(see towards foot of page for weblinks to heritage policy and guidance)
The relevance of Looe's past to its future...In this section of the blog we've been focussing on Looe's historic environment and sharing ideas/ making suggestions as to how this irreplaceable resource can be supported and hopefully enhanced. Initially we look at what protection is given by planning policy.
Looe's maritime heritage is an invaluable asset to the town, both in terms of giving the community a sense of pride and identity and also by providing a unique selling point for business and leisure/ tourism sectors. The Government recognises the benefits of conserving and enhancing the historic environment in Section 12 of its National Planning Policy Framework (NPPF) as follows:
NPPF Policy 16 (Paragraphs 189 to 208) Conserving and enhancing the historic environment
- Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats.
- In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance.
- In developing this strategy, local planning authorities should take into account the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring.
Cornwall Council has also addressed the historic environment in the Cornwall Local Plan (CLP) as follows:
Policy 24: Historic environment
Development proposals will be permitted where they would sustain the cultural distinctiveness and significance of Cornwall’s historic rural, urban and coastal environment by protecting, conserving and where appropriate enhancing the significance of designated and non-designated assets and their settings.
Development proposals will be expected to:
Policy CL9: Areas of Great Landscape Value (saved from the Caradon Local Plan)
Proposed development in the Areas of Great Landscape Value identified on the Proposals Map will not be permitted if it would materially harm the character of the particular area and if it does not closely reflect the traditional building styles and local materials, or the characteristic pattern of settlement, in the particular area.
Development proposals will be permitted where they would sustain the cultural distinctiveness and significance of Cornwall’s historic rural, urban and coastal environment by protecting, conserving and where appropriate enhancing the significance of designated and non-designated assets and their settings.
Development proposals will be expected to:
- sustain designated heritage assets;
- take opportunities to better reveal their significance;
- maintain the special character and appearance of Conservation Areas, especially those positive elements in any Conservation Area Appraisal;
- conserve and, where appropriate, enhance the design, character, appearance and historic significance of historic parks and gardens;
- conserve and, where appropriate, enhance other historic landscapes and townscapes, including registered battlefields, including the industrial mining heritage;
- protect the historic maritime environment, including the significant ports, harbours and quays.
Policy CL9: Areas of Great Landscape Value (saved from the Caradon Local Plan)
Proposed development in the Areas of Great Landscape Value identified on the Proposals Map will not be permitted if it would materially harm the character of the particular area and if it does not closely reflect the traditional building styles and local materials, or the characteristic pattern of settlement, in the particular area.
Looe's Conservation Area
Conservation areas have a prestige value and provide a means of protecting the sustainability of communities and their cultural and economic vitality. The centre of Looe was first designated a conservation area in January 1973 under the Town and Country Planning Act as follows:
"for the purpose of conserving and enhancing the architectural and historic character of the designated area as a whole and to ensure that special regard is is paid to the architectural and visual qualities of the area when proposals for development are under consideration"
Conservation area designation confers planning controls which include:
Looe's conservation area has twice since 1973 been extended to what it is today.
The map below shows Looe's Conservation Area (excluding the Hannafore extension)
Article 4(2) Direction
- the requirement in legislation and national planning policies to preserve and/or enhance
- local planning policies which pay special attention to the desirability of preserving or enhancing the character or appearance of the area
- control over demolition of unlisted buildings
- control over works to trees
- fewer types of advertisements which can be displayed with deemed consent
- restriction on the types of development which can be carried out without the need for planning permission (permitted development rights)
Looe's conservation area has twice since 1973 been extended to what it is today.
The map below shows Looe's Conservation Area (excluding the Hannafore extension)
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| Map derived from >> Looe Conservation Area Appraisal Appendix 1 |
Article 4(2) Direction
In order to help sustain the quality of Looe's historic environment the local authority has introduced an Article 4 Direction for Looe which results in 'permitted development' rights being removed for properties within the zone shaded green on the map above.
The Article 4 Direction requires a planning application to be submitted for any of the following developments to an unlisted property which would front a highway, waterway or open space:
- the enlargement, improvement or other alteration of a house
including the alteration to or replacement of windows and doors of a house - the alteration of a house roof, including re-roofing
- the erection or construction of a porch outside any external door of a house
- the erection or demolition of a gate, fence, wall or other means of enclosure within the grounds of a house
- the painting or rendering of walls and other minor works.
Planning permission is also required for the erection, alteration or removal of a chimney on a house, or on a building within the grounds of a house.
What are the implications of the Article 4 Direction?
The removal of the normal 'permitted development' rights and the requirement to obtain planning permission in the above cases gives local authority officers an opportunity to provide guidance to owners on changes to the outside of properties that are appropriate for the conservation area.
Planning applications for alterations that would not preserve or enhance the character or appearance of the conservation area such as; replacing traditional window frames with aluminium or uPVC, altering the proportion of traditional windows to a modern layout or replacing traditional wooden doors with synthetic replica doors will normally be recommended for refusal.
