CONTEXT 188 : JUNE 2026 21 INFRASTRUCTURE Listing for historic interest: the shrapnel and fire-damaged former labour exchange building in Milk Street, Bath (1936), listed in 2002 as a poignant witness to the Bath Blitz of 1942. The walls have been retained and new upper floors subsequently added. now being undertaken to inform heritage statements. Do historic environment records (HERs) help bridge this gap? Not really. Uploading photos of new listings should be automatic too. Showcasing new listings: knowing what is getting listed is vital if current thresholds for designation are to be understood by outside parties. Creating an updated gallery of new listings with links to the entries would help achieve this. Could they be grouped by Selection Guide? Updating entries after major works: it is not as though there is not money in the property industry. Thousands of listed buildings receive consent for works every year. And yet the list entries get completely ignored. As listings get older – and most are over 40 years old – they fall ever further behind. Look up St Pancras Station – there is no mention of the remarkable Fosters intervention. Look up the British Museum: ditto. Or the Holburne Museum, Bath: no mention of the Eric Parry extension.Why can’t updating list revisions be part of the development process, at least for bigger projects? The discussions have been had, the significance agreed on, the changes effected, the buildings understood. ‘Not my job,’ says the conservation officer or the planning adviser at Historic England. Something has to change here if listing upgrades are to be woven into the system, and to show the owner that it would be worthwhile for them to pay for such work. The Enhanced Advisory Services offer can clearly help to deliver this. Timing: listing takes a long time, and it is not always clear why. Make it possible for the owner to find out what stage a listing case has reached and what the timescales are. And insist that DCMS decision-making is subject to scrutiny too: cases can get stuck there. Briskness is a virtue. Neutrality: Historic England needs to be unbiased and even-handed in its approach. It is the government’s adviser and its role is different from an amenity society. It needs to maintain its independence and not be too chummy with outside parties. Maintaining impartiality is essential for the sake of fairness. Should living architects be able to influence listings on their buildings? A tricky one, that. Exclusions: these should always be used in list entries if warranted. Say when special interest is not present (‘the interiors of the upper floors were entirely rebuilt after a fire in 1963’ or ‘the rear extension of 1970 is not of special interest’): be proportionate. Curtilage remains a contested issue, and clarity on what components are included should be implicit in any new or revised listing, and promoted through the Listing Enhancement service. The Historic England guidance on curtilage needs updating too. Listing has done its job pretty well over the decades since the 1944 and 1947 acts. Twenty years on from the start of the last review, it is time to make sure that it keeps pace with the 21st century, and endures as a remarkable compendium of England’s most interesting buildings and structures with clear protection outcomes. Roger Bowdler is a partner at Montagu Evans. His book The British Cemetery 1700–2020, cowritten with Brent Elliott, has just been published by Historic England/Liverpool University Press. THE LISTING PROCESS IN ENGLAND
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