Written evidence submitted by Historic Houses

About us

  1. Historic Houses is the representative body for around 1,450 independently owned houses, castles, and gardens across the UK, mostly listed at grade I and II* (or equivalent). Our member houses range from the iconic Blenheim Palace, Highclere Castle and Knebworth House to houses such as Traquair in Scotland and Treowen in Wales.  

 

  1. In 2022, our member properties have welcomed over 21 million visitors, generated over £1.3 billion for the economy and supported over 32,000 FTE jobs. This is a significant part of the estimated £45.1 billion the heritage sector contributed to the UK economy in 2021. 

 

  1. Our member properties serve as hubs of culture, community and commerce, often acting as lynchpins in local economies across some of the most rural parts of the UK. On a national level, our houses and gardens provide vital support to the UK’s dynamic creative industries by hosting, and inspiring, filming, festivals and fashion amongst many more parts of our rich cultural industries.  And internationally, heritage is key to the UK’s tourism offering, drawing millions of visitors a year and acting as a defining feature of the UK for international visitors.

Question 1: What are the most significant challenges facing owners and operators of built heritage assets, and how are they affecting what those sites can offer?

  1. Most built heritage is in private ownership. Historic Houses represents around 1,450 independently owned historic houses and gardens across the UK. The majority of these – at least two-thirds of them – are in private ownership. The remaining third are held either as trusts, as charitable trusts, as limited companies, or else they are owned by local authorities. (Historic Houses represents 19 of more than 200 mansion properties that are owned and managed by local councils in the UK.)

 

  1. Despite these different ownership structures, all these houses face a similar challenge: how to meet the ongoing costs of repairs and maintenance from within often limited budgets.

 

  1. Independently owned heritage has enormous economic benefits for the UK, generating over £1.3 billion annually in GVA, all while saving the taxpayer from the burden of maintaining these important but costly heritage assets.

 

  1. Two primary issues that owners and operators of built heritage assets face are regulation and funding. Within these broad themes, there are a series of specific difficulties, some of which are listed below.

Planning

  1. While designed to protect built heritage, the planning system can create further difficulties for owners and operators of built heritage assets. Important historic buildings are given special designation by law. The listing system is an important method of recognising the special status of heritage assets, and ensuring that key features and buildings are given statutory protection (through the application of the listed building consent process).

 

  1. However, designation brings additional burdens for owners attempting to conserve, protect, and adapt listed buildings. The planning system can at times be overly slow and bureaucratic. To remain relevant and in use, buildings must evolve and adapt over time. Preventing them from doing so is likely to mean that they fall out of use, leading to long-term disrepair.

 

  1. In 2022, Historic Houses and the CLA conducted a joint survey of those of their members who had responsibility for listed buildings. Almost half (48%) of respondents thought the planning system was working poorly or very poorly. The most recent Historic England survey of listed building owners contains a similar figure, with 44% of respondents describing their experience of the listed building consent system as either ‘poor’ or ‘very poor’. This was a marked increase on the proportion that said the same in 2017 (33%).

 

  1. The process of obtaining Listed Building Consent from a local authority can be unnecessarily slow, particularly if the heritage asset sits in an overwhelmed local authority. This is holding back the pace at which historic buildings can be adapted: 87% of the respondents to the Historic Houses/CLA survey said they believed the planning system was a blocker to decarbonising historic buildings.  Historic Houses believes that introducing Listed Building Consent Orders (LBCOs) on certain low-risk, high-impact measures such as secondary glazing, loft insulation, and heat pumps in grade II listed buildings would be a low-cost, effective solution to help expedite the process.

 

  1. The Royal Borough of Kensington & Chelsea have introduced the use of LBCOs to allow some window works and solar PV panels for Grade II listed buildings. This initiative has made it simpler for owners to adapt their buildings towards being more cost-effective and energy efficient without damaging the heritage asset, itself. We would welcome the introduction of LBCOs on a national level, which is the only way they can be effective on the scale they need to be in meeting our need for net-zero.

