[Help] Listed Building Consent - re-roofing & insulation

[MJsGhost]

Greetings NSC hive mind!

I am going around in circles on the government planning portal & internet in general, so I thought I would ask the great and good of NSC (who have never let me down before).

Context:
I live in a grade II listed house (yes, I know, there's my first mistake). It's a semi and the slate roof is failing (nail rot AND slates at end of life), so have joined forces with next door to get the whole roof re-slated together.
We have made a listed building consent (LBC) application and the Heritage team at Wealden is now asking about insulation. It's a cold roof and if I'm honest the depth of insulation (between the joists & under the loft boarding) is not to the requirements of the current building regs for thermal resistance/energy efficiency.

Question 1:
What I gather from my research is that because more than 25% of the roof is being renewed, we must also ensure that we upgrade our loft insulation to meet current building regs and get approval for this. Am I right?

Also, Wealden's Heritage team is suggesting that we need to add the insulation upgrade to the LB consent application (which will further delay things because they are a bureaucratic nightmare and EVERYTHING takes forever, with a raft of pointless questions & back & forth between us, the planning case officer and Heritage).
I disagree that LBC is needed as I got quotes earlier in the year for reboarding the loft - raised boarding with extra insulation. I questioned all the suppliers about the need for LBC and they all said no it isn't (I took their word for it as that was the answer I was expecting). Also, English Heritage advises the following: "Loft insulation is a simple way of helping to insulate a house and many houses have already received such insulation, in almost all cases without LBC"
Question 2:
Is LBC required for the extra loft insulation?

Thanks in advance!

 

[Gabbiano]

Greetings NSC hive mind!

I am going around in circles on the government planning portal & internet in general, so I thought I would ask the great and good of NSC (who have never let me down before).

Context:
I live in a grade II listed house (yes, I know, there's my first mistake). It's a semi and the slate roof is failing (nail rot AND slates at end of life), so have joined forces with next door to get the whole roof re-slated together.
We have made a listed building consent (LBC) application and the Heritage team at Wealden is now asking about insulation. It's a cold roof and if I'm honest the depth of insulation (between the joists & under the loft boarding) is not to the requirements of the current building regs for thermal resistance/energy efficiency.

Question 1:
What I gather from my research is that because more than 25% of the roof is being renewed, we must also ensure that we upgrade our loft insulation to meet current building regs and get approval for this. Am I right?

Also, Wealden's Heritage team is suggesting that we need to add the insulation upgrade to the LB consent application (which will further delay things because they are a bureaucratic nightmare and EVERYTHING takes forever, with a raft of pointless questions & back & forth between us, the planning case officer and Heritage).
I disagree that LBC is needed as I got quotes earlier in the year for reboarding the loft - raised boarding with extra insulation. I questioned all the suppliers about the need for LBC and they all said no it isn't (I took their word for it as that was the answer I was expecting). Also, English Heritage advises the following: "Loft insulation is a simple way of helping to insulate a house and many houses have already received such insulation, in almost all cases without LBC"
Question 2:
Is LBC required for the extra loft insulation?

Thanks in advance!

It's been several years since I worked in the council planning department, so maybe others with a more up to date knowledge can correct me.

Most likely yes LBC is needed because unfortunately as a listed building you need these extra approvals even for internal works. And most likely the planning officer will make their decision completely based on the opinion of the Heritage Officer's recommendations. Heritage officers are notoriously picky and difficult.

The way to argue your way around it is to talk about where the heritage value actually lies, i.e. what does the listing actually describe and what are the features of importance. Find the policies in the local plan that talk about heritage, those that talk about climate change and those that support retrofitting etc.

It might be worth seeing if you can talk to building control about the required standards too if you're not clear on that - Building Control and Planning won't talk to each other and wires might get crossed and you find you've got approval for something that Heritage likes but BC don't.

