Will Arnold of the Institution of Structural Engineers has argued for a so-called “Grade III” listing of all buildings in England. The idea is that a Grade III listing would make demolition unacceptable except where a building was structurally unsound or where there was a special dispensation from the local planning authority.

This idea flows from the existential threat of climate change and the resultant existential crisis happening within the property and development industry: to retrofit or to redevelop.

In the midst of the retrofit versus redevelopment debate, the Grade III proposition is one that plays well in the national discourse – it helps raise awareness of the issues. However, the proposition unhelpfully blurs the distinction between heritage and sustainability. It reflects a wider pattern seen in the heritage lobby, which has moved towards a carbon argument to push for retention. Reducing carbon is rightfully persuasive and explains why the Grade III idea has been noticed.

But let’s be clear, a Grade III designation is not realistic or deliverable and, as a result, could be dangerously ill-conceived.

THE CHALLENGES OF INTRODUCING A BLANKET GRADE III LISTING

First, the Planning (Listed Buildings and Conservation Areas) Act 1990 applies statutory protection to buildings that are of special architectural or historic interest. These are the c380,000 buildings which are deemed by the Secretary of State to stand out as part of the nation’s heritage. Introducing a blanket Grade III listing would dilute the law and limit the potential to identify buildings that are truly special and worth conserving.

Second, the administrative burden on local planning authorities through new planning or conceivably “listed buildings consent” applications would be extraordinary, particularly if a blanket listing is applied to all 25 million standing buildings. The system is already chronically underfunded, and conservation teams are at their smallest size in years. The bureaucratic challenge would be crippling.  That’s before we consider the difficulty of setting policies around which assets or areas “benefit” from special dispensation.

Third, there is already a significant challenge to retrofit and upgrade historic buildings with inconsistent decisions being made in an area reliant on profound professional judgement and subjectivity – see King’s College Chapel, Cambridge versus Medway Council’s HQ. A blanket listing would add a further layer of complexity, making it harder to improve buildings that are already a challenge to retrofit and upgrade.

Fourth, Grosvenor’s recent research Heritage and Carbon Addressing the skills gap, has identified a chronic under-provision of skills needed to deliver retrofit at the required rate. For specialist areas of historic buildings alone, 105,000 full-time retrofit specialists are estimated to be needed annually through to 2050. Grosvenor has called for a “retrofit army”. With such a significant shortfall for historic buildings, what hope do we have to retrofit all buildings across the country?

Fifth and this is crucial; not all buildings are capable of retrofitting. Many are durable, flexible and capable of repositioning, but many others are not; they are poorly built, highly inflexible, dark and incapable of achieving good thermal performance. Compromises must be made to ensure development is economically deliverable and operationally carbon efficient. The alternative is that we risk having stranded assets in urban centres.

And finally, what does Grade III do to the value and status of property assets and proposed new development across the country? The effects would be seismic. Overnight, the value of assets with alternative use potential would fall dramatically, bogged down by uncertainty over the viability and deliverability of any repositioning strategy. 

This would have severe economic and financial consequences for individuals and organisations across all parts of society. All whilst existing development sites would become burdened by a new restriction potentially affecting extant planning permissions and schemes going through planning. The impacts would be particularly exaggerated in our urban centres, where regeneration need is most pronounced.  This is not to advocate the “status quo” approach to development - because the industry has already changed and continues to move the dial on the approach to sustainability - but merely reflect some genuine realities.

CONSIDERING ALTERNATIVE SOLUTIONS TO THE DEBATE

This proposition for a “Grade III” listing of all buildings in England reminds me that the planning system can be a blunt tool, and reactionary changes can lead to long, complicated, and often unforeseen consequences.

Other tools might usefully be deployed, such as the use of permitted development to allow works to improve the efficiency of buildings and more accurate and balanced whole-life carbon options appraisals, as we see in London. 

A focused and effective tax on embodied carbon might also play a role in helping society balance the carbon budget whilst reaping the economic and social benefits of redevelopment, where appropriate. In tandem, of course, the economics of development will influence new schemes, particularly as lenders place emphasis on the sustainable outcomes of the projects they fund.

Ultimately, it is clear there is a need for the industry to adapt to the retrofit agenda, but a blanket designation is not the answer.