The Lower Saxony state government has presented a draft amendment to the Lower Saxony Heritage Protection Act, with the stated goal of reducing bureaucratic hurdles. This initiative addresses the current challenges in the housing market. As part of the ongoing consultation process, the Association of Housing and Real Estate Companies Lower Saxony Bremen (vdw) has generally welcomed the proposals contained in the draft law. However, the industry notes a lack of specific and clear regulations regarding climate-friendly building renovation.
Dr. Susanne Schmitt, Managing Director of the vdw, commented on the draft law, emphasising that the association's 180 member companies handle cultural assets worthy of protection and designated architectural monuments sensitively. Within their total portfolio of around 400,000 homes, there are numerous multi-family houses and building ensembles where heritage protection regulations apply and are respected. She highlighted that the framework conditions in the housing market have changed significantly in recent years. Socially-oriented housing companies increasingly find that heritage protection authorities often show little willingness to compromise, actively promoting overarching goals such as affordable and climate-friendly housing.
The vdw considers the planned restriction of the scope of protection for group monuments to their external appearance to be appropriate. Often, buildings within such areas are beyond renovation and need to be replaced by contemporary residential developments. Furthermore, the association supports the proposed amendment to the archaeological investigation requirement for earthworks. Previous practice, even with 'zero finds', led to significant costs and unnecessarily delayed and increased the cost of planned housing construction. High construction costs result in high rents, which does not align with the business model of housing cooperatives and municipal housing companies, which aim to create affordable housing for households with low and middle incomes.
Dr. Schmitt referred to a previous guest article for the State Office for Heritage Preservation, in which she had outlined the need for fewer regulations in construction and for moderate, feasible, and affordable renovation of old buildings, coupled with a demand for political support for this approach. The current draft for the new Heritage Protection Act shows significant gaps in this regard. There is a lack of uniform and comprehensible criteria for the heritage assessment of modernisation measures. In practice, inconsistent evaluation of identical measures in comparable properties can be observed, as demonstrated by the example of insulating a rear façade, which was approved once but then rejected for a similar property.
The Managing Director stressed that heritage protection and climate protection must be reconciled through pragmatic regulations. Energy-saving measures in listed buildings, such as facade insulation on non-dominant building sides, modern window solutions, and the use of renewable energies, for example, photovoltaic systems on roofs, should not be thwarted by heritage protection rules. Moreover, in many cases, documents or records of the original appearance of a monument are missing. Heritage assessments are then often based on expert opinions, which can vary depending on the individual case and are not always transparent. Transparent and objective standards are essential here to ensure planning and investment security for owners.
