Memorandum submitted by the Society of
Antiquaries of London
The Society welcomes the Committee's choice
and timing of its inquiry on Protecting, Preserving and Making
Accessible our nation's heritage, which offers an opportunity
for Learned Societies and others in the voluntary sector to identify
priorities in advance of the forthcoming heritage White Paper.
The inquiry represents the first independent review of Government
performance on actions outlined in The Historic Environment:
in A Force for the Future (AFFOF), which was published over
five years ago (2001), and which, despite its age, remains the
current Government policy statement. The Society particularly
also welcomes the multidimensional scope of the inquiry, which
includes both historic environment and museum/archive aspects
of the cultural heritage.
Founded in 1707, the Society is charged by its
Royal Charter of 1751 with the "encouragement, advancement
and furtherance of the study and knowledge of the antiquities
and history of this and other countries". Its membership
comprises an elected college of around 2,300 Fellows from the
fields of archaeology, art and architectural history, material
culture studies, museology, archives and heritage management.
Fellows serve in senior positions in universities, museums, libraries,
archives, professional bodies, local authorities, national heritage
agencies, as well as in private practice.
The Society is a registered charity and leading
non-Government organisation working in the cultural heritage sector.
The Society is an active member of the Archaeology Forum and Heritage
Link, umbrella bodies of national NGOs concerned with the investigation,
management and interpretation of the historic environment. It
also advises the All-Party Parliamentary Archaeology Group (APPAG).
The Society awards grants from its own funds
for academic research and the conservation of historic buildings.
It is also an Accredited museum and holds a pre-eminent collection
of paintings, prints, manuscripts and artefacts together with
the country's leading research library for archaeology and the
cultural heritage. It also maintains for public enjoyment Kelmscott
Manor in Oxfordshire, the former country home of William Morris,
Fellow, and leader of the English Arts and Crafts movement.
Thus as a leading national Learned Society,
research sponsor and publisher and as a museum, library and archive,
the Society is actively engaged in all areas of debate on the
heritage and cultural property. One of the Society's strategic
aims is to influence policy making in the national and international
heritage. Its independence of government and of any vested sectarian
interests makes it uniquely placed to encourage and facilitate
public debate on the management, conservation, presentation and
public understanding of the heritage. The depth and breadth of
knowledge and expertise among the Society's 2,300-strong Fellowship
gives it the authority to speak on key issues of policy and delivery.
Q1. What the Department for Culture, Media
and Sport should identify as priorities in the forthcoming Heritage
White Paper
1. A key priority is the reform of the current
regimes for designations and consents, which will unify the various
registers of historical assets, both for listed buildings and
for Scheduled Monuments. The Society has consistently supported
a holistic approach to understanding, protecting and managing
the historic environment, together with the enhancement of local
delivery currently being promoted by English Heritage (EH). We
are anxious that the outcomes of EH's Heritage Protection Review
will be available to inform the drafting of the White Paper. The
Society is also looking for assurances that any new regime will
be properly resourced, both centrally and at local level.
2. Damage to archaeological sites by deep
ploughing through the Class Consents system remains one of the
most critical issues in national heritage conservation. Recent
deep ploughing of areas of the Roman city of Verulamium, one of
the Society's key associations through its former President, Sir
Mortimer Wheeler, revealed the flaws of the current Class Consents
system. Reform of the Class Consents regime should form part of
the White Paper proposals.
3. The White Paper also presents an opportunity
to review the current provisions for Conservation Areas and their
resourcing, together with a more inclusive consultation on valuing
significance by local communities.
4. In addition, the timing of the White
Paper should have the effect of accelerating the review of the
non-statutory Planning and Policy Guidance Notes (PPGs), which
represent an opportunity to improve best practice in the quality,
delivery and communication of developer-led archaeological interventions.
Accelerated progress on the revision of the frameworks that dictate
the current character of developer-led archaeology will ensure:
— greater public benefit through requirements
to store, conserve and display artefacts recovered during fieldwork;
and to involve the public in excavations in their neighbourhood
and to open sites for visitors;
— a greater research dividend through
requirements to analyse, research and publish excavation results
in forms accessible to the archaeological community and the wider
public;
— a greater quality of work, through
encouragement of planning authorities to specify that archaeological
work must be carried out in accordance with accredited standards
and led by accredited organisations or individuals; and
— better management of historic buildings
through a requirement for investigation and recording of buildings
damaged or destroyed in development, including archiving and publication
of the results.
5. As Professor Richard Bradley FSA has
argued in a seminal lecture recently given to the Society, and
now available on the Society's website (www.sal.org.uk), it is
now time to move on from the increasingly arid philosophy of "preservation
by record", which dictates so much of the PPG 16 environment.
