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The Complexity of Confusion - A.N.A.L (Advanced National Architectural Levy) Policies

Updated: Feb 25, 2022

The grey box on the photo was where the client wanted his single storey rear house extension. (behind the fence). According to the heritage officer the extension would not fit in a conservation area, except, officer you have missed one vital point which is that all the new build houses by a prominent developer have been mass produced in a conservation area, these houses don't actually belong there either?...….(quite right young chap, it must be true most sincerely?)

Ok I get... it's all in the title, perhaps? or maybe it just might make sense after the latest show stopping real life scenario.

I will be presenting to the reader a series of case studies that relate to the real world and the many things that many departments within their own meta verse world think that is fit for the purpose for Architects. As Architects we know more, it is now apparent that the seven years of studying gave us that self exploratory journey that we all really thought was true?

But boy... oh boy... how we did not realise that during the course of our real scientific and evidential based research, and upon conclusion, that some departments are full of the residue that you may find in a sewer pipe that is about to explode! maybe the curry kicked in after the booze? or "it was like a fecal Jackson Pollock!" as defined by Ryan Gosling

....Only heaven knows and we don't want to disturb the Lord! or move the Universe, that's travelling at 78,000 kilometres per hour, through space time (Sorry Stephen) but this blog post might just do it! (So Google watch out! I am going to get you on your secret algorithm's this time and your information superbots might just have a good night out, fetching information for the super highway). Yes Google we do actually love you!

We may compare a person from the heritage department to a guest on a Graham Norton show, hang on a sec, let me correct myself here, the latest news is that you only get intelligent people on the Graham Norton show, so I guess these departments that judge us can only be in the queue for the red chair, however, they might just get flipped!

(I have the lever right here, just like the famous architect Mies Van der Rohe who had a steel beam under his desk) depending on their story. Maybe they had the Ibiza clubbing weekend or met one of the future bitcoin founders from Gemini, (which twin was it that bought the 100 bitcoins)? only time will tell, especially if you see that shaky hand holding the pen during the meeting, and perhaps he or she may of just done a copy and paste job, (really officer? we must actually, go that far...…definitely!) before they came into "work."

Maybe that chewing gum behind your ear, like when Alex Ferguson, is watching his team play, might just allow you to think with a bit more clarity, or there are plenty of self help books out there that you may or may not need. (Our Guru and chief officer Anthony Robbins being one of them).

But (and its a BIG one!) in the above project

We can say that these other form of hybrid species actually nest with the planning authority and seem to also pollinate at the same time with the Heritage department, (I am wondering what the bees or Marcus Aurelius may think of this?)

There are obviously different type of hybrid departments but they don't seem to have got a clue or got the basics right and are far from trained, and maybe just before the football match they did see their girlfriends.

One word of advice... don't buy New build Homes (especially in or close to conservation areas) as you will get the following case:-

So let us begin....A client of ours thought he had the perfect property, fresh and new and modern and in a conservation area. As Master planners that we are, and based on our experience of designing entire cities, it can be said, conclusively, that these house builders want to mass produce houses and hit targets for the Government, purely for the sake of a need. It's apparent that the minimum dimensions of corridors, (unless your in a larger exclusive estate, that has actually been designed) fit the minimum building regulation requirements, often cramped and you may often find the sofa in the corner oversized and over stretched thinking it fits? ummm really? let us not go there...that's another story indeed...

So one particular house builder (e.g. Persimmon Homes, Taylor Wimpey, Bharat Homes etc) built their development in a conservation area, I wonder how did they manage that? ummm interesting, maybe it was Mel Gibson's Payback that influenced them? but the development lets say had one particular client of ours that wanted to do a single story extension, and according to my colleague, he did not have a living room, (well done boys). I mean really no living room? so basically cutting a long story even longer as (we may need the whisky on this one), we designed the extension in accordance with the planning policies and to meet the required standards set out in the housing design guide by the council, when at last we were struck down by a bolt of lighting greater than the father of Thor himself) by the you guessed it....the heritage officer, these human beings are actually walking the face of our planet folks, So they had these comments to say which I will answer in the style of Q&A session.

The Proposal was for a Single Storey Rear Extension with Roof Lantern to Replace Existing Conservatory

Legislative and Policy context


  • Town and Country Planning (Listed Buildings and Conservation Areas) Act 1990

Question: 72 (2), special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area.

Answer: why were the house builders allowed to put green substations facing the public highway and garages on the main axes, offset on the street which became the focal point of the development? where's the special attention to the substations? (which is more like an after thought), how has the positioning of the garages preserved or enhanced the character and lets not forget the special appearance of the garages being in front of the main elevational context of the houses, which places an importance on the garages more than the houses.

The site is in a Conservation Area.

Question: Paragraph 194 of the NPPF states ‘In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation’.

Answer: how did the planning authorities get into bed with the housebuilders? and what is exactly an appropriate desk-based study? surely not a Phd Essay again? are you not going to go to the building site officer? or even look at the extension proposed in the curtilage of the private house, which is not within the public realm? by the way who assessed the field evaluation? did they actually go out in the field? was a prospective recruitment name obtained?

Question: Paragraph 195 of the NPPF states ‘Local planning authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise. They should take this into account when considering the impact of a proposal on a heritage asset, to avoid or minimise any conflict between the heritage asset’s conservation and any aspect of the proposal’.

Answer: The answer is under your nose. There is no heritage asset present, as you have already allowed a national housebuilder to invade the conservation area with a primary school design, that has evolved by the "architectural designer" on a time constraint, to satisfy mass production. Surely officer how did this large goat escape, and we are not talking about Paulo Coelho's book the Alchemist here, no sir....The impact of the proposal cannot really be seen from the public highway, yet the substation is okay again. By the way the necessary expertise comes from Architects and therefore should take this into account.

Question: Paragraph 197 of the NPPF states ‘In determining applications, local planning authorities should take account of: a) the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; b) the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality; and c) the desirability of new development making a positive contribution to local character and distinctiveness’.

Answer: An extension you can't see....hmmm....It's very distinctive isn't it? and they obviously don't want to desire new development. Bottom line.

A few policies later..................................(hang in there folks, we can get to the end)

Question: Paragraph 201 of the NPPF states ‘Where a proposed development will lead to substantial harm to (or total loss of significance of) a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply: a) the nature of the heritage asset prevents all reasonable uses of the site; and b) no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and c) conservation by grant-funding or some form of not for profit, charitable or public ownership is demonstrably not possible; and d) the harm or loss is outweighed by the benefit of bringing the site back into use’.

Answer: I rest my Case

The departments are again throwing every policy available under the sun, for a simple single storey house extension, even though the homes have been mass produced by reputable housing developers.


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