Examination of Witnesses (Questions 207
- 219)
TUESDAY 28 MARCH 2006
MR PETER
HINTON, MR
BRIAN AYERS
AND DR
MIKE HEYWORTH
Chairman: We are now focusing specifically
on the archaeological aspects of the heritage and, although each
of you represents a different organisation within the archaeological
sector, you each come under the umbrella of the Archaeological
Forum.[10]
Q207 Philip Davies: The written evidence
had lots of praise for PPG16 in terms of its effect on archaeology.
Are you happy that planning controls generally are effective in
preserving archaeological remains where it is necessary?
Mr Hinton: I think we are. There
are changes that we would like to make to PPG16 in terms of fine-tuning,
particularly in terms of ensuring the proper public benefit is
derived from it, but it seems to be a system that has worked well
in protecting and allowing investigation of archaeological sites
that are threatened by development where that development is covered
by the planning process. What PPG16 does not do is protect sites
that are threatened by processes that are not covered through
the planning process.
Mr Ayers: It is important that
the basic principles of PPG16 are recognised and sustained. The
principles of the fact that there should be preservation by record
where it is not possible to maintain sites but, where possible,
there should be a principle of mitigation strategies to avoid
damage to sites recognising that we have a limited resource and
it is not one that we can replace. Whilst we want to see PPG16
enhanced so that we can bring the benefits that it has brought
to a relatively narrow sector to a wider community, we want those
underlying principles to be maintained.
Q208 Philip Davies: If you want it
to be enhanced is there any evidence that you have got that we
have lost sites due to inadequate planning controls? Is there
any evidence you can give us where we have lost sites due to that?
Dr Heyworth: In the majority of
cases PPG16 works very well. The key thing now is that for the
first time archaeology is a material consideration in the planning
process. What often happens is that there has to be a decision
taken as a result of earlier work—evaluation-type work—as
to how much archaeological work is going to be undertaken during
the course of the development. Sometimes inevitably there are
pressures during development work and it means that the archaeological
excavation or whatever mitigation strategy is put in place does
not necessarily have the opportunity to recover the full range
of evidence that you might like, but that is a balance. What is
certainly the case is that, since the introduction of PPG16, the
contribution to knowledge has vastly increased over what was previously
the case, so it is a huge improvement, but there are certain areas
where we believe it can be improved more and the key for us is
to make a better link between the acquisition of that knowledge
and its dissemination to the broader public. That is where we
would like to see more of an emphasis.
Q209 Chairman: I understand there
are discussions going on about the merger of PPG15 and PPG16.
How are those going and what response are you getting from the
ODPM and DCMS to the points you are making?
Dr Heyworth: One of our frustrations
at the moment to a certain extent is that the work to merge PPG15
and PPG16 has been somewhat put on hold awaiting the Heritage
White Paper and the Heritage Protection Review. We certainly argued
previously that we felt there were opportunities to make some
small amendments to PPG16 in particular but the suggestions at
the moment are that those should really wait until we have gone
through the process of the Heritage White Paper later in the year,
so we are a little bit stuck on that loop at the moment. Certainly
the principle of merging the two, looking at the historical environment
in a holistic way, is something we would all very much support.
Mr Ayers: It is also fair to say
that, from our perspective, PPG16 has been a more effective tool
than PPG15. We have been able to develop the principles of PPG16
in such a way that we can get a record made of threatened sites
in a manner where frequently with changes to historic buildings
it has been less easy to do that.
Q210 Chairman: You have all drawn
attention to your concern about the operation of the Class Consents
Order and the way in which this is being used to damage some important
sites. How important do you regard it to correct that problem,
and is it universally accepted that it should be corrected or
is there some opposition particularly from the farming community?
Dr Heyworth: Amongst the archaeological
community there is absolutely a unanimous view that it should
be corrected. It seems absurd to us that these sites which have
been categorised as the most nationally important sites in the
country in many cases are being actively destroyed day by day
by agricultural processes, forestry processes and other land management
processes. The principle from our point of view is a clear one.