It is time to seek ways of expanding the accessibility and audience
for post-intervention client reports (the so-called "grey
literature"). As a research resource, the value of this primarily
descriptive record is compromised by its inaccessibility and labour-intensity
of use. Through Professor Bradley's lecture (itself the outcome
of an Arts and Humanities Research Council grant), the Society
has initiated a debate on how to improve the quality of research
outcomes from development-led field archaeology and to create
a resource that researchers will want and be able to use efficiently.
Greater capacity building will be required to realise this ambition
but one which, though supporting the facilitating role of the
Learned Societies, such as ourselves, could be achieved.
6. Finally, on the subject of developer-led
archaeological intervention, the Society would like to register
its concerns about the current curatorial provision for the results
of the planning process. There is an increasingly serious crisis
looming concerning the availability and resourcing of adequate
storage space for the new archives generated by work undertaken
under the PPG 16 regime. The direct result of this is to imperil
the effectiveness of the principle of "preservation by record",
which is so fundamental to the current system. It also makes the
use of those archives by curatorial staff and by scholars difficult
or impossible and so may preclude their value in contributing
to knowledge and to public enjoyment. The Society notes the development
of the London Archaeological Archive and Resource Centre in Islington
as a model approach to this widespread problem (itself enabled
by a HLF grant).
7. The Society strongly supports the enhancement
of the existing Sites and Monuments Records into comprehensive
local services, in the manner of Historic Environment Records
(HERs), as recommended by APPAG in its 2003 report Current
State of Archaeology in the United Kingdom (recommendation
number 3). These facilities should be made statutory with additional
funding from Government to ensure all local authorities maintain
and provide access to them and that they meet a standard level
of content and service delivery around the country. HERs should
also exploit the latest electronic technology to ensure they act
as portals for widest public access. It is worth noting that Article
2 of the Valletta Convention (European Convention on the Protection
of the Archaeological Heritage 1992), ratified by the UK government
in 2000, requires States Parties to make provision for the maintenance
of an inventory of "archaeological heritage".
8. Apart from improvements to the heritage
protection system, the White Paper also provides an important
opportunity to assess the role and contribution and capacity of
the voluntary sector in the management of the nation's heritage.
We are looking for a new inclusive approach with resources that
will encourage participation and build skills in national bodies
and local communities.
Q2. The remit and effectiveness of DCMS, English
Heritage and other relevant organisations in representing heritage
interests inside and outside Government
9. The Society regards the historic environment
and cultural property as central to the social and economic fabric
of the nation, to community cohesion and to the quality of life
for all our citizens. As our sector's umbrella bodies have urged,
the heritage represents a positive force for change and regeneration.
However, Fellows of the Society are concerned about the relatively
low priority given to heritage in a Government department that
administers increasingly competing sectors, particularly with
the demands of 2012 in prospect. We anticipate that discussions
and consultations surrounding the 2007 Comprehensive Spending
Review will test the commitment of DCMS to its heritage responsibilities.
10. DCMS needs to play the champion role
more effectively and more publicly. The APPAG Report of 2003 identified
the lack of leadership in Whitehall, this as a major weakness
of effective policy making on the heritage. The Society continues
to support the thrust of APPAG recommendation (number 1) that
the DCMS establish an inter-departmental Committee on the historic
environment, at Ministerial level, which would coordinate policy
in this area. For instance, such an initiative may avoid the blight
that has characterised the pace of the PPGs reviews, which represent
a relatively low priority for DEFRA, the lead body in this case.
11. DCMS needs to improve its effectiveness
for engaging with the respective professional and voluntary sectors
on policy. Recently, English Heritage has been distracted by internal
restructuring and has failed to engage constructively and consistently
with the voluntary community. Confusion remains widespread about
the new structures and the points of delivery. The lack of consultation
on the recent published EH Research Strategy 2005-10 is
a case in point. Few, if any, of the national Learned Societies
were involved in its formulation. The Society would like to see
more open meetings and seminars such as the recent touring presentations
on the Heritage Protection Review. EH should be more forceful
in supporting the voluntary sector to develop and contribute to
research and management agendas. In addition, it would be helpful
if EH would assist NGOs, such as the Society, to play a more active
part in hosting debates for the sector on key policy issues. With
its independence of government and central location, the Society
is ideally placed to facilitate this engagement. A capacity-building
funding stream would be welcome here. Altogether, we would urge
EH to develop a more inclusive approach to research strategy and
policy development.
