Written evidence submitted by Historic England
1 Introduction
1.1 Historic England is the Government’s statutory adviser on all matters relating to the historic environment in England. We are a non-departmental public body sponsored by the Department for Digital, Culture, Media and Sport (DCMS). We champion and protect England’s historic places, providing expert advice to local planning authorities, developers, owners and communities to help ensure our historic environment is properly understood, enjoyed and cared for.
1.2 Some definitions may be of assistance to the Committee. The historic environment comprises all of the physical remains of past human activity that surround us, whether visible, buried or submerged and whether especially valued or not. Heritage, in this context, is the part of the historic environment that is valued by the current generation and therefore viewed as being worthy to pass on to future generations. Heritage conservation is a set of practices seeking to balance the needs from heritage of the current generation with those of future generations and the heritage sector is shorthand for the many different organisations and their workforces that strive towards achieving that balance.
1.3 As set out more fully in paragraphs 5.1-5.5 below, a vibrant heritage sector is a positive force for local and national economies. Using the latest available national statistics (2022), 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 addition, the heritage sector supports tourism, both domestic and international, which generated visitor spend estimated at £28 billion in 2022 (CEBR, 2024).
2 Summary
2.1 Many heritage operators are struggling, with some reducing their opening hours to make ends meet. This affects older people and community activities the most. A recent survey of heritage organisations found that the biggest concerns include rising operating costs, the backlog of maintenance and repairs, difficulty in attracting visitors, the financial strain from the cost-of-living crisis and climate change adaptation.
2.2 A large proportion of listed building owners struggle with maintenance costs despite feeling a strong sense of responsibility. Publicly owned heritage sites face increasing repair backlogs, as funds are mainly used for health and safety measures rather than full restoration.
2.3 ‘Managed decline’ involves allowing heritage sites to deteriorate safely when full restoration is not possible. ‘Adaptive release’ is a newer approach where heritage sites are repurposed, often for ecological benefits. Although this may be appropriate for some heritage buildings on public land, this is not a cost-free solution.
2.4 Transferring heritage assets to local communities can be an effective way of preserving them. However, this comes with financial risks, particularly when the cost of repairs exceeds the market value of the property. To provide greater clarity and certainty, public bodies should make explicit their approach to community ownership when disposing of assets.
2.5 The overall cost of repairing England’s built heritage is hard to estimate, but just those at the tip of the iceberg – buildings considered to be ‘at risk’ because of their poor condition – have a conservation deficit of around £4.3 billion.
2.6 Heritage organisations rely heavily on visitor income to offset maintenance costs, but this model is precarious. Supplementary public funding for heritage is unpredictable and short-term, with most local authority grants lasting only a year. The National Lottery Heritage Fund is the largest source of heritage grants, but it mainly funds specific projects rather than long-term operational costs. Rather than stop/start Government capital funding programmes, strategic and targeted investment would be better for long-term sustainability in the sector.
2.7 The pandemic exposed the financial vulnerability of heritage organisations. Many are now struggling to break even, with larger organisations particularly affected by rising costs. The distribution of hardship is likely to be uneven because of the differing priority given to heritage in local authorities.
2.8 Retrofitting historic buildings for energy efficiency is crucial to achieving net-zero targets. The best approach is to maintain and adapt existing buildings rather than demolish and rebuild. More funding and training are needed to achieve appropriate energy-efficient upgrades without damaging historic features.
2.9 There is a growing shortage of skilled workers in heritage construction. Nearly half of the workforce is over 45, and few young people are entering the field. More apprenticeships and training opportunities would sustain the industry and could provide skilled jobs and contribute to economic growth. Volunteering also plays a critical role, particularly in the maintenance of historic churches and industrial heritage sites.
2.10 There is strong support amongst owners as well as the wider public for regulations to protect heritage, but local authority conservation teams lack resources which can make the process of obtaining listed building consent slow and costly. More efficient systems, such as bulk consent for routine works, could help reduce delays.
2.11 In the longer term, public funding should shift from reactive repairs to preventative maintenance. Tax reliefs or financial incentives could encourage investment in historic building conservation. VAT rates may be one option to consider but others may be as effective.
2.12 The heritage sector should align itself to a greater extent with social and environmental initiatives to attract new sources of funding based on the services that the built heritage provides.
2.13 A national forecast of heritage-related projects could be developed to provide the certainty needed by heritage construction firms to invest in the workforce and grow their businesses. Alongside this, the repair of the Palace of Westminster could be used to inspire young people to consider a career in heritage.
3 What are the most significant challenges facing owners and operators of built heritage assets, and how are they affecting what those sites can offer? What interventions are needed to prevent the managed decline of heritage assets on publicly owned land? What can the Government do to make it easier for communities or local businesses to take ownership of historic buildings?
3.1 Built heritage sites can offer a wide range of benefits to places and communities, ranging from economic prosperity through jobs creation and tourism to social impacts including community cohesion and pride in place.
3.2 The greatest concern amongst a sample of one hundred heritage operating organisations surveyed prior to the 2024 Autumn Budget Statement by insurance providers Ecclesiastical was increasing operating costs. Others in the top five concerns were:
- the growing backlog of maintenance and repair;
- the challenges of diversifying their offer to attract more visitors;
- the impact of the increased cost-of-living on earned income and, finally;
- adapting to climate change.
