Do You Need a Heritage Impact Statement? (A Guide to Avoiding Council RFIs)

One of the most common reasons clients urgently contact our office is because they have just received a Request for Further Information (RFI) letter from their local Council requesting a Heritage Impact Statement (HIS).

"Please provide a Heritage Impact Statement prepared by a qualified heritage consultant."

While we can certainly step in and rescue a planning application at this statutory stage, receiving this letter often signals a costly missed opportunity for the project.

If a local Council is requesting this document after you've already submitted your plans, it means your design has been assessed and potentially red-flagged without expert heritage support. Many people treat this statement as a basic administrative exercise to be completed at the end of the design phase, which is a potentially risky and costly strategy.

Designing a project within a Heritage Overlay without specialist advice runs the risk of receiving an RFI that demands significant, structural changes to your plans. You may be forced to pay your architect to redesign a non-compliant partial demolition, roofline or setback, pay to resubmit the amended plans, and endure months of unnecessary project delays.

What is a Heritage Impact Statement?

A Heritage Impact Statement isn't an academic essay about your house or commercial building. It is a highly technical statutory planning report that analyses exactly why your proposal should be approved under the specific heritage controls of the local Planning Scheme and the significance of your heritage place.

Guided by Heritage Victoria’s frameworks, our statements provide high-quality analysis written in plain English. A standard Heritage Workshop report begins with a rigorous significance assessment, defining exactly why the place matters through its historical, architectural, scientific, and social values.

Following this, we conduct a detailed statutory policy review to break down how your proposal meets complex local and state planning policies. The report culminates in an impact assessment, which forms the core, defensible positions justifying your specific design choices, such as demolition, setbacks, building heights, materiality, and streetscape sightlines.

Statutory Triggers Under Clause 43.01

While some local Councils mandate a Heritage Impact Statement for all works within a Heritage Overlay, others may not explicitly require one upfront. Some of the Councils we often see RFI heritage requests from include the City of Melbourne, City of Yarra, City of Boroondara, City of Stonnington, City of Port Phillip, City of Glen Eira, City of Merri-bek, City of Darebin, and City of Maribyrnong.

However, a Council can still demand this documentation later in the statutory process if a statutory planner or their internal heritage advisor flags a risk, making it crucial to verify your specific local requirements before lodging your planning application.

In Victoria, under Clause 43.01 of the Planning Scheme, a planning permit is triggered by a Heritage Overlay for a variety of works. This can include the demolition of any structures, even non-original rear sheds or dilapidated additions, as well as the construction of visible modern extensions and new homes on subdivided heritage lots (called in-fill).

Furthermore, a permit and accompanying heritage justification can be required for altering front boundary fences or undertaking external painting and restoration, particularly if specific External Paint Controls apply to your site. Addressing these triggers proactively helps make sure your initial submission is compliant and, ideally, ready for approval.

The Risk of a DIY Approach

Technically, a homeowner or developer can attempt to write their own Heritage Impact Statement, but we strongly advise against this approach. Heritage planning is a highly specialised framework, and subjective opinions about a design looking attractive or improving the streetscape don't constitute a defensible heritage argument.

We frequently see do-it-yourself applications rejected because applicants inadvertently admit to non-compliant actions or use terminology that triggers immediate refusal from the assessing statutory planner. Without a deep understanding of the Victoria Planning Provisions, local heritage policies and the Burra Charter, you risk compromising your entire application.

Instead, when you engage Heritage Workshop early, we can provide background briefings and preliminary advice to your architect to inform your plans and designs from the outset, meaning you get the most value out of our expert services and a stronger heritage outcome for your project.

By engaging us during the early concept stage, we provide a comprehensive service that guides your design team and mitigates your statutory risk. We identify the constraints before you finalise your design, ensuring your investment is protected and your vision is supportable from the very beginning.

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Don't wait for a Council RFI to dictate your project's heritage timeline.

Contact Dr James Lesh and the team at Heritage Workshop at the start of your project. We can provide a transparent, step-by-step service proposal for a Heritage Impact Statement that guides your design team, mitigates your risk, and supports your vision from Day One.