ANNEX
Letter from the Welsh Office to the Clerk
of the Committee
Welsh Affairs Committee Third Report:
The Preservation of Historical Buildings and Ancient Monuments:
Follow Up
Introduction
1. The Welsh Office welcomes the Select Committee's
continuing interest in arrangements for the preservation of historic
buildings and ancient monuments in Wales. The Department believes
that the Committee's original inquiry in 1993, its subsequent
report and the Government's response did much to raise their profile
and contributed to a broader public understanding of the issues.
The Department also appreciates the Committee's acknowledgement
of progress made on a number of fronts and shares many of the
Committee's views on other issues identified in the Committee's
report.
Listing - progress of the resurvey
2. The Department is pleased that the Committee was
able to congratulate Cadw on the acceleration of the listing resurvey.
The Department notes that the Committee remains of the view that
the task should be completed in three years but believes that
the incremental approach adopted, set alongside issues such as
quality control, resources, and the availability of experienced
contractors to conduct fieldwork will see the resurvey most effectively
completed.
3. Meanwhile the Department can assure the Committee
that effective arrangements remain in place for the urgent evaluation
of any threatened structures. Cadw continues to consider urgently
requests that buildings should be spot-listed when there is an
identifiable threat, and resources available for this work have
not been reduced. Cadw has spot-listed fewer buildings in the
period 1994-96 than the period 1990-93, but the total number of
candidate buildings for spot-listing diminishes as the resurvey
progresses.
Listing - criteria for selection
4. The Committee noted concerns that the criteria
used to identify buildings of special architectural or historic
interest in Wales are conditioned by English perceptions. The
Committee has recommended that the listing process should acknowledge
the importance of buildings linked with people significant in
Welsh history, whether or not they are of architectural interest,
and be sensitive to Welsh culture in its broadest terms.
5. The Department recognises the need to ensure that
the listing criteria offers proper protection to characteristic
Welsh buildings and acknowledges the importance of historical
association. They presently state that where otherwise unremarkable
buildings have such associations, listing is likely to be appropriate
only in exceptional cases. Although this criterion has been met
in Wales in a number of cases, the Department accepts the need
for sensitivity to Welsh culture at all times and proposes to
revise the criteria, so that while they will continue to require
a significant historical connection no presumption will be made
that only a small minority of buildings will qualify for protection.
Chapels and Churches
6. The Department shares the Committee's view that
the listing of chapels is an important component of the national
resurvey and recognises the valuable part played by chapels in
Welsh social and economic development. For this reason, in letting
contracts for the community-based surveys, priority has been given
to areas which are rich in chapel buildings, and it is probable
that about half the number which will merit listing have already
been listed. However, rather than wait for the end of the general
resurvey before completing coverage of chapels, the Department
will undertake a 'thematic' survey of chapels in those communities
for which general lists are not in place or contracted. The Department
aims to let a contract within six months and complete the project
within a further two years.
7. The Department notes the Committee's view that
too few chapels are being listed, particularly at the higher grades,
in comparison to churches. But it can be misleading to draw a
comparison between the number of chapels and churches listed.
The listing criteria recognise that the older a building is,
and the fewer the surviving examples of its type, the more likely
it is to justify listing. In general, churches in Wales pre-date
the chapels and many are medieval or several centuries old. All
buildings built before 1700 which survive in anything like their
original condition are listed. For the period after 1840, during
which the majority of chapels were built, the criteria recognise
that greater selection is necessary. The same principles are
applied to both churches and chapels, and in fact only two Victorian
churches in the whole of Wales are currently listed at Grade I
compared with a significantly larger number of higher graded chapels.
Among the total number of chapels surveyed so far, 11 have been
listed Grade I, 28 Grade II* and 500 Grade II. This distribution
(roughly 2% Grade I and 5% Grade II*) conforms very closely with
the distribution of grades across all buildings which have been
listed in Wales.
8. The Department would like to echo the welcome
which the Committee has extended to the establishment of a Redundant
Churches Fund. The Department would also like to record its appreciation
for the collaboration of the Church in Wales in this respect and
offer its thanks to the Friends of Friendless Churches. This
body will have lead responsibility for the care of those churches
vested in the new Fund.
