listed heritage-139-Final from Connor for Paperturn - Flipbook - Page 19
DE PA RT ME N T O F C U LT U R E
The Department of Digital, Culture, Media and Sport has also
seen a new minister appointed, with Nadine Dorries arriving to
replace Oliver Dowden who received a sideways move to the
role of party chair. DCMS is the primary department for heritage,
and bodies such as Historic England report to the ministry. While
they cannot change the law, they do have a great deal of impact
on policy and are involved in apportioning grants and subsidies, so
they remain an important part of government.
Dorries is a contentious figure and a strong ally of the Prime
Minister, so her arrival can be seen as an attempt for Johnson to
gain greater control over the department. However, the removal
of Dowden who had a strong interest in heritage also likely signals
that changes in policy will be more focused on the digital and
media parts of the brief.
listing decision, for Dorman Long Tower in Teeside, covered in
more depth in our news section. Regardless of the merits of the
decision, it is relatively rare that the Secretary of State themselves
intervene in listing decisions, so we will continue to monitor this
and see if this is a one off or a sign of greater political involvement.
While the Club does not welcome decisions being made by
those with little real knowledge of heritage, there are many listed
buildings like car parks and blocks of flats that are significantly out
of step with the public’s understanding of what listed buildings
are. Equally, it is not positive for the whole system to see attempts
to list buildings against their owners’ wishes, or used as a political
This may come as a relief to owners, because existing heritage
policy is reasonable enough and it is hard to imagine any radical
change being anything other than negative. The existing structures
of Historic England, Heritage Counts and the annual policy
publications from the Department of Digital, Culture, Media and
Sport are not perfect, but they are solid institutions that need
gentle shifts in emphasis rather than aggressive action.
EN ERGY P ER F OR MAN C E C ERTIF IC AT ES
Energy performance certificates are tricky topic for listed building
owners, especially in a time where energy use is one of the most
pressing issues. EPCs have become a standard part of buying,
selling and renting homes, but almost all listed buildings cannot
achieve the standards necessary. There are exemptions available
for historic buildings, but the process to get an exemption is
complex and bureaucratic and is also not guaranteed. This month,
the Club are beginning efforts to have listed buildings formerly
exempted from the EPC regime, to make them easy to sell and
use, and leaving it to owners rather than the EPC regime to
decide the best way to improve energy efficiency.
A major driver of this effort is the continuing challenges that
members have reported in Scotland, where exemptions are not
available. While not major problems for long term private owners,
members who use their listed home as a holiday let or occasional
event venue have faced real problems continuing to operate.
Over time the minimum standards required for commercial
property have increased from an E rating to a D; and some listed
buildings are simply incapable of achieving the higher rating.
In England, commercial listed building owners are able to apply
for an exemption, and can therefore avoid the challenges involved
with trying to achieve higher EPC ratings, but bafflingly the
exemption is not offered on the basis that a building is listed,
or even that is was build before 1900. Exemptions have to be
obtained by effectively proving that the building cannot possibly
achieve the required standards. That involves having the building
assessed for an EPC, considering all options to improve, and even
applying for consent to install improvements that will definitely
be rejected simply so the owner can show that the changes are
The Club has written to the new secretary of state to open a
dialogue with her office, and we aim to keep listed buildings on
her agenda in the same way as we have done with Dowden.
While she has no particular connection to built heritage she
has rather traditional views of culture, so we hope that she can
understand the value of our historic homes and the need to
We have asked her to reconsider our scheme for VAT grants,
and while we see this as a long shot, we strongly feel that this
issue must be raised with the new minister, because it is such
a critical and long running concern for our members. We have
also emphasised the need to include owners, and not just public
bodies, in discussions of heritage and listed buildings and for
official advice and support to focus on normal people.
This level of difficulty and informality is simply unnecessary, and
wastes everyone’s time. It is also not a robust exemption that
owners can count on in the long term. Just as in Scotland, the
government could decide to no longer offer the exemption
anymore. . The Club think that this is unfair as well as wasteful; for
listed buildings to have a sustainable future owners need to plan
in advance and use their efforts to maintain the building rather
than battling over their EPC.
Unlike at LUHC, DCMS have not announced any pause to
their on-going work and we do not believe that there will be
any significant changes in policy before the heritage statement
is published. The Club has been engaging with DCMS on the
statement over the past few months, and the work was quite
well developed at the re-shuffle, with little that could be seen
as objectionable to the new minister. Other work within DCMS,
specifically to the data protection act, is much more likely to be
the focus of any changes.
We are asking the Department of Business, Energy and
Industrial Strategy to simply make listed buildings legally exempt
from the EPC regime. At any point where an EPC might be
required, the owner would simply show that the building is
listed; easily confirmed by checking the satutory list; and the EPC
requirements would not apply. Since many listed homes are
demonstrably incapable of meeting the required standards, this
would not have any real impact on energy efficiency, it would just
eliminate the waste involved in trying to prove the home cannot
A particular benefit would be for owners who might occasionally
want to use their home as anything other than a home. Listed
buildings are characterful and interesting, and while not all are
viable just as an event venue or holiday let, giving owners the
choice to use their home this way to offset the costs would be a
A formal legal protection would also help to hedge against the
challenges of changing times, and the tendency of government
to forget about listed buildings when changing the law. As energy
becomes an ever more important part of our lives, it is almost
certain that minimum standards will increase, and that there
would be a desire to remove any way to avoid the scheme.
Establishing in law that EPCs are not required for listed buildings
would make it impossible for a minister to abolish the exemption
at the stroke of a pen.
There are a handful of relatively newer buildings from the 50s
and 60s that are listed and may possibly be more amenable to
being updated. However, there are vanishingly few listed homes
from this later period, and even those that do exist would
never be prevented from improving energy performance. The
lack of an EPC would simply allow the owner to make the
choice themselves, rather than being forced to pursue obviously
unacceptable changes such as modern PVC double glazing.
This issue will continue to be a major concern for all listed
building owners in the coming years. The tension will continue
to rise between the broader drive to be more efficient and the
reality that most historic features are less efficient than modern
alternatives. We see reforming the EPC regime would secure the
significant position of listed buildings and ensure that their historic
and cultural value is protected for future generations.
However, it should still be noted that one of Dorries’ first actions
on arriving at the Department was to overrule a Historic England
W E NEED YOUR HE L P
If you support our goals, tell your friends and neighbours
about our campaign and recommend they join us. Our
campaign is working to help all listed building owners
across the whole UK, and every new member strengthens
our call for reform.
Listed Heritage Magazine March/April
Club members get the full news and analysis from our
campaign in every issue of Listed Heritage, as well as the
chance to shape our campaign strategy and bring
up the issues that have affected them.
As you can imagine this task is very expensive which is
why we need your help. We’re not asking you for money,
but if you could give some thought to moving your
home insurance to the Club’s providers they will pass an
introductory fee back to us and it is this fee
that will finance our efforts.
As the policies they offer provide an exceptional
combination of reasonable cost and comprehensive cover,
it’s a true win/win situation.
Please call us on 01795 844939 or e-mail your current
policy’s renewal date to email@example.com and we’ll
contact you at the appropriate time.
Listed Heritage Magazine November/December 2021