The Council will not normally approve the loss or replacement of important or traditional features with modern ones, and is unlikely to allow the use of inappropriate substitute materials such as aluminium or plastic. Where modern materials have replaced traditional ones in the past, it is expected that the correct original materials and details will be restored when circumstances allow or when further replacement is needed.
We advise you always to consult Cornwall Council's planning team (tel 0300 1234 151) if you are proposing to carry out alterations or other building works in the Conservation Area.
Are there additional requirements if a Listed Building?
Planning applications for alterations that would not preserve or enhance the character or appearance of the conservation area such as; replacing traditional window frames with aluminium or uPVC, altering the proportion of traditional windows to a modern layout or replacing traditional wooden doors with synthetic replica doors will normally be recommended for refusal.
The Council will not normally approve the loss or replacement of important or traditional features with modern ones, and is unlikely to allow the use of inappropriate substitute materials such as aluminium or plastic. Where modern materials have replaced traditional ones in the past, it is expected that the correct original materials and details will be restored when circumstances allow or when further replacement is needed.
We advise you always to consult Cornwall Council's planning team (tel 0300 1234 151) if you are proposing to carry out alterations or other building works in the Conservation Area.
Are there additional requirements if a Listed Building?
Yes, Looe has many nationally important buildings that are listed for their special architectural and historic interest. Irrespective of the Article 4 (2) direction, Listed Building Consent is required for all works of demolition of a listed building, or for its alteration (inside or out) or extension, which is likely to affect its character as a building of special architectural or historical interest.
Are there controls on trees in Looe's Conservation Area?
Yes, if you are thinking of cutting down a tree or doing any pruning or root work you must notify Cornwall Council at least 6 weeks in advance by completing the apply to work on protected trees form. This is to give the Council time to assess the contribution the tree makes to the character of the Conservation Area and decide whether to make a Tree Preservation Order.
It is an offence to carry out the work within that period without the consent of the Council.
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What national planning policy applies to planning applications in a Conservation Area?
For applications in the Conservation Area it should be noted that the National Planning Policy Framework (NPPF) states:
194. In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. 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. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.
197. In determining applications, local planning authorities should take account of:
(a) the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation;(b) the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and(c) the desirability of new development making a positive contribution to local character and distinctiveness.
199. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.
202. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.196. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.
See NPPF Chapter 16 Conserving and Enhancing the Historic Environment
If you think your proposals might affect a designated heritage asset (including a listed building or a conservation area) in any way then it would be advisable to get expert advice on whether you need to prepare a heritage statement in support of your planning application.
Cornwall Council has a 'Validation Guide'' which lists the required documentation to accompany a planning application, see here... Cornwall Validation Guide
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The Importance of Monitoring and Enforcement
English Heritage advises that Article 4 Directions are more likely to be effective if:
It is unfortunate that in recent years the implementation of Article 4 has not been as effective in Looe as one would have hoped. Many examples of unauthorised alterations have slipped through the net and the prevalence of poorly executed 'improvements', often designed by double-glazing salesmen, has degraded many of the town's buildings. English Heritage advises that Article 4 Directions are more likely to be effective if:
- there is a dated photographic record of the properties affected for the purposes of tracking any subsequent changes;
- guidance is provided for homeowners on how the direction affects them with advice on appropriate repair and alteration;
- the local authority undertakes regular monitoring for compliance and appropriate enforcement;
- the need for the article 4 direction is reviewed if circumstances change.
s u g g e s t i o n . . .
This a situation that could be reversed in time given the will, and we would be glad to support a publicity drive to raise local awareness, via say a circular delivered to all property owners in the area, and with links to further guidance on the web.
When the opportunity arises we would encourage the re-instatement of lost architectural features, along with the removal of previous unsympathetic changes to buildings.
To assist the process we support the creation of a photographic record of every building within the Conservation Area boundary. This would be publicly accessible in the same way as English Heritage created their "Images of England" website for listed buildings and we envisage a similar "Images of Looe" web-based photo log for Looe.
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the impact of building alterations on property value:
We believe it is in all our interests to raise awareness locally of the opportunities that exist for improving property in a manner that is sympathetic to Looe's character areas. This applies just as much to a building that has been spoilt in the past with inappropriate works as to a building that is still intact.
The asset value of a property may at first appear irrelevant to 'conservation' but it actually helps with its acceptance as a viable concept. Reinstating authenticity and investing in conservation measures through re-installing correctly detailed windows for example is a good long-term investment and will result in raising the value of the property and the status of the area generally.
Estate agents suggest that, on the other hand, using poor facsimiles of historic features can actually reduce the value of a property. A national survey of UK estate agents carried out by English Heritage found: "Unsympathetic replacement windows and doors, particularly PVCu units, is the single biggest threat to property values in conservation areas."
