Memorandum submitted by the Council for
British Archaeology (V18)
THE CBA
The Council for British Archaeology is the principal
UK-wide non-government organisation that promotes knowledge, appreciation
and care of the historic environment for the benefit of present
and future generations. It is a UK-wide, non-profit making educational
charity that has been nationally influential for 60 years, with
a growing membership base of nearly 600 affiliated heritage organisations
and circa 10,000 individual subscribers of all ages.
INTRODUCTION
1. Today's rural environment has been shaped
by countless generations of farmers, foresters, builders, engineers
and quarrymen. Contrary to the general thrust of Defra's Rural
Strategy, we do not live in a "natural" environment,
but one whose character has been changed more by past human exploitation
over the last 8,000 years than by any other process. The countryside
is where the greatest time-depth, proportion and diversity of
the physical remains of the past are situated. Everything we now
see has been shaped by the fundamental inter-relationship between
nature and society—our human habitat.
2. Britain's historic environment encompasses
a wide range of buildings, structures, sites, deposits and landscapes.
Their common feature is that historic fabric is irreplaceable:
Bronze Age barrows do not breed. We must seek to conserve what
there is, where it is. If we do not, communities and visitors
are robbed of the patina of historic character that enriches the
places where they live, work or enjoy their leisure; and future
generations are robbed of the materials by which they can study
their own past. This is not about fossilising the countryside,
but it is incumbent upon us to manage the rate of change and prevent
widespread, irretrievable degradation of the rural historic environment
of the sort that has occurred in the last 50 years (see Appendix).
3. This is a fundamental part of society's
long-term responsibilities towards the cultural heritage of future
generations. Change is inevitable—it is what has created
the historic character of the countryside today—but it must
become more sustainable to benefit society as a whole, both now
and in the future.
4. Speaking on behalf of the Government
in a House of Lords debate on Power of Place: the future of
the historic environment, (December 2000) Lord McIntosh stated
that:
"Great progress has been made over the past
20 years in recognising the important public interest in taking
firm action to protect the natural environment. We now want to
make similar progress to protect the historical environment, which
has significance for us all."
5. This has since been reinforced in the
Government's own 2001 statement of policy, The Historic Environment:
A Force for our Future which stated that:
". . . given the span of issues and Departments
which have an impact on the historic environment or vice versa,
the Government acknowledges the need to develop a cross-Whitehall
approach to promote awareness of the historic environment through
all relevant Departments and maximise its contribution to the
Government's programme as a whole."
". . . although the lead responsibility
rests with DCMS and DTLR, other parts of Government have a major
interest in the subject and have taken part in the preparation
of this document. Not least among these is the Department for
Environment Food and Rural Affairs, whose involvement reflects
the importance of the historic environment for rural areas . .
."
6. Against this background we find Defra's
vision of the Countryside as articulated in the Rural Strategy
2004 breathtakingly blinkered in its failure to recognise
the basic importance of archaeology and heritage in the countryside
and its appreciation by the public. The sections referring to
conservation and protection, education and tourism all fail to
recognise that the countryside is a massive cultural resource
that underpins our knowledge of our own history, people's sense
of place, recreational activities and the British tourism industry.
7. While Defra has been doing good work
at a detailed level to improve provision for the historic environment—and
recognises the need to liaise with English Heritage—it is
evident from the Strategy that the Department does not see the
cultural heritage as being fundamental to the character and value
of the countryside and market towns. This is clear from:
— The reference to protecting only
the natural environment for priority three of achieving a sustainable
countryside (page 5) and no reference to the historic environment
in Defra's Strategy for Sustainable Farming.
— No reference to the Government policy
statement The Historic Environment: A Force for our Future
in the background to the rural strategy (pages 5-6).
— No reference to the historic environment
(including its educational and recreational value) in the Summary
of the value of the countryside (page 34).
— Reference only to the natural environment
in the strategy for protecting and enhancing rural and urban environments
(paragraph 69 page 35).
— No reference to protecting and
conserving the historic environment under "Other Actions"
(paragraph 81 page 38)—only to access, education and tourism.
— No reference to protecting an
conserving the historic environment under "Protecting
the rural environment" (pages 40-41).
— No reference to the historic environment
under the "Role of agriculture and forestry" (despite
work by Defra to strengthen its coverage in agri-environment reform).
