Review of Heritage Protection: The way forward

A response from RESCUE - The British Archaeological Trust

RESCUE - The British Archaeological Trust welcomes the publication of the Review of Heritage Protection: The way forward as representing a generally positive contribution to the future of the Historic Environment in England.  The response to the consultation document (over five hundred separate contributions) demonstrates the widespread concern over issues related to the historic environment.  A similar level of concern amongst the general public was in evidence when English Heritage commissioned a public opinion survey as part of the preparation for the publication on Power of Place.  In spite of the shortcomings of this document and of then subsequent Force for our Future, there can be no doubt that issues around the Historic Environment are of significance, as acknowledged in the Foreword to the Review.

While generally welcoming the publication of the Review and of the measures which are proposed within it, RESCUE does have a number of concerns, the majority of which relate to areas upon which the Review is silent.  Given that the Review will structure a programme of government action (including legislation) it is of concern that there are such silences within it on these issues.  The following notes are intended to highlight areas where RESCUE considers that further action is necessary and where we will continue to press for changes in existing policy and the establishment of new and innovative policies.  Attention is also drawn to specific cases in which the commitments apparently given in the Review are contradicted by active government policy whether at the local or national level.

Introduction

Context for the review

References to the importance of the Historic Environment are still 'instrumental' in the terms defined by Tessa Jowell in her recent essay Government and the value of culture - briefly summarised, it would seem that while we can have 'art for art's sake' the protection of the Historic Environment seems to have to be justified in terms of wider policies and anticipated outcomes; (egeneration, tourism, education etc) rather than for its own sake.  RESCUE would like to know how this apparent lack of consistency can be justified, particularly given the level of interest in and concern for, the Historic Environment as measured by the public opinion survey undertaken during the preparation of Power of Place.  Clearly education, regeneration and tourism are important issues and the Historic Environment can and should make a central contribution to them, but there remains the issue of research which is fundamental to any consideration of the Historic Environment.  Research underpins and, in a very real sense, creates the Historic Environment by bringing knowledge and understanding of it into existence through the application of investigative and interpretative techniques to the material traces of the past.  We still need a clear commitment to research and this is lacking in the document as presented.  Some acknowledgement that Universities and Colleges have a role here would have been welcome, particularly as the Research Assessment Exercise (which acts to structure university research) is currently underway.

Decisions

Short-term package

The proposals for short-term measures, while they are to be welcomed, place the responsibility for a great deal of work on English Heritage.  RESCUE is concerned that this additional responsibility will not be reflected in an increase in funding for the organisation or even in a reversal of the severe cuts which have been made in the last ten years.  If no additional funding is to be forthcoming, where will the further cuts necessary to fund the additional work fall?  RESCUE also notes that most of the short-term proposals concern standing buildings - will the extra spending required come from cuts elsewhere in the E.H. budget?  Specifically, will the emphasis on buildings be at the expense of archaeology?  If so, this will have to be regarded as a negative outcome from the review exercise as a whole.

The review of class consents is to be particularly welcomed, especially with regard to the effects of ploughing.  But will there be an increased commitment to prosecution (or, should I say some commitment to prosecution as it is singularly lacking at present) where damage is done to monuments or where changes of use occur in spite of Scheduled status?

Longer-term package

It is regrettable (although the practical problems have to be acknowledged) that the longer-term package is to be delayed - in the interim we can expect to see an increased level of destruction as the development industry races to 'beat the clock'. How will this threat be dealt with?

The commitment to the statutory provision of Historic Environment Records is to be welcomed, but will extra funding be made available to ensure that they are able to carry out their responsibilities effectively.  Although not specifically included in this review, it is worth noting that the archives resulting from archaeological survey and excavation are as much a part of the Historic Environment as are standing buildings and scheduled sites - where is the protection for these assets? It is to be anticipated that if local authorities are to be compelled to establish and maintain H.E.R.s without increased resources, then cuts will fall elsewhere - most probably on local and regional museums which will, in practice, mean that the current campaign of cuts and sackings will continue and will probably increase.  RESCUE has outlined the concerns of its members in relation to these issues in a series of letters to DCMS but has yet to receive a satisfactory response and meanwhile the programmes of closure and sacking are continuing apace.  Without a reversal of this policy the principle of 'preservation by record' (which is fundamental to P.P.G. 16) will cease to operate effectively and a crucial and central part of the Historic Environment (the archives resulting from archaeological excavation and survey) will become inaccessible and unusable, to the detriment of our understanding of the Historic Environment as a whole.  The archives resulting from excavation and survey are as much part of the Historic Environment as is a standing building and it is a matter of great concern that there is nothing in the Review to suggest that the DCMS acknowledge this important fact.

