The Georgian Group asked Dartford council to refuse eight flats at Grade II* 45 High Street without a proper heritage statement. Comments close 11 September.
A national heritage body has told Dartford Borough Council it should refuse the plan to put eight flats into 45 High Street unless the applicant produces a proper heritage statement.
The building is Grade II* listed, the second highest grade in England.
The Georgian Group set out its position in a consultation response dated 27 August 2026, now published on the council’s planning file. It is short and it is blunt.
“This application needs to be accompanied by a suitable Heritage Statement which meets the guidance set out within the National Planning Policy Framework. Guidance on what is required is set out within policy HE5. Without a suitable Heritage Statement, the impact of the proposals cannot be assessed. If the applicant is unwilling to provide one, then your local authority should refuse consent.” (Georgian Group consultation response, 27 August 2026)
The council has not yet decided the application. Its target date for a decision is 1 October 2026.
What is proposed
The application is DA/26/00912/LBC. It was received and validated on 6 August 2026 and is listed as awaiting decision. The applicant is Old Civic House Ltd and the agent is MY Planning Consultancy. The case officer is Jas Bansil, and the site sits in the Town ward. (Dartford Borough Council planning register)
The council’s own description of the works includes:
- change of use
- roof demolition
- a new roof extension with a central flat top design
- dormers to the front and the rear
- internal and external alterations
- a roof terrace
- eight self-contained flats on the upper floors and in the roof
- Class E commercial floorspace at ground floor
The applicant’s statement sets out the eight flats as three on the first floor, three on the second and two in the new loft. Seven are one-bedroom and one is a studio. The smallest is 45 square metres and the largest 73.9. (Design and access / heritage statement, MY Planning Consultancy, August 2026)
The building
45 High Street is a large late 18th century house, listed on 22 December 1953 at Grade II*, national list entry 1336369. Kent County Council’s historic environment record carries the full designation text.
It describes three storeys of red brick, a modillion cornice and parapet, two large bays of three windows each running the whole height of the house with a central sash between them, and glazing bars intact. The doorway sits between the bays in a moulded architrave with an enriched frieze, a pediment on console brackets, a rectangular fanlight and a six-panelled door. A lamp hangs over it from an elaborate scroll bracket. (Kent Historic Environment Record TQ 57 SW 1085)
Photographs of the frontage show the name Home House over the doorway. An older entry in the same Kent record lists the address as council offices, which is echoed in the name of the applicant company, Old Civic House Ltd.
The grade matters here. Under the National Planning Policy Framework, policy HE6, development causing substantial harm to a Grade II listed building “should be exceptional”. For a Grade II* building the bar is higher again: “wholly exceptional”. (National Planning Policy Framework, August 2026, policy HE6)
The council’s own public notice, dated 20 August, described 45 High Street as a “Grade 2S Listed Building”. The national list records it as Grade II*. (Dartford Borough Council public notice, 20 August 2026)
What policy HE5 asks for, and what was submitted
Policy HE5 of the National Planning Policy Framework says proposals affecting heritage assets should come with an assessment of the significance of the assets affected, including any contribution made by their setting, and of the potential effect of the proposal on that significance. It then says the assessment should identify whether the proposal would have a positive effect, no effect, cause harm, or cause total loss, and that where there is harm the degree should be identified.
A six-page design and access and heritage statement was submitted with the application on 6 August. It runs through the site, the flat schedule and a list of local and national policies. On heritage it says external alterations “have been kept to a minimum”, that “alterations are limited to loft only”, and that the significance of the listed building and the character of the conservation area “are preserved”.
It does not describe what makes the building significant. It gives no architectural description, no date, and no assessment of the effect of removing the roof. It does not say whether the effect would be positive, neutral or harmful, or to what degree. It also puts the star in the wrong place, writing the grade as Grade II Listed Building followed by a star rather than Grade II*.
That is the gap the Georgian Group is pointing at.
Why the Georgian Group gets a say
The Georgian Group is one of six national amenity societies that councils are required to notify about certain listed building applications.
Under the Arrangements for Handling Heritage Applications Direction 2021, councils must notify those societies about applications for works that demolish a listed building, or for alterations that “comprise or include the demolition of any part of that building”. The same direction requires Historic England to be notified about works to any Grade I or Grade II* listed building. (Handling heritage applications Direction 2021, paragraph 4)
This application involves roof demolition, so both duties are engaged. No Historic England response had been published on the file as at 1 September.
A framework that changed after the application went in
The Georgian Group cites policy HE5. That policy did not exist when the application was submitted.
The government published a rewritten National Planning Policy Framework on 17 August 2026, replacing the December 2024 version. It reorganises national policy into lettered policies, and the historic environment chapter now runs from HE1 to HE10. The application was validated on 6 August, eleven days before.
Annex A of the new framework says its policies “are material considerations which must be taken into account in decision-making from the day of its publication”. So the decision on 45 High Street will be taken against the new policies, whatever framework the application was written for.
Nobody else has commented
The council consulted 19 neighbours. As at 1 September it had received no comments, no objections and no letters of support on this application. The Georgian Group’s response is the only substantive comment on the file.
There is no accompanying planning application on the register. The related cases tab for 45 High Street lists zero planning applications, so at present the only live case is the listed building consent.
What it means for you
If you want to comment, note that the file carries three different closing dates, which is not unusual on a Dartford application and is worth taking seriously:
| What the record says | Date |
|---|---|
| Standard consultation expiry | Thursday 3 September 2026 |
| Neighbour consultation expiry | Monday 7 September 2026 |
| Public notice, 22 days from 20 August | Friday 11 September 2026 |
The safest course is to comment by Thursday 3 September, the earliest of the three. Comments go in through the council’s Public Access system against reference DA/26/00912/LBC. The council’s notice states that any representation you make must be made available to the applicant or any interested party, so write it on that basis.
On a listed building consent the only matters that count are the effect of the works on the building’s special interest. Points about the number of flats, the loss of office space or parking belong to a planning application, and there is not one here yet.
The building stands on the south side of the High Street. Its listing records group value with No 43 next door, which the council treats as a building of local interest. If you are following what is happening around it, we also cover Dartford planning applications week by week and the wider planning news for the borough.
Sources: Dartford Borough Council planning register, DA/26/00912/LBC; Georgian Group consultation response; design and access / heritage statement; Kent Historic Environment Record; National Heritage List entry 1336369, via planning.data.gov.uk; National Planning Policy Framework, August 2026; Arrangements for Handling Heritage Applications Direction 2021.
Document links open the application’s documents tab on the council’s planning portal, where each file is listed by name and date. The portal’s direct file links only work inside a live browsing session, so we do not link to them.
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