What we then need to discuss are other ways of land management
and that is where some of the environmental stewardship schemes
that have come into place over the last year or two in particular
are very helpful in that regard. That is where the bridge is being
built to discuss this with farmers and landowners.
Mr Ayers: The key to it is the
best land managers are the people who own the land and the people
who work the land. They are also the people who frequently care
most for it as well. One of the things that we have discovered
is that by helping to explain what the historic environment is
all about, what the sensitivities are with regard to management
of that land, is one of the best ways of ensuring effective protection
for monuments within the landscape. What is important is that
we do take this holistic view of the historic environment, we
try and recognise that there are other pressures, we realise there
is an economic aspect to farming as much as there is an historic
environment protective aspect to it, and that we, through mechanisms
such as the agri-environment schemes that are coming on stream,
use those to get a common way forward.
Q211 Helen Southworth: Where did
the impetus for the reforms in the Heritage Protection Review
come from in your perspective and how confident are you that they
are going to be effective in archaeological terms?
Mr Hinton: We certainly know that
representatives of this forum argued for the kind of reforms that
are set out in the Heritage Protection Review, a few ministers
back, I think, and I remember being told at the time that perhaps
our aspirations then were unrealistic in terms of the level of
reform that we were looking for for heritage protection legislation.
I do not think we would claim credit as being the progenitors
of the programme but it is certainly something that has been bubbling
up over many years through the archaeological and heritage community
more widely, a feeling that the current legislative package is
confusing, arcane, obstructive and has great areas of unaccountability
in it, and so we were delighted when DCMS and English Heritage
got behind this agenda. I think the second part of your question
was about how effective it is going to be, will it work? Our concerns
cover a range of issues. There is certainly concern about the
area of resourcing. We do not yet know quite what the resourcing
implications will be but there will be resourcing implications.
They may not be enormous on the archaeological side but there
will be some. Also, if a Bill seems—and you will have a
better feeling on this than we have—to have quite wide support
through the heritage community we want to be sure that that will
pass through Parliament successfully. Those are two of our major
concerns. What we would like to see is a White Paper that explores
those issues so that we can anticipate with greater authority
than we have at the moment the hazards that lie ahead.
Dr Heyworth: One of the real opportunities
here is to link it in much more explicitly to public benefit and
the public agenda. We feel that the historic environment can make
a huge contribution to sustainable communities and community regeneration,
and if we get this process right, make it much more open and accountable,
there is an opportunity to really bring heritage in as one of
the key assets and one of the key drivers to regeneration and
sustainable communities and, as Brian said earlier, that is one
of the best ways to protect and preserve these assets for the
future, by getting local people to engage with them. There are
some fantastic examples now of schemes like Adopt a Monument where
a local community would take responsibility for particular monuments
in their parish or locality and for maintaining them in the future,
just as we get in environmental conservation, et cetera. If we
can get the process right and link it into the public value and
get the knowledge base linking in to understanding it in that
sense then I think there are some real opportunities to move forward.
Mr Ayers: Another interesting
aspect of the Heritage Protection Review is the way that it is
implying a broader philosophical understanding of what we mean
by the historic environment. It is much more encouraging for us
to have people like yourselves discussing the historic environment
than merely built heritage. We are talking about a cultural construct
out there which is everywhere. There is probably not a square
centimetre of England and probably the UK which does not have
the impact of humanity upon it. It is a much more inclusive and
constructive process to be talking about the historic environment
as a whole and involving the wider community as a whole in stewardship
of that environment than it is to be continually talking about
individual monuments and protection of, as it were, hot spots
within that environment.
Q212 Helen Southworth: Can I ask
you to expand a little about the public benefit, and when you
do so can I ask you—and this is in almost direct opposition
to what you have just said—if you would look at the role
of archaeology in the built environment in terms of interpretation
and access as well as below ground sites? We tend to think of
archaeology as being things that are damaged by ploughs.
Dr Heyworth: I think that is changing.
One of the projects that my organisation was involved with very
recently was the Defence of Britain project which was a survey
of 20th century military sites, particularly associated with anti-invasion
defences in the Second World War. One of the great advantages
of that was that it brought to a very large audience the idea
that there was an archaeological approach to those sorts of constructions.