Of the estate agents surveyed, 82% agreed that original features added financial value to homes and 78% thought that they helped houses sell more quickly. This is a significant opportunity for homeowners, particularly those in conservation areas, because houses in these areas sell, on average, for 23% more than houses elsewhere according to research carried out on behalf of Historic England.
See Appendix A at foot of page for more information from Historic England.
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| Map derived from Looe Conservation Area Appraisal >> Part 4 and Part 5 |
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Listed Buildings in Looe's Central Area…
see also > britishlistedbuildings.co.uk/looe/map
and Cornwall Industrial Settlements Initiative (CISI) > CISI Looe report
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Below is a statement from Cornwall Council's Historic Environment Team . . .
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BELOW IS AN EXCERPT FROM... THE CORNWALL LOCAL PLAN (ADOPTED NOV 2016)
and Cornwall Industrial Settlements Initiative (CISI) > CISI Looe report
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Below is a statement from Cornwall Council's Historic Environment Team . . .
"Unfortunately, at the present time, we do not have the resource to be able to comment in detail on applications in conservation areas and are prioritising our Listed building casework.
We draw attention to part 1 s.72(2) of the Planning (Listed Buildings and Conservation Areas) Act 1990. This sets out our duty in the exercise of planning functions within conservation areas and states 'special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area'.
Applications should be determined in accordance with paragraphs 58, 60, 61 and 64 of part 7 and paragraphs 131, 132 and 137 of part 12 of the NPPF and the relevant local policy.
We also refer you to the guidance contained within the Cornwall Design Guide and the Looe Conservation Area Character Appraisal and Management Plan."This means that Cornwall Council is not able to provide the guidance that we would have hoped for and we suggest that it will be down to the local community to take a more prominent role and actively promote conservation matters in their area.
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BELOW IS AN EXCERPT FROM... THE CORNWALL LOCAL PLAN (ADOPTED NOV 2016)
Policy 24: Historic environment
Development proposals will be permitted where they would sustain the cultural distinctiveness and significance of Cornwall’s historic rural, urban and coastal environment by protecting, conserving and where appropriate enhancing the significance of designated and non-designated assets and their settings.
Development proposals will be expected to:
- sustain designated heritage assets;
- take opportunities to better reveal their significance;
- maintain the special character and appearance of Conservation Areas, especially those positive elements in any Conservation Area Appraisal;
- conserve and, where appropriate, enhance the design, character, appearance and historic significance of historic parks and gardens;
- conserve and, where appropriate, enhance other historic landscapes and townscapes, including registered battlefields, including the industrial mining heritage;
- protect the historic maritime environment, including the significant ports, harbours and quays.
Development within the Cornwall and West Devon Mining Landscape World Heritage Site (WHS) and its setting should accord with the WHS Management Plan. Proposals that would result in harm to the authenticity and integrity of the Outstanding Universal Value, should be wholly exceptional. If the impact of the proposal is neutral, either on the significance or setting, then opportunities to enhance or better reveal their significance it should be taken.
All development proposals should be informed by proportionate historic environment assessments and evaluations (such as heritage impact assessments, desk-based appraisals, field evaluation and historic building reports) identifying the significance of all heritage assets that would be affected by the proposals and the nature and degree of any effects and demonstrating how, in order of preference, any harm will be avoided, minimised or mitigated.
Great weight will be given to the conservation of the Cornwall's heritage assets. Where development is proposed that would lead to substantial harm to assets of the highest significance, including un-designated archaeology of national importance, this will only be justified in wholly exceptional circumstances, and substantial harm to all other nationally designated assets will only be justified in exceptional circumstances.
Any harm to the significance of a designated or non- designated heritage asset must be justified. Proposals causing harm will be weighed against the substantial public, not private, benefits of the proposal and whether it has been demonstrated that all reasonable efforts have been made to sustain the existing use, find new uses, or mitigate the extent of the harm to the significance of the asset; and whether the works proposed are the minimum required to secure the long term use of the asset.
In those exceptional circumstances where harm to any heritage assets can be fully justified, and development would result in the partial or total loss of the asset and/or its setting, the applicant will be required to secure a programme of recording and analysis of that asset, and archaeological excavation where relevant, and ensure the publication of that record to an appropriate standard in a public archive.
Proposals which will help to secure a sustainable future for the Cornwall's heritage assets, especially those identified as being at greatest risk of loss or decay, will be supported.
Quote from David Moore - former Conservation Officer for Looe...
Each decision made by an individual property owner, business, statutory authority or service provider can have a negative, neutral or positive impact on Looe's conservation area. In recent years the balance has tended towards the negative in some parts of the town and there is a risk of the trend accelerating.
This matters because the special character of Looe is the sum of many parts; if the good is diluted too much then there will be harm to the local economy, property values and it will not be such a good place to live or spend time. It is quite alarming when some of the worst examples of poor management and maintenance are in the most visible locations; the impact of these is much greater than it would be in a backstreet.
and he gives the following answers to these frequently asked questions...
Q1: I can't afford to repair my timber windows - it doesn't cost a lot more to replace them in plastic, so why keep something old when I can have something new?
