# Heritage Representation Nppf 2024 12

> ARCHIVED - December 2024 NPPF edition (superseded 17 August 2026). Use only when the user explicitly asks to work under the pre-August-2026 framework and has confirmed they want the archived skills; outputs must state they cite a superseded framework. Evaluate the heritage/historic-environment evidence submitted with a UK planning application (Heritage Statement / Statement of Significance, setting and archaeological assessments), identify the statutory duties and national policy it engages, and draft a concise, well-founded objection — or advise that no sustainable objection exists. Covers listed buildings, conservation areas, scheduled monuments, non-designated assets and archaeology. England-focused. Not legal advice; no warranty; output requires human review.

- Skill: `seagulltwo/heritage-representation-nppf-2024-12` (Agent Skill, multi-file: 8 files)
- Install (CLI): `npx skillmds@latest add seagulltwo/heritage-representation-nppf-2024-12`
- Raw SKILL.md: https://api.skillmd.com/api/skills/seagulltwo/heritage-representation-nppf-2024-12/raw
- Safety review: pending
- Works with: Claude Code, Claude.ai, OpenAI Codex
- Category: Coding & Dev Tools
- License: MIT
- Author: SeagullTwo (https://skillmd.com/u/seagulltwo)
- Updated: 2026-09-17
- Page: https://skillmd.com/skills/seagulltwo/heritage-representation-nppf-2024-12

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# Heritage representation on a planning application

Help a member of the public produce a rigorous, credible representation on the **heritage /
historic-environment** merits of a planning application. The skill does three things:

1. **Evaluate** the applicant's heritage evidence against the statutory duties and current
   policy and guidance, and identify the material deficiencies.
2. **Map** each deficiency to the specific legislation, national policy and guidance it
   engages.
3. **Draft** the representation in clear, precise, concise language — or advise that the
   evidence is sound and no sustainable objection exists.

## When to use

The user has a planning application (or a listed-building-consent application) and wants to
object, or find out whether they can, on heritage grounds — harm to a **listed building** or
its **setting**, a **conservation area**, a **scheduled monument**, a **registered park/garden
or battlefield**, a **non-designated heritage asset**, or **archaeology**. Trigger phrases:
"object on heritage grounds", "is this Heritage Statement adequate", "this harms the
conservation area / the setting of the listed building", "they haven't assessed the
archaeology."

Not this skill: ecology, transport, flood risk, general amenity — separate matters.

## What you need first

- The **application reference and council**, or the **documents themselves** — uploaded,
  pasted, or already-downloaded files work directly; the companion **planning-document-search**
  skill is only needed when you don't have them (it retrieves them from the reference + council).
- The **heritage documents** — the Heritage Statement / Statement of Significance, any setting
  assessment, archaeological desk-based assessment or evaluation, and the heritage section of
  the Design and Access Statement. Also the **conservation officer's and Historic England's
  consultation responses** (often the strongest anchor).
- The **designations and their significance** — what is listed (and its grade), the
  conservation area and its **appraisal**, scheduled monuments, registered parks/gardens
  (check `planning.data.gov.uk` and the Historic England list).
- The **local plan's** historic-environment policies.

## The integrity principle and two framing points (read before drafting)

**Only object where the evidence is genuinely inadequate or the harm genuinely unacceptable.**
Heritage harm is a matter of planning judgement; if significance is properly assessed and the
proposal genuinely preserves or enhances, there is **no sustainable objection** — say so.
Treat "don't object" as a valid output.

Two points specific to heritage:
- **The level of harm drives the test.** *Substantial harm / total loss* engages a very
  demanding test; *less than substantial harm* is weighed against public benefits. Applicants
  routinely under-state harm — getting the level right is decisive. (But don't over-claim
  "substantial harm" either; credibility depends on the honest level.)
- **"Less than substantial" is not "neutral".** The Act requires **considerable importance and
  weight** to preserving the asset, its setting and conservation-area character; the NPPF
  requires **great weight** to conservation of a designated asset.