3.3 The considerable concern over increasing costs is corroborated by the results of the UK Heritage Pulse October 2024 survey of 227 heritage organisations in which one respondent in four had little or no confidence that their organisation could adapt to challenges around increasing costs. Research commissioned by Historic England in March 2024 to amplify the data from the UK Heritage Pulse survey indicated that the main effect of the income squeeze that was being experienced was to reduce opening hours. When asked about the impact of this, respondents identified older people as the group most affected (64%) and community activities as the main casualty (60%). Our own heritage and wellbeing work provides some case studies of the sort of activities that may be jeopardised.
3.4 With regard to owners rather than operators, a survey of over 1500 listed building owners carried out in 2022 by BMG on behalf of Historic England found that 64% of respondents struggled to maintain their listed home in spite of their very high (89%) levels of pride in their stewardship, with affordability the main reason for their struggle. Regulation was overwhelmingly (81%) supported as being necessary to protect heritage value in spite of nearly half of recent applicants reporting a poor or very poor experience of making an application for consent – an assessment that was substantially worse than the previous survey in 2017. This would be alleviated by increasing local authority planning and conservation resource (see paragraph 6.5 below).
3.5 The effect of the increasing cost of maintaining built heritage is the build-up of a backlog of repairs in both the public and private estate. In the private estate, this is largely managed by market forces, with property values reflecting condition and owners investing periodically. In the public estate, however, the same market forces do not apply. Instead, repair backlogs tend to accumulate, with money spent mainly or only on health and safety essentials. This can mean minimum repairs such as consolidating wall-tops to prevent injuries from falling fabric, but it can also mean fencing-off heritage sites either partly or completely to prevent public access while the heritage asset is allowed to continue deteriorating. Thus the ‘conservation deficit’ - the gap between the cost of repairs and the eventual market value should the building ever be disposed of (to use the language of public sector divestment) - grows year-by-year, making it ever-harder to find a viable new use.
Managed decline
3.6 A management strategy of allowing a heritage asset to deteriorate safely is often referred to as ‘managed decline’. It is an active management strategy in contrast to the passive strategy of ‘neglect’. Managed decline may be appropriate in some circumstances, such as where gradual loss is inevitable owing to rising sea level. In recent years, however, a more constructive approach has been developed labelled ‘adaptive release’ by which the heritage value of a place might best be exchanged incrementally for other, usually ecological, value so that society is to some extent compensated.
3.7 Adaptive release is an option that might be suitable for heritage assets on publicly owned land which are and which will remain unsuitable for public access, for example owing to military training needs. If these assets cannot be made useful to people, they might contribute to nature recovery. We would emphasise, however, that this is not a ‘no cost’ option – it is neither a euphemism nor a synonym for neglect.
3.8 Adaptive release is unlikely to be the optimum approach for many heritage assets on publicly owned land. The Biennial Report on the Care of the Government Historic Estate is an overview of the c.6,000 heritage assets held by many, but not all, government departments and arms-length bodies such as the Environment Agency and Forestry England. Although there is an adopted Protocol for the Care of the Government Historic Estate, which sets out the expected standards of approach to protect heritage assets, there is no specific remit for any department to enquire of other arms of Whitehall on their adherence to it. The Cabinet Office is responsible for government property and could be the logical focal point.
Asset transfer
3.9 Transferring a heritage asset from public ownership into community ownership can be a highly effective way of securing its long-term future (see example at Annex 1). Communities often have a strong appreciation of the local significance of the asset and bring with them a passion and enthusiasm. It is not a process without risk, however, and it is vital that communities understand the implications and costs associated with ownership ahead of any transfer. Where there exists a conservation deficit (i.e. an asset has a negative value owing to the cost of repairs being greater than the market value of the asset once repaired), that needs to be made transparent when transfers are sought or proposed. Assets with a negative value, cannot be used as collateral for loans, which might affect a community’s financial planning.
3.10 We would welcome encouragement for public bodies (especially strategic authorities) to have asset disposal policies that explicitly reference the potential for community groups to take on the ownership/management of assets that are being considered for disposal. Such policies have been shown to increase the opportunities for community organisations take ownership of assets previously in public ownership for the benefit of the wider community. The use of dowries should be considered so that an asset can be returned to a state in which ongoing maintenance becomes realistic for the receiving organisation.
4 How effective are the current funding and finance models for built heritage? What should long-term public funding for the sector look like?
4.1 The scale of the funding challenge for England’s built heritage is hard to measure but, as an illustration, just to close the gap between repair cost and market value – known as ‘the conservation deficit’ – for the tiny percentage of the whole that is the Grade I (one) and Grade II* (two-starred) buildings on the Heritage at Risk Register was estimated in 2015 to cost £475.4m which, owing to building cost inflation, is equivalent to £822m at 2025 prices. If a similar 4% of Grade II (two) buildings were also at risk and the average conservation deficit was £250,000, the total conservation deficit would rise by £3.5bn to around £4.3bn at current prices. This figure does not include the cost of repairs to heritage buildings that are in poor condition but not yet ‘at risk’[1].