A: The timber in old windows is so well seasoned that it will last a very long time. Your property will also be worth more and you will be contributing to the heritage of your town, so repair is a sound investment.
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Q2: If I fit double glazing it will save energy and pollution and I will save money.
A: If your timber windows are capable of repair then you can fit draughtproofing and repair saves the energy used in producing replacements. Most of the benefit of window replacement comes from elimination of draughts anyway, and the payback period on the double glazing itself is long. There are cheaper and more effective ways of saving energy, like added loft insulation and more efficient heating systems.
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Q3: My home suffers from road traffic noise so I need double glazing to solve this.
A: The optimum gap between panes of glass to reduce noise pollution is about 80-100mm; the air gap in double glazing is typically less than 22mm. Secondary glazing is, therefore, much more effective and costs a lot less. Traditional wooden shutters are also very good at reducing noise nuisance.
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Q4: I'm fed up with having to paint my windows - at least plastic is maintenance free.
A: There is no such thing as 'maintenance free' windows. Plastic gets dirty and needs cleaning, the opening mechanisms often fail over time and the rubber or mastic seals break down - all of which can be difficult and costly to replace.
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Q5: I can't decorate my sash windows without expensive scaffolding.
A: Sashes can be easily adapted to allow them to hinge inwards or be lifted out for maintenance, while in daily use they still slide as normal.
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Q6: I think we should look forward and use modern materials; why use old fashioned timber when we have plastic that does the job better?
A: Timber is a material of the future. The tree that supplies the wood for your windows has used up carbon dioxide, locked carbon within its structure and released oxygen; the sapling that replaces it in a managed forest will do the same. In production PVCu has used up non-renewable resources, generated toxins and used lots of energy; when its useful life ends it cannot be disposed of without causing more environmental problems.
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Q7: My property already has replacement windows that I don't like, but why should I change them again.
A: It's up to you what to do; but putting back windows that are properly detailed for your property will add value. Reinstatement of lost character will also enhance the street you live in and you'll be doing your bit to help improve the image of the town.
see householder advice from Historic England...
I want to alter my windows also I want to alter a door
I want to alter my windows also I want to alter a door
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CASEMENT WINDOW TYPES - Flush vs Stormseal
Windows in domestic architecture generally fall into one of two categories - casement windows which are side-hinged and sash windows which are vertically sliding.
Here we look at casement windows which can also be divided into two types - traditional flush fitting and modern stormseal as follows:
Here we look at casement windows which can also be divided into two types - traditional flush fitting and modern stormseal as follows:
Traditional casement windows are flush-fitting. This means that the opening part of the window sits fully within a recess in the outer frame when closed and is therefore in line and 'flush' with it when viewed from the outside. Any fixed lights
(those which do not open) are necessarily set within a subframe, resulting in all panes of glass being the same size, the framing a consistent thickness and the window having a symmetrical layout.
two examples of flush casement windows above and right
Modern casement windows (pictured below) whether upvc, metal or timber, tend to be 'stormseal' design (also known as 'stormproof'). They have a shallow recess in the outer framing to receive any opening lights which fit partly into this recess and partly lip over.
The imbalance associated with stormseal windows can sometimes be overcome by employing subframes for any fixed lights, per the ticked example below. This compromise is visually preferable and closer resembles a traditional flush-fitting casement window.
Despite the terminology, 'stormseal' window design is no more weatherproof than traditional flush-fitting. Flush casements should always be used in historic buildings and conservation areas or in instances when refurbishment of the original windows is not an option.
See Section 2.3 of Looe Heritage Guidance Notes >> Windows and Doors
See also guidance from the former Caradon District Council >> windows & doors
(This was originally intended to guide all development in the Caradon area but is particularly relevant to conservations areas).
LINKS AND DOWNLOADS
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(This was originally intended to guide all development in the Caradon area but is particularly relevant to conservations areas).
