Retrofit or ruin: Grosvenor says dysfunctional rules prevent crucial upgrades to heritage buildings

England’s three million listed buildings and properties in conservation areas risk becoming uninhabitable, unaffordable and functionally obsolete unless ministers urgently simplify the heritage planning system to make basic, low-risk energy retrofits easier, property firm Grosvenor has warned.

In a recent report entitled Retrofit or Ruin, the company found that local authorities spend around 4,000 working days each year processing listed building consent applications for retrofit measures such as secondary glazing, insulation and heat pumps.

And while 93% of applications are eventually approved, only around 30% are dealt with in the required eight-week timeframe, which Grosvenor says slows down work that would cut carbon emissions, lower heating bills and protect heritage buildings.

At the heart of the problem is the fact that owners of protected heritage buildings must navigate two distinct but overlapping legal regimes: heritage protection and planning control.

The Planning (Listed Buildings and Conservation Areas) Act 1990 governs the protection of heritage assets and requires listed building consent for works that affect a building’s special interest. The planning system controls broader matters of use, design and impact on character.

The two regimes have complementary objectives, but in practice, owners face parallel assessment pathways that combine to make a complex, risk-averse and resource-intensive consent process that delays and discourages improvements.

The report argues that in the absence of clear national parameters defining what constitutes acceptable, low-risk change in heritage buildings, “decisions are pushed down to the local level, resulting in a patchwork of approaches in which the same intervention may be supported in one area but resisted in another”.

The problems are compounded by a lack of capacity among local planning authorities. The report cites a recent Historic England survey, in which only 16% of local authority officers said they felt “very confident” making decisions on heritage retrofit.

It’s a headache for Grosvenor, which manages some 1,500 listed buildings and has retrofitted around 1.5 million sq ft of space across its London portfolio since 2020.

“We have a £90m retrofit programme that is designed to go into properties and do interventions either when tenants are in situ or very quickly in between lettings,” Ed Green, sustainability director for Grosvenor Property UK, told CM.

“Those teams are nimble, they’re doing hundreds of projects a year and, because of the time constraints they’re dealing with, sometimes there are things they’re not able to do because they’ve found out too late that the unit is becoming available, and too late to be able to get through what is often a very slow planning process. So with a reformed system, we’d be able to do more significant interventions on more projects per year.”

Green added: “The system isn’t facilitating what the policy aims are, and getting consents to make those improvements is slow, often inconsistent and complicated, and those three things basically mean costly.”

Grosvenor says that with around 350,000 listed dwellings in England and 2.8 million homes in English conservation areas, the issue affects more than 10% of England’s total housing stock of around 25.2 million dwellings.

Simplifying retrofits at that scale would create a whole new industry that could generate around £35bn in economic output each year and support 205,000 jobs, it adds.

The report also cites independent analysis showing that retrofitting historic buildings across England and Wales could cut operational carbon emissions by up to 7.7 million tonnes of CO2 a year, equivalent to around 30% of the annual emissions reductions required to meet the UK’s Sixth Carbon Budget.

Grosvenor is calling for four measures it says would be the biggest reform of English heritage planning in more than 35 years. The idea is to shift the system from case-by-case control to what it calls “proactive enablement”.

The first, pertaining to heritage protection, is for the government to introduce a National Listed Building Consent Order. This would establish a new national baseline for automatic consent for a defined set of low-risk, high-benefit retrofit measures that have been shown to have negligible or reversible impacts on buildings’ heritage value.

Grosvenor calculates that this could save local planning authorities 30,000 hours and £1m a year.

“Councils are not paid for listed building consents so that’s a significant cost to them,” said Green. “They get a lot, and they’re very hard to deal with, and that has an impact on our viability because we know we have to wait a long time for consent for projects.”

He said a National Listed Building Consent Order would “effectively remove that hurdle for thousands of potential interventions”.

The second measure, intended for the planning side of the equation, is for the government to introduce a National Model Local Development Order. Local development orders (LDOs) allow local planning authorities to grant planning permission for specific forms of development within a defined area without requiring individual applications.

Grosvenor says a National Model LDO would draw on the established evidence base so that a given local authority would not have to start from scratch in assessing whether to grant an LDO, reducing the burden on local authorities to justify permitted works individually.

Green said a National Model LDO would be a resource for local authorities but not a prescription. “We’re very conscious that there’s a local context when it comes to planning. It’s very important for local decision-makers to retain control over some of those local factors,” he said.

A Model LDO would enshrine the expertise of central government and Historic England, allowing councils that don’t have that expertise to use it in a way that’s fit and right for their context.

“We need to remember that the local heritage community may not be happy to take exactly the same, off-the-shelf planning policy as somewhere else,” said Green.

Third, Grosvenor recommends embedding retrofit in national planning policy. As it stands, the company says, energy retrofits and climate adaptation measures are framed as risks to heritage buildings. It wants planning reforms to more explicitly position climate adaptation as an integral part of historic building conservation.

Finally, Grosvenor urges the government to launch a Heritage Capacity and Skills Programme, building on Historic England’s existing training programmes to ensure every local authority has access to qualified conservation expertise.

“There’s a longstanding mantra that we quote to each other here, which says the most sustainable building is a building that already exists,” Green said.

“So, it’s important to get existing buildings up to the best possible standard. People want to live in warm, energy-efficient homes. We don’t want to have to knock down all the existing stock and build new ones to create that.”

Tor Burrows, chief sustainability officer at Grosvenor, added: “Historic buildings only survive if they can adapt. If they are cold, expensive to run and difficult to upgrade, they risk falling into disuse. Once that happens, heritage is lost.

“The real issue now is speed and scale. Retrofitting historic buildings needs to happen across millions of buildings, not slowly, one application at a time.”