4.2 The dominant business model for the heritage sector has long been to offset the cost of maintaining the asset through visitor income. On-site food and beverage and gift shops are often important sources of income alongside ticketing. The sector is slowly diversifying, however, by offering a range of additional services to local communities such as social prescription opportunities or social infrastructure.
4.3 Public revenue funding for the built heritage is precarious and unpredictable. Data from the UK Heritage Pulse survey, albeit from a small sample, indicates that around three quarters of organisations receiving revenue grants from local authorities have a current funding agreement only for the current year; just one in five have agreed funding for three or more years. The impact of this is that much of the energy of organisations is taken up with securing future funding instead of running the sites (see also paragraph 6.7 below). For nearly half of those organisations in receipt of regular local authority support, however, this income makes up 10% or less of their income. For only around a fifth of organisations does local authority funding make up 70% or more of their income. Some organisations also reported receiving in-kind support from their local councils, such as access to finance, IT, legal or HR advice.
4.4 For multi-site organisations such as English Heritage and the National Trust or the more managerial organisations such as the Heritage Alliance and the professional bodies (CIfA[2], IHBC, Icon etc and the national amenity societies[3]), memberships and subscriptions are important sources of income.
4.5 At the beginning of the Covid-19 pandemic, the fragility of the sector was starkly revealed; the prevailing funding model had proved insufficient to build up reserves and the sector, in general, was living ‘hand-to-mouth’. Notwithstanding the injection of funding through the Culture Recovery Fund during the pandemic, the current situation is much the same. Capital grants are usually needed for substantial cyclical repairs such as reroofing. The National Lottery Heritage Fund is by far the largest source of grant-aid for the sector. Defra’s grant budget for rural heritage is larger than Historic England’s for the whole country, rural and urban, which has reduced since 2010 and now stands at around £11m per year. At today’s prices Historic England would need a grant budget of £30.6m to reach the same purchasing power as we had in 2010 (these figures use the building cost inflation rate rather than the standard consumer prices index).
4.6 Lottery funding is hugely important for heritage, but it does have limitations. Unlike lottery funding for the Arts (distributed via Arts Council England), the National Lottery Heritage Fund only awards project-specific, largely capital funding. This has forced many sector organisations to pivot towards unsustainable business models geared towards project delivery rather than an ongoing public service; when the project ends, the funding ceases and the project team disperses. This is a structural financial threat for the sector.
4.7 Welcome as it has been in some ways, the unpredictable and short-term nature of Government capital funding programmes such as the Towns Fund and the Levelling Up Fund works against heritage construction SMEs investing in skills and it stops owners of assets developing investable propositions that involve repairs, as they cannot predict whether or when funding will be available. Unpredictable spikes in funding do not help supply chains but rather drive inflation as demand suddenly outstrips supply. A more strategic, evidence-led and targeted approach to capital investment for heritage and culture would achieve better outcomes by allowing the growth of skills and supply chains that are required to deliver the maintenance and repair of historic buildings and places over the long-term, improving the quality of delivered schemes, dampening inflationary pressures, and ensuring that the recipients of funding, especially local government, are investment-ready (knowing where, when and how to make best use of the funding for the benefits of the communities they serve).
4.8 This role of strategic direction, encouragement and support for sector development is carried out for the cultural sector by Arts Council England – indeed, it is part of ACE’s statutory duties. There is no equivalent for the heritage sector. This lack of strategic management contributes to the situation that we now see in which a significant proportion of the UK’s heritage remains in very poor condition, with nearly 5,000 nationally designated historic buildings, monuments and places at risk from neglect, decay or inappropriate development in England alone. Contiguous and sustained capital investment programmes are required to keep pace with the threats to the UK’s heritage from the effects of climate change and failing local economic markets to ensure that the public benefits of heritage are maintained and grown across the country.
4.9 The heritage sector has less fundraising capacity and expertise than arts and museums (with a few notable exceptions such as the National Trust, which is one of the most successful fundraising charities across the board, with over £100m – 16% of its income – raised from donations and legacies every year). Many heritage organisations are relatively small, often volunteer-led, and need support to be able to plan and develop good conservation projects – particularly in the early stages of design – to access larger capital grants down the line. Nonetheless, around half of the heritage organisations that responded to a recent UK Heritage Pulse survey receive 50% or more of their income from other grant-giving sources such as trusts and foundations.
4.10 As a cause, traditional heritage conservation (“bricks & mortar”) is becoming less appealing for younger generations of philanthropists, who tend to be more concerned about social and environmental impact. Heritage can play an important role in this arena but, in general, it has yet to develop its narrative to demonstrate relevance today and in the future. Partnerships between heritage organisations and charities working in these complementary fields could be an effective tool to enhance these types of outcomes.
4.11 There is also an expectation from philanthropists that responsibility for maintaining publicly-owned historic assets should sit, to a certain extent, with public budgets – whether local or national. Philanthropy can add value and enable more transformative investment; it is less likely to step into the gap created by diminishing public funding. Although there is the potential to leverage additional private investment (whether philanthropic or commercial), in our experience this needs to be unlocked by an initial match or seed funding commitment from public sources.