— No reference to the real achievements
of the ERDP in helping to safeguard the cultural heritage (page
43).
— No reference to the value of the
historic environment in promoting enjoyment of the countryside
and tourism despite good polling and other evidence (pages 44-46).
— No reference to the historic environment
in the "Evidence Base" (Annex B) despite English Heritage's
annual Heritage Counts publication.
— No specific mention (Annex B, paragraph
43 page 68) of the historic environment as part of the value of
the countryside—despite the acknowledgement that the countryside
has been shaped by centuries of economic activity.
8. This blinkered attitude reflects differences
in departmental responsibilities, NOT the real nature of the countryside.
There is a fundamental problem that despite the aspiration of
A Force for our Future heritage is still seen strategically
as a DCMS responsibility of only peripheral interest to Defra.
It is appalling that unlike biodiversity, the Government still
has no PSA targets for conserving the historic environment.
9. Section 17 of the 1986 Agriculture Act
obliges the Secretary of State to seek to achieve "a reasonable
balance" between "(a) the promotion and maintenance
of a stable and efficient agricultural industry; (b) the economic
and social interests of rural areas; (c) the conservation and
enhancement of the natural beauty and amenity of the countryside
(including its flora and fauna and geological and physiographical
features) and of any features of archaeological interest there;
and (d) the promotion of the enjoyment of the countryside by the
public".
10. Under the 1995 Environment Act, the
Environment Agency has a similar statutory duty in relation to
all their functions, to consider the needs of conservation and
access that is even more explicit in relation to the diversity
of the historic environment.
11. This holistic approach is also reinforced
by the recognition in PPG15 of the "all-pervasive" character
of the historic environment, which has been further emphasised
by the Government's recent statement of policy The Historic
Environment: A Force for our Future. Force for our Future
(paragraph 1.2). This, together with the UK's ratification
of the Valletta Convention on Protection of the Archaeological
Heritage, has established the principle that state bodies should
provide leadership in safeguarding the historic environment in
accordance with how their policies and activities affect it.
12. Key National Priority (NP3) of the ERDP
is for "the protection and enhancement through appropriate
management of historic and archaeological features of international,
national and local importance, and their settings, in particular
by conservation and repair of ancient monuments and landscapes
at risk." Yet Defra's Strategy for Sustainable Farming
and Food makes no mention of the historic environment.
13. We have actively contributed to and
strongly welcome the real improvements in coverage of the historic
environment in the reforms of agri-environment support that Defra
has been developing over the last two years. We believe that this
reflects a real commitment amongst officials to improve this situation.
But we have been repeatedly dismayed at the failure of this to
feed into high level policy within Defra.
KEY NEEDS
FOR IMPROVING
RURAL DELIVERY
FOR THE
HISTORIC ENVIRONMENT
AS RECOMMENDED
TO THE
HASKINS REVIEW
BY THE
CBA
14. Objective A
Establishing conservation of the Historic Environment
as a core environmental issue for Defra and other Government Departments
and Agencies on a par with other environmental issues by:
(i) Developing high level PSA targets for
sustainable and monitorable management of the historic rural environment
for Defra and its agencies and other Government Departments, including
development of the role of Green Ministers in this area supported
by expert advice at a senior level.
(ii) Ensuring that Defra and Environment
Agency treat their statutory obligations towards HE on an equal
footing with biodiversity and habitats in terms of resources for
research and qualified staff for delivery and/or co-ordination
of expert advice.
(iii) Establishing a Code of Good Conservation
Practice for Agriculture (and rural development).
Reasons:
Neither the huge public interest in the historic
environment (evident from MORI polling, TV viewing and other indicators)
nor the need to deal with major problems for rural historic environment
are reflected adequately in Government policy targets for the
rural environment.
Recurrent failures of central Government to
recognise, let alone properly understand, issues for conserving
the historic environment and give it adequate weight in policy
development and resourcing. Current resources devoted to delivery
of environmental conservation in rural areas still demonstrate
a severe imbalance between historic environment and other interests.
15. Objective B
Putting Local Government historic environment
information and advisory services on a statutory footing with
adequate resources—including funding from Defra to invest
in maintaining and improving delivery of information from historic
environment records and provision of on-the-ground advice to farmers.
