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Preparing a retrofit project

7. Identifying planning constraints


Housing providers will be well versed in local planning policy when it comes to new build, but may be less familiar with planning related to retrofit. The good news is that many retrofit measures do not require planning permission; however, some local authorities have unique rules and there may be constraints related to older buildings, conservation areas or specific local building types which you will have to follow.



    Housing providers will be well versed in local planning policy when it comes to new build, but may be less familiar with planning related to retrofit. The good news is that many retrofit measures do not require planning permission; however, some local authorities have unique rules and there may be constraints related to older buildings, conservation areas or specific local building types which you will have to follow.

    Why it matters

    If you didn’t seek planning permission for a new development, your organisation would face legal action, fines and even the need to take down your newly built homes. Planning for retrofit may not seem as strict, but it is still better to identify local planning constraints, build them into your retrofit plan and comply with planning and regulatory requirements. Doing it right means only having to do it once and being clear about requirements means you can build this into your delivery plan avoiding delays and programme disruption down the line.

    Key steps to take

    1. Check if the works are permitted development: Many types of retrofit work fall under Permitted Development Rights and do not require planning permission. However, these rights may not automatically apply, so you must always check.

    2. Check if the buildings are listed or in a Conservation Area: If your homes are listed, then you will need to obtain Listed Building Consent for most work that is carried out. If the properties are in a conservation area, then some permitted development rights may not apply.

    3. Check local planning conditions: Every local authority should have a local development plan (or local plan). You should check local planning conditions at an early stage of your project to identify any approvals that you might need. If your retrofit project crosses local authority boundaries, you will need to check multiple local plans, as they will vary.

    4. Talk to the planning authority/authorities: An early conversation with the local planning team(s) can help you understand more about what is required and the process for securing permissions. It also helps avoid any surprises later in the process and having to re-submit an application, which costs time and money.

    5. Make sure your business plan allows time and resources for the planning process: Planning permission can take 8-16 weeks to work through the approval process; if your project is grant-funded within a very tight timeframe, then this may preclude some works from happening. Planning applications will also carry costs and these will need to be included in your business plan.

    6. Make sure the right team is in place: You may need to appoint consultants to assist you with your planning application as most local authorities have strict requirements on the information that needs to be submitted as part of the application. The consultants required will depend upon your project but they may include an architect, planning consultant, heritage consultant and ecology consultant.

    7. Make sure all permissions are in place before starting on site: All necessary planning approvals must be in place before the retrofit works start on site. If you go ahead without permissions, you could be asked to “undo” work, which will cost time and money and damage your organisation’s reputation. If the works affect a protected historic building, this could be a criminal offence.

    Success factors

    Start early - it is a good idea to identify any potential planning issues as soon as possible. You can take steps to find any problems before getting too deep into the project and avoid later delays and difficulties. Always seek the advice of the relevant local authority’s planning team to confirm your conclusions.

    Do not make assumptions – a lot of retrofit measures are counted as permitted development and, in most cases, do not need planning permission. The important word is “most”. Some local authorities have set specific rules around what is allowed without permission. Always check the local plan for every local authority area where your target properties are located.

    Align with the local plan – if you are applying for planning permission, it’s important to show that your project contributes to the aims and objectives of that plan. In some cases, this is fairly clear: if the local authority has a commitment to carbon reductions (eg, a net zero target), you can demonstrate how the retrofit will help cut emissions. Other considerations in the local plan could include design guidance to reflect local architectural heritage or wider local or community benefits.

    Plan for planning – the planning process can take time and feel frustrating. It is crucial to think about planning from the outset to make sure that you can manage the expectations of senior management and residents and that you can set a realistic timetable for procurement and delivery of your retrofit works.

    Manage residents expectations – letting residents know that a planning application needs to be submitted for works to their home is key. They might need to give access for assessments to their homes as part of preparing the application. Letting them know about the process will also avoid them getting surprised by seeing a planning notice up or being asked questions by neighbors who have received a letter about the proposed works.

    Deep dive

    National planning policy

    Planning is a devolved issue, which means that each national government in the UK sets its own planning rules. You can find links to the national planning frameworks for each country in the table below:





    National Planning Policy Framework

    Visit website (


    Scottish Planning Policy

    Visit website (


    Planning Policy Wales

    Visit website (

    Northern Ireland

    Strategic Planning Policy Statement

    Visit website (

    Permitted development

    Many types of retrofit work fall under Permitted Development Rights and do not require planning permission. These works include PV roof panels, air source heat pumps, external wall insulation and loft insulation. However, some local authorities are able to override permitted development rights, so do not assume that they will apply.