4.12 Taking as a whole this pen-portrait of the funding models of the sector, it is clear to us that the sector could and should do more to help itself rather than relying on public subsidy. The Heritage Recovery Plan prepared with sector representatives in February 2021 included calls to action on resilience not only for the Government but also for the sector itself, few of which have been taken forward in a concerted way. Today, we would be more ambitious still, urging sector partners to be innovative and prepared to try new business models, especially regarding the sharing of services, perhaps looking to merge where feasible. Without such innovation, we foresee a sector consisting of too many small organisations without the necessary incentive or expertise to find new ways to keep the heritage assets they look after in good condition. Adopting an approach similar to Arts Council England’s Cultural Compacts model is one way in which the heritage sector could become more resilient.
Long-term funding
4.13 Looking to the future, the key issue is finding new ways to support revenue funding. Borrowing from the doctrine now applied to support for the rural economy, a case can be made for a ‘public funds for public goods’ approach. Pilot initiatives such as Rejuvenate, Heritage Buddies and Heritage Connectors are showing how heritage-based services, in these cases linked to social prescribing, may be ways in which the heritage sector could diversify its revenue income sources. The evidence is mounting up for the social impact of heritage activities such as increasing life satisfaction and improved social cohesion. The DCMS-led Culture and Heritage Capital programme is at the cutting edge of research on how to capture robust evidence of these wider benefits that can be obtained through heritage. Using this and similar evidence, entrepreneurial organisations may be willing to develop offers based on their heritage assets, either on their own or in partnership, for public goods such as social cohesion, pride in place and civic engagement. These offers may attract public funding from local councils or, as the Architectural Heritage Fund is demonstrating with their Heritage Impact Fund, they may be attractive to social investors.
4.14 Even the more resilient heritage organisations, however, are likely to continue to need help with substantial cyclical repairs in the form of capital grants. There is a clear market failure argument for continuing public support as the spillover effects of heritage are often substantial but cannot be monetised; for example, an improved high street shopfront benefits not only the occupier and customers but also the other users of the high street who enjoy a better-quality environment. The High Streets Heritage Action Zone demonstrator project in Coventry is a clear illustration of this effect. Keeping a historic place of worship in a usable condition is another example of a heritage asset with major spillover benefits for the community, faithful or otherwise.
4.15 In order to make sure that available funding is being spent to greatest effect, Historic England is pivoting towards using small offers of grant-aid strategically alongside its expert advice to give confidence to other funders in a mixed funding package. Effectiveness can also be increased by aligning funding and expertise across cultural ALBs, as has been demonstrated in the shaping of Levelling Up Fund projects to maximise co-benefits by a pioneering inter-agency service led by Historic England and Arts Council England but also involving Sport England, the BFI, Visit England, the National Lottery Heritage Fund and the National Lottery Community Fund.
4.16 Placing decision-making closer to the source of the demand is a further way of making sure that any available funding is spent to greatest effect. In order to ensure the creative, cultural and heritage subsectors are part of the national debate about devolution, Historic England joined forces with Culture Commons and other partners to deliver a major four-nations open policy development programme to explore how these subsectors might make the most of devolution and address some of the deep-seated policy challenges we face. Detailed recommendations from this programme were published in November 2024.
4.17 Ultimately, public policy will need to put greater emphasis on prevention rather than cure – on encouraging good maintenance across the board rather than funding major repairs for a small number of ‘winners’. Working with DCMS and with the Churches Conservation Trust, we have already published user-friendly guidance aimed at encouraging ‘stitch in time’ maintenance to prevent backlogs of costly repairs from accumulating. In the longer-term, public funding may need to shift from grants for major repairs to financial incentives for maintenance. This approach is favoured in many countries including Germany, the USA and Japan, where tax reliefs are used to encourage private investment in maintenance and repair. The quid pro quo for tax reliefs could be a lower threshold for the use by local authorities of their powers to require improvements in the condition of historic buildings in poor repair. Hastings Council’s Grotbuster campaign has demonstrated how effective this approach can be in addressing the dragging down of localities by neglectful owners.
5 What role does built heritage play in the regeneration of local areas and in contributing to economic growth and community identity? How can heritage buildings be supported to increase energy efficiency and contribute to the Government’s net zero targets?
5.1 The heritage sector, which extends beyond ‘built heritage’, is an integral part of England's national economy. The economic value of heritage stems from various sectors and subsectors; from archaeology and conservation, to hospitality, construction, and public services. Using the latest available national statistics (2022), 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 (CEBR, 2024).
5.2 In addition, the heritage sector supports visitor-related spending through tourism, both domestic day and overnight), and international. Four of the top six activities of overseas visitors to Britain in 2011 were either cultural venues (castles/historic houses, museums/galleries and religious buildings) or parks and gardens. In 2022, heritage tourism surged following the COVID-19 pandemic, with sites seeing their highest-ever visitor numbers. In 2023, there was a slight drop in visitor numbers, although they remained above the pre-pandemic period. In 2023 there were 211 million domestic day visits, 14.9 million domestic overnight trips, and 17.6 million international trips to heritage attractions. These visits generated visitor spend estimated at £11.5 billion; £4.5 billion and £12 billion respectively (CEBR, 2024).