LINKS AND DOWNLOADS
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Planning Policy and Guidance:
National Planning Policy
National Planning Policy Framework (NPPF 2021)
Planning Practice Guidance (PPG)
Looe Town Council
LTC planning information
LTC - Article 4(2) Directions
Cornwall Council
Cornwall Local Plan Strategic Policies (adopted 22nd November 2016)
Cornwall Design Guide Sections-7-8-9-10 (see 7.8 Facades and Elevations)
Conservation Areas information
Caradon Local Plan
(now superseded by the adoption of the Cornwall Local Plan per above)
Caradon Design Guide 2000 (Superseded by Cornwall Design Guide)
(3 sections now digitised - full reference copy at 711.40942374 Cornish Studies Library, Camborne)
caradon design guide windows & doors
caradon design guide shopfronts
caradon design guide dormers & rooflights
Looe Conservation Area Character Appraisal and Management Plan 2009
Looe Conservation Area Appraisal
Looe Conservation Area Management Plan
Looe Heritage Guidance Notes
(now digitised per below and copies also held at Looe Town Council)
Cornwall Industrial Settlements Initiative LOOE
English Heritage - Valuing Places: Good Practice in Conservation Areas
Further Windows Guidance:
(now superseded by the adoption of the Cornwall Local Plan per above)
Caradon Design Guide 2000 (Superseded by Cornwall Design Guide)
(3 sections now digitised - full reference copy at 711.40942374 Cornish Studies Library, Camborne)
caradon design guide windows & doors
caradon design guide shopfronts
caradon design guide dormers & rooflights
Looe Conservation Area Character Appraisal and Management Plan 2009
Looe Conservation Area Appraisal
Looe Conservation Area Management Plan
Looe Heritage Guidance Notes
(now digitised per below and copies also held at Looe Town Council)
1. Shopfronts and Signage
2. Roofs and Rainwater Goods
3. Windows and Doors
Cornwall Industrial Settlements Initiative LOOE
English Heritage - Valuing Places: Good Practice in Conservation Areas
Further Windows Guidance:
Victorian Society website - Windows and double glazing
Design Guide - Windows and Doors - Mid Devon District Council
TRADITIONAL CASEMENT WINDOWS Design Guide - Tewkesbury
Design Guide - Windows and Doors - Mid Devon District Council
TRADITIONAL CASEMENT WINDOWS Design Guide - Tewkesbury
Casement window types - flush vs stormseal
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Ventrolla sash and casement window repair
TimberWindows.com
http://www.fdhall.co.uk/joinery.html
Chris Horsfield Joinery SE Cornwall - Window Repair and Restoration
Twenty years ago, a campaign called Framing Opinions (English Heritage 1994-7) was launched to highlight the increasing loss of traditional windows from older buildings and historic areas. Other initiatives have since continued to highlight the issue. Research on measuring change in conservation areas (Booth and Pickles 2005) documented the change to key building elements and recorded the widespread replacement of traditional windows, despite additional planning controls being in place to prevent such loss. In 2009, the Heritage at Risk campaign on conservation areas also raised the loss of traditional windows as a cause for concern, stating that unsympathetic replacement of windows and doors represented the number one threat and affected no less than 83% of conservation areas.
1.2 Why is repair better than replacement?
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SPAB technical Q&A5 old doors.pdf
Energy Efficiency and Historic Buildings - Building Regs Part L - Historic England
Improving Energy Efficiency in Cornish Historic Buildings - Cornwall Council
Windows: their care, repair and upgrading - Historic England Feb 2017
Secondary Glazing for Windows - Historic England Apr 2016
Draught-Proofing Windows and Doors - Historic England Apr 2016
Thermal Performance of Historic Windows - Building Conservation.com
Duchy Sash Window Repairs
Energy Efficiency and Historic Buildings - Building Regs Part L - Historic England
Windows: their care, repair and upgrading - Historic England Feb 2017
Secondary Glazing for Windows - Historic England Apr 2016
Draught-Proofing Windows and Doors - Historic England Apr 2016
Thermal Performance of Historic Windows - Building Conservation.com
Duchy Sash Window Repairs
Ventrolla sash and casement window repair
TimberWindows.com
http://www.fdhall.co.uk/joinery.html
Chris Horsfield Joinery SE Cornwall - Window Repair and Restoration
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Appendix A
Historic England
Traditional Windows: Their Care, Repair and Upgrading
(April 2015)
(April 2015)
Summary
The loss of traditional windows from our older buildings poses one of the major threats to our heritage. Traditional windows and their glazing make a hugely important contribution to the value and significance of historic areas. They are an integral part of the design of older buildings and can be important artefacts in their own right, often made with great skill and ingenuity with materials of a higher quality than are generally available today. Furthermore, the distinctive appearance of antique hand-made glass is not easily imitated in modern glazing.
Windows are particularly vulnerable elements of a building as they are relatively easily replaced or altered. Such work often has a profound affect not only on the building itself but on the appearance of street and local area.
With an increasing emphasis being placed on making existing buildings more energy efficient, replacement windows have become a greater threat than ever before to the character of historic buildings and areas.
Contents
Introduction
1 Challenging perceptions
1.1 Why preserve historic windows?
1.2 Why is repair better than replacement?
1.3 Can old windows be made energy efficient?
1.4 Why are plastic (PVC-u) windows so unsuitable?
1.5 Can replacement windows affect 3.3 property values?
2 Planning Permission and Building Regulations
2.1 Obtaining permission for work to windows
2.2 The Building Regulations
2.2 The Building Regulations
Introduction
Twenty years ago, a campaign called Framing Opinions (English Heritage 1994-7) was launched to highlight the increasing loss of traditional windows from older buildings and historic areas. Other initiatives have since continued to highlight the issue. Research on measuring change in conservation areas (Booth and Pickles 2005) documented the change to key building elements and recorded the widespread replacement of traditional windows, despite additional planning controls being in place to prevent such loss. In 2009, the Heritage at Risk campaign on conservation areas also raised the loss of traditional windows as a cause for concern, stating that unsympathetic replacement of windows and doors represented the number one threat and affected no less than 83% of conservation areas.