Reasons:
— The only means of ensuring that adequate
delivery of information and advice which is fundamental to principles
of sustainability and informed conservation.
— Adequate information and advice represents
a long-term investment, the benefits of which in terms of environmental
protection are likely to last far longer than the lifetime of
individual schemes because it taps into a basic willingness of
many farmers to conserve their historic environment.
16. Objective C
Developing far stronger provision for monitoring
the state of the rural historic environment.
Reasons:
— Mechanisms for condition surveys
of historic environment and other feedback are still poorly developed.
— Monitoring and feedback is essential
to establish effectiveness of policy implementation.
THE PROPOSAL
TO ESTABLISH
AN INTEGRATED
AGENCY
17. We welcome the recognition in the Government's
Rural Strategy 2004 of the need for Defra and the proposed
new Agency to work closely with English Heritage—a point
that was ignored by the Haskins review, despite its being made
by ourselves and English Heritage.
18. But given our concerns expressed above,
we have reservations about what real commitment there is to make
the historic environment a core objective of the overall strategy.
— Although English Heritage has become
much more pro-active in seeking to influence rural policy, budgets
are under massive pressure.
— The Departmental separation of English
Heritage from Defra coupled with the lack of any EU Directives
and PSA targets for the cultural heritage greatly compound the
potential for the historic environment to remain relatively neglected
in the new arrangements. The statutory obligation on the Environment
Agency to take account of the historic environment has not led
to it being treated on a par with biodiversity.
19. We urge the Committee to look very hard
at exactly how the new arrangements will overcome this. In particular
we would like to see the committee press the Government to:
— Include in primary legislation a
statutory obligation on the new Agency to take account of the
historic environment as applies to Defra and the Environment Agency.
— Back this up with commitments about
how, in collaboration with English Heritage, this will be put
into practice on a par with wildlife and landscape responsibilities.
— Establish how this will be put into
practice through policies, targets, staffing, resources and research
and development projects, all of which currently lag far behind
provision for wildlife.
THE PROPOSED
STREAMLINING OF
RURAL, AGRICULTURAL
AND ENVIRONMENTAL
FUNDING SCHEMES
20. Overall we welcome the principles and
proposals for streamlined funding. However we are concerned that
unless the basic strategic status of the historic environment
is addressed, the proposals will not automatically improve the
situation for the rural cultural heritage. The summary of the
Rural Funding Review Report explicitly states (see main Strategy
page 91) that the system is designed to support the Defra strategic
priorities and PSA targets. But these do not include the
historic environment.
21. In developing more streamlined funding—which
we welcome—we would like to see a very conscious effort
(as we have been pleased to witness in the proposals for reforming
agri-environment schemes) to take full account of the historic
environment issues.
22. More work is needed to establish clearer
principles of how conservation of non-renewable historic assets
and their appreciation should relate to rural production, regeneration
and environmental enhancement.
THE DELIVERY
MECHANISMS FOR
THE STRATEGY,
INCLUDING THE
IT STRATEGY THAT
UNDERPINS IT,
ITS ENVIRONMENTAL
IMPACT AND
ITS LINES
OF ACCOUNTABILITY
23. The figures for the attrition on the
historic rural environment in our Appendix reflect the past inadequacy
of delivery mechanisms to protect the historic environment.
24. Despite a number of excellent initiatives
and some real recognition of issues (eg proposed agri-environment
reforms; to some extent the soil strategy; and technical research
by Defra into plough damage issues) there has been something like
50 times less research into the rural historic environment than
biodiversity to underpin rural policy and delivery.
25. We support the Government's recognition
of the need for more customer-focused delivery, but we remain
dismayed that provision of information and advice to farmers continues
to be seen as a bureaucratic overhead that should be kept to a
minimum cost. Instead it should be seen as an investment in training
and capacity-building in sustainable development and informed
conservation that will bear fruit well beyond the lifetime of
any particular scheme. There is a real danger that the new improvements
for the historic environment promised by the reform of agri-environment
schemes will not be maximised. If so, the taxpayer will get poor
value for money in terms of properly integrated long-term conservation.