5.3 The distinctiveness of built heritage can contribute to economic growth and community identity as the basis of ‘place-branding’ with which to compete with rival centres. Examples include the Cathedral Quarter in Blackburn, Chester’s famous Rows, Birmingham’s Jewellery Quarter, the Old Town in Hull and the Royal William Yard in Plymouth.
5.4 Built heritage has a clear symbiotic relationship with creative businesses, which are in one of the main growth sectors for the UK economy; 26% of UK creative firms operate from within the 2% of the country that is designated as a Conservation Area, showing the importance of characterful built heritage to business location (Colliers International 2018). Our recent research on this symbiotic relationship identified a number of buildings at risk in or near creative clusters where a creative business use might simultaneously enable growth and sustain important heritage.
5.5 Many historic buildings (i.e. built before 1919) in urban areas remain unused or underused, especially the upper floors of retail units. We have estimated that there is capacity for 120,000 1-bed homes in the vacant spaces above shops and that there are over 300,000 vacant historic dwellings. Bringing these characterful spaces back into residential use would contribute to the urgent need for housing and, both directly and indirectly, to more economic activity.
5.6 The focus of the Committee’s inquiry, however, is understood to be the built heritage operated as a visitor attraction. Some owners and operators of heritage assets are facing significant challenges after the Covid-19 pandemic. Research for Historic England shows that fewer heritage organisations are able to break even now than was the case pre-pandemic; 10% fewer heritage organisations were making a surplus in 2023 (45%) than in 2016 (55%). Heritage organisations have fared worse than a comparator cohort of arts and culture organisations. Larger heritage organisations (especially those with income over £1m per year) are generally struggling more than smaller ones. The biggest change is in the proportion of income spent on salaries. We interpret the data to be showing that the cost-of-living pressures have suppressed trading income (e.g. tickets, gift shops and cafes) while larger organisations have also been faced with increased energy costs and employment costs yet have tended to maintain paid staffing levels in the expectation of an upturn. These organisations, since they fall outside the scope of Arts Council England, cannot benefit from revenue support as a national portfolio organisation.
5.7 Heritage is amongst the smallest components of local authority spend on culture; a representative figure for the average annual net expenditure by councils in England on heritage in 2012-22 (not including councils’ own staff costs) is £35.7m (1.3% of the total net expenditure on culture-related services. This average, however, disguises three quite different but roughly equal-sized cohorts of councils (Table 1). In one cohort (Group 1 in the table), spending on support for heritage has grown substantially (163%) over the past decade from a relatively high starting point. In Group 3, spending was low in 2012 and has diminished by over 80%. In Group 2 councils, support was once as high as in the first group but, instead of increasing, has dropped by 60%. We infer from Mycake’s analysis that it is heritage organisations located in Group 2 council areas, rather than organisations within council areas that have issued or are likely to issue a Section 114 notice, which are likely to be in greatest jeopardy, their previous support having waned over the past decade.
Table 1. Spend on heritage and culture in three cohorts of local authorities
5.8 Built heritage embodies the past achievements of communities, engendering pride and place attachment which leads to better citizenship. When its condition is allowed to deteriorate it confirms a shared sense of despair and even of collective shame at being part of a place that used to be something but is no longer. When heritage-led regeneration is proposed, it is usually welcomed by the community because it offers a release from this toxic emotion. Using the built heritage as a spearhead of regeneration can therefore build belief, trust and public support for subsequent phases of regeneration. The regeneration of the Albert Dock in Liverpool in the aftermath of the Toxteth riots of 1981 is a good example of this phenomenon. The Adams Building in Nottingham’s Lace Market is another.
5.9 The recently completed High Streets Heritage Action Zone (High Streets HAZ) programme, funded by the MHCLG and DCMS with support from the National Lottery Heritage Fund and Arts Council England and delivered by Historic England, provides an effective and popular model for the regeneration of local areas. Provisional evaluation results are showing that over four years the £92m programme levered-in an additional £140m for improvement work, created 44,000 square metres of additional commercial floorspace, restored 462 historic shopfronts, improved the equivalent of 17 football pitches worth of public realm and bucked the trend of declining footfall in retail centres. More than 2.7 million people celebrated the rediscovery of their high streets through the accompanying cultural programme, successfully changing people’s perceptions of their local high street. Harder to measure but equally important is the legacy of skills and experience built up through the High Streets HAZ programme which we continue to nurture as an on-line community of practice so that it can contribute to future regeneration initiatives.
5.10 The character given to a place by its built heritage is cherished by local communities - in a nationally representative survey of 2,000 members of the public, 81% of people said that ‘looking after historic buildings, monuments and archaeology to safeguard the places people love’ was personally important to them (Britain Thinks, 2022). Using this historic character to shape new development using the planning system is one of the ways in which change and growth can gain the support of the community and reduce objections. Historic England responds to around 17,000 cases per year, in 28% of these cases with detailed and tailored advice. The multi-award winning Princesshay development in Exeter, the design of which benefitted from major input from Historic England, is an example of how modern design can fit into the heart of an historic city and be embraced by the community.
