Folkestone’s Local List of Heritage assets

In their recent consultation on their Heritage Strategy, Folkestone and Hythe District Council indicated that they intended to introduce, under Policy HE3, a Local List of Buildings and Sites of Architectural or Historic Interest. This was refined as Priority 8 of their Heritage Strategy as a Local List of Heritage Assets.

FHDC’s approach to the subject was it was to be largely led by officers of the district council, but the Government’s aspirations, enshrined in the Localism Act 2011, and expressed in Historic England’s Advice Note 7 on Local Heritage Listing say that it should be community led.

This makes more sense since it is only the local community that really understands what is important to local people and “local”, in this case, meaning town or parish level. It is difficult to imagine how people from an urban environment, e.g. Folkestone, could understand what people from Romney Marsh would consider to be an important part of their heritage.

Similarly, professional officers from the district council, some of whom may not even live in the area, are likely to be too far removed from the community they serve to assemble a meaningful list of what is important to the diverse communities that make up the district.

Whilst they have declared their intention to create such a list, mainly because they were obliged to by the Government, FHDC have also said that they neither the time, funding nor resources to actually get on with creating it.

As a result, a number of communities have started to put their own lists together, lists that can be submitted to FHDC at some later stage when they are ready to take over.

Section 5 (Setting Up and Running a Local List) of Historic England’s notes outlines the various stages involved with the “Local Heritage List  cycle”, the first of which is the Initiation (Public announcement of intention to create a local heritage list and invite participation from partners), which is the purpose of this publication.

This, then, is Folkestone’s list, albeit in an early, skeletal form. Of necessity, this issue is heavy on explanation and light on information about the heritage assets in the town. As the list grows and more information becomes available about the sites on the initial list and additional sites in the future, the emphasis will change towards a simple listing of sites and their parameters.

The Folkestone list is owned by the community but is currently being held on a database that is curated by the Go Folkestone group, but any individual or local community group is encouraged to contribute new sites or additional information about those already on the list.

So what exactly is a “Local List”?

Paragraph 39 of the Government’s Planning Practice Guidance encourages local planning authorities and/or local communities to create a ‘local list’ of ‘non-designated heritage assets’, which are ‘buildings, monuments, sites, places, areas or landscapes that have a degree of significance to the local community that merit consideration in planning decisions but which are not important enough to be included in the national list itself.

Historic England maintains that national list of heritage assets, which categorises buildings under the headings: Grade I, Grade II* and Grade II. Each of these categories has legal protection and cannot have work carried out on them without prior permission (listed building consent) from the local planning authority. The level of involvement of Historic England in those decisions and the standards that have to be maintained depend on the level of grading given to the building involved.

The “local list” is a similar list to the one maintained by Historic England but maintained, as the name suggests, locally – usually by the district council.

Heritage assets on the local list do not enjoy the same legal protection as those on the national list but the local planning authorities do have to take their local listing (some have called it a grade III category) into account when considering planning applications in the area.

An example of this might be the “area” which we all know as “The Stade”. It is made up of a number of buildings (houses, pubs, souvenir shops, sea-food stalls) situated on a quayside. Individually, the buildings may have no particular significance, be of no particular architectural merit nor have any historic interest, but collectively they make up an area which, in the past, was key to the evolution of the town’s fishing industry and, today, is an important part of the town’s tourist industry. Knocking down all those quaint cottages to erect a mega-block of high-rise flats may be acceptable from a planning point of view but it would have a serious impact on the number of visitors to the area. That has to be taken into consideration before granting that planning permission.

What can go on a local list?

That is pretty much up to the local community, but assets might include:

  • Buildings
  • Monuments

    The Bayle Pond

  • Sites
  • Places
  • Areas
  • Landscapes
  • Wreck
  • Archaeological sites
  • Parks and gardens
  • Tracks and paths
  • Watercourse/sources
  • Artworks (statues, “Banksy”, etc.)
  • Woodlands
  • Place names
  • Industrial
  • Infrastructure (roads, rail, bridge, tunnel)
  • Network (energy, communication)
  • Defence

Who decides what goes on the list?