 

  1. A 2023 report commissioned by the Historic Environment Protection Reform Group (HEPRG) into heritage-related planning determinations found the planning system to be under strain, with performances across local authorities deteriorating since 2016. The system as it stands, one in which the efficient process of a planning application of a heritage asset is dependent on the local authority it sits in, is inherently unfair. The impression of the planning system found in the report is of a complex system struggling to fulfil its function.

 

  1. Furthermore, there is a general lack of expertise within the local authorities; there is no training for staff that specifically addresses heritage, retrofitting and sustainability together. This is a long-term problem compounded by a decrease of historic environment staff over the past two decades: between 2006 and 2018, historic environment staff in local authorities decreased by 35%. The report also found that Heritage Statements are a ‘poorly understood and implemented component of the heritage planning system’. 

 

  1. This lack of expertise within the planning system is a barrier for those seeing to adapt built heritage for modern life. It is vital for the protection and preservation of built heritage that owners can engage constructively with their LPAs to facilitate change and navigate sensitive adaptation.

 

  1. These problems within the current planning system must be addressed if the issue of a managed decline of heritage assets is to be reversed. It is our view that the planning system requires significant, but carefully considered, reforms in order to cope with demand and to protect built heritage from damage.

Climate change

  1. Old buildings are some of the first to feel the impacts of climate change: more extreme weather patterns, warmer winters, wetter summers – all have their impact on the fabric of built heritage, and none of it good. Flooding has been a growing cause for concern for built heritage, both in terms of the impact on the material fabric of buildings and their contents, but also in terms of business interruption.

 

  1. Recognising the danger of climate change, 98% of Historic Houses members are keen to pursue net zero goals. However, 87% of our member houses view the current planning system as a barrier to decarbonisation. There is a real danger that without meaningful reforms to the planning system for listed properties the government risks squandering momentum and public support behind net zero targets.

 

  1. Historic Houses supports government’s ambitions to create 1.5 million new homes. However, the greenest building is the one already built. Historic England estimates repurposing existing buildings across the country could create up to 670,000 homes. The National Planning Policy Framework (NPPF) paragraph 167 requires tightening so that an equal ‘significant weight’ is given to decarbonisation as well as heritage. Britain’s built heritage should not be seen as a barrier to progress in this respect. Rather, it should be considered the foundation through which this target can be achieved. Planning policy can, and should, do more to support the renovation and retrofit of existing buildings, rather than working on the assumption that new development is always the best option.

Staffing

  1. Recruiting and retaining suitable staff remains a challenge for heritage-based businesses. The rise in minimum wage and in employers’ NIC contributions has had additional impact for many: the knock-on effect of a higher minimum wage means that differentials need to be maintained throughout staffing structures, increasing wage bills across organisations. Our members have reported the changes will mean an additional £10,000 per year to well over £230,000 per year, depending on the number of employees.

 

  1. Most heritage businesses are not particularly profitable. Salaries in the heritage sector are not competitive compared with other sectors, making it difficult for some to recruit and retain good staff. For Historic Houses member properties that are open to the public, the increased costs of employment is likely to impact their ability to provide their local communities with access to heritage, culture, and green spaces. It is important to recognise the public good that heritage assets bring to local communities and the benefits they bring to the rural economy when broadbrush fiscal decisions are implemented.

Question 1a: What interventions are needed to prevent the managed decline of heritage assets on publicly owned land?

  1. The challenges confronting publicly owned heritage assets are the same as those facing private and charitable owners.  It is imperative to prevent disrepair by ensuring that, where possible, heritage buildings are used in a way that means they are valued by their owners and occupiers and financially viable. Improved regulation to permit a viable use for these buildings is critical.

Question 1b: What can the Government do to make it easier for communities or local businesses to take ownership of historic buildings?

N/A

Question 2. How effective are the current funding and finance models for built heritage?

  1. The Gowers Report, commissioned by Clement Attlee’s post-war Labour Government and published 75 years ago, in 1950, established a position on country houses which successive governments have taken: “‘it is in the public interest for houses of outstanding architectural or historic interest to be preserved...”, and equally as importantly, “the owner of the house is almost always the best person to preserve it was the unanimous opinion of our witnesses, and is our own firm conviction”.

