Saunders Report – Consulting with the Amenity Sector on the National Heritage list for England

A decade after the Heritage Protection Reform Bill, in a changed and changing landscape, with public value, place-making and community engagement centre stage, it is timely for Historic England to consider afresh how best to administer the National Heritage List for England (the List).

Towards this, to establish the views of some key stakeholders, we commissioned Matthew Saunders to report on the amenity sector’s perspective of what is required.

The report 'Towards a Strategy for the Future of the National Heritage List for England; A view from the Amenity Sector’ (the Saunders’ Report) was completed in December 2019 (updated in 2020). Below is a distillation of the report’s key findings, the synergies we have identified, a note of the further work needed or underway and our priorities for this strategic and pivotal resource.

Historic England is grateful to Matthew Saunders for the care and experienced professionalism that distinguish this report, and to the valuable contributions of those he spoke to.

Download an executive summary of the report here:

You can find the full report within Historic England’s Research Reports:

Read the full report

Project background

The commission was to consider broadly the following:

  • The current state of the List (light touch) in terms of coverage, consistency
  • The implications of the brief legacy entries (the majority, without reasons for the designation decision or much detail)
  • Application of the present criteria (expressed in the DCMS Principles of Selection, November 2018)
  • Effectiveness of the process – speed/ flexibility
  • Relationship with other existing or potential protective systems (Conservation Areas, Local Listing, marker schemes, notably)
  • Improvements/ alternative ways of working/ solutions to problems identified
  • How initiatives such as Enriching the List and tools such as minor amendments / enhancements can best be employed.
  • While the focus was to be Listed Buildings, the interest of the four companion designations was to be kept in view.

Around 60 different groups, societies and individuals submitted responses. Notice of the inquiry was publicised through various outlets such as The Heritage Alliance. Face-to-face meetings occurred with several stakeholders and, in addition, with officers at various levels within Historic England and with the Department of Digital, Culture, Media and Sport (DCMS). Fact-finding visits were made across England. Data and supporting information were supplied by Historic England at the author's request.

Main recommendations from the Saunders’ Report

Saunders opened the report stating his profound appreciation for the professionalism behind the List and with recognition of its status and achievement as an informative resource for the historic environment and tool for the benefit of all. The emphasis of the report is to ensure that the calibre of this work continues, the List is enhanced to meet the greater expectations of today's communities and its wider potential.

The recommendations are headed with four principal findings that embrace the over-riding conclusions of the work:

  • Recommendation 1:
    Need for systematic review to address blatant omissions, critically nineteenth and early twentieth century, industrial and agricultural assets.
    See actions against recommendation 1
  • Recommendation 2:
    The minimalist content of the majority of List Entries and their out-of-date form is damaging in practice and in reputation.
    See actions against recommendation 2
  • Recommendation 3:
    Reactive listing should be accompanied by area-based and thematic listings to remedy the concerns.
    See actions against recommendation 3
  • Recommendation 4:
    Historic England should lead a mixed economy to address recommendations 1 and 2 – engaging the wealth of expertise outside of Historic England in 'informed communities', to mutual benefit.
    See actions against recommendation 4

Other recommendations

The principal recommendations that follow the key four can be grouped thematically:

Recommendation 5: Continuation of strengths.

The report applauds the work of Listing since its inception. The recommendations call for key elements to continue:

  • The work to compile and maintain the List should remain dynamic, as should the grading system, the application of the ‘30 Year Rule' and approach to the expiry / renewal of Certificates of Immunity (COIs). 
  • Powers to list in the presence of live planning or development proposals which might threaten the future of the building.

See actions against recommendation 5

Recommendation 6: Suggested reforms requiring legislation and DCMS agreement

  • Interim Protection for buildings being considered for listing, with Welsh precedent cited. Or,
  • Removal of right to compensation for the owner should the outcome of a Building Preservation Notice (BPN) be a decision not to List.

See actions against recommendation 6

Recommendation 7: Suggested improvements requiring DCMS agreement

  • Reducing consultation requirements and referral procedures to allow non-controversial amendments to existing List Entries
  • Introducing a defining sentence (‘masthead') to each List Entry, setting out legal status, possession of special interest and extent of listing
  • Using further historical watersheds as pivotal dates for assessment of age / rarity and consequent eligibility
  • Using photos as part of the formal list entry.

