Review of Heritage Protection: The way forward

A response from RESCUE – The British Archaeological TrustRESCUE – The British Archaeological Trust welcomes the publication of the

Review of Heritage Protection: The way forward

as representing a generally positive contribution to thefuture of the Historic Environment inEngland.The response to the consultation document (over five hundred separate contributions) demonstratesthe widespreadconcern over issues related tothe historic environment.A similar level of concern amongst the general public was in evidencewhen 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 thensubsequent

Force for our Future

, there can be no doubt that issues around the HistoricEnvironment are of significance, as acknowledged in the Foreword to the Review.While generally welcoming the publication of the Review and of the measures whichare proposed within it, RESCUE does have a number of concerns, the majority of which relate toareas upon which the Review is silent.Given that the Review will structure a programme of government action (including legislation) it is of concern thatthere are suchsilences within it onthese issues.The following notes are intended to highlight areas where RESCUE considers thatfurther action is necessary and where we will continue to press for changes inexistingpolicy andthe establishment of new and innovative policies.Attention is also drawn to specific cases inwhich 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 importanceof the Historic Environmentare still 'instrumental' in theterms defined by Tessa Jowell in her recent essay

Government and the value of culture

–brieflysummarised,it would seem that whilewe can have 'art for art's sake'the protection of theHistoric Environmentseems to have to be justified in terms ofwider policies and anticipatedoutcomes;(egeneration, tourism, education etc) rather than for its own sake.RESCUE wouldlike 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 surveyundertaken during the preparation of

Power of Place

.Clearly education, regeneration andtourismare important issues and theHistoric Environmentcan and should make a centralcontribution to them, but there remains the issue of research which is fundamental to anyconsideration of theHistoric Environment.Research underpins and, in a very real sense, createsthe Historic Environment by bringing knowledge and understanding of it into existence throughthe application of investigative and interpretative techniques to the material traces of the past.We still need a clear commitment toresearch and this is lacking in the document as presented.Some acknowledgement that Universities and Colleges have a role here would have beenwelcome, particularly as theResearch Assessment Exercise (which acts to structure universityresearch)is currently underway.

Decisions

Short-term package

The proposals for short-term measures, while they are to be welcomed, placetheresponsibility for agreat deal of work on English Heritage.RESCUE is concerned that thisadditional 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 additionalfunding is to be forthcoming, where will the further cuts necessary to fund the additional work fall?RESCUE also notes thatmost of the short-term proposals concernstandingbuildings - willthe extra spending required come from cuts elsewhere in the E.H.budget?Specifically, will theemphasis on buildings be at the expense of archaeology?If so, this will have to be regarded as anegative outcome from the review exercise as a wholeThe review of class consents is to be particularly welcomed, especially with regard to theeffects of ploughing.But will there be an increased commitment to prosecution (or, should I saysome commitmentto prosecution as itis singularly lacking at present) where damage is done tomonuments 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 thelonger-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 thisthreatbe dealtwith?The commitment tothe statutory provision of Historic Environment Recordsis to bewelcomed, 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 notingthat the archives resulting from archaeological survey and excavation are as much a part of theHistoric Environmentas are standing buildings and scheduled sites - where is the protection for these assets? It is to be anticipated that if local authoritiesare to be compelled to establish andmaintain H.E.R.s without increased resources, then cuts will fall elsewhere - most probably onlocal and regional museums which will, in practice, mean that the current campaign of cuts andsackings will continue and will probably increase.RESCUE has outlined the concerns of itsmembers in relation to these issues in a series of letters to DCMS but has yet to receive asatisfactory response and meanwhile the programmes of closureand sacking arecontinuingapace.Without a reversal of this policy the principle of 'preservation by record' (which isfundamental to P.P.G. 16) will cease to operate effectively and a crucial and central part of theHistoric Environment (the archives resulting from archaeological excavation and survey) will become inaccessible and unusable, to the detriment of our understanding of the HistoricEnvironment as a whole.The archives resulting from excavationandsurvey are as much part of the Historic Environment as is a standing building andit is a matter of great concern thatthere isnothing in the Review tosuggest 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 seeman unusual choice of words, given thatco-operation has not, hitherto,been a characteristic of these two departments, as witnessed by the St Pancras Cemetery affair.It is to be hoped thatthere will be a greater commitment to communication and an integration of response between thetwo departments as a result of the changes outlined in the Review but this is something that will

needto be monitored.Elsewhere a greater spirit ofco-operation is required - the issue of thelooting of the wreck of HMS Sussex by a branch of the Ministry of Defenceand an Americantreasure 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 theEnglish 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 arecurrently threatening sites in Derbyshire and on Dartmoor, not to mention theThornborough Henges.It is most regrettable that the Review isto be silent on this issue.Giventhat much of the stone and other material quarried under these consents is linked with road andhouse 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 thecountry, 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 notedhere and the continued negative impact of the control exerted by the development industry onarchaeology is to be regretted.

Conservation areas and local lists

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

Resources

In our contribution to the consultation document,RESCUE drew particular attention tothe lack of resources available to conservation staff and the Field Monument Wardensand is pleased that this issue has been tackled.The proposed response will have to be assessed once theresults 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 regimeenforcedunder PPG 15 / PPG 16.Should some mechanism for an input from the private sector beconsidered?Clearly a scale of fees would be needed to prevent consultants from over-charging, but this should not be impossible, given the existence of establishedwage rates in E.H. and inlocal 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 regionalmuseums) and it is good to see the issue addressed at last.Increased resources are needed in this