26. There needs to be more serious investment
in locally based systems of providing historic environment information
and advice on the ground, building on frameworks for well-informed
integrated heritage and environmental management on a whole farm
basis. Investment in developing adequate staff and resources to
deliver information and advice is an essential prerequisite for
historic environment conservation as illustrated by the National
Parks and the National Trust. We welcome recent moves by Defra
and English Heritage to enhance such services—but they still
lag far behind the overall provision for ecological advice.
27. We welcome the establishment of the
principle of a joined-up approach to provision of integrated environmental
information through MAGIC and the LAMIS initiative—though
MAGIC in particular will need a good deal of refinement to become
really useful.
28. Defra's current review of its obligations
in implementing the Aarhus Convention on environmental information
must fully take account of historic environment information. The
Committee should note the proposals being examined by DCMS (in
its Heritage Protection Review) to put historic environment records
onto a statutory footing, which would enhance this provision.
THE EXTENT
TO WHICH
THE STRATEGY
INCORPORATES THE
RECOMMENDATIONS OF
LORD HASKINS'
RURAL DELIVERY
REVIEW, PUBLISHED
IN OCTOBER
2003
29. We were extremely disappointed that
Lord Haskin's report almost entirely ignored the historic rural
environment and the role of English Heritage. However, Recommendation
16 included a reference to the "historical landscape"
as being an aspect of the proposed integrated agency's remit.
30. We welcome the Government's proposal
for close liaison between the new Agency and English Heritage,
but it is a sign of the Government's ambivalent attitude to the
historic environment that despite this, EH is not included
with the Environment Agency and Forestry Commission in the "strategic
group" set up "to champion change" (see Annex C,
Recommendation 16, bullet point 1 page 81).
APPENDIX
THE LEVEL
OF THREAT
TO THE
HISTORIC RURAL
ENVIRONMENT AND
SUPPORT SERVICES
— 10% of destruction and 30% of damage
to archaeological sites in the last 50 years attributable to agriculture;
32% of all archaeological sites and 21% of Scheduled Monuments
in rural areas are still under the plough; 65% of monuments in
arable areas are at medium or high risk of damage (1).
— 11,600 wetland ancient monuments
have suffered desiccation and partial destruction in the last
50 years, mainly caused by drainage and ploughing for agriculture
(2).
— 17% of all listed farm buildings
were "at risk" and 24% were "vulnerable" (3).
— Only 60% of unlisted field barns
in the Yorkshire Dales National Park were intact, and the rate
of decline was rapid (4).
— Only 20% of 10,000 ancient threshing
barns being maintained to high standards (5).
— 33% of ridge and furrow in East Midlands
lost since 1950s (6).
— Approximately 33% of hedges in England
& Wales were lost between 1984 and 1993 (7); 49% drystone
walls derelict and 38% in serious decay in 1994 (8).
— Defra employ 10 times fewer archaeological
advisers than ecologists; there are only 9.5 FTE countryside archaeological
officers in local authorities; 30% of local authorities do not
have historic building conservation officers.
— At 11% the proportion of applications
for total demolition of listed farm buildings and their cartilages
(rather than alteration or refurbishment) is nearly twice as high
as for listed buildings in general (9).
REFERENCES
(1) Darvill, T and Fulton, A 1998. The Monuments
at Risk Survey of England 1995. Main Report. English Heritage.
(2) English Heritage Survey of Wetland
Monuments at Risk 2001.
(3) English Heritage 1992 Buildings at
Risk Sample Survey of circa 40% rural Listed Building.
(4) Gaskell, P and Tanner, M (1998) Landscape
conservation policy and traditional farm buildings: a case study
of field barns in the Yorkshire Dales National Park, Landscape
Research 23(3) 289-307.
(5) Gaskell, P (1994) SPAB Barns Database,
SPAB.
(6) Anderton, M, Went, D (2002) Turning
the Plough, Loss of a Landscape Legacy, EH Conservation Bulletin
42, March 2002 52-55.
(7) DOE. 1993. Countryside Survey 1990:
Main Report and Barr, C J, Gillespie, M K and Howard, D C
(1994) Hedgerow Survey 1993: stock and change estimated of
hedgerow length in England and Wales, 1990-93. Institute of
Terrestrial Ecology.
(8) Countryside Commission. 1996. The
Condition of England's Dry Stone Walls (Countryside Commission
Publication No 482).
(9) CBA internal database of statutory notifications
to the CBA of proposals to demolish or alter listed buildings.
20 September 2004
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