Before considering whether any proposed work on a thatched property requires consent, owners should be aware of the undated Historic England A guide to Owners of listed Buildings, reference to “a relatively new process which allows you to find out if proposed work to your home needs listed building consent or not. If not, then a Certificate of Lawfulness will provide clear evidence that the work to be carried out will not require consent.” The advice continues to remind owners that “you may also have trouble selling a property which has not be granted listed building consent or a Certificate of Lawfulness for work carried out, as the lack of permission will be revealed by the legal search.”
On 25th February 2016 Historic England (HE) published a new “Advice Note 2: Making Changes to Heritage Assets”. This is the third change in the past twenty years, and replaces PPG15 and PPS5 and will impact directly on the care, repair and maintenance of thatched roofs. The relevant paragraph relating to rethatching is on page 3. Par.12. it states:
“Replacement of one material by another may harm significance and will in those cases need clear justification. Therefore while the replacement of an inappropriate and non-original material on a roof, for example, is likely to be easily justified, more justification will be needed for changes from one type of thatch, slate or tile to another or for changes in the way the material is processed applied and detailed.”
Because of the relatively ambiguous nature of this statement, clarification has been provided in two enquiry response letters from the Department for Culture Media and Sport (DCMS), which might help thatchers and owners when making a case to local authority conservation officers (LACOs).
“HE’s advice is expressed in terms that are firmly conditional, therefore following Government policy in the National Planning Policy Framework. HE does not absolutely rule out the use of any kind of roof covering on any listed building but simply points out that the replacement of one material with another may harm significance. This does not affect the replacement of a roof material where that replacement is genuinely like-for-like.”
The second response states that: “Normally, a conservation officer would only insist on reversing a change of thatching material if that change had been undertaken without listed building consent. It is important to bear in mind that even if a change from one type of material to another might be justified, listed building consent is still needed for such work. If consent was not obtained prior to carrying out work on a listed building, it is quite common for a conservation officer to invite the owner to make a retrospective application, and only if they fail to do so, or if the application is subsequently refused, would enforcement action be considered.”
It is becoming apparent that any work to a thatched roof other than very routine maintenance is going to require, at the minimum, a discussion with the conservation officer and the issuing of a Certificate of Lawfulness. In more extensive work a formal application may be required and in cases where the whole roof is involved also a meeting with the local authority building control officer.