    You can apply for a Lawful Development Certificate if you want to be certain that the existing use of a building is lawful for planning permission purposes or for confirmation that your proposal does not require planning permission.

    Local Planning

    All UK local authorities are required to have a local development plan (or local plan) that sets out their building development policies and designations for different geographic areas. These local plans can exclude some Permitted Development Rights. Many local authorities will also have Supplementary Planning Documents (SPDs) providing specific guidance in relation to certain projects such as those in Conservation Areas.

    In addition to the national legislation for listed buildings, there may be locally listed buildings which are identified in the local plan due to their architectural or historic interest.

    There are also species which are protected by law, such as bats. If there is potential for disturbing protected species as part of your works (e.g. works to the roof/within the loft where bats may be present) then mitigation measures may be required. Many local authorities will provide biodiversity checklists which will indicate whether protected species may be affected. There may be a requirement for a preliminary ecology appraisal or more in-depth ecology surveys to be submitted as part of any planning application.

    Most local authorities will encourage submitting a pre-application enquiry which is a way of receiving formal advice on your proposed scheme. There is usually a fee involved and it can take around 4 weeks to receive advice. Pre-application enquiries are confidential so can be very useful in the early stages of the project prior to any resident engagement.

    Historic or heritage buildings and conservation areas

    There are strict regulations related to buildings of architectural and historical interest (listed Grade 1, 2*or 2) or identified in the local plan.

    The table below – developed by theCentre for Sustainable Energy - gives an indication of when you might need consent, but it could vary by local authority. As noted above, it is always best to check with the council’s planning department.


    Consent needed for internal work

    Consent needed for external work

    Listed buildings (Grades I and II)



    Conservation area



    World Heritage Site



    Area of outstanding natural beauty



    Schedule of monuments



    Undesignated heritage buildings



    If your building is listed, you will need to obtain Listed Building Consent for most work that is carried out. Listed Building Consent is separate to planning consent but you can apply through your local authority. You may need to apply for both Listed Building Consent and planning consent for your project.

    You will likely need to appoint a heritage consultant to assist with your application if your building is either listed (Grade I,II* or II), locally listed, a scheduled ancient monument or is within a conservation area. 

    Future directions in planning policy

    Where planning considers energy and carbon, it has tended to do so in terms of operational energy use (ie, how much is used by the occupants of a home or building). It has had less to say about the emissions associated with the construction of the building, the materials used, or the end of life of a building.

    Local authorities are starting to consider how these factors could be included in their local plans, particularly for major new developments or regeneration projects. For example, in 2020, the Mayor of London published guidance (for consultation) into whole life carbon assessments as part of the London Plan. The Royal Institute of Chartered Surveyors (RICS) has also published guidance on whole life carbon assessment.

    Although in relation to new build, in the new London Plan the Mayor of London updated his energy hierarchy to include ‘be seen’ - to assess performance in use:

    1. be lean: use less energy and manage demand during operation

    2. be clean: exploit local energy resources (such as secondary heat) and supply energy efficiently and cleanly

    3. be green: maximise opportunities for renewable energy by producing, storing and using renewable energy on-site

    4. be seen: monitor, verify and report on energy performance.

    Further resources

    How does the planning process work?

    Planning permission – – this guidance will walk you step-by-step through the principles of planning permission, permitted development, what happens if you don’t have the appropriate permissions and important factors to consider. The guidance is focused on England and Wales.

    Visit Website (What is Planning Permission)

    What are my permitted development rights?

    More information on permitted development rights can be found here.

    Visit Website (Permitted Development Rights)

    What are the planning requirements for historic buildings?

    Practical Guidance on Energy Efficiency – Historic England – this guidance sets out considerations for most of the changes you might want to make to a building and offers advice on the principles, risks, materials and methods of making changes to the building fabric. Following the guidance should help to avoid objections from the local planning authority.

    Visit Website (

    Do I need planning permission for solid wall insulation?

    Insulation – – this step-by-step guide explores different types of insulation and the planning and building regulations requirements associated with them. In all cases, be sure to check with the local planning authority for any specific local requirements or conditions.

    Visit Website (Planning Permission)

    Where can I get more guidance on planning issues in relation to heat pumps?

    The Greater London Authority has published research looking at heat pump retrofits. Chapter 10 of the report provides more detail on planning permission for heat pumps.

    Visit Website (

    Get in touch

    If you would like to discuss planning issues on your retrofit project, pleasecontact the RISE support team -

    We would love to hear about your experiences. What has worked for your organisation? What lessons have you learned? What documents, reports or tools have you found most helpful? Please contact if you would like to share your experiences.

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