HH1 requires development to make a positive contributions to the historic environment and identity of the city, and sets out key considerations for development affecting heritage assets in Exeter.

Policy HH2 sets out how historic buildings can positively contribute towards reducing carbon emissions through sensitive and sympathetic adaptations that secure their retention, repair, retrofit and re-use whilst also conserving the design and special significance of the heritage asset.

Policy HH3 recognises the importance of the Exeter City Walls scheduled monument to Exeter. It sets out the intention to seek ways to secure funding to support a programme of works to conserve, repair, maintain and enhance the Walls and improve public access and their visibility.

Heritage-led regeneration and the positive role Exeter’s heritage plays in local identity is a key factor in development. It is important that the potential impacts on all heritage assets and their settings, whether designated or non-designated, are considered through the planning process. The National Planning Policy Framework is clear that when considering the impact of a proposed development on the significance of a heritage asset, great weight should be afforded to the conservation of heritage assets with the weight linked to their importance regardless of the level of potential harm or loss resulting from proposals. When devising development proposals affecting heritage assets, Historic England has an extensive range of guidance and technical advice on looking after historic buildings and sites, climate change adaptation, retrofit and energy efficiency, recording and project management.

All planning applications affecting heritage assets or their settings must include a heritage statement describing the significance of the heritage asset and/or their settings, and assessing the impacts of the proposed development upon them. The level of detail should be proportionate to the asset’s importance, and this assessment should be used to inform and explain the design concept.

All planning applications affecting heritage assets must be considered in terms of the impact of the proposal on the significance of the heritage asset. ‘Significance’ in terms of heritage-related planning policy is defined in the National Planning Policy Framework glossary as ‘the value of a heritage asset to this and future generations because of its heritage interest’. Significance derives not only from a heritage asset’s physical presence, but also from its settings. 

All heritage assets have settings, defined in the National Planning Policy Framework as the surroundings in which a heritage asset is experienced. The extent and importance of settings are not fixed and may change as the asset and its surroundings evolve. A thorough assessment of the impact on settings needs to take into account, and be proportionate to, the significance of the heritage asset under consideration and the degree to which proposed changes enhance or detract from that significance and the ability to appreciate it.

Policy HH1 sets out the key heritage considerations for development in Exeter. When considering the impact of development on heritage, the priority is to retain, re-use and enhance heritage assets with great weight afforded to the conservation of heritage assets, and weight linked to the importance of the heritage asset. Where it is not possible to retain the assets, or where there are substantial public benefits that outweigh the loss (wholly or in part), appropriate mitigation will be required and this could include recording, analysis, reporting and archiving of the significance of the asset. This must be agreed with the City Council as the local planning authority in advance of development commencing on site. Advice and guidance can be sought from the City Council and Historic England. 

Policy HH1 also outlines the different considerations for development to take into account depending on whether the heritage asset affected by a development proposal is designated or non-designated, and in the case of designated heritage assets, whether the harm is substantial or less than substantial. 

Whether a proposal causes substantial harm or less than substantial harm will be a judgment for the decision-maker having regard to the circumstances of the case and the policy. In general terms, substantial harm is determined by considering the degree of harm to the asset’s significance and its special architectural or historic interest. The harm may arise from works to the asset or from development within its setting.

When considering whether the public benefits of a development are substantial or outweigh the less than substantial harm, they should be of a nature or a scale to be of benefit to the public at large and could be anything that delivers economic, social or environmental objectives. Public benefits do not always have to be visible or accessible to the public in order to be genuine, for example, works which secure an asset’s future as a designated heritage asset could be a public benefit.

In addition to protecting and enhancing heritage assets, consideration will need to be given to whether development can improve public access to and interpretation of the asset. Development should weave heritage assets into green infrastructure and high quality public spaces in order to enhance public enjoyment of the historic environment. 

Planning obligations could be used, where appropriate, to secure improvements to, and the mitigation of, adverse impacts on the historic environment. This could be provided through archaeological investigations, access and interpretation, and the repair and reuse of heritage at risk buildings or other heritage assets.

In order to ensure the future of our heritage assets and to sustain this cultural heritage for future generations, they need to be adaptable to, and protected from, the effects of climate change. Historic buildings can also positively contribute towards reducing carbon emissions through sensitive and sympathetic adaptations that secure their retention, repair, retrofit and re-use alongside conservation of the significance of the heritage asset. The embodied energy (the energy used within the materials and construction activities) in historic buildings means that their retention aligns with the ambition to reduce carbon emissions and the priority to conserve heritage assets.

Addressing and adapting to climate change may require alterations to historic buildings or development that affects heritage assets, including their settings. This could include development or retrofit to ensure the building’s retention or reduce carbon emissions, energy generation, or protection from flooding. A holistic view should be taken when considering such alterations. This should balance the need to safeguard the future of the asset and the conservation, and where appropriate, enhancement, of its significance and historic and architectural qualities. Alterations to listed buildings should improve energy efficiency, reduce emissions and / or enable the building to adapt to climate change while taking considerable care to preserve the historic fabric, character and appearance of the building. This approach is set out in policy HH2. 

Historic England offers information and advice on many related topics including energy efficiency and historic buildings, conserving their significance and avoiding maladaptation.

The Exeter City Walls are designated as a scheduled monument, legally protected due to their national historical importance. Around 70% of the circuit remains intact delineating the origin of the city. The Walls became subsumed by modernity as the city expanded and faced 20th century transport infrastructure demands. The challenge lies in re-energising and re-imagining the significance of the Exeter City Walls and all they symbolise into a sustainable future city and to celebrate the individuality of the inherited city. 

The Exeter City Walls play an important role in defining the historic city and contributing to the social, cultural and economic life of the City. Its presence on the national Heritage at Risk Register highlights its vulnerability and priority for safeguarding. Its designation offers the Walls a high degree of protection setting the precedent that development proposals that cause loss, substantial harm or restrict public access to the Walls will not be permitted.

The City Council will seek ways to secure funding to support a programme of works to conserve, repair, maintain and enhance the Exeter City Walls and improve public access and visibility of the Walls to celebrate their presence and meaning. This may include planning obligations to secure improvements and mitigate adverse impacts on the historic environment.

Policy HH3 recognises the importance the Exeter City Walls scheduled monument to Exeter and sets out intention to seek ways to secure funding to support a programme of works to conserve and enhance the Walls.