See actions against recommendation 7

Recommendation 8: Recommended changes for Historic England

  • Clarifying the definition of historic interest – eg through Selection Guides
  • Adding the date of changes made to List Entries and a brief explanation of what has changed within the formal entry.

See actions against recommendation 8

Recommendation 9: Recommendations requiring technical input (Historic England and DCMS)

  • Improving the List website and its search facility and including links to related sites such as Heritage Gateway
  • Moderating text and image additions through the Enriching the List process
  • Better archiving of all data, images, metadata and other changes.

See actions against recommendation 9

Recommendation 10: General Recommendations

  • Further promoting designated status so that owners and List users are better informed, including legislative requirement in conveyancing, introduction of QR tags and / or a Listing App
  • Caution in the use of exceptions to define the extent of cover as permitted by 2013 legislation (at s1(5A) of 1990 Act).

See actions against recommendation 10

Historic England’s overarching response

Historic England is very pleased to see that the report is roundly supportive of designation as a process and welcomes the wide range of constructive ideas put forward. It notes that the key recommendations broadly align with its own assessment of the current situation and the desirable direction of travel.

Historic England welcomes the clarity and priority relayed in the four over-arching goals for future work. They chime with its own findings and echo those of the Martin Cherry and Gill Chitty report of 2010, Statutory Lists: Review of Quality and Coverage. We acknowledge that the absence of a third national resurvey has left the later periods of our heritage (aside from a committed drive on post-War design) under-represented on the List. Similarly, as appreciation that good management of the historic environment requires attention to place-shaping and engaged communities, the need for more informed focus on design, material quality and historic interest, as much as building type, is paramount in assessments and designation.

Current expectations and potential for the list entries in this digital age are very different from those of their original purpose, which was simply to pin down the subject with an address and a very succinct description sufficient to confirm the identity of the building and its basic form. Hence the majority have minimal content whereas over the last twenty years’ greater effort has been made to distinguish the particular interest that led to their designation, and to include an image. This additional information helps owners, agents, researchers and decision-makers considerably. Historic England is keen to ensure that there is improved clarity on what the entry actually covers for these earlier listings, that is, further understanding as to why the fabric meets the criteria set, with some narrative on the circumstances that brought them into being.

In 2016, the capacity for anyone with information to ‘Enrich the List’ was successfully introduced to engage and enthuse those interested in this resource. Over 23% of list entries have now been enriched and these complement the more formal enhancement of the official entry. For all its value Enriching the List text is not authenticated by Historic England or DCMS and therefore cannot be part of the formal description.

Central to the development of the List has been a mix of strategic research (known as thematic listing) and of responding to requests to list buildings from third parties (known as reactive listing), often because the building in question is thought to be at risk in some way. At present, the Heritage Action Zones are the dominant thematic projects and there is capacity for only a few others, for example, listings to illustrate the 75th anniversary of the D-Day Landings, or to protect key examples of Islamic Places of Worship. However, Historic England is working to improve the coverage on the List of buildings from the nineteenth and early twentieth centuries (where overlap with work in the High Streets Heritage Action Zones will assist) and to identify and address gaps in the designation of industrial and agricultural buildings.

However well-resourced it is, a national List such as this one will never be complete either in identifying every single site of value, or in the information included in each entry. As expectations for the List have grown since it started, new processes added in, such as consultation and greater challenge to the entries, proportionately more resource has had to be put into adding each entry and amending those existing ones in need of attention for a particular reason. The challenge therefore is to identify the gap. In order to continue to enhance the value of the List in line with public expectations Historic England is both keen to engage communities in its benefits to a greater degree and to harness informed individuals in its compilation and improvement.

Historic England welcomes the Saunders’ Report both as an endorsement of what has been achieved to date, but also as a challenge for how the organisation might prioritise future action. It provides a solid foundation on which to build a better understanding of the needs and aspirations of those who use the List.