1940s concrete is not necessarily what people think of as archaeology,
not your average Time Team viewing perhaps, but for many
people they recognised for the first time that archaeology as
a series of techniques had a contribution to make in terms of
the study of that period. That equally applies to buildings of
all types. It is only about three weeks ago that I was sharing
a platform with the chief executive of English Heritage. We were
launching a document on good practice in terms of recording built
fabric of historic buildings, and for many people, as you rightly
say, townscapes and individual buildings are what they see every
day and that is part of the historic environment, and a very significant
part for them, but the key for us as archaeologists is not only
to understand that built fabric but also how it relates to layers
that went beneath and building up those layers of time and understanding
how the communities developed. What emerges in nearly all the
local society groups and community groups that are involved in
the historic environment and heritage is that there is a real
thirst for knowledge out there about their community, how it has
developed and what the buildings mean. Archaeology has a huge
role to play there in terms of it interpreting and understanding
the past and allowing people to value it perhaps in ways they
have not been able to before.
Mr Ayers: Your question is an
interesting one because what it does is highlight the point about
archaeology, which is that it is dealing with two things. There
is archaeology as a product, the cultural items, if you like,
be they buildings or objects in the ground or the sites, and there
is archaeology as a process, the science of discovery, the manner
in which we investigate the environment, be it above or below
ground, be it buildings or holes in the ground, and that investigative
process is one which has terrific engagement with the wider public.
We have used it with schools and teachers and have found that
we can address areas right across the curriculum. We do not just
have to stick to history or geography. We can deal with English
and mathematics and science because archaeology is a great broad-based
discipline which enables that creative investigation of the world
around us to take a more concrete form through looking at the
products, but it is the intermix of archaeology as process and
archaeology as study of product which is enriching.
Mr Hinton: One of the things that
we would like to see, particularly through the reform of PPG16
when the new planning policy statement is produced, is more opportunity
to allow the public to participate in that process. I may be here
representing the professional body for archaeologists but it is
a widespread myth that we want to keep the general public out
of active participation in archaeology. It is very important that
people engage in this process. It really captivates minds, and
one of the things that we have to do is make sure that it is a
reasonable requirement of a local authority to ask for public
open days and possibly public participation in projects that are
going forward. If there is a public interest argument in archaeology,
and I firmly believe there is, then we need to find a mechanism
for interesting the public.
Mr Ayers: Could I come back in
briefly? I happen to work within a museums environment and it
is quite interesting, this being a Culture, Media and Sport Committee
because, of course, museums are sponsored through DCMS. We are
currently working with the Renaissance in the Regions initiative.
That initiative is very much linked to inspiring learning and
ensuring that there is a wider understanding amongst the community
as a whole of the value of museums and the value of archaeology
and the archaeological process within that. It is particularly
valuable, if you are talking to us as archaeologists, from our
perspective because we are a cultural pursuit and we do firmly
believe that we help to brighten the nation.
Q213 Mr Hall: In June 2004 the Government
announced that it was going to require local authorities to maintain
historic environment records. We have had evidence to this committee
that unless archaeology services are involved at a higher level
status in that record collection the system will be seriously
undermined. Have you got a comment on that?
Mr Ayers: The historic environment
records have been built up over the last 30 years as a partnership
primarily between English Heritage and local authorities. We now
have pretty well comprehensive coverage across the country. We
have been developing systems which ensure that those records have
compatibility and fairly soon I hope that we will also have interoperability.
We are also developing ways in which those records can be accessed
much more easily by the public. They are the basis upon which
objective decision-making is taken. We are providing advice to
local councillors with regard to planning applications and they
provide a very great deal of the information which will be required
for the proposed management agreements and the statements of significance
which the HPR process is seeking. They are remarkably powerful
tools but they are at the moment entirely discretionary. Without
them I cannot see the HPR process working. We understand that
there is likely to be a recommendation that it will go into the
White Paper that they should be made a statutory responsibility
of local authorities and we believe that that is extremely important,
not just the records themselves but the actual historic environment
services. There is no point in having a database if you do not
understand the information within it. What we need to make sure
is that we get good objective data to those people who need to
use it, either the decision-makers or the wider public.