The pressures for change
The pressures that threaten traditional windows come from many different sources. Probably the most significant of these is the replacement window industry that relies on PVC-u windows for almost all of its business. The industry has invested heavily in marketing over a long period and as a result has persuaded many home- owners that their old timber windows are rotten, draughty, and beyond economic repair, whereas in most cases minor repairs and some upgrading would have allowed them to remain fit for purpose and serviceable for years to come.
Replacement plastic (PVC-u) windows pose one the greatest threats to the heritage value of historic areas, particularly in towns and villages. Despite attempts at improving the design of these windows they are instantly recognisable because they cannot match the sections and proportions of historic joinery. According to the English Housing Survey (2011) commissioned by the Department for Communities and Local Government, more than 52% of dwellings built before 1919 now have PVC-u double glazed windows.
The ‘one stop shop’ installation offered by PVC-u window companies can appear an attractive option. Windows on an entire four-bedroom house can be removed and replaced within a day, without having to involve and co-ordinate other trades. If the installer is a member of a Competent Persons Scheme such as FENSA (fenestration self-assessment scheme) then approval under the Building Regulations is taken care of through self-certification. Although many timber-window companies are registered with a Competent Persons Scheme, the timber-window industry has been not been able to match this level of service, though sash window refurbishment companies are now much more common than ten years ago.
Home ownership provides a huge potential market, especially in areas where properties are frequently changing hands. New ownership invariably leads to some upgrading work, which often involves replacing windows because they are ‘worn out’. However, the idea that old windows are ‘worn out’ is driven largely by a culture of replacement and fashion rather than by an actual assessment of their condition and performance.
Traditional windows are often completely replaced to improve a building’s energy efficiency when many simple thermal upgrading options, such as draught-proofing or secondary glazing, are usually available at much less cost. In the case of listed buildings and those in conservation areas, owners can often be under pressure to adapt windows to accommodate double glazing, which in most cases ends up in their complete renewal or inappropriate adaptation.
1 Challenging Perceptions
1.1 Why preserve historic windows?
Windows are the eyes of a building - they let in light and give views out - and profoundly affect its appearance. In addition, traditional windows bear witness to the artistic, social, economic and technological developments of past ages. Their design and detailing were influenced by contemporary architectural fashion, and reflected the status of a dwelling (and sometimes the individual rooms within it). They were further shaped by factors such as methods of taxation, building legislation and craft advances, particularly in glass manufacture.
An assessment of the significance of a window or windows and the contribution they make to the overall significance of a building is an important first step in deciding the right course of action. For most listed buildings and those in conservation areas, surviving historic fenestration is an irreplaceable resource which should be conserved and repaired whenever possible. The significance of a historic building, both as a whole and in terms of its constituent parts, can be assessed by considering its heritage values, using the framework set out in Conservation Principles (2008).
Surviving historic fenestration is an irreplaceable resource which should be conserved and repaired whenever possible.
Determining significance
“The significance of a place embraces all the diverse and natural heritage values that people associate with it, or which prompt them to respond to it. These values tend to grow in strength and complexity over time, as understanding deepens and people’s perceptions of a place evolve.”
The values that give significance to heritage assets are wide-ranging and interrelated: buildings and places provide material evidence about the lives of past generations. For example, they may offer insights into developments in construction technology, reflecting the distribution of materials, skills, ideas, knowledge, money and power in particular localities and at particular points in time.
The values that give significance to heritage assets are wide-ranging and interrelated: buildings and places provide material evidence about the lives of past generations. For example, they may offer insights into developments in construction technology, reflecting the distribution of materials, skills, ideas, knowledge, money and power in particular localities and at particular points in time.
Evidential value
Evidential value reflects the potential of a building or its fabric to yield information about the past. Rarity adds to evidential value. If the fabric of the window is old it will probably have considerable evidential value. An early 19th-century sash window in an 18th-century house will have considerable evidential value. In contrast, a modern standard ‘off the peg’ window in the same opening will have a low evidential value.
Evidential value reflects the potential of a building or its fabric to yield information about the past. Rarity adds to evidential value. If the fabric of the window is old it will probably have considerable evidential value. An early 19th-century sash window in an 18th-century house will have considerable evidential value. In contrast, a modern standard ‘off the peg’ window in the same opening will have a low evidential value.
Historic value
Most historic windows will illustrate, in varying degrees, the materials and technology, the craftsmanship and the architectural taste of the period from which they date. A shop window in a domestic building may carry considerable historic value indicating the development of the function of the building.
Most historic windows will illustrate, in varying degrees, the materials and technology, the craftsmanship and the architectural taste of the period from which they date. A shop window in a domestic building may carry considerable historic value indicating the development of the function of the building.