9. The Department shares the Committee's disappointment
that a mechanism to care for the best of redundant chapels continues
to elude those committed to this important area. The need for
such a mechanism is accepted and the Department is willing to
provide generous levels of financial support. However, the Department
strongly believes that continuing success would be better assured
if such a mechanism enjoyed from the outset the leadership of
the voluntary sector, especially those voluntary groups whose
commitment and enthusiasm would certainly be needed to sustain
it. In this respect the Department is seeking a solution along
similar lines to that agreed between Cadw, the Church in Wales
and the Friends of Friendless Churches, although in the absence
of a financial contribution from the denominations the new body
will have more fund-raising to do. Equally, the Department believes
that such a mechanism should concentrate on preserving the best
rather than trying to address questions of widespread redundancy
among the stock of chapels. Those questions are real, but should
not cloud the objective of ensuring that the best redundant examples
of Wales' Non-Conformist past continue to be available to be enjoyed
by future generations.
Conservation Areas and Town Schemes
10. The Department shares the Committee's view that
the designation of conservation areas and the creation of town
schemes can make a striking contribution to the built environment.
Cadw and representatives of the local authorities met in March
to discuss ways of promoting and sustaining such initiatives and
both are considering how a fresh impetus might be given to such
programmes.
Improvement Grants
11. The Department recognises that improvement grants
have the potential for making a negative impact upon the historic
environment, but does not believe that this need be (or generally
is) the case. New guidance to local authorities has recently
been issued by the Housing Division of the Welsh Office, and Cadw
has emphasised to local authorities the need for close collaboration
between those involved in both conservation and regeneration.
Building Preservation TrustsBuilding Preservation Trusts
12. The Department agrees that building preservation
trusts have a valuable role to play in the preservation of individual
buildings at risk. While the number of trusts (and completed
projects) in Wales remains modest, the Department believes that
- through the resources which it has provided to the Architectural
Heritage Fund (AHF) and the information work upon which it is
engaged - a platform for real progress has been established.
In February Cadw joined an all-Wales meeting of the Association
of Building Preservation Trusts hosted by the AHF at which local
and national groups were able to exchange views and plan further
development. Cadw has since emphasised to local authorities the
potential benefits which collaboration with a building preservation
trust can reap. To be effective a trust needs to be the product
of voluntary action, often drawing on local enthusiasm and commitment,
and delivery of a numerical target could not be guaranteed, but
Cadw will seek further progress in this area.
Ancient Monuments
13. The identification of monuments for scheduling
under the provisions of the Ancient Monuments and Archaeological
Areas Act 1979 remains an important task for Cadw. It is a priority
for Cadw's own team of Inspectors but in addition the agency will
continue to look to the four Welsh Archaeological Trusts and the
Royal Commission on the Ancient and Historical Monuments of Wales
(RCAHMW) for assistance with this work.
The Record
14. The Committee notes concerns over the adequacy
of funding provided by the RCAHMW for the maintenance of the Sites
and Monuments Records (SMRs) of the Welsh Archaeological Trusts.
The Department recognises that the Trusts are continuing to seek
additional funds for this work. However, it feels that the trebling
of funding over the last three years, facilitating the employment
of additional staff, has greatly increased the overall level of
activity in this area and has put this work on an equal footing
with other activities which make a call on the Royal Commission's
resources.
15. As the Committee recognises, the proposal to
give English local authorities a statutory duty to maintain the
SMRs reflects different arrangements between England and Wales.
In England the SMRs are currently the responsibility of local
authorities but in Wales they are maintained by the Trusts which
are independent charitable bodies. However, like their counterparts
in England the Welsh SMRs are an essential source of necessary
information for the fulfilment of statutory duties. Indeed, the
Department has recently encouraged Welsh local authorities to
formally adopt the Trusts' SMRs for planning purposes.
16. The Department acknowledges that the use of digital
mapping has advantages for a range of tasks including the development
of the SMRs. However, the initial and ongoing resource costs
of using digital data are high. Potential digital data users
need to identify the tasks which would benefit from its use together
with the digitised products which would best serve their needs.
Negotiations with the suppliers of digital mapping can ascertain
the costs of supplying the required product. Only then can the
additional costs, over and above the current costs of undertaking
the work without digitised mapping, be calculated and set against
the benefits.
