Why we need to make heritage assessments 'thoroughly thorough'
The process of completing heritage assessments is not what it once was. Certain things used to be OK to say, or sufficient for the job. Not now. The margin for error is now so slim and the structure for justifying your conclusions so well established now, that there is little wriggle room. Therefore, the buzz word is “thoroughness”.
Now and again, I am asked to undertake a peer review of another consultant’s work – usually because heritage is such a ‘tricky’ area and clients or other professionals sometimes don’t much like what it tends to throw up.
At such times, and having been on the end of peer reviews myself over the years (for the same reasons), it is always with some trepidation that I commence the task because there can be a tendency for the impacts on surrounding heritage assets to be underplayed.
With regard to being thorough, we often spend quite a bit of time explaining to new clients why it is that we need to consider heritage assets which seem very distant from a particular site that they know well. In fact, quite often, the client will end up being entirely correct and we did cast the net too far. However, on many occasions, this is not the case, and the asset sitting some considerable distance away has a particular orientation that means that the development will have an effect that no-one ever imagined.
As we now fully understand the extent of setting (defined as “the surroundings in which the asset is experienced) to be as broad as it needs to be to identify harmful or beneficial effects, one cannot be lazy about such things.
When I think about checking for distant impacts, I personally always think of the designed view through the woodland at the National Trust’s Trengwainton House in Penzance towards St Michael’s Mount, where somebody somewhere really cannot have checked that the proposed intervening wind turbine would end up slap bang between the two and central in the view. The memory of seeing that always gives me a shudder and spurs me on to check further!
So, in this context, I was struck when undertaking two reviews of Heritage Statements relating to tall buildings recently – which happened to be in different parts of the same city. Such proposals are always fraught for the heritage consultant because the nature of the development implies a very wide-ranging change to townscape or skyline. However, while I understand the concept of proportionate reporting, nowhere in the policy or guidance does it suggest that it will ‘probably be fine if you don’t cover things off’.
In the first example, the site of the tall building was in a part of the city which was not bristling with listed buildings or other designations. From map assessment, the consultant had collected up the nearest assets and written the Heritage Statement based on those, with some very good research information on these particular assets in the course of concluding that no harm would arise. What the consultant had not done, however, was to consider how the 20+ storeys of height proposed might lead to other unintended appearances – particularly in views out of the city centre and from long view towards the city centre and its cluster of historic buildings in a Conservation Area. When I read the report from my desktop, I felt the shudder of a Trengwainton-like outcome looming. As you can imagine, the impact was much more extensive than had been identified and we provided an alternative report to clarify the position and enable the application for the scheme to be approved.
And that’s not me trying to be smart – for the client, this is a question of achieving a sound approval and one which is not open to legal challenge. The original report was not sound and could have been challenged because the effect of the development had not been sufficiently assessed in relation to numerous designated heritage assets.
This brings me to my second example. A tall building on the urban edge of the same city. Numerous heritage assets in visual and physical proximity to the site in its current form and, certainly, to the site in its developed form. Lots of viewpoints had been produced for townscape and visual impact assessment reasons, but an equal number of incidental views which weren’t so obvious as to require a visualisation but where there was still at least some degree of change to skyline and streetscene. That’s where things went astray, in my opinion. The headline assets were carefully assessed and levels of impact identified but the others (the ones that we were to assume were not affected) were not clearly and decisively discounted from impact. An occupant or owner of one such property, or a legal review by any separate party, could have been left feeling that an assessment had not be adequately made in relation to this listed building, with potentially serious consequences for the application.
Therefore, when my team and I are assessing the extent of assets to review for impact, we go as far as this experience and this risk suggests that we should. I don’t want anyone being left without an answer to the question at appeal: “Explain to me how you provided your assessment of the impact on the setting of Building A”. The result of this is that we are also very careful to assess assets where impacts are identified but equally careful to ‘actively discount’ impacts on assets which are further afield. This means making sure we have considered effects from those locations and then clearly stating the absence of effects. Now that the risks of not doing so are so evident now, clients are more understanding of why this work needs to be done.
There aren’t shortcuts to heritage assessments, and it’s therefore advisable to be thoroughly thorough.