Actions already underway

The desirability of a system of interim protection safeguarding properties for the duration of their assessment was acknowledged during the efforts for Heritage Reform around 2008-9 but shaping new legislation to this end remains unlikely. Accordingly DCMS and Historic England are piloting a triage system that includes spot listings, indemnified Building Preservation Notices BPN (in which Historic England agrees to cover Local Planning Authorities for any potential compensation sought after service of a BPN) and standard BPNs in a compromise that has so far proved successful and which will inform future provision. Further information on this is available on the website.

Endeavours to improve use of resources and time in listing are ongoing and subject to regular audit to ensure that the system is effective. Streamlining processes is constant and we are exploring new parameters with DCMS for enhancement of existing listings to this end, with potential pilots in the High Streets Heritage Action Zones. Similarly, discussion with DCMS on the potential use of a sentence that defines the legislative extent and intent of listing, to help reduce any excessive descriptive length, are at the early stages. Images of England are now displayed alongside the official List and Enriching the List images have joined many thousands of entries.

Revision of the Selection Guides may lead to less precise date brackets for certain building types – outlining different watersheds critical to their development, as already set out for railways.

Historic interest is given greater emphasis in assessments than in previous decades and the planned addition of a Selection Guide on the subject will help clarify. The distinction between intangible heritage and physical associations requires definition and there is work underway here, including an exploration of the implications of intangible heritage for the historic environment.

Historic England’s digital improvements are constant, with priorities including arranging accessibility, equipping staff with the latest version of software and enhancing the List online. The need to engage further with the database’s search and reporting abilities is firmly on the horizon, a recognised priority with improvements being made this year and with others to be attended as soon as more pressing developments are complete.

Promoting understanding and enjoyment of the historic environment are clear goals for Historic England and current initiatives to improve community engagement, not least in High Streets HAZs, include pilots across England to improve awareness and establish a greater appreciation and involvement with place-shaping. The List’s ‘Search the Map’ facility is used by many in lieu of an App whose development remains an aspiration: it now features a proximity field to align with your location.

Historic England commits

There is insufficient resource to deliver all the recommendations in full, but Historic England has discussed the actions proposed below and commits to a process of improving the List. We must recognise that while we want to carry on with this work, the full impact the coronavirus pandemic will have on our resources, our priorities and the nature of the tasks that we and others can undertake is yet unknown and will influence how we take the actions forward.

Historic England will:​

  • continue discussions with DCMS officials towards this improvement;
  • use the Saunders’ Report to instigate conversations with a range of other stakeholder groups and interests to inform future direction. These conversations will take place from early 2020;
  • produce and publish a Listing Strategy as soon as those conversations are complete. The Strategy will signal the direction and purpose of Listing and provide the point from which progress in its delivery may be measured. The strategy will identify actions to be progressed and the reasons why;
  • continue to pilot small pieces of research to better understand the resource implications for some of the larger recommendations;
  • seek to find additional resource, from a wide range of sources, to be able to progress those areas deemed most urgent;
  • explore how it can work with other organisations who share an interest in developing the List;
  • explore how communities and special interest groups can become more engaged in actively improving the List.

Recommendation 1: Need for systematic review to address blatant omissions

Proposed ActionWhen / Status
Scoping reports to inform further research/ thematic programmes and Spending Review bids.Underway
Scoping industrial coverage in 100 ‘Towns Fund' PlacesUnderway
Survey of Local Planning Authorities inviting identification of building types or periods notably unrepresented from their ListUnderway

Recommendation 2: The minimalist and out-of-date-form of list entries

Proposed ActionWhen / Status
Ability to provide enhancements of LEs without resource-hungry wider consultation and advice report is being explored and pilot project proposed for High Streets Heritage Action Zones (HS HAZ).Underway
Survey of Local Planning Authorities to establish their priorities for future work on the minimalist early List entries.Underway

Recommendation 3: Reactive listing should be accompanied by area-based and thematic listings

Proposed ActionWhen / Status
Internal project needed to determine current areas meriting priority attention or thematic input. Further analysisIn hand
Listing Strategic Programme with new interim governance monitors existing, and developing ‘potential' list.Underway
High Streets Heritage Action Zones in hand. Historic England Regional Directors invited to nominate regional projects.2021 -22 programme