 

  1. In words which reflected the realities of post-War Britain (but which could equally have been written in 2025), Gowers also highlighted ‘the growing difficulty of getting, and expense of paying, the necessary staff, both indoor and outdoor… Gardeners are scarce and expensive; few recruits are now attracted into the career of estate carpenter, plumber or mason; and, in default of these indispensable workmen, minor repairs are left until they become major repairs and major repairs, if they can be done at all, must be carried out at heavy cost by contractors’.

 

  1. Most built heritage is in private ownership. The costs associated with the care and maintenance of listed buildings are enormous: in 2022, each of our member properties spent an average of £99,000 per annum on repairs and maintenance work (a combined total of £156 million per annum).

 

  1. In most cases, the income required to pay for these costs is generated through commercial and business activities. For private owners, there are few alternative sources of funding available: they do not have access to the same range of grants that can be sought by charitable owners. The National Lottery Heritage Fund permits private owners to apply for Lottery resources, but the amount is capped. Thankfully, this cap was raised from £100,000 to £250,000 in January 2024.

 

  1. It is impossible to stress enough how vital a supportive fiscal framework is for privately owned built heritage. Many of our members, as rural SMEs, planned succession strategies around the availability of full BPR and APR: tax reliefs which they, as hard-working small business owners who ploughed their profits into care of nationally significant heritage, were eligible for.

 

  1. The removal of these reliefs will have a significant impact: a survey we ran in December 2024 suggested affected members would find themselves in line for an average additional inheritance tax bill of just under £4 million. 54% of respondents said changes to IHT reliefs will leave them unable to develop/diversify their business; 41% of respondents say they will either have to make redundancies or freeze hiring new staff as a result of changes made in the Budget; 1/3 of respondents say they are likely to have to sell chattels to meet their new IHT liabilities.

 

  1. Private ownership of heritage is a cost-effective model, which – by and large – works well. Our heritage relies on private owners to do the bulk of caring for historic buildings. Government policy must recognise and support these owners in doing this, or risk losing hugely significant buildings.

Question 2a: should long-term public funding for the sector look like?

  1. More funding for capital works is vital, particularly (for example) for buildings on the Heritage At Risk Register (HARR).

 

  1. Giving built heritage a purpose (as a visitor attraction, a wedding venue, a filming location etc) is vital in ensuring it has a future. The businesses that operate from historic premises all pay taxes that any other business would pay, and plough the money they make straight back into the care and maintenance of significant heritage assets. Ensuring changes to the fiscal framework (like the changes to reliefs like APR and BPR) are fully thought through, and their impact on heritage mitigated, is vital for the care of these buildings.

 

  1. As recommended in our VAT report (outlined more fully in Question 4), a directly targeted, fully costed rebate scheme which would reduce effective VAT rates on the repair and maintenance of listed buildings open to the public for a minimum of 28 days a year.

 

  1. During the pandemic, some Historic Houses member properties benefitted from Culture Recovery Fund grants. These ensured that urgent repairs and maintenance projects were able to take place, and in the case of our members, all projects were completed on time and on budget. There is often a perception that ‘grants’ going to private owners will see money disappear into private pockets: our members have proved time and time again that they want support to complete urgent capital works, or to develop new, innovative projects which have clear public benefit.

Question 3. What role does built heritage play in the regeneration of local areas and in contributing to economic growth and community identity?

  1. Built heritage plays a vital role in the regeneration of local areas, and contributes significantly to economic growth and community identity.

 

  1. A report produced by the Centre for Economics and Business Research for Historic England found that England's heritage sector is estimated to have contributed £44.9 billion in Gross Value Added (GVA) to the UK economy in 2022 and supported the employment of over 523,000 workers. In 2022, our 1,450 members alone welcomed over 30 million visitors, generated over £1 billion for the economy and supported over 32,000 FTE jobs.

 

  1. Beyond its value to the British economy, built heritage is hugely important to place-making across the UK. Historic England’s 2024 analysis illustrates that Grade II listed buildings are a significant driver of life satisfaction increases, and by extension, that ‘it is proximity to a wealth of everyday local heritage – rather than the presence of rare, exceptional historic places – that is responsible for driving most higher life satisfaction.’

