Applying for Energy Efficiency and Retrofit works

Planning and Listed Building Consents

Internal works will normally require consent if the building is listed. For external works, planning permission (and listed building consent) may be required, however this is subject to designations e.g. listed building or Conservation Area, and the works being proposed.   Refer to the Planning Portal’s interactive house and When is permission required? guidance for further information regarding when planning permission is required, and contact the LPA

Heritage Statements and Heritage Impact Assessments

If planning permission or listed building consent is required, the proposal must be supported with a heritage statement, which describes the significance of any heritage assets affected. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. For example, for a listed building, if the proposed works are intrusive and result in a high number of changes, a detailed report including the historic development of the building and an understanding of the existing fabric must be provided. This may have to be supported with additional reports such as a condition survey and a structural survey. It is good practice to undertake a Heritage Statement at the outset of the project, given the understanding of significance is fundamental to forming appropriate schemes.

To understand the significance of a building, the assessment must be in line with Historic England’s Advice Note 12: Statements of Heritage Significance: Analysing Significance in Heritage Assets

Assessing Impacts of Energy Efficiency Measures

The NPPF outlines how the impact of proposals, including energy efficiency measures, should be assessed. Paragraph 195 states that local authorities ‘avoid or minimise any conflict between the heritage asset’s conservation and any aspect of the proposal.’

When assessing the impacts of energy efficiency measures to designated heritage assets, Paragraph 199 notes that great weight should be given to the conservation of the designated heritage asset, and a clear and convincing justification is required by Paragraph 200 of the NPPF. As such, whilst energy efficiency measures could be considered as a clear and convincing justification, particularly when the works are to make the building compliant with building regulations or improvements for EPC ratings, this should not be detrimental to the conservation and significance of the building or heritage asset, and great weight will be afforded to this principle. As a ‘rule of thumb’, the higher the level of harm to a designated heritage asset that will result from proposed energy efficiency measures, the greater the public benefits that are required to outweigh the harm. These public benefits will be challenging to justify at the scale of a single property.

Building Regulations

Planning permission and listed building consent only applies to certain buildings and works, however Building Regulations apply for any type of building, and is subject to the type of work being carried out.

Guidance for when approval will be required can be found here: Building regulations approval: When you need approval

Work covered by building regulations

The Building Regulations 2010 cover the construction and extension of buildings. The guidance sets out building regulations approval for may be needed for a number of alteration projects, this includes:

  • replace fuse boxes and connected electrics
  • install a bathroom that will involve plumbing
  • change electrics near a bath or shower
  • put in a fixed air-conditioning system
  • replace windows and doors
  • replace roof coverings on pitched and flat roofs
  • install or replace a heating system
  • add extra radiators to a heating system

Approved Documents for Energy Efficiency Measures

There are a number of relevant Approved Documents for Energy Efficiency Measures, including:

Approved Document L, Conservation of fuel and power, Volume 1: Dwellings

Ventilation: Approved Document F

Overheating: Approved Document O

The requirements of Energy Efficiency Measures to apply and when a building is exempt is cover by Approved Document L. Further guidance on this application of this document has been provided by Historic England: EEHB: Application of Part L of the Building Regulations to historic and traditionally constructed buildings.

Due to the impacts that energy efficiency measures and retrofit can have on the building and its performance, Approved Document F and Approved Document O also apply to minimise the risks of the project.


Key Documents and Links

Legislation and Planning Policy

Planning (Listed Buildings and Conservation Areas) Act 1990

National Planning Policy Framework, July 2021

Building Regulations

Government Advice on Building Regulations Approval

Building Regulations and Approved Documents index

Relevant Approved Documents for Energy Efficiency Measures -

Approved Document L, Conservation of fuel and power, Volume 1: Dwellings

Ventilation: Approved Document F

Overheating: Approved Document O

Local Guidance and Sustainability

UK Green Building Council Policy Map

Historic England Guidance

Advice Note 12: Statements of Heritage Significance: Analysing Significance in Heritage Assets

Advice Note 16: Listed Building Consent

Page updated: 10/07/2023

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