Recommendation 4: Historic England should lead a mixed economy to address recommendations 1 and 2

Proposed ActionWhen / Status
Costing of full survey style list (Survey Costing project) to establish in present day terms cost of full area survey.Underway
Exercise to establish location of priority lists for attention, building on earlier research, refreshing the position and digging deeper. Results to inform potential area surveys.Underway
Pilot engagement project using 3 ‘informed communities' to look at condition of older lists2021-22
Tier 2, 1.4 and 4.1 of Corporate Plan set out priority ambitions hereCorporate Plan 20-21

Recommendation 5: Continuation of strengths

Proposed ActionWhen / Status
Potential to make Certificate of Immunity assessments only available through Enhanced Advisory Services charging to maximise income generated for service mostly offered to commercial operatives.To be explored
Building Preservation Notice Indemnification pilot strengthens position through Local Planning Authority engagement / improves context when listing with live planningUnderway
Audit of Listing Process in 2019 found process robust with all risks managed. Further Audit intended. Constant monitoring, revision of guidance. Pending access to website for changes needed (new software training). Efficiencies sought to improve capacity/ delivery. Agreement on priority content for strategic work post High Streets Heritage Action Zones will be sought. This has been identified in Historic England's Corporate Plan.On-going

Recommendation 6: Suggested reforms requiring legislation

Proposed ActionWhen / Status
BPN Indemnification pilot underway precursor of longer-term reformUnderway
Historic England Listing ‘Reform' candidate list to be compiled in parallel with / as subset to HE Planning Reform Group's aspirational list. This suggestion will join the list.In hand

Recommendation 7: Suggested improvements requiring DCMS agreement

Proposed ActionWhen / Status
Pilot parameters for enhancement to be tested in HSHAZIn hand
DCMS discussion and internal discussion with legal team on textIn hand
Recent revision of Principles of Selection for Listed Buildings (2018) prevents any such for the moment, but attention being paid to the Selection Guides where ‘type-specific' watersheds can be flagged together with improvements re place and later periodsConsider in future revision of Principles. Guide revision by 2022.
The NHLE is to be re-presented to figure Images of England and Enriching the List images more prominently. Inclusion of interior images not welcomed by owners in this publicly accessible resource unless a public place.Re-presentation underway

Recommendation 8: Recommended changes for Historic England

Proposed ActionWhen / Status
Provision of selection guide on historic interest to be preceded by thought piece – but pending:
a: results of intangible culture commission
b: consideration of a historical marker scheme
c: establishment of permissions to address LEs with contested heritage without full case assessment (major enhancements)
Under consideration
Combination of work for the major enhancements HS HAZ work and the development of a new Listing casework management system (ICE) will endeavour to address this. Note: Listing ICE is to be a new and improved case managements system for all designation work, replacing the Unified Designation System (UDS).Underway, ICE 2022

Recommendation 9: Recommendations requiring technical input (Historic England and DCMS)

Proposed ActionWhen / Status
Corporate Plan (Tier 2, 4.1, Tier 3) activity for ‘Re-presentation of the National Heritage List for England (NHLE) including links to related interest/ guidance.Underway
While we are not resourced to moderate these, the occurrence of any concerning enrichments will be passed to relevant team.In hand
Both the Major Enhancements and development of Listing ICE are seeking to address these issues.In hand

Recommendation 10: General Recommendations

Proposed ActionWhen / Status
Proximity button on Search the List Map goes some way to improve visibility of listed assets and use of the search map. Listing App more problematic and difficult in cost terms to prioritise. Heritage Counts surveys go a long way to engage with bodies such as LPOC, property owners and so to promote awareness not just during conveyancing.In hand
Revision of the 100+ template letters for Listing to include links to guidance, eg at notification2021-22
Need for overview of performance of s1(5A) in assisting the management of the historic environment2021-22

Wider stakeholder engagement

Proposed ActionWhen / Status
Saunders' commission focused on the amenity sector and wider input / surveys across the stakeholder landscape continue, providing opportunity for stakeholders and HE to consider issues and discuss further potential priorities to address.On-going
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