 

  1. Many historic properties are integral parts of their local community providing employment, education and cultural opportunities. Ushaw and Wentworth Woodhouse are two Historic Houses members whose stories fully illustrate the benefit that built heritage can bring to a community – both as a driver of economic regeneration, but also in creating a vibrant, dynamic community hubs which have brought joy, inspiration and opportunity to people living in places of high socio-economic depravation.

Ushaw

  1. A former Catholic seminary in County Durham, Ushaw re-opened for tourism and the local community in 2014. The team at Ushaw offer several initiatives and events for the local community. In 2024, with the help of volunteers from the local community, Ushaw planted a new woodland on their land consisting of 24,524 new trees, improving biodiversity and working with the local community on planting, management and maintenance, and as part of Ushaw’s wider commitment to support local families, they have provided complimentary Ushaw Annual Memberships for all those who are entitled to Free School Meals in their 12 nearest schools.

 

  1. Ushaw’s story shows exactly how heritage can foster a sense of identity for local communities, and pride in place: this was recognised through the learning & community team at Ushaw being awarded the 2024 Historic Houses Frances Garnham Award for Innovation in Heritage Education.

Wentworth Woodhouse

  1. Wentworth Woodhouse sits in a former mining area, just north of Rotherham, South Yorkshire. After being saved for the nation, the Wentworth Woodhouse Preservation Trust have worked incredibly hard to create a heritage site for the whole community, providing opportunities for people of all ages in the local area to build their skills, and be inspired by the Grade I listed building.

 

  1. With an active volunteer community, and an impressive vision, Wentworth Woodhouse is a true success story, highlighting exactly what historic houses can do to revitalise people and places.

 

  1. The above case studies are just two examples of the excellent work Historic Houses members are providing to their local communities. They are hubs that benefit local economies, centres around which community identity can be forged (including rural locations where these opportunities can be sparse), and sites of regeneration for biodiversity. They offer an example of the good work heritage assets can provide to local communities, and more specifically, the reason they need to be protected. 

Question 3a: How can heritage buildings be supported to increase energy efficiency and contribute to the Government’s net zero targets?

  1. Heritage buildings have a core role to play in helping contribute to net zero targets. Around 25% of the UK’s housing stock was built pre-1919, making the need to improve the energy efficiency of historic buildings vital if the UK is to meet its legally binding net zero obligations.

 

  1. Firstly, significant reform is required to Energy Performance Certificates (EPCs). EPCs have an important role to play in ensuring everyone lives in a warm, energy efficient home: however, EPCs measure cost, not carbon, and so often recommend measures which prioritise fossil fuels over renewables. Recommendations to improve EPC ratings are often harmful to heritage assets; a more individualised approach that takes into account the specific circumstances of listed buildings would improve this system greatly.

 

  1. Secondly, 90% of Historic Houses members believe decarbonising their property is either ‘quite’ or ‘very’ important. However, the current planning system is a barrier to this goal. 87% of Historic Houses members that wish to carry out decarbonisation work on their property view planning permission and listed building consent as an obstruction to them doing so.

 

  1. As mentioned in our response to question 1 above, the introduction of LBCOs would go a significant way in allowing owners of heritage assets to install energy-saving measures, such as secondary glazing, whilst maintaining the historic appeal of the property. This would allow built heritage owners to pursue their own net zero objectives, and go some way in contributing towards the Government’s net zero targets.

 

 

Question 4. What are the financial, regulatory and practical barriers to preserving built heritage?

  1. There are many challenges in preserving built heritage – many of which have been addressed above. These relate to the planning system, the current system of EPCs, and the imposition of VAT on repairs and maintenance.

Question 4a: What policy changes are needed to make restoring historic buildings easier and less expensive?

VAT

  1. One significant financial barrier to preserving heritage is the imposition of VAT to the repair and maintenance of listed buildings. In 2024, Historic Houses produced a report looking at VAT on repairs and maintenance to listed buildings, which we published publicly on 30 January. The report is available here. This extract, below, provides a good summary for the purposes of this inquiry.

