C O N T E X T 1 0 9 : M A Y 2 0 0 9 11 in the needs of historic buildings, did not understand how they performed, and saw their role as ensuring total compliance with approved document targets. Applying special consideration was too vague for many building control staff. By contrast, a significant number of conservation officers reported that their building control colleagues did have a good understanding of the technical issues. Here building control officers were prepared and interested in pursuing imaginative solutions which achieved energy and conservation objectives. A vigorous debate surrounding these issues was often needed and compromises were made by both sides. A good working relationship did seem to be the key. Even where this existed, conservation officers were clear that the exemptions were a key factor in establishing this productive method of working for the reasons already cited. Exemptions also send an important message. They show that the government values historic and traditional buildings. This has been particularly important in countering the relentless emphasis on potentially destructive measures such as insulating buildings and replacing windows. Removing the exemptions would be interpreted by many (including applicants, agents, building control and product suppliers) to mean that these buildings should not be given special consideration. The removal of the definition of historic buildings in 2006 had this effect. A common problem was experienced with approved inspectors, certifiers from the National House Building Council (NHBC), energy installers and Fensa-registered installers, few of whom felt any compunction to follow the recommendations in the approved documents covering historic and traditional buildings. This has led to conflicts where ‘illegal’ work has been carried out, without listed building consent. There was a wide variation in the extent to which building control staff were prepared to be flexible. Most accepted this for listed buildings, although some were selective about measures they would accept, for example allowing single glazing (with improvements) but refusing any compromises over insulation targets. There was a great deal of doubt as to whether unlisted buildings in conservation areas received a flexible approach, some building control staff refusing to countenance it. By contrast some conservation officers reported very positive approaches by building control officers who recognised the uncertainties and risks of internal wall insulation, and the great value of concentrating on more benign improvements such as loft insulation and improved heating systems. The research meeting in London covered the issues at some length and gave representative conservation officers the opportunity to make researchers aware of problems on the ground. There was a common desire to see energy performance improved in all buildings, including those of architectural or historical interest. This was the same for churches, although in all cases it was agreed that some measures were not appropriate. However, Part L did not distinguish which these were. It was the indiscriminate application of the guidance in the approved documents that often caused problems. It was agreed that the existence of formal exemptions had been beneficial. Those present felt strongly that they should remain in the 2010 Part L, but with clearer qualifications about how and when they should be used. For instance, should they apply to buildings or works? Greater clarity needed to be given to the conservation officer’s role. It was felt that the approved documents should use language which was stronger and more specific than simply suggesting that: ‘In arriving at a balance between historic building conservation and energy efficiency improvements, it would be appropriate to take into account the advice of the local authority’s conservation officer’. Such language was considered much too equivocal, as it did not stress the importance of the role of the conservation officer. What is clearly needed is the publication of more detailed advice on applying Part L. English Heritage intends to do this in the coming months. But there was scepticism as to how effective these might be because of the vast amount of technical documents already resourced by building control officers. Some felt that additional technical documents would not be read or used, and that the only place for such advice on application was within the approved document. Focused training is clearly needed and should include conservation officers, building control officers, approved inspectors and others who are involved in the process. However, this is not something that can be accomplished before 2010. Look at the IHBC website for details of the formal consultation by CLG. All those interested are urged to respond. ChrisWood works for English Heritage and is a member of the IHBC Technical Panel.
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