Mr Hinton: We are concerned at
the moment that a number of local authorities who are facing budgetary
difficulties are targeting heritage services, particularly archaeological
services,[11]
and therefore the danger that Brian has described is quite real
in some areas of having a record that becomes fossilised at a
particular point in time and is not interpreted and updated. As
Brian says, HPR is going to be very much dependent on having these
historic environment records. We are in quite a delicate time
at the moment with DCMS and English Heritage and ODPM furiously
knitting away creating a structure at one end if we have a few
local authorities who are pulling the wool and unravelling it
at the other end, so I think this is something that is going to
have to be looked at very carefully in the near future. Certainly
leaving such an essential plank of heritage protection reform
as an entirely discretionary process does leave the whole process
very fragile and very vulnerable indeed.
Dr Heyworth: The other slight
danger is that they are also just seen as linked to and associated
with development control processes whereas in fact they are the
local knowledge base which people should be tapping into and learning
from and using. They should be very much live resources, and the
way in which they now can be made more available through the internet
has really helped community groups to do that, but again the frustration
is that the small resource that you need to facilitate the process
and engage with community groups through education and outreach
is invariably the one post that is the first one to be cut when
you look at your resources, and yet that post can be a real driver
to all sorts of community engagement. There are some frustrations
about that as well. It is not just about development control.
Q214 Mr Hall: Peter, you actually
anticipated the next question in that while local authorities
are expected to allocate resources between their responsibly for
scheduled monuments and their responsibility for protecting listed
buildings, are you confident that local authorities are going
to respect the need for archaeology in that allocation of resources?
Mr Hinton: It is always very worrying
that so much of archaeology is done on a non-statutory basis.
What we need to do is make sure that there are proper indicators
in place which do not just take account of the statutory designated
assets. If I may I will deflect that question to my colleague,
Brian Ayers, who is more of a local government man than I am.
Q215 Mr Hall: With regard to the
possibility that statutory responsibilities being brought into
the equation will distort the picture and make local authorities
have a distorted view of what their priorities should be, perhaps
you could answer both those questions together.
Mr Ayers: I will try. I do not
think that making historic environment records statutory should
distort the issue inasmuch as from our perspective it is effectively
resource neutral. They are already there. They are currently being
paid for. They are an asset which is important, as Mike said,
across the spectrum, so that should not distort the issue. There
is an interesting part of your question with regard to responsibilities
towards listed buildings and historic monuments, and I think I
would refer you back to my earlier answer, which is the need to
work in greater partnerships, particularly with rural monuments,
for instance, operating within things like agri-environment schemes
in an attempt to ensure that there is effective stewardship of
those monuments at what is often low cost. In my own county, which
is Norfolk, we have a remarkable project called the Norfolk Monuments
Management Project which is a partnership between the county council,
English Heritage, Defra, the National Farmers' Union, the CLA,
people like that, where we work very closely with 500-plus landowners
right across the county to ensure effective management of monuments,
which is frequently done at the cost of the individuals concerned
and not of the public sector at all.
Dr Heyworth: In some ways one
of the most potentially distorting factors is this artificial
divide between monuments and listed buildings, and one of the
great advantages of the HPR process hopefully will be to start
to look at these through some sort of unified regime. One of the
key things that emerges in many cases is that the most complicated
areas to deal with are complexes where you have potentially got
underground archaeology and historic buildings and listed buildings
and hedgerows and all sorts of other things going on, and to be
able to look at that in a holistic sense will be much better all
round and will enable the real benefits to be seen in the planning
process as well, hopefully. That is another of the real golden
opportunities coming up, I think, through the HPR.
Mr Hinton: However, it is worth
noting that of the assets that are recorded as entries on sites
and monuments records something in the order of 98% of them are
not designated in any formal way other than appearing on the register.
The Heritage Protection Review will bring many great things but
what we need to do is make sure through statutory sites and monuments
records services that there are facilities for dealing with the
other 98%.