Aesthetic value
Fenestration may form an integral part of the design of the building or contribute to a building’s visual character. If later in date, its aesthetic qualities may add to the interest of a building. Replicas or recreations of fenestration of aesthetic quality will maintain this value. In contrast, much off- the-peg joinery is of little aesthetic value and is unsympathetic to the visual qualities of historic buildings. The surface character, reflectivity and transparency of the glass are further aesthetic values to be considered.
Fenestration may form an integral part of the design of the building or contribute to a building’s visual character. If later in date, its aesthetic qualities may add to the interest of a building. Replicas or recreations of fenestration of aesthetic quality will maintain this value. In contrast, much off- the-peg joinery is of little aesthetic value and is unsympathetic to the visual qualities of historic buildings. The surface character, reflectivity and transparency of the glass are further aesthetic values to be considered.
Communal value
This value will not usually be applicable to domestic windows, but may be relevant in public buildings and places of worship.
This value will not usually be applicable to domestic windows, but may be relevant in public buildings and places of worship.
Significance
Significance is the sum total of heritage values. Historic windows will almost always be of such significance that every effort should be made to conserve them.
Significance is the sum total of heritage values. Historic windows will almost always be of such significance that every effort should be made to conserve them.
Traditional windows can be simply and economically repaired, usually at a cost significantly less than replacement. For timber windows this is largely due to the high quality and durability of the timber that was used in the past (generally pre-1919) to make windows. Properly maintained, old timber windows can enjoy extremely long lives. It is rare to find that all windows in an old building require new sections. Many historic components continue to give service after 150, 200 or even 250 years. Traditional metal windows can also usually be economically repaired and their thermal performance improved, avoiding the need for total replacement.
The whole-life environmental costs of replacement will be much greater than simply refurbishing. It will take many years before savings on heating offset the large amounts of energy used to make PVC-u windows in the first place. Repairing traditional windows rather than replacing them is not only more sustainable but makes better economic sense, particularly when the use of shutters or secondary glazing to improve their thermal performance is taken into account.
Crucially, retaining historic fabric, including traditional windows, is fundamental to good conservation.
1.3 Can old windows be made energy efficient?
An increasing focus on energy efficiency makes older windows particularly vulnerable. Windows are generally presumed to account for 10-20% of the heat loss from buildings, although this will vary greatly from one building to another, depending on the size and number of openings in relation to the external wall area. In many older buildings, windows are small relative to wall areas so the cost of double glazing will seldom be covered by energy savings within the lifetime of the insulated glazed units.
The thermal performance of traditional windows can be improved significantly by draught-proofing or secondary glazing. Further benefits can be gained simply by closing curtains, blinds and shutters - measures that can produce the same heat savings as double glazing. Measures to improve the thermal performance of windows are described in more detail in Section 5 of this guide.
1.4 Why are plastic (PVC-u) windows so unsuitable?
The appearance and character of PVC-u windows is highly likely to make them unsuitable for older buildings, particularly those that are listed or in conservation areas. PVC-u is short for Poly Vinyl Chloride un-plasticised and these windows are assembled from factory-made components designed for rigidity, thermal performance and ease of production. Their design, detailing and operation make them look completely different to traditional windows. Manufacturers have been unable to replicate the sections/glazing bars used in timber and steel windows due to the limited strength of the material and the additional weight of the secondary glazing units. False ‘glazing bars’ which are merely thin strips of plastic inserted within the glass sandwich of a double glazed unit can change the character of the window.
Repairs can be a major problem. Because of the nature of PVC-u, complete replacement is often the only viable option, which makes them a very unsustainable solution when compared to timber and steel.
The frames of PVC-u windows need cleaning every six months to prevent discolouration from dirt and ultra violet light. They also need to be lubricated and adjusted annually and weather-seals and gaskets renewed at least every ten years. Paints are now available for some of the early varieties of PVC-u windows that have since faded or discoloured.
Although recycling does exist for PVC-u windows this is limited to waste sections left over in manufacturing rather than for complete redundant windows. Discarded windows end up in landfill sites with the potential for releasing some of the most damaging industrial pollutants.
1.5 Can replacement windows affect property values?
Home improvements are big business. The installation of replacement double glazed windows closely follows new kitchens and bathrooms as the most popular improvements, often in the belief that such work adds value to a property.
Estate agents suggest that using poor facsimiles of historic features can actually reduce the value of a property. A survey of UK estate agents carried out by English Heritage in 2009 showed that replacement doors and windows, particularly PVC-u units, were considered the biggest threat to property values in conservation areas. Of the estate agents surveyed, 82% agreed that original features added financial value to homes and 78% thought that they helped houses sell more quickly.
This is a significant issue for homeowners, particularly those in conservation areas, because houses in these areas sell, on average, for 23% more than houses elsewhere. This has been shown by research carried out on behalf of English Heritage by the London School of Economics (Ahlfeldt, Holman and Wendland, 2012).