 

[deletebeepbeepbeep]

I think you probably do need consent for the insulation but that is unlikely to be an issue assuming it does not change the external appearance and no historic fabric needs to be removed to allow for it.

In any case it now seems the Council are on the case so you may as well get on with it rather than spending time arguing the toss as I doubt they will back down.

This obviously depends hugely on your building and whether any of the internal fabric is important and whether that needs to be mucked about with.

The alternative is you throw the English Heritage advice back at them, say that the works will not change the external appearance, no internal features are being removed and that you want them to get on with determining the application on that basis.

 

[HantsSeagull]

Not sure if you are replacing roof tiles like for like that you even need LBC for that either. I live in grade 1 and took planning advice about replacing an existing window with like for like and was told no need.

 

[Elbow750]

Not sure if you are replacing roof tiles like for like that you even need LBC for that either. I live in grade 1 and took planning advice about replacing an existing window with like for like and was told no need.

Hmm, not sure about that. In Lewes, like for like window replacement needs Planning Permission in the conservation area, and Grade 2 listed buildings need Listed Building Consent as well.

In most cases its better to go along with the council rather than fight them, as they can really make things difficult if you end up fighting. I also agree with the above poster about making sure you clear everything with Building Control as well as the Planning Department and Heritage Officer. They won't talk to each other, and will stick rigidily to their own standards, even if others within their same organisation have agreed something different. Regarding the roof insulation, I'd definitely upgrade to the latest best industry standards. But be aware that older buildings often need to 'breathe' otherwise you might get condensation and damp. Building control should advise on this, but make sure you ask them. My son had this problem on his 1800's cottage.

Good luck and let us know how you get on. It's always a hassle but well worth it in the end. You'll laugh about it in 10 years time...

 

[MJsGhost]

Not sure if you are replacing roof tiles like for like that you even need LBC for that either. I live in grade 1 and took planning advice about replacing an existing window with like for like and was told no need.

We definitely need LBC for the re-roofing.
Heritage are currently mulling over whether to allow Canadian slates (c. £15k just for the slates) or insist on Welsh (like-for-like, but over £40k).

Replacing some slates doesn't require consent, but an entire re-roof does according to multiple sources & advice.

EDIT: but thanks for your reply

 

[MJsGhost]

It's been several years since I worked in the council planning department, so maybe others with a more up to date knowledge can correct me.

Most likely yes LBC is needed because unfortunately as a listed building you need these extra approvals even for internal works. And most likely the planning officer will make their decision completely based on the opinion of the Heritage Officer's recommendations. Heritage officers are notoriously picky and difficult.

The way to argue your way around it is to talk about where the heritage value actually lies, i.e. what does the listing actually describe and what are the features of importance. Find the policies in the local plan that talk about heritage, those that talk about climate change and those that support retrofitting etc.

It might be worth seeing if you can talk to building control about the required standards too if you're not clear on that - Building Control and Planning won't talk to each other and wires might get crossed and you find you've got approval for something that Heritage likes but BC don't.

Thank you.

The listing mentions the windows as the feature of interest. To be honest, there's nothing particularly special about the property, so it would have been a borderline listing.

Good point about planning/heritage and building control not communicating - the planning case officer and heritage have enough trouble with that as it is.

 

[MJsGhost]

I think you probably do need consent for the insulation but that is unlikely to be an issue assuming it does not change the external appearance and no historic fabric needs to be removed to allow for it.

In any case it now seems the Council are on the case so you may as well get on with it rather than spending time arguing the toss as I doubt they will back down.

This obviously depends hugely on your building and whether any of the internal fabric is important and whether that needs to be mucked about with.

The alternative is you throw the English Heritage advice back at them, say that the works will not change the external appearance, no internal features are being removed and that you want them to get on with determining the application on that basis.

That's probably the way we'll have to go. The amount of contradictory guidance and advice out there is crazy, but I'm going all in for English Heritage as their advice here suits me.

As just mentioned above, there's very little of significance to the property except perhaps the windows, which are entirely unaffected.