Q216 Alan Keen: One thing that surprised
me was seeing the growing amount of investment, if you like, by
developers, and I took that to be people wanting to develop sites
and therefore putting money into not damaging them until they
have been fully investigated, but I read further and realised
it was archaeological contractors. How does that work? There must
be a down side to it.
Mr Ayers: It works in that PPG16
makes requirements for archaeological work a material consideration
within the planning process. That means that local authorities
can require a developer to undertake a range of archaeological
works ranging from a desktop study up through evaluation work
to full scale excavation. Local authority archaeologists provide
the advice, using the historic environment record, to the planning
authorities. The planning authorities pass the requirement on
to the developer, usually together with an archaeological brief
or specification detailing the type of work that is required that
has been prepared by the local authority archaeologist. It is
then up to the developer to secure an archaeological contractor
to undertake that work. Increasingly that is a process that is
being done through a tendering system and another role of the
local authority archaeologist is therefore to monitor the work
to see that it is done to an appropriate quality, that standards
are maintained and that the outputs in terms of a report and archive
are appropriate for the requirements of the local authority and
of archaeology itself. That is the process and that is how the
funding comes in.
Q217 Alan Keen: What are the down
sides for the profession?
Mr Hinton: One of the things that
the profession is finding is that we have had to adapt quite rapidly
in the light of PPG16 from a situation of largely public funded
archaeology to doing private sector funded archaeology working
in a competitive environment and it is very difficult for any
profession in its early years to handle competition. One of the
things that my institute does, the Institute of Field Archaeologists,
is run a quality assurance scheme for archaeological organisations
called the Register of Archaeological Organisations Scheme. This
is a form of corporate accreditation. We also have accreditation
of individual members through the entry requirements into the
institute, but that is something that will need to be beefed up.
What we need to do to build in better quality assurance into the
whole of the archaeological process is ask those bodies that are
requiring or commissioning work to look for accredited archaeological
professionals to undertake the work, and I emphasise again that
the object of that exercise is to ensure that quality is maintained,
that standards are maintained, not that the very important voluntary
sector is driven out of the business. There is absolutely no reason
why they cannot get the same accreditation as the paid archaeologists
do. There are problems there and there are also significant problems
in terms of pay for archaeologists where we lag very seriously
behind average levels of pay, getting more like 60% of the average
pay of other professions. There are a number of issues to be addressed,
many of which can be done through PPG16, again by indicating to
local authorities what is reasonable, what is defensible in the
way of a requirement, and we are, I am pleased to say, working
quite closely with English Heritage and DCMS to try and develop
such a scheme which we hope also to introduce in partnership with
the Institute of Historic Building Conservation from whom you
have taken evidence earlier.
Q218 Helen Southworth: Do you think
there should be a planning requirement that people working on
sites should meet the registered archaeological organisations'
standards?
Mr Hinton: I personally believe
it would be extremely helpful if local planning authorities had
the facility to make that requirement when it was appropriate.
I do not believe that it would be necessary for every archaeological
excavation. I think it needs to be applied proportionately. In
the case where a local planning authority is requiring archaeological
intervention for someone putting an extension on to a small house,
that would be overkill. When you are dealing with major developments
with very serious sensitive archaeological sites I think that
would be an appropriate step to take. As ever with the planning
process, we would be dealing with questions of reasonableness
and what we would look to English Heritage and its sister organisations
across the UK and DCMS and ODPM to do through the planning policy
statement is to give some guidance on reasonableness, and we would
like to see them take a tougher line on that at the moment to
create some barriers to entry to professional practice that allow
proper self-regulation to take place and ensure that public benefit
is maintained in a way that it is not always at the moment, we
have to confess.