 

  1. Looking after historic buildings is expensive. Maintenance of listed buildings require specialist craftspeople, techniques and materials. Even a like-for-like replacement, which doesn’t usually require listed building consent, is much more costly than for most normal houses. As the majority are in private ownership, their upkeep is funded almost entirely by the individuals who enjoy and care about the heritage they live in. The challenges of repairing and maintaining historic buildings are increased by the current fiscal regime. Most repair, renovation and improvement work to existing buildings is subject to Value Added Tax (VAT) at the standard rate of 20%

 

  1. Listed buildings which support the activities of commercial businesses can — mostly — reclaim VAT from repairs and maintenance work. However, listed buildings which are not registered as commercial businesses cannot reclaim VAT in this way. The heritage sector has long campaigned for reducing the VAT on the repair and maintenance of historic buildings, and this campaign broadened out further after the government removed the only significant VAT concession for historic buildings, zero-rating for ‘approved alterations’, in 2012.

 

  1. A series of reports and evidence to parliamentary select committees presented the case that cutting VAT would facilitate repair of historic buildings, to the benefit of both the national heritage and the environment. The campaign has, however, met with resistance from the government, which has consistently argued that there is little evidence that VAT is impeding repair or that a blanket reduction of VAT would provide public benefits sufficient to compensate for the resulting loss of VAT revenue.

 

  1. We would suggest otherwise. A targeted VAT rebate scheme would also almost certainly encourage beneficial reinvestment of recovered VAT expenditures into additional repair and maintenance works: the vast majority of VAT-paying respondents saying that they would reinvest 100% of any savings in more repair and maintenance works.

 

  1. Based on our evidence, we are proposing a directly targeted, fully costed rebate scheme which would reduce effective VAT rates on the repair and maintenance of listed buildings open to the public for a minimum of 28 days a year. This targeted support would not only help owners and managers of heritage tackle the huge backlog of repairs and maintenance work, but our research suggests it would provide enough of an incentive for even more properties to open for public access, generating an estimated 300,000 additional visits to historic buildings every year. It would allow owners to choose the best contractors for the job, increasing the demand for specialist heritage skills, and it would encourage almost certainly encourage beneficial reinvestment of recovered VAT expenditures into additional repair and maintenance works.

 

  1. Our research suggests such a scheme would cost HM Treasury around £5 million per year in foregone VAT revenue. It would also directly induce economic activity worth in the region of £7 million per year, as well as bringing the demonstrated wellbeing benefits of heritage-related activities, especially those involving historic buildings.

 

  1. In short: there’s a strong case for a directly targeted, fully costed rebate scheme which would reduce effective VAT rates on the repair and maintenance of listed buildings open to the public for a minimum of 28 days a year.

Planning

  1. It is also, as outlined in response to question 1, vital to address the difficulties that arise for owners of heritage assets in navigating the planning system.

 

  1. One of the overarching points is about wording in heritage legislation. Heritage policy, in the NPPF and elsewhere, has for two decades been sensibly based on the ‘conservation’ of heritage, which – vitally – allows the careful change which gives heritage a viable future. 

 

 

  1. Heritage legislation in England has not been updated to match this: it explicitly refers to duties to ‘preserve’ heritage, which override heritage policy, and against which every planning decision has to be matched, strongly discourage change, especially the vital changes needed to ensure that heritage is in viable use.

Skills

  1. Heritage skills are in short supply in the UK. Finding appropriately skilled contractors, workmen and craftspeople is difficult and costly: a topic which was explored (in part) in Heritage and Carbon, the 2022 report by Grosvenor, Historic England and the National Trust.

 

  1. Moreover, there is a lack of skilled, specialists within local authorities. As mentioned above, historic environment staff in local authorities have been reduced in large numbers since the mid-2000s.

Question 5. What policies would ensure the UK workforce has the right skills to maintain our heritage assets?

  1. Built heritage has the potential to generate thousands of jobs through green initiatives involving pre-1919 housing stock. Often, with heritage assets, a more specialised skillset is needed. The requirements and construction of historic and traditional buildings needs to be embedded in construction practice, and further training qualifications for those wishing to specialise in the retrofit of traditional buildings should be made available.

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