Energy efficiency
5.11 The former president of the American Institute of Architects, Carl Elefante, is often quoted as having said: ‘The greenest building is the one that already exists’. A report by the US National Trust for Historic Preservation in 2016 found that it can take 80 years for a new building that is 30 per cent more efficient than an average-performing existing building to overcome, through efficient operations, the negative climate change impacts related to the construction process.
5.12 Retaining most historic buildings and adapting them for new uses, therefore, rather than wasting the embodied carbon they hold by demolishing and rebuilding, is the only realistic pathway to net zero by 2050. The management of this process will need a partnership between the development sector and local authority planners, including conservation officers. Historic England is playing a part in supporting a more collaborative approach through its expert advice and through practical guidance such as Heritage Works for Housing. It is essential, however, that there is sufficient capacity in the planning system to enable planners to play a constructive part. We welcome the announcement in the autumn budget 2024 of £46m of extra funding to recruit and train additional planning officers but a proportion of this funding needs to be allocated for conservation expertise if the planning process is to be accelerated.
5.13 Historic buildings, where well maintained with appropriate materials, are more resilient to our changing climate and will waste less energy than those poorly maintained or altered with inappropriate modern materials. Historic England has published clear and concise guidance for owners and occupiers on suitable measures to reduce energy consumption and therefore lower bills.
5.14 We advocate a ‘whole building approach’ to increasing energy efficiency. Historic buildings (generally those constructed before 1919, after which traditional building techniques were rapidly superseded) need to be understood as systems; altering one part of the system without regard for how the rest of the system is affected is unlikely to prove successful and can lead to adverse consequences (maladaptation). Improving insulation without also improving ventilation, for example, is likely to lead to increased mould growth, as case studies published on our website illustrate.
5.15 This whole building approach requires training, not just for retrofit assessors, but for all parties in the supply chain, especially those who will work on heritage buildings. Research by Grosvenor in collaboration with the Crown Estate, Historic England, the National Trust and Peabody published in 2023 quantified the skills gap if the national historic estate is to be made more energy efficient. The analysis points to the need for an additional 105,000 full time workers to retrofit historic buildings each year through to 2050. This is on top of the 100,000 already working in professions associated with the retrofit of historic properties. Historic England has developed an interactive map to break down the demand by region and local authority to assist with supply planning. For example, the South West of England needs an average of 10,000 additional full-time equivalent workers per year to meet the demand, supporting an estimated £1.3bn in direct economic output by 2050.
5.16 Historic England supports the development of improved regulations and standards for historic buildings and/or buildings of traditional construction, to ensure that appropriate energy efficiency improvements are made to all buildings, whilst ensuring that they are also resilient to climate change hazards such as flooding and overheating. There is a need, however, to improve the process around Energy Performance Certificates (EPCs) and to improve the understanding of the exemption that is often claimed in relation to listed buildings.[4]
5.17 We are aware that there have been instances when listed building consent has been refused for energy efficiency measures that appear to do little or no harm. Whilst it is the prerogative of local authorities to assess the balance of harm and public benefit, in the interests of consistent decision-making Historic England has recently produced guidance and training to provide clarity on approaches to improve the energy efficiency and support carbon reduction of historic buildings, whilst conserving their significance.
6 What are the financial, regulatory and practical barriers to preserving built heritage? What policy changes are needed to make restoring historic buildings easier and less expensive?
Financial barriers
6.1 Historic England appreciates that the financial risk to local planning authorities of using their planning powers in extremis to protect and repair heritage assets is a barrier to their more frequent use. The preparation of the necessary paperwork involves considerable time and small mistakes in the process can lead to abortive expenditure. As well as providing detailed guidance to councils on how to minimise this risk, Historic England can underwrite the costs through offering grant-aid should the costs not be recoverable as they would normally be. We also welcome measures introduced in the Levelling Up and Regeneration Act 2023 that reduce the financial risk attached to the use of Compulsory Purchase Orders and have commissioned research to explore how these powers might best be used to unlock the potential of redundant buildings such as textile mills for housing, health or educational use.
6.2 The use of these powers is rare; the vast majority of owners do the best they can within their resources. In our most recent survey of 1,678 owners of listed homes in 2022, 57% of respondents agreed with the proposition that it was difficult to afford the cost of carrying out maintenance and conservation work, 26% neither agreed nor disagreed and 16% disagreed. At the same time, 86% said that they were able to keep on top of necessary maintenance and repair work. From this we infer that cost is not preventing owners and occupiers from carrying out necessary repairs – their pride in their home (89% positive) and belief that it is important to the character of their local areas (also 89% positive) outweighs their concern over cost when they are deciding whether or not to spend on repair and maintenance.
6.3 It can be difficult to find skilled contractors to carry out repairs but, overall, our recent sector skills analysis shows that supply and demand in relation to the conservation of England’s built heritage are currently in equilibrium. It is the availability of funding and therefore the demand for skilled workers that caps the amount of work done. If there were to be an injection of capital funding for repairs, we would expect a new equilibrium to be established following a period of adjustment in which demand may exceed supply, leading to some inflationary pressure.