You do!

Folkestone and Hythe District Council, in their heritage strategy says:

“The Council will create and maintain a Local List of Heritage Assets.

The List shall:

  • include all types of heritage assets – e.g. built heritage, archaeology, landscape features;
  • have clear and robust criteria for selection of heritage assets on the list;
  • require supporting statements of significance, condition, vulnerability and potential opportunities for sustainable use. “

looking at those points in turn, they don’t say how people can propose assets for inclusion on the list – this is clearly addressed in the Historic England notes, i.e.

“35 Public nomination can form a key element of the process. If using public nomination it will be helped if supported by a nomination form to guide those wishing to put forward a building or other heritage asset for consideration.”

The phrase: “clear and robust criteria” implies that the council is more concerned to stop assets getting on the list, but they do list those criteria which are appended as appendix 2.

The Historic England notes say that the community needs to get together to establish what the criteria are for their own local list but that is not to say that the FHDC ones aren’t a good starting point.

What the council doesn’t expand on is who does the “selection” but the Historic England notes are more forthcoming i.e.

“Once the assets on the shortlist for nomination have passed all the necessary checks, final ratification can be sought at the appropriate level within the local planning authority, which might include Committee or Cabinet Member sign-off.”

But it also says:

“Before the authority ratifies the final local heritage list, public comment can helpfully be sought”

So, until FHDC produce a working process sometime in the future, I, we, you or the community should develop the fledgling list and processes for populating it. We should also develop processes for making sure that anything going on the list deserves to.

For the moment, though, it is enough to just populate the list with just about anything the community wants. It is only by doing so that we can establish where the community’s concerns lie in terms of preserving their heritage and, thereby, establish the ground rules and criteria for inclusion later on.

It may well be that during the process of putting assets on the local list and producing the supporting statements, we identify those assets which may well be better suited to be submitted to the national list.

The last bullet on the list above says that all proposals for inclusion will “require supporting statements”.

Once again, it is only the community that can really say why an asset is important to them. If FHDC had the resources to produce such statements they would only be a bland history from existing records.

What can you or your group do now?

Firstly, let us know that you or your group wants to be included in the process. “Being included” can mean as much or as little as you like:

  • just being included in the distribution list of the local list
  • proposing heritage assets for inclusion on the list
  • supplying information to be included with supporting statements, whether this is just for the assets you propose or any others already on the list

it is quite likely that some small group may already be beavering away to protect something in town. Carry on doing so but get it added to the list, if it is appropriate, so that it can be seen in a wider context.

So, if you want to nominate something to be included on the list just tell us what it is, where it is and why you think it should be put on the list by email to 

Criteria for inclusion on the local list

From the Folkestone and Hythe District Council Heritage strategy:

“For inclusion within the Local List, the Heritage Asset must comply with at least one of the criteria listed below:

Historic Interest.

This can include:

  • Association with a figure or event of significant local or national importance.
  • Buildings relating to traditional or historic ‘industrial’ processes.
  • Age and use of distinctive local characteristics. Archaeological importance.

Architectural and Artistic Interest.

This can include:

  • Buildings of high-quality design, displaying good use of materials, architectural features and styles and distinctive local characteristics, which retain much of their original character.
  • Designed by an architect or engineer of local or national importance.
  • Demonstrating good technological innovation. Good quality modern architecture.

Social, Communal and Economic Value.

This can include:

  • Reflecting important aspects of the development of a settlement.
  • Demonstrating an important cultural role within the community.
  • Places which are perceived to be a source of local identity, distinctiveness, social interaction and coherence.
  • Demonstrating links to a significant local industry or trade.

Townscape Character.

This can include:

  • Providing a key local or national landmark.
  • Of significant townscape or aesthetic value.
  • Playing an integral role within a significant local vista or skyline.
  • Groupings of assets with a clear visual, design or historic relationship.”