Revisions are being proposed to the National Planning Policy Framework (NPPF) to strengthen heritage protections and provide greater clarity around assessment requirements. For owners of listed properties and for developers working on sites with archaeological or historic interest, these updates offer opportunities to engage more confidently with the planning process. Below, we outline what the changes mean and how they may shape your upcoming projects.
Key changes in heritage policy:
- Removal of ‘Optimum Viable Use’ – previously, this concept allowed flexibility in determining the most practical use for heritage buildings. Its removal signals a stronger emphasis on preserving heritage significance over purely functional considerations.
- Recognition of carbon reduction as a public benefit – the reuse of listed buildings is now explicitly acknowledged as contributing to sustainability goals. This aligns heritage conservation with broader environmental objectives, encouraging adaptive reuse rather than demolition.
- Mandatory Local Lists of Non-Designated Heritage Assets – local authorities would need to maintain lists of non-designated heritage assets, providing greater transparency and predictability for developers.
- Universal Requirement for Heritage Impact Assessments (HIAs) – applicants must produce HIAs for all designated and non-designated heritage assets, ensuring systematic evaluation and reducing ambiguity in planning decisions.
- Clearer harm assessment framework – the revisions eliminate the somewhat confusingly phrased ‘less than substantial harm’ category, requiring impact on designated heritage to be classified as a positive effect, harm, substantial harm, or total loss. Policy HE5 includes reference to proposals being judged to have ‘no effect’. Importantly, harm is judged by its effect on the asset’s significance—not by the scale of development.
Implications for Developers and Property Owners
These changes aim to strike a balance between conservation and development. There would be greater certainty in decision-making with clearer definitions of harm categories that should reduce ambiguity, making planning outcomes more predictable.
Any proposal that affects heritage assets must be accompanied by a proportionate Heritage Impact Assessment. Seeking early advice on the significance of the heritage involved can help de‑risk projects by ensuring that emerging designs respond appropriately to that significance.
There is clear support for sustainability embedded within the document. In particular, by recognizing carbon reduction as a public benefit, the policy encourages adaptive reuse and long-term viability of heritage buildings.
The requirement of each Council to have a Local List of Non-Designated Heritage Assets provides greater transparency to applicants – knowing which assets are considered significant helps developers plan more effectively.
Our practical advice for navigating the changes:
- Engage early with heritage advisors – early consultation can help identify potential risks and streamline the approval process.
- Prepare for detailed assessments – factor in time and budget for comprehensive Heritage Impact Assessments, even for non-designated assets.
- Monitor local lists – stay informed about local heritage asset lists to avoid surprises during planning.
- Align with sustainability goals – highlight how your project supports carbon reduction and adaptive reuse—these are now recognised as public benefits.
Final Thoughts
The NPPF heritage revisions represent a significant shift toward stronger conservation measures and sustainability integration. For developers and property owners, the key takeaway is clear: plan ahead, seek expert advice, and embrace adaptive reuse as a strategy for success.
Author
- Rachel Fletcher – Heritage Associate, Edgars
Our highly knowledgeable heritage and planning team at Edgars can support you in navigating development within historic settings by providing proportionate assessments of significance and heritage impact assessments, collaborating with you and your project team, and engaging with the relevant stakeholders to de-risk projects and applications.
Back to news