Regulatory barriers
6.4 Our survey of owners of listed buildings showed overwhelming support (81%) for the proposition that ‘the requirement to obtain listed building consent is important to protect the special architectural and historic character of the property’ and only 7% disagreed. We drilled deeper into people’s experience of seeking listed building consent; of 423 recent applicants, 44% had had either a poor or very poor experience, compared with 33% in 2017. Dissatisfied applicants reported lengthy delays, difficulties with getting advice and onerous application requirements – 36% of 226 respondents said that they had been put off from applying for listed building consent by the cost of obtaining the necessary drawings and supporting information such as Statements of Significance and Design and Access Statements.
6.5 The regulatory system is, therefore, a barrier to conservation for at least some owners and occupiers. We contend, however, that it is the operation of the regulatory system and not the system itself that is the barrier; capacity within local authority historic environment teams has shrunk considerably over the last decade, with a long-term decline between 2006 and 2018 where the number of conservation or archaeological specialists fell by 35%, since when it has flat-lined. It is not just numbers – the Institute of Historic Building Conservation points to the loss of senior staff and the consequent wealth of knowledge and experience that is no longer available.
Practical barriers
6.6 Evidence on practical barriers can also be drawn from our survey of listed building owners. We asked, ‘Who would be your first port of call if you were looking for information about repair and maintenance?’ Of the 1,678 respondents, 34% said a builder or craftsperson, 18% would look to their local authority and the next highest was ‘don’t know’ at 12%. Accessing reliable advice, therefore, is a practical barrier for many people, especially first-time repairers who may be unwary of unqualified advisers providing inflated cost estimates. The services of an accredited Conservation Architect are likely to be a good investment for all but the smallest of repairs.
6.7 Lack of capacity amongst heritage sector managers is a second significant practical barrier to better heritage conservation. This links to the impact of the dominance of capital over revenue funding described in paragraph 4.3 above. When managers’ time is consumed by seeking the next source of project funding, their capacity for innovation is necessarily limited. We have highlighted our view in paragraph 4.11 that there needs to be less reluctance to consider new models, including sharing of services between organisations or actual mergers rather than lapsing into grant dependency.
Policy changes
6.8 Historic England takes the view that streamlining the heritage protection system is required rather than watering it down. We are committed to working closely with MHCLG and DCMS to reform planning policy to improve the speed, consistency and quality of planning decisions. Fewer applications need to be made when there is clarity amongst regulators over the types of work that do not require consent, such as that provided in our guidance on adapting historic buildings for energy and carbon efficiency. Section 4 of that guidance makes it clear which adaptations we consider would normally require consent and which would not. Secondary glazing, for example, which can outperform double-glazing in many cases, is not likely to require consent.
6.9 Our guidance also points out that there are other routes to permissions in addition to individual listed building consent applications. A Local Listed Building Consent Order (LLBCO), for example, allows a planning authority to grant listed building consent for routine or minor changes, such as the fitting of solar panels, to any identified listed buildings in their area over an extended period. This would quickly strip a substantial number of applications out of the system, leaving expert staff more available to give advice to owners on more complex alterations. The up-front cost to local authorities would quickly pay back in efficiency savings; for example, if a local authority processes 100 applications annually for similar works, and the LLBCO eliminates 80% of those, staff costs and administrative overheads can be reduced proportionately on this task and redirected to others. A payback interval of 1-3 years is realistic.
6.10 Even more strategically, national-scope Listed Building Consent Orders (LBCOs) could be used to allow works which would otherwise require a series of applications for listed building consent to be dealt with by a single consent mechanism. A pioneering example is being developed[5] in partnership with the Canal and River Trust which would mean, for example, that they need not submit repetitive applications for works to the many hundreds of more-or-less identical canal bridges in their estate because they would already be granted consent by the Order. At the same time, the local planning authorities would need to process fewer listed building consent applications for minor works. Where applied to groups of buildings which sit in more than one local planning authority or which are nationally distributed in this way, an Order would have the potential to ensure consistency in handling consented work and in assuring the standards of those works.
6.11 Some streamlining like this requires no new policies but more use of existing powers. Other streamlining would require policy change, such as empowering local authorities to delegate authority to qualified professionals to sign off conditions attached to planning and listed building consents, for example matching replacement bricks to original ones or selecting an appropriate mortar mix. This would reduce the frustration of waiting for the council’s conservation officer to be available, which can cause costly delays and unhelpful inconvenience to occupiers.
6.12 We are working with developers, major estates and heritage membership organisations to review heritage protection policy and jointly to develop new ideas for streamlining policy and practice to make it easier to repair, adapt and reuse historic buildings and places. The objective is to ensure that the economic, social and environmental benefits of heritage can be accessed with as little hinderance as possible – getting the right balance between sustaining what is significant whilst also ensuring buildings and places can continue to adapt and grow to meet our economic, social and environmental needs.
6.13 Notwithstanding these suggestions about streamlining, there is a clear consensus amongst both developers and regulators that too much capacity has been stripped from the heritage protection system to allow it to work properly. As stated in paragraph 5.6 above, we welcome the announcement in the autumn budget 2024 of £46m of extra funding to recruit and train additional planning officers but a proportion of this funding needs to be allocated for conservation expertise if the planning process is to be accelerated.
