Viability or development appraisals are a planning tool used for many different purposes. One of the lesser-known uses is as quantitative justification for ‘enabling development’ proposals.
Enabling development is defined by Historic England as ‘development that would not be in compliance with local and/or national planning policies, and not normally be given planning permission, except for the fact that it would secure the future conservation of a heritage asset.’
Broadly Enabling Development proposals usually comprise some element of new build development which is used to financially cross-subsidise conservation of a listed or locally listed building. Minor conflicts with the development plan such as limited harm to the setting of a heritage asset from new build dwellings, green belt development or a lack of affordable housing can be justified in relation to the importance of said conservation.
However, the quantum of enabling development must be fully justified as the ‘minimum amount necessary’, and the ‘conservation deficit’ of repairing, refurbishing or otherwise bringing the heritage asset into along-term viable use must be specifically quantified.
In terms of method then, two development appraisals must be completed: one to identify the conservation deficit and one to identify the minimum amount of development appropriate to fund that deficit. This approach is important not only during submission of a planning application but at the early stage during the design of any enabling development proposal to ensure that the site is not overdeveloped, creating unnecessary harm to the heritage asset and jeopardising the principle of development. It is also vital to provide a detailed quantitative justification upon which officers can rely to allow other minor conflicts with the development plan.
There is very specific guidance from Historic England in relation to both method and inputs for enabling development proposals. However, very few consultancies have the crossover of heritage planning and viability expertise to advise fully and allow full compliance with Historic England’s advice. Enabling Development reports are often attempted, but provide limited detail, miss or leave out key parts of the Historic England guidance, including valuation of the existing buildings and resulting value once they are brought back into use; detailed cost justification and schedule of required works; and sensitivity analysis of reasonable adjustments in costs and values.
S106M are experts at advising on, developing and assessing enabling development proposals impacting designated and non-designated heritage assets. We have assisted a number of clients UK wide to successfully achieve planning permission on enabling development proposals, including the below case studies:
LPA: Tonbridge & Malling
Case: A Grade II listed building previously in hotel use faced closure due to business non-viability; however, it was clear from marketing that the building faced a long vacancy due to its green belt constraints, and existing repair requirements due to vandalism were substantial. A new, long-term viable use was required to ensure its ongoing conservation into the future.
S106 Management assisted the applicant testing the viability of several design solutions, providing planning and architecture services through several rounds of preapplication advice with conservation officers to develop a wholesale redevelopment of the site. It was apparent that conversion of the existing building alone would not be viable; and therefore 6 detached dwellings were assessed as the minimum necessary development to cross-subsidise the heritage works. As part of the full application a detailed enabling development report was submitted including a viability assessment of the proposals, detailed costings of the required works and sensitivity analysis of alternatives.
Case: A derelict locally listed (non-statutory) barn in a Cotswold conservation area was proposed to be brought back into use as a residential dwelling. However, the scale of costs in remedying the long-term derelict status of the building was substantial.
S106M advised the applicant on development of proposals for the locally listed barn and surrounding modern barns to provide 5 new build dwellings which would adequately cross-subsidise this conservation deficit. Policy requirements were balanced against the requirements of Historic England’s GPA4 guidance note. Sensitivity testing was also provided to advise the project designers on how different changes to floor area and number of units might impact the overall scheme’s financial outcomes.
Viability of different design options was examined at the design stage with recommendations made for how to improve the balance of enabling development to conservation.
A full enabling development viability report accompanied the application demonstrating that this was the ‘minimum necessary’ enabling development to support conservation of the asset.
Case: An applicant had previously achieved consent for an ‘enabling development’ cross-subsidy scheme of dwellings, holiday lodges and a wholesale refurbishment and function room extension of a listed pub building; however, during implementation it had become clear that the holiday lodge element was no longer financially viable.
S106 Management provided detailed enabling development appraisals to fully justify the conversion of the holiday lodge element to further housing to ensure the proposals remained viable and deliverable and the conservation of the heritage asset was assured.