The new system

Management and control for items on the register

Reference is made to DCMS and ODPM 'continuing' to work together. This would seem an unusual choice of words, given that co-operation has not, hitherto, been a characteristic of these two departments, as witnessed by the St Pancras Cemetery affair.  It is to be hoped that there will be a greater commitment to communication and an integration of response between the two departments as a result of the changes outlined in the Review but this is something that will need to be monitored.  Elsewhere a greater spirit of co-operation is required - the issue of the looting of the wreck of HMS Sussex by a branch of the Ministry of Defence and an American treasure hunting and salvage company looms large here.

The rural historic environment

The review of the class consents issue is particularly welcome and the contribution of the English heritage 'Ripping up the Past' initiative should be noted here.  Unfortunately a major omission lies in the area of the renewal of old mineral extraction planning consents (ROMP) which are currently threatening sites in Derbyshire and on Dartmoor, not to mention the Thornborough Henges.  It is most regrettable that the Review is to be silent on this issue.  Given that much of the stone and other material quarried under these consents is linked with road and house building, the issue of the expansion of house building in the south east is of particular concern in this regard, with the demands of the south-east literally consuming other areas of the country, including some of our most valuable and sensitive landscapes.  Can we expect co-operation between the DCMS and the ODPM in this area?

Protection at regional and local level

PPG 15 and 16

The ongoing delay to the (highly secret) revision of these documents should be noted here and the continued negative impact of the control exerted by the development industry on archaeology is to be regretted.

Conservation areas and local lists

Once again, the commitment to communication between the DCMS and the ODPM is to be welcomed, but the poor record of the ODPM in respect of archaeology means that we will await the outcome of their deliberations with some concern.  How far will the views expressed in the responses to the consultation weigh when up against the demands of the development industry?

Resources

In our contribution to the consultation document, RESCUE drew particular attention to the lack of resources available to conservation staff and the Field Monument Wardens and is pleased that this issue has been tackled.  The proposed response will have to be assessed once the results of the pilot studies are known, but for the interim it should be noted that a good deal of expertise exists in the private sector, a direct result of the competitive tendering regime enforced under PPG 15 / PPG 16.  Should some mechanism for an input from the private sector be considered?  Clearly a scale of fees would be needed to prevent consultants from over-charging, but this should not be impossible, given the existence of established wage rates in E.H. and in local authorities which can be used to set limits on consultancy fees.

Training

The issue of the skills and training has been highlighted by many bodies and individuals (particularly in connection with the ongoing destruction of the skills base in local and regional museums) and it is good to see the issue addressed at last.  Increased resources are needed in this area, particularly for E.H. but a rolling back of the programme of sackings and dismissals instituted by local authorities in respect of museums would be welcome here.

Historic Environment Records

The acknowledgement of the importance of Historic Environment Records is most welcome and the commitment to make them a statutory responsibility is particularly welcome (assuming that increased resources are made available for their maintenance and staffing, as noted above).  Only the inclusion of the phrase 'or have access to one' raises a slight concern.  Will local authorities be able to use this to evade their responsibilities?

Once again (see above) there is an emphasis on the instrumental role of the Historic Environment in terms of education and this is fine as far as it goes, but  Historic Environment Records are also a key research resource and this element should be acknowledged in their establishment, mission statements and raison d'etre.  It is inadequate to say that 'good decisions about the historic environment can only be based upon good information' without acknowledging that the source of 'good information' is high quality, innovative research and that this requires an appropriate level of input.  Here again, some recognition of the role of the Research Assessment Exercise in structuring research within colleges and universities would be appropriate.

General points

There is also a general point to be made regarding the Review as a whole.  The orientation of the Review seems to be primarily towards buildings and the built environment (although, to be fair, much of what is said does cover buried archaeology as well) and in this reflects the emphasis in both Power of Place and Force for our Future which drew considerable comment when these documents were published.  RESCUE is concerned that this emphasis will lead to a diversion of resources from archaeology and towards standing buildings