Mr Ayers: There are a couple of
other down sides to the contracting process. One is the relative
lack of effective synthesis of the amount of work that is being
undertaken. There is a terrific amount of archaeology which is
now being done and in many cases you could argue that the bringing
in of private sector money and competitive tendering has driven
up standards and has driven up ways of doing things, but the lack
of synthesis is really quite worrying. There is a very great deal
of information which is coming out. It is being recorded, it is
going into the county HERs and it is going into what we call grey
literature, but it is not being synthesised in a way which would
help the profession to develop further as a whole. That is one
aspect. The other aspect, which is in a way quite distressing
in a country where archaeology grew out of public enthusiasm through
county societies in the 19th century and what-have-you, is the
manner in which the amateur archaeologist has necessarily been
removed from the excavation process, or at least the funded excavation
process. If you are in a competitive tender, obviously you cannot
use volunteers as part of that competitive tender, and also if
you are undertaking the work you cannot deliver a project late
because it rained and the volunteers did not turn up but your
professionals did. Accordingly, there has been a very significant
contraction of opportunity for the public to engage in archaeology,
in digging holes and finding things, which is what a lot of people
like to do and there is nothing wrong with that, and so that is
a problem for us.
Mr Hinton: But, as I said earlier,
that is something that could be relatively easily rectified through
a bit of tweaking of the PPG16 to make it a reasonable requirement
on the developer to contracting archaeological organisations which
would additionally provide opportunities but not depend on volunteer
input into the archaeological process. I think that would achieve
an effective balance.
Q219 Helen Southworth: In terms of
the information that is gathered from sites are you confident
that there is a national standard of depositing? I am thinking
particularly if you have sites next to each other that might have
five years between developments. Is there a methodology for being
able to identify the detail of a previous excavation?
Mr Hinton: There is a problem
certainly in synthesising the results of two excavations five
years apart on different sites because each one can be a discrete
piece of work funded by a different developer for different purposes.
This really is where we look very much to English Heritage and
its Historic Environment Enabling Programme to provide opportunities
for that synthetic overview that cannot be undertaken on a piecemeal
funded basis through the development process. Another concern
is in terms of the deposition of the written archive and the material
that is excavated. In some parts of the country there are museums
that are willing to take and are capable of taking that archive.
In other parts of the country there is nowhere for it to go and
it is currently sitting around being looked after by archaeological
contractors at their own cost waiting for a suitable repository
to be found. There are some very good models around the country,
museum based repositories, for archaeological information which
are not just dumps where they are buried like some kind of embarrassing
nuclear waste but actually places where the material can be studied
by academics, by members of the public, by anyone, and we need
to get that network spread out across the country.
Mr Ayers: There are two parts
to your question. The first part we are generally on top of. I
think what you were asking was, are we, as it were, providing
a standard of record even if two parts of the same side are done
separately by different contracting organisations five years apart?
Broadly speaking we are on top of that. We have the procedures
and the processes in place to ensure a compatibility of standard
and indeed of interoperability between records, but as to the
second part of your question there is an emerging problem with
regard to public storage of and access to material and, as Peter
said, it differs across the country but I would suggest that even
in those places which are now generally well set up it is a problem
which could easily get worse. Certainly within my own museums
and archaeology service we regularly review our procedures for
both acquisition and indeed disposal simply in order to manage
a developing issue.
Dr Heyworth: The other thing worth
touching on is that one of the other difficulties here is that
a lot of this work is quite small scale as individual pieces of
work and therefore within that individual piece of work it is
very hard to justify to the developer who is paying for it why
they should perhaps see that piece of work in a broader context,
so you end up with lots of bits of jigsaw puzzle, if you like,
and it is very hard to see who pays for the work that tries to
put the jigsaw back together to tell the story. Whilst the technical
standard side is probably stronger than it ever has been the difficulty
of the process is that often the output is what is termed a piece
of grey literature, which is a relatively technical report which
is not actually even published formally, is stored in an archive
et cetera, but often—and this comes back to a certain extent
to the pressures of the competitive tendering environment in which
they work—the organisations undertaking the work do not
have the capacity, often because they have gone on to the next
job, to tell the story. This is where it comes back to the fact
that we are missing an opportunity in terms of public value and
public benefit. That is the area I think we would want to probe
more. The technical standards I think are well looked after.
10 See HC 912-II, Ev 5 Back
11
Footnote by Witness: Northamptonshire County Council,
Leicester City Council, Surrey County Council, Isle of Wight and
Northumberland National Park. Back
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