17. The Department is negotiating a service level
agreement with Ordnance Survey covering the supply and maintenance
of digitised maps. Those agencies and non-departmental public
bodies wishing to be party to this arrangement would be expected
to contribute to the cost. The Department is also involved in
discussions with a number of other Government Departments and
agencies examining the feasibility of a consortium service level
agreement with Ordnance Survey for the purchase and maintenance
of digital mapping.
18. The key issue is financial and turns upon the
amounts which consortium partners are prepared to contribute.
The general position is that current expenditure on mapping (largely
conventional products) by the relevant organisations is modest
and the financial costs of moving to digital mapping are significant.
There is a considerable gap between what organisations in the
Welsh Office consortium are currently prepared to contribute and
the sum that would be necessary to deliver the service. Until
that gap is reduced an agreement in unlikely. Nevertheless the
Department will continue to work to provide a service that will
meet needs at a price that will match the benefits to be gained.
Historic Landscapes, Parks and Gardens
19. Since the Committee's last report, Cadw has been
working closely with the Countryside Council for Wales and the
International Council of Monuments and Sites to compile an advisory
register of landscapes of historic interest in Wales. This work
has also involved the Welsh Archaeological Trusts, the Royal Commission
and local authority representatives. In addition, discussions
have taken place with landowners and the farming community. The
Department notes the Committee's view that Cadw should reinforce
its role in the integrated protection of the wider historic landscape
in Wales, and believes that the completion of the Register will
provide the means of achieving this.
Cadw
20. As the Committee knows, Cadw's status as an agency
of the Welsh Office means that it is directly responsible to Ministers.
It acts with their authority, is bound by Government policy and
(in matters of policy advice) principles of confidentiality.
However, Cadw is well placed to contribute to the interests of
the built heritage in Wales through the advice which it can put
directly to Ministers and is free to inform planning inquiries.
The agency is adequately staffed to fulfil its statutory duties
and to manage budgets which - allowing for differences in size
between Wales and England and Scotland - are comparable to those
deployed in other parts of the United Kingdom. But since they
are inevitably smaller in absolute terms, Cadw must take particular
care to control its organisational and overhead costs. While
the creation of an office in North Wales (or other parts of the
Principality) would not be advisable for these reasons, Cadw staff
(professional and administrative) travel widely, visiting local
authorities to discuss statutory matters and all applicants for
grant as a matter of course. The agency's principal tasks are
encapsulated in the performance targets, many of which include
measures of timeliness - and in 1996-97 all agency targets were
met.
21. The reduction in the number of professional staff
was a temporary interlude following two retirements. Replacements
have now been appointed, and the number of professional staff
in Cadw has never have been higher - although total manpower has
been falling because of reductions in administrative staff. The
Committee deduced from Cadw's 1995-96 Annual Report that during
that period the agency had 95 administrative staff but only 11
professional advisory staff. However, the latter described only
the professional officers in the Inspectorate of Ancient Monuments
and Historic Buildings. Cadw's architects and others with professional
qualifications were counted among the 82 industrial staff also
identified in the Report. Currently there are 33 archaeologists,
architects, architectural historians and staff with comparable
professional expertise in Cadw and 60 administrative staff. The
balance in a total complement of 190 is composed of 65 craftsmen
(such as masons and joiners) and 32 permanent custodians (supplemented
by seasonal recruits).
22. As already noted, Cadw must marshal its resources
and bring them to bear wherever it can do so cost effectively
- often in support of local initiatives. However, developments
such as the formation of the Heritage Forum and the forging of
stronger links with key organisations such as the Architectural
Heritage Fund and the Historic Houses Association will better
enable Cadw to supplement its statutory duties by offering strategic
advice on future directions.
Local Government Reorganisation
23. The Department agrees with the Committee that
all of the new local authorities need competent staff versed in
the issues of conservation in order to carry out their duties,
and Cadw has renewed its offer to receive local authority personnel
on visits and short placements as a contribution to their training.
Planning Policy Guidance
24. The Department is pleased to have been able to
supplement its central guidance on built heritage issues with
Circulars 61/96 and 60/96. Their presentation reflects the advice
received during the course of consultation.
National Lottery
25. The Department is very conscious of the new opportunities
presented by Lottery funding and Cadw in its advisory role to
the Heritage Lottery Fund is anxious to promote Welsh interests.
The Department notes the Committee's concerns that Lottery funding
should not displace Government funding, and is able to confirm
that the principle of additionality remains a central tenet of
the Heritage Lottery Fund.
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