The Department of Culture, Media and Sport (DCMS) has set out four options for streamlining the listed building consent system, including one option that would see developers appointing their own 'accredited agent' to submit recommendations to the local planning authority (LPA).All four reform proposals have been designed to reduce the burden on local authority planning departments, particularly for less sensitive works that would not detract from a listed building's special character, and form part of the DCMS's commitment to streamline non-planning consents in line with the Penfold Review.The first is a system of prior notification where a developer would send a simple notification to the planning authority, setting out proposed works. If the notification is judged to indicate little or no harm to special interest, or a case is put for the justification of limited alteration, the LPA would be able to simply confirm that work could go ahead, or give deemed consent after a period of 28 days.The second would require a system of local and national 'class consents' to be put in place. These would allow the LPA to voluntarily grant consent in advance for defined works to listed buildings within a defined area or of a defined typed, effectively removing certain classes of works from the listed building consent system.

 Third is a system that would see the introduction of a 'Certificate of Lawful Works'. This could be issued by the LPA to a developer, setting out those works considered permissible without consent. Certificates would be able to specify, by reference to plans and drawings, the precise nature of works declared to be lawful. Two forms of certificate are proposed: one for proposed works and another for the granting of retrospective consent for works carried out in the belief that consent was not required.
But it is the fourth option, accredited agents, that has already provoked warnings and opposition among conservation interests, including SAVE Britain's Heritage.
The agent would be commissioned by the applicant to make expert, technical recommendations to the LPA – setting out the building's special interest, analysing the impact of proposed works, and making a recommendation on the suitability of works for receiving listed building consent. This option would see much of the work of the local authority conservation officer delegated to the developer's own agent, with the expectation that the LPA would normally be expected to accept the expert recommendation.
The obvious criticism of the plan is that agents commissioned by developers will be neither independent nor objective, and when making judgement calls will feel pressured to support development proposals to some degree at least. Fears have also been raised that the rise of the accredited agent will hasten the demise of the local authority conservation officer.
With the number of conservation officers already in steady decline, the question also arises of whether LPAs will have the expertise to assess the value and integrity of the agent's recommendations in the future.
The DCMS consultation proposes that appropriate standards for accredited agents could be monitored and enforced by existing professional institutions, suggesting that architects could be well placed to move into such work, with the RIBA's Conservation Register already in place to provide a potential quality assurance framework. The consultation runs until 23 August 2012. 

RIBA Practice Bulletin 656