**Classify every point's ask — (A) refuse, (B) don't determine yet, or (C) condition it.**
An evidential deficiency is not itself a reason for refusal. For each confirmed point, be
explicit about which outcome it supports: **(A)** the evidence *demonstrates* unacceptable
harm under the applicable test → a refusal reason; **(B)** the evidence is *insufficient* for
the Council to reach the necessary conclusion (significance not assessed; archaeology not
established before determination) → the application should **not be determined** until the
information is provided; **(C)** the issue can be adequately controlled → ask for the
*specific* condition or obligation (materials, detailed design, a written scheme of
archaeological investigation). Most deficiency findings are (B), not (A) — claiming (A) on
(B) evidence is the classic credibility mistake. And test every point against (C): if a
condition would lawfully and satisfactorily resolve it, ask for that rather than refusal —
over-asking weakens the whole representation.

## Workflow

### Step 1 — Intake and read
Identify the asset(s) affected and their designation/grade; whether the effect is on the asset,
its setting, or a conservation area's character; and the application type (permission vs
listed-building consent). Read the conservation officer's / Historic England's response first.
Get the Statement of Significance and any setting/archaeology assessments.

### Step 2 — Evaluate against the deficiency catalogue (function 1)
Work through [`references/deficiency-catalogue.md`](references/deficiency-catalogue.md). For
each candidate deficiency, confirm it is **present** and **material**, and capture the specific
evidence — the document, author, date, paragraph. Quote the Heritage Statement's own words.
Grade findings and lead with the decision-critical. Apply the integrity principle.

Key tests: Is **significance** assessed, and proportionately (fabric *and* setting, group
value, historic interest)? Is the **level of harm** correctly characterised? Are the
**statutory duties and great weight** given effect? Is the **public-benefit balance** genuinely
carried out? For conservation areas, does the scheme **preserve or enhance**? For archaeology,
is significance established **before** determination?

### Step 3 — Map to law, policy and guidance (function 2)
Attach the precise instrument from
[`references/national-guidance.md`](references/national-guidance.md) — the LB & CA Act 1990
duties (ss.66/72), the NPPF historic-environment paragraphs and the harm tests, the PPG,
Historic England guidance, the relevant case law on the statutory duties — plus the **local
plan** heritage policies and the **conservation area appraisal**. Cite specifically.

### Step 4 — Draft (function 3)
Draft to [`references/house-style.md`](references/house-style.md) and
[`references/objection-template.md`](references/objection-template.md): header → RE line
(name the asset) → opening → bulleted framework list → numbered conclusion-headed points
(quoted evidence; establish significance / characterise harm / invoke the duty; the ask) →
numbered **Summary of requests** → objection sentence → sign-off. Keep it concise; use bullets
for lists and `(a)/(b)` for multi-limb points.

### Step 5 — Check before sending
- Every point is evidenced from the documents or cited guidance; nothing asserted.
- The harm level is characterised honestly (not over- or under-claimed).
- The statutory duties and great weight are correctly invoked.
- Consultant-/campaign-specific framing excluded unless the user asked and it is defensible.
- Requests are concrete and correctly timed.
- Every point is classified **(A) demonstrated harm / (B) insufficient evidence / (C)
  conditionable** — and no point asks for refusal where a condition would lawfully and
  satisfactorily do.
- **Hand back to a human, with the two warnings:** the draft must be read and checked, and
  submitting it puts a **public document in the user's name** on the council's portal.

## Reference files

- [`references/deficiency-catalogue.md`](references/deficiency-catalogue.md) — the evaluation
  checklist.
- [`references/national-guidance.md`](references/national-guidance.md) — the law/policy/guidance
  catalogue with citations.
- [`references/house-style.md`](references/house-style.md) — how a strong representation reads.
- [`references/objection-template.md`](references/objection-template.md) — skeleton + annotated
  worked example.

## Scope and limitations

- **Not legal advice, and no warranty.** Not a substitute for a solicitor or a heritage
  professional; guarantees no outcome; provided "as is".
- **Human review is necessary before submitting.** A person must check every quote and
  citation against the actual documents.
- **A UK planning representation is a public document in the submitter's name** — normally
  published on the council's portal; include only personal details the user is content to make
  public.
- **England-focused.** The 1990 Act applies in England and Wales, but national policy (NPPF/
  PPG) is England; devolved policy differs — flag when outside England.
- **Evidence-bound; heritage harm is a matter of judgement.** Identify significance and harm on
  the evidence; don't assert a level of harm you cannot support.
- **The honest answer is sometimes "don't object."**