2 Planning Permission and Building Regulations
2.1 Obtaining permission for work to windows
Basic maintenance of a listed building, such as redecorating, will not generally require consent but work involving repairs may require permission if these involve renewal of material. What activity does and does not require consent is a matter of considerable complexity, which is why it is advisable to discuss any proposed work to windows in a listed building or in a conservation area with the local planning authority’s conservation officer.
Planning protection
Planning controls are designed to protect the built environment for the benefit of its residents and users. They aim to promote a responsible approach to old buildings while at the same time accommodating private and commercial interests. In the case of listed buildings, consent for alterations is normally refused where the detailing of modern substitute products fails to match the original.
In many conservation areas, Article 4 Directions enable local planning authorities to manage change that otherwise would be harmful to their special character An Article 4 Direction is therefore targeted at specific types of alterations (these usually include windows) that cumulatively can undermine local character. If there is an Article 4 Direction in place that includes windows, planning permission will be required for any changes.
Paragraph 94 of the National Planning Policy Framework advises planning authorities to adopt proactive strategies to mitigate and adapt to climate change. Paragraph 134 states that ‘Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal.....’
However, the public benefits arising from improvements to a building’s thermal efficiency will only very rarely outweigh the harm to the public interest caused by the loss of the existing windows.
Historic England therefore generally opposes the removal or alteration of significant windows in listed buildings and in conservation areas in order to accommodate double-glazing. It does so on the grounds that only a small proportion of the country’s building stock is protected, the importance of fenestration to the significance of such buildings and the damage that is done by its removal. It also reflects the fact that there are generally other means of achieving improved thermal efficiency, both of the building as a whole and of its windows.
Historic England normally recommends that consent for the installation of insulated glazed units, should be granted only when:
- a historic window retains no significant glass, and has sufficiently deep glazing rebates and is robust enough to accommodate the increased thickness and weight of the insulated glass units without significant alteration (for example, late Victorian or Edwardian ‘one-over-one’ sash windows); or
- an existing modern replacement window of sympathetic design is to be retained and is capable of accommodating insulated glass units; or
- steel windows are able to accommodate a slim double-glazed unit.
In cases where the significance of a building has already been harmed by the installation of replacement windows of inappropriate character, consideration may be given to the installation of new slim-profile double-glazed replacement windows where:
- the new windows are of sympathetic and appropriate design, and used in locations where the significance of the building will not be harmed; and
- no incidental damage to the building fabric will result from the removal of the existing windows.
2.2 The Building Regulations
Under the Building Regulations a new window is a ‘controlled fitting’ and would need to meet certain standards covering heat loss, safety, ventilation and spread of fire.
A ‘certificate of compliance’ can be issued either by using an installer who is registered with a competent-person scheme or by making an application to the relevant Building Control body.
Thermal performance (Part L)
For existing buildings, energy conservation upgrading is generally only required for thermal elements that are to be substantially replaced or renovated or where there is a change of use. If windows are being renewed or if they form part of a building undergoing a change of use, then they need to meet the requirements of Part L. The new window should comply with the current U-value in relation to the amount of heat that can pass through the glass and framework.
To help reconcile thermal performance and building conservation, certain classes of historic buildings are expressly exempted from the need to comply with the energy efficiency requirements of the regulations where compliance would unacceptably alter their character and appearance.
These include:
■ listed buildings
■ buildings in conservation areas
■ scheduled monuments.
■ buildings in conservation areas
■ scheduled monuments.
The regulations also include ‘special considerations’ which can apply to the following categories:
■ locally listed buildings
■ buildings in national parks and other historic areas
■ traditionally constructed buildings
■ buildings in national parks and other historic areas
■ traditionally constructed buildings
Relaxations can be considered for buildings in these categories even though they do not have exemption status. However, the special consideration in relation to buildings of traditional construction relates only to not compromising their breathable performance. Replacement windows would not therefore fall within this area of consideration.
More detailed advice on the application of Part L of the Building Regulations can be found in the publication by Historic England EnergyEfficiency and Historic Buildings: application of Part L of the BuildingRegulations to historic and traditionally constructed buildings.
Safety glazing (Part N)
The need for safety glazing depends on any window being within a ‘critical area’ such as a certain height above floor level or distance to doors.
Ventilation
The type and extent of ventilation required will depend on the use and size of the room. For example, kitchens and bathrooms require higher levels of ventilation. In other rooms trickle ventilators in windows may suffice.
Fire safety and means of escape (Part B)
Windows need to comply with fire-safety regulations if they are close to adjacent properties or provide a means of escape in case of fire. If windows are between adjacent properties they may fall into what is defined as an ‘unprotected area’. Whether a window is within this area depends on its proximity to the boundary of the adjacent property.
When replacing any window, the opening should be sized to provide at least the same potential for escape as the window it replaces. If the original window that is being replaced was larger than necessary for the purpose of escape then the new window could be reduced down.
The above is an excerpt from a very informative 68 page article on traditional windows, their care, repair and upgrading published by Historic England, see >> Windows: their care, repair and upgrading - Historic England Feb 2017...
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