much better way of assessing proposed changes to listed buildings than is often the case at present. It is an encouragement to do things the right way round: to look at the outset at the effect of the proposal on the listed building involved, not as often happens at present to design the scheme and then consider the effect on the listed building or even worse, and one of the banes of the life of many local authorities, to have an application submitted by an unqualified agent. PPG15 puts the onus or duty (unusually for government advice the words "must", "should" and expect" are used) fairly and squarely on applicants and their advisers to make an assessment of the impact of their proposal on the listed building before submitting an application. The positive way to look at it is that it also presents an opportunity to demonstrate to the local authority that they have an understandi11g of and are good custodians of the listed building in question. A request by local authorities to submit an "impact assessment" should become the norm for all but minor listed building consent applications and I would expect to be asked for them if I were acting for an applicant. The starting point for preparing all Impact Assessments, in effect a thorough critical site/building appraisal, is the criteria for evaluating all listed building consent applications set down (for the first time) in para 3.5 of PPG15. A proposal clearly has to respond to the reasons why a building is listed. The listing description is (or should be) the logical place to begin the assessment of the first two factors in para 3.5, the intrinsic architectural and historic interest of the building and any particular features which it may possess. Descriptions vary considerably in quality as well as length. The best identify in reasonably plain English precisely what is listed, accompanied by a map, and identify the important elements in the building and the reasons for listing. Unfortunately, many simply describe everything on the site without distinction including commonplace modern structures, and to understand some of them requires an architectural thesaurus. This type will not be a great help to many applicants who will have to make their own interpretation of the intrinsic importance of the building. The best listing descriptions, which do identify what is listed and why, will be a tremendous help in the preparation of an impact assessment; the worst will be a handicap. The setting of the listed building is the third factor to be included in the assessment. Strictly speaking this is not something which affects the merits of whether a building should be included on CONTEXT 44 the statutory list. It does, however, very often have an important impact on the appreciation of the building, particularly where it is in a publicly accessible area and adjacent new development or extensions can have an important impact upon this. The fourth factor in para 3.5, what might be termed "Community Factors", is the most difficult to predict. In some proposals the weight to be attached to these potential benefits of the scheme may well be the most controversial factor between authority and applicant. If the proposal involves demolition (and in future a larger proportion of listed building consent applications will because of the inclusion of the words "any significant part" in the definition of demolition) then of course the additional specific criteria in para 3.19 of PPG15 have also to be considered. These are considerably stricter and in most cases clearer than in Circular 8/87. The Impact Assessment may also have to respond to other factors such as any relevant Local Plan/Unitary Development Plan policies. Bearing in mind that section 54A of the 1990 Planning Act does not apply to applications for listed building consent, these are most likely to relate to any associated planning application. There is nevertheless a challenge to the policy frame to introduce into the Local Plan, policies relating to factors such as differences in building character within a district. The assessment may also beneficially comment about factors such as the "optimum viable use" of the building. There is a continued clearly expressed recognition in PPG15 that usually, when dealing with proposals for a historic building, a heritage balance has to be drawn up involving a range of factors before a judgement can be made of the optimum viable use (a new concept in the PPG). The Impact Assessment is clearly a question of balancing the impact of a number of factors on the listed building. Most of these will be subjective judgement, not something that can be worked out with a computer programme (thank goodness). There will as a consequence be differences of opinion. This is not in itself a bad thing. What the appraisal will do is to highlight the issues which need to be discussed at meetings between Local Authority and applicant the importance of which are stressed in para 2.11 of the PPG. The need to justify a listed building consent proposal should not be seen as an excuse to produce the conservation equivalent of War and Peace. It is to everyone's advantage that they should be brief and avoid overkill. In most cases they can be done on no more than two or three sides of paper with, of course, in addition, detailed drawings or at the very least good quality illustrative drawings. This is not a particularly onerous requirement. The only general exception should be where demolition and the consequent marketing and other tests are involved. When listed building consent application forms are issued, it would help considerably if authorities gave general guidance on how they would like Impact Assessments to be presented. If this is done and the advice followed, it will establish a much better basis for discussing and determining listed building consent applications than is often the case at present. It should highlight the issues that matter and get the debate about an application onto a sound footing at an early stage. If full advantage is taken of the advice in paras 2.11 and 3.4 of PPGJ 5, it represents a great opportunity for both applicant and local authority to contribute to a more effective system of listed building control. To achieve this requires a bit of pro-active work from authorities at the outset to specify the desired format of the Impact Assessment they require and then for the applicant to produce it. This will probably mean a longer lead in time before applications are submitted. The end product should, however, save work in the long run for both parties as the proposals should be better thought out and the issues which need discussion easily identifiable. If authorities do not take the lead, then probably the potential benefits of paras 2.11 and 3.4 will not emerge. One of the main problems with listed building consent applications at present is that many are submitted by unqualified people. Para 3.15 of PPG15 does comment that "proposals for alterations or extensions .... should always be based on specialist expertise". An impact assessment is likely to need some form of professional input. If it leads to a reduction in applications by unqualified people, then surely it would be worth it for that alone. TAILPIECE When I was at school it was drummed into me that I must never put a comma after 'and' or 'but' otherwise I would never pass 'O' level English. It happens hundreds of times in PPG15. The semicolon and colon are also developed into an art form which means that there are some sentences of world record breaking length. All this means that there are so many punctuation marks in the PPG that Victor Borge, if he were still alive, could make a fortune by producing an LP of it. David Morton is principal of the Conservation Consultancy. 29
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