Non-Designated Heritage Assets

Don’t have a Listed Building? How, why - and crucially, when - are buildings that fall short of local listing nonetheless identified as non-designated heritage assets (NDHAs)?

The Traditional Craft of Designing Oak Frames

Oak frames complement any style of home Many people are familiar with the idea of a building being “locally listed,” whereby a local planning authority (LPA) recognises a heritage asset of some significance, albeit not enough to meet the criteria for statutory designation. The concept of a non-designated heritage asset, however, is broader and more recent. While all locally listed buildings are considered NDHAs, the reverse is not true - raising an important question about how other buildings come to be identified as such. In practice, LPAs can designate a building as an NDHA at any stage, though most are identified only after a planning application has been submitted. This timing can create significant uncertainty for applicants at a critical point in the development process. To address this, amendments to the Planning Practice Guide (PPG) in July 2019 clarified that NDHA identification should be the exception rather than the rule. Where a building is identified, there must be clear justification and credible evidence of heritage significance. Age alone, or inclusion in a Historic Environment Record (HER), is not sufficient. As the PPG emphasises, the vast majority of buildings hold little or no heritage value, and only a minority merit recognition as NDHAs. Nationally, the approach to identifying NDHAs is inconsistent. Some LPAs maintain local lists with defined selection criteria, offering a degree of transparency. However, since local listing is not synonymous with NDHA identification, gaps in understanding remain. At the other extreme are authorities without local lists, where the process can feel unpredictable - leaving developers and property owners unsure whether a building might be designated during the course of an application. A further issue is the absence of a formal, independent appeals process for NDHA designation. Applicants must instead challenge the LPA’s judgement within the planning process itself or pursue the matter through an appeal to a Planning Inspector, which can be both complex and uncertain. This lack of clarity has prompted increased involvement from the Planning Inspectorate, with several appeal decisions in recent years attempting to apply the updated PPG guidance. However, these decisions have not always been consistent, adding to the uncertainty. Overall, the identification of NDHAs remains a complex and often opaque area of the planning system. Without clearer national guidance - particularly around thresholds of significance and consistent criteria - it is likely to remain a source of confusion and contention for the foreseeable future.

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