Planning Application Support Document Suggestions
This is the basis of the template, with explanations that the NSMT recommend when we are asked for help in preparing planning applications. It should be relatively easy to adapt for most planning situations for work on thatch. The more compelling and well presented the argument the more difficult it will be for the local authority to turn down. Even if early discussions with conservation officers take place before a formal planning application is made, it is recommended that some thought has already been given to statements that will be part of the formal proposal. Get all responses from the council in writing and if the going looks like being rocky copy correspondence to your local MP copied also to Sir George Young who is the thatching Parliamentary champion.
PPG15 Requirements
Paragraphs 3.4 and 3.5 below are extracted directly from PG15 (1994 page 15), in preparing any application for listed building consent a compelling case for change will need to be provided, that directly addresses each of these points.
3.4 Applicants for listed building consent must be able to justify their proposals. They will need to show why works which would affect the character of a listed building are desirable or necessary. They should provide the local planning authority with full information, to enable them to assess the likely impact of their proposals on the special architectural or historic interest of the building and on its setting.
General criteria
3.5 The issues that are generally relevant to the consideration of all listed building consent applications are:
i. The importance of the building, its intrinsic architectural and historic interest and rarity, in both national and local terms
(‘historic interest’ is further explained in paragraph 6.11);
ii. Materials or location which justify its inclusion in the list: list descriptions may draw attention to features of particular
interest or value, but they are not exhaustive and other features of importance (eg. interiors) may come to light after the building's
inclusion in the list;
iii. The building's setting and its contribution to the local scene, which may be very important, eg. where it forms an element in
a group, park, garden or other townscape or landscape, or where it shares particular architectural forms or details with other buildings
nearby;
iv. The extent to which the proposed works would bring substantial benefits for the community, in particular by contributing to the
economic regeneration of the area or the enhancement of its environment (including other listed buildings).
Raising Local Issues
In addition to the requirements of PPG15, the points described below are ones that experience in presenting planning application for thatch have shown to add weight to the case, and have proved to be successful. It is around these points that a compelling case for change of materials or style will need to be constructed.
- Is the building listed? what the impact will be on the proposed changes on the character, appearance and future sustainability of the property. Entries for Historic/listed buildings were compiled in the mid 1970s, more often than not these make no reference to or distinction between the differing types or styles of thatching materials in use at the time. Properties are very often just described as “thatched”. This clearly indicates that there was never any intention by the authority to distinguish so precisely between the different thatching materials and styles, but to insure that where thatched roofs existed their coverings were not altered to slate or tiles as required by PPG15.
- History of early degradation and short life span of previous thatches. It is important to be able to demonstrate that the property consistently requires re-thatching at intervals shorter than the publish longevity predictions for the type of material.
- Local authority policy documents on thatch. Some local District Councils have their own thatching policy documents or local plans individual versions. These will be published on their websites, and must be referenced and quote in the application.
- In addition to the local policy and regional strategy plans local councils will also quote PPG15 in refusal notices for change of
material. The relevant part of this document is:
In Part 1 of PPG 15 - Planning and the Historic Environment 1.2 states “The function of the planning system is to regulate the development and use of land in the public interest. It has to take account of the Government's objective of promoting sustainable economic growth, and makeprovision for development to meet the economic and social needs of the community. As PPG1 makes clear, planning is also an important instrument for protecting and enhancing the environment in town and country, and preserving the built and natural heritage.” further 1.3 states “Yet the historic environment of England is all-pervasive, and it cannot in practice be preserved unchanged. We must ensure that the means are available to identify what is special in the historic environment, to define, through the development plan system its capacity for change, and, when proposals for new development come forward, to assess their impact on the historic environment and give it full weight, alongside other considerations.” - Impact on the immediate local area, the style and character of other thatched houses in the vicinity. Provide a local review and include photographs with the application.
The English Heritage thatch and thatching guidance notes (1999) focus very heavily on preserving local style and character. Page 12 of the guidance notes makes reference to the abundance of materials and techniques found in historic thatch, but the publication does note that the current range of materials and techniques has become much more limited as a consequence of a gradual process of standardisation. However in the same paragraph it is stated that “thatchers remain unparalleled in their ability among building craftsmen to adapt their practice to the demands of the task in hand. The ability of the Thatcher to solve unexpected problems of detailing by varying his techniques should be respected.”
Assessment of the alteration to the character and appearance to the detriment of a listed building is for anybody both, expert and a casual onlooker a subjective measurement based very much on opinion and assumed assessment criteria. It is a very inexact and subjective science. The National Society of Master Thatchers occasionally becomes involved in discussions with different local authority conservation officers who in making claims for the character of an area will use an historical assessment of each local area to evaluate local authority views on what is or isn’t traditional. If there is evidence to challenge the validity of claims for tradition, include these under this section.
Making the case within an historical context
Thatching as a craft has evolved over many hundreds of years. It is appreciated that the current requirement for listed building consent might be laudable in attempting to protect the visual impact of change; when a change of material or thatching style might change the appearance and character of a listed building. However, over time slavish adherence to the rules without reviewing the long term impact can be a recipe for unintended and adverse consequences. (highlight particular features of the property where this could be an issue, the condition of roof timbers or the risk of fire as examples).
In making a decision on appearance and its relationship to conservation principles, English Heritage states “Thatching is a living craft and its history is obviously still being written, and regularly destroyed, by thatchers who continue to adapt their methods and materials to the economic and material realities of the modem age. In this sense, the underlying tradition of thatching has remained unchanged and its freedom to innovate will undoubtedly be essential to its survival in the future”. This is an ambiguous statement that can be interpreted in two ways. For the survival of thatching it is essential that the latter part of the sentence is highlighted.
Experience of change
Wherever possible the National Society of Master Thatchers Limited follows up all thatch planning applications that go to appeal or have problems with gaining listed building consent. It is always worth contacting the office to ask for details of other similar cases these can then be referenced in the application.
The NSMT can provide up to date National statements on harvest and materials quality and availability. In April 2010 PPG15 was superseded by PPS5 which is allegedly designed to make the planning process simpler and more attuned to sustainability and long term viability for buildings of historical significance. The document PPS5, Planning for the Historic Environment. Historic Environment Planning Guide, Par 165 page 45. The Practice Guide is a joint publication by CLG, DCMS and English Heritage. As such, although the PPS itself has primacy in plan-making and individual planning decisions, the Practice Guide carries governmental weight and is a material consideration in planning terms.
The relevant part is “Replacement of one material by another for example on roofs may result in a loss of significance and will in those cases need clear justification”. Unfortunately The NSMT are experiencing problems at the moment with local coincils interpreting the phrase ‘Following the type and form of thatch traditional to the region” to be any thatch provided it is long straw, is giving great cause for concern and resulting in properties being rethatched in inappropriate materials and styles, and is running totally contrary to the like for like replacement policy, which the NSMT does not support either.
At present NSMT work is targetting water reed quality, particulalry in regard to post harvest handling and storage for imported material. We are working in conjunction with thatching organisations across Europe as the issues are not just confinded to the UK and are mainly as a consequence of demand out stripping supply. Problems are only occuring on a very few properties and should not be considered as a reason for not using water reed, as there are many factors that affect thatch longevity.
The Society is also working with the Broads Authority to encourage and promote the commercial production of home grown thatching water reed, current environmental projects actively discriminate against the commercial cutting of water reed and we are concerned that when all the grant aid finishes there will be no mechanism to manage and maintain reed beds. Reed cutters are already becoming as rare as bitterns.
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