6.14 One of the long-advocated ways of reducing the cost of repairing historic buildings would be to restore the exemption from VAT that prevailed until 2012 or to equalise VAT on new build and alteration of existing buildings at 5% so that demolition and rebuild was not incentivised. Historic England accepts that the case for changing the VAT regime is not yet compelling enough to succeed in persuading the Treasury. Whilst we continue to work with sector partners on developing that argument, we consider that there are alternatives that might be as effective in encouraging owners to invest in the repair and maintenance of historic buildings. These include better dissemination of existing reliefs available to historic property owners, exploring other fiscal incentives such as a tax credit scheme for maintenance spend and using innovative finance options such as the retrofit carbon credits being developed by the Housing Associations’ Charitable Trust (HACT) and PNZ Carbon.
7 What policies would ensure the UK workforce has the right skills to maintain our heritage assets?
7.1 Our 2024 Skills Needs Analysis clearly indicates that the heritage construction sector is not bringing on new recruits at the rate necessary to replace our aging workforce; 43% are aged 45+ and just 14% of companies employ staff under the age of 25. Only a third of respondents to our survey currently employed a trainee or apprentice.
7.2 Whilst the streamlining measures and incentivisation of repairs discussed above will address some of the demand-side issues, if this is not coupled with urgent and significant investment in upskilling and growing the construction workforce, the benefits will not be realised. Tilting the equilibrium of supply and demand in the heritage construction sector runs a substantial risk of unintended negative consequences, either fuelling a ‘cowboy economy’ in which repairs are carried out by unqualified people to the detriment of the heritage or simply driving prices up further.
7.3 A package of incentives is therefore key, both of financial and administrative support, to encourage greater numbers of craftspeople to pass on their skills and replace the aging workforce. The biggest challenge, and the area which could have the biggest positive impact, would be enabling and encouraging heritage construction firms to take on new trainees. Heritage construction companies are often micro businesses that do not have the financial or administrative capability to take on trainees. On the job training – typically informal, not attached for a formal qualification – is, however, by far the most popular form of training within the sector. What is needed is a network of training co-ordinators to whom the micro-businesses can turn for support.
7.4 A visible medium-term pipeline of investment would provide the confidence that specialist construction firms need to grow; at present, they are reluctant to take the chance of growing their operations as there are insufficient assurances that enough new work will be available. Historic England would therefore encourage the Government to work with major sector partners to co-ordinate a forecast of repair and adaptation programmes at a strategic level to inform supply planning. Such a pipeline would also make business planning for higher education providers easier.
7.5 Increasing the flexibility of the apprenticeship levy to enable its use for a wider variety of training and upskilling options, alongside a concerted effort to simplify communications and logistics around its use, will increase its efficacy in meeting the immediate and longer-term needs of the heritage construction workforce. We would urge that the revised Growth and Skills Levy is accessible for use when employing career changers, whereas apprenticeships are perceived to focus on young people. This would increase its use in our heritage construction sector, as well as potentially improve the retention rate of apprentices.
7.6 In some parts of the heritage sector, volunteering is crucial for the maintenance of heritage assets. This is especially the case for England’s historic places of worship, which are managed and maintained by thousands of volunteers who give their time and raise money to make them fit for use. There are several organisations, including the Society for the Protection of Ancient Buildings and the National Churches Trust, that give practical advice on maintenance. A second part of the sector that is highly dependent on volunteers for maintenance is working industrial machinery such as pumping stations. The need to train a new generation of volunteers is becoming increasing urgent as existing ones approach retirement. We welcome the Plan for Action published by the Institute of Conservation in 2023 in this regard.
7.7 Finally, to tackle the retrofit and wider repair and maintenance challenge, the sector could be supported and encouraged to bring in early career entrants. Restoration & Renewal (R&R), the proposed multi-year programme to restore the Palace of Westminster, would be a great opportunity to advertise heritage construction skills as a career path. This would turn on its head recent public comment on the fear that R&R would absorb all the country’s skilled workers to the detriment of all other projects. Could schools in the UK be enabled to visit the works in progress, not only to encourage an appreciation of the ‘Mother of All Parliaments’ – a World Heritage Site – but also to inspire young people into considering a future in preserving the past?
ANNEX A: Example of a successful Community Asset Transfer
Saltdean Lido Community Interest Company (CIC)
Saltdean Lido is the only Grade II* listed coastal lido in the country. Designed by RWH Jones and opened in 1938, its unique streamlined design encapsulates Britain’s modernist and social aspirations of the time for creating seaside architecture for the enjoyment of the masses.
Saltdean Lido CIC (a not-for-profit community interest company) has a 60-year lease for the site, and with support from the National Lottery Heritage Fund, Historic England, the local community, Brighton & Hove City Council and others has brought new life and a sustainable future to the previously neglected building. The building has been restored and refurbished so that the lido complex functions as whole again. They have brought new life to this unique building creating a destination venue for visitors to come and enjoy all that the 1930s Art-Deco lido movement promised, while also serving to be a vibrant community hub for all those volunteers who have worked so hard to bring this restoration project about.
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