Heritage Rebuttal Against the Statutory Listing for a New Primary School in Ipswich

Fuller Long is delighted to have worked alongside the Department for Education to challenge a request for several buildings in Ipswich to be added to the statutory list of buildings of special architectural and historic interest.

Whilst the preservation of historic buildings and areas in our country is important and can make a substantial and positive contribution to the quality, interest and very nature of our environment, the statutory designation has to meet national criteria that ensure the concept and rationale for designation is not undermined by the addition of buildings to the national list that do not fulfil said criteria. It is also important to recognise that ‘designation’ does not take place in a vacuum. The desire, justified or not, to designate can and does, have real world consequences, both positive and negative, and those consequences can have a direct impact on how communities and places can respond to prevailing circumstances. 

Often, the designation can inspire new, more considered approaches to development and aid in regeneration that is more reflective of ‘place’ and its capacity to adapt in a sustainable way. But this is not always the case. Sometimes well considered schemes based on a need and desire to act to resolve critical issues of long term decline can collide with interest in historic, or not so historic, buildings. Knowing where a recognisable interest is sufficient to justify statutory protection, and where it may not, is not always easy but it is always important to make sure any decision is well informed, well-balanced and wholly justified. It is equally important to understand the implications on communities, places and their ability to prosper when a lack of resources can leave schemes in the balance. There are times when the listing of a building can result in wider harm to an area if they might hinder or prevent well considered development to move forward where it supports a community. 

In this particular case, the buildings in question were the subject of a recent planning application for a new school. The existing buildings on the site have been vacant and without sign of any new users for nearly a decade. They comprise a range of buildings dating from the early 20th century to the 1960s in former retail use. All have been altered, and in some cases even effectively rebuilt, since their original construction. Due to the extended period of vacancy, the location, and need for a new school, the site was allocated for this use by the LPA, and proposals for a new school were advanced initially based on a degree of retention of the existing buildings due to their general historical and architectural interest. However, due to a number of issues, including condition and adaptability, a brand new school was considered the only achievable way forward. A full application was submitted and granted full planning permission subject to conditions, including building recording. Subsequently, the buildings were put forward for statutory listing. The addition of the buildings to the statutory list would create serious problems for the site’s consented use for a new school – putting the whole scheme at risk. As a result, our heritage team was commissioned to collate evidence and put forward an informed assessment of the special architectural and historic interest of the buildings and whether or not they did merit consideration for statutory listing. 

For a building to have special architectural interest it must be of sufficient importance in its design, decoration or craftsmanship to warrant consideration on the statutory list. To be able to justify special historic interest a building must illustrate important aspects of the ‘nation’s history’ or have closely substantiated historical associations with nationally important individuals, groups or events. The building’s themselves, in their current form, must also afford a strong connection with a valued aspect of history. Looking into the history of the site, our team were able to determine that the buildings present are all 20th century in date and each of the earlier historic buildings have been subject to large scale rebuilding behind their frontages. They concluded that the survival of the buildings had been entirely dependent on a large redevelopment scheme that saw the conversion of all the buildings into one, large department store in the 1960s. 

Subsequently, and having fully assessed the buildings against listing criteria provided by the Government for the selection of listed buildings, our team concluded that the subject buildings, both individually and collectively, did not meet the criteria set out for statutory designation as buildings of ‘special’ architectural and historic interest. This case was presented to the designation team (Historic England) responsible for investigating the building’s suitability for listing on behalf of our client. 

Following consideration of our evidence, and independent assessment, the designation team responsible for assessing the buildings suitability for statutory designation concluded, in line with our assessment, that the buildings, although of interest, did not meet the criteria for statutory designation. 

If you know of a request for a building near you to be added to the list of statutorily designated heritage assets and are unsure if it warrants consideration, Fuller Long can help.  To speak with one of our experienced team of planning and heritage consultants, please call us on 0808 164 1288 or email us at hello@fullerlong.com.