site or building illustrates, or tells the story of its history. Significance will often be derived from the age of the fabric of a building, for example a late 20th Century extension to an 18th Century house, will not be as significant as the earlier original fabric. Where a heritage asset has numerous phases of development, or differing levels of significance, plans can be used to show this. Historical associations with famous people, architects, or events will usually increase the significance of the asset.
A description of the building/structure/site and its setting. This should include information on architectural style, date(s) of construction, materials, key notable characteristics generally and specifically in the location of any proposals. If it is a conservation area, what is its particular townscape quality? Aesthetic value can be fortuitous or designed. Unusual or rare features will usually give the building, or area, a higher level of significance. A note could be made of any features which detract from its significance with an explanation as to why this is the case. The setting of a heritage asset can make an important contribution to its significance. A description of the heritage asset’s setting should include other buildings in the grounds, details of landscaping and views towards and away from the asset.
The importance of the place for society, or a particular group in society, such as a war memorial, church, school or a public building.
The potential of a place to yield as yet unknown evidence about past human activity, this would particularly, but not exclusively apply to areas of archaeological importance.
Once the significance of the heritage asset has been established this should be used to inform any proposals, minimising any damage to the ‘significance’ of the asset. Stage 3 Impact of Proposals on the Significance of the Heritage Asset When the proposals have been formulated, then their potential impact on the ‘significance’ of the heritage asset needs to be evaluated. There is no set way of doing this, however it could be done in a tabular form, like this example - evaluation sheet. This breaks down the proposals into a schedule of works, listing them item-by-item. The ‘significance’ of the historic fabric/area affected is identified. In the ‘impact’ column, the effect of the specific proposal on the significance of the asset should be evaluated. If any harm to that ‘significance’ is identified, then any perceived justification for this could be identified under the ‘justification’ column. Any mitigation measures could also be mentioned here. This will clearly demonstrate that the full impact of the proposals, have been evaluated.
Tel: 01304 872486