The process thus far (with this and also an ongoing planning application) makes me want to bypass dealing with these clowns as much as possible. Common sense is in short supply.

 

[MJsGhost]

Hmm, not sure about that. In Lewes, like for like window replacement needs Planning Permission in the conservation area, and Grade 2 listed buildings need Listed Building Consent as well.

In most cases its better to go along with the council rather than fight them, as they can really make things difficult if you end up fighting. I also agree with the above poster about making sure you clear everything with Building Control as well as the Planning Department and Heritage Officer. They won't talk to each other, and will stick rigidily to their own standards, even if others within their same organisation have agreed something different. Regarding the roof insulation, I'd definitely upgrade to the latest best industry standards. But be aware that older buildings often need to 'breathe' otherwise you might get condensation and damp. Building control should advise on this, but make sure you ask them. My son had this problem on his 1800's cottage.

Good luck and let us know how you get on. It's always a hassle but well worth it in the end. You'll laugh about it in 10 years time...

We've got extra ventilation covered in the LBC application already made, so we are covering the bases there already.
I am just hoping that (as per English Heritage advice) extra insulation does not require LBC so we can just push through the application as it is - every extra step seems to add months to the process and we'd like to get the roof done before winter arrives (which I guess depends on summer ever arriving first)

 

[zefarelly]

Its 25 years ago, but, my old gaff was G2 listed, thats external structural, not internal . . . I had to have a load of structural work done which was all internal. Ironically because the tiles had been changed, some decades previosly, to clays from slate and the structure spread as there was timber framed wall, all the work was roof and internal structure)

so . . My understanding is, you can change/renew the external, like for like, without consent. Just don't do anything 'different'

What you choose to do with insulation is up to you, its not part of the original building, structure or listing . . . . And its not a new building so it doesn't have to comply with latest BR's . . . By their very nature they conflict.

deciding what's best for an old house is always a challenge and a compromise.

fix the roof first, get clear of busy bodies . . . . Then insulate.

Oh, and old houses are 27.39 times better than new shit. So enjoy The fact you don't live in a chipboard shed Covered in cladding

 

[Bold Seagull]

At the time of re-roofing you need to know how you will insulate. This will inform the type of membrane you use, how the roof space might be ventilated etc.

It’s a legitimate question for heritage to ask. It might not need much detail back if it’s straight forward.

They just need to know you’re not going to be sticking projecting tile vents on it or other detailing that changes the appearance, or impacts the building fabric.

Breather membranes, vapor control layers, warm or cold roof detailing - there is some technical considerations especially to a listed building.

 

[Westdene Seagull]

We definitely need LBC for the re-roofing.
Heritage are currently mulling over whether to allow Canadian slates (c. £15k just for the slates) or insist on Welsh (like-for-like, but over £40k).

Replacing some slates doesn't require consent, but an entire re-roof does according to multiple sources & advice.

EDIT: but thanks for your reply

Could you not replace a few slates and then a couple of months later a few more and so on until the whole roof is done ? Would save dealing with council jobsworths

 

[HantsSeagull]

YOu could try this lot

Help & Advice - Listed Property

www.lpoc.co.uk

 

[Sid and the Sharknados]

Thank you.

The listing mentions the windows as the feature of interest. To be honest, there's nothing particularly special about the property, so it would have been a borderline listing.

Good point about planning/heritage and building control not communicating - the planning case officer and heritage have enough trouble with that as it is.

I've a bit of experience dealing with council heritage officers and Historic England on listed bridge works, so I just want to back up Gabbiano's point about Heritage Officers. Don't be surprised if they get hung up on things that you've been advised aren't an issue, or if they're completely unconcerned about something you'd instinctively think should be important.

They're pretty much entirely capricious and impossible to predict, even if you're actually a heritage expert.

Edit: I appreciate this isn't particularly helpful advice. I think anything else I could contribute would be too general or removed from what you're doing to be of any use.