Q3. The balance between heritage and development
needs in planning policy
12. We question the on-going tension between
preserving the old versus building the new, which portrays heritage
not as an asset but an obstacle. Fellows urge a more mature debate
about the contribution of historic assets to development and regeneration
of communities. Adaptive reuse of heritage resources can also
provide a sense of stability and continuity for people and communities
that helps to counteract the climate of disruption exacerbated
by economic globalisation (Heritage in Europe: absorbing the
pace of change, Europa Nostra European Policy Forum meeting,
Brussels, December 2005).
13. The Committee is urged to recognise
the threat to the heritage in designated regeneration or renewal
areas, which side-step normal planning controls. The Society would
wish to avoid a repeat of the recent St Pancras cemetery debacle,
where archaeologists were barred from the site by developers working
on the Channel Tunnel Rail Link terminus under the CTRL Act 1996.
Q4. Access to heritage and the position of
heritage as a cultural asset in the Community
14. Volunteering is the lifeblood of the
sector in Britain (Volunteering and the Historic Envionment,
Heritage Link, 2003). The Society could not open William Morris's
home at Kelmscott without the support of 60+ volunteers who man
the office, shop and restaurant and who lead the public around
the site. Our heritage environment needs to discover new ways
of enabling non-professionals to get involved in all areas of
activity and to encourage greater public participation.
15. DCMS needs to maintain its vision for
Power of Place (DCMS 2000), which emphasised the significance
of locality and the importance of heritage for local communities
in terms of identity building.
16. Government, together with the heritage
community, urgently needs to address issues of diversity in the
sector, which is notoriously narrow. Voluntary and community bodies
are best placed to work with Government on the issue.
17. Once more, the need for outreach to
local communities amplifies the need to make rapid progress on
the reviews of the PPGs, with a view to improving outcomes of
development-led excavation for public benefit and improved local
understanding (see para 4 above). Equally, local authorities must
be properly resourced to enable outreach and educational activity.
Q5. Funding, with particular reference to
the adequacy of the budget for English Heritage and for museums
and galleries, the impact of the London 2012 Olympics on Lottery
funding for heritage projects, and forthcoming decisions on the
sharing of funds from Lottery sources between good causes
18. We understand that some £3.3 billion
has been allocated to around 18,000 projects since the inception
of the Heritage Lottery Fund, with archaeology alone benefiting
from some £90 million of lottery proceeds. In addition to
the conservation benefit, the HLF has also most crucially enabled
ordinary people to get involved in their local heritage and to
make decisions about its future.
19. Funding for the heritage remains one
of the central issues for the entire sector, particularly in the
face of threats to the allocations from the Heritage Lottery Fund
and pressure on Government to divert grant support for English
Heritage and the regions in favour of London sport-related needs.
We believe, however, that the Olympics in 2012 represent a huge
opportunity for the UK to showcase its heritage assets and cultural
property to the world. Government needs to invest in the opportunity
for that legacy, not waste it. To this end, HLF share of lottery
funding must be protected and at least maintained at the present
level.
20. The White Paper also offers the prospect
of finally dealing with one outstanding negative anomaly, that
is the VAT charged at higher rate for repair and restoration,
which continues to distort the sustainability and public value
of historic buildings.
21. Funding for national and regional museums
is stretched to breaking point, to the extent that many collections
of significance are at risk, both through lack of care and opportunities
for public access. The problem is particularly acute at local
authority level. Standards of curatorial expertise are collapsing
nationally due to job cuts and lack of continuity planning. Museums,
particularly those in local authorities, lack sufficient staff
with the skills and expertise they need to support active programmes
of research, collection and communicating to the public. The situation
is particularly acute in the archaeological sphere, which forms
an important link in the communication of interest and enjoyment
of the historic environment to local communities. The lack of
capacity that was identified in the Renaissance in the Regions
report has not yet been remedied despite successive commitments.
22. Purchase funds are a particularly easy
target for cuts when museums have to make difficult choices in
order to save money. Acquisition budgets have been squeezed in
real terms in recent years and are now at the level they were
20 years ago. The virtual extinction of purchase budgets in local
authority museums has resulted in a very grave threat to the nation's
portable heritage. In 2002 museums withdrew a stated interest
in acquiring a total of 13 important Treasure finds, even though
some were valued as little as £250. Such acquisitions are
vital if local communities are to benefit from the revised Treasure
legislation.
23. It is hoped that in any decisions on
funding some priority might be given to applications for assistance
in purchasing works of art and cultural objects deferred under
the Review of Export of Works of Art regime (Waverley system).
These are by definition pre-eminent items relating to our national
heritage. Given that the National Heritage Memorial Fund (NHMF)
has only £5 million a year to spend since the launch of the
National Lottery (and much less for the future after intervening
to save Tyntesfield), its designation as a fund of last resort
has become meaningless. We believe that the NHMF funding must
be restored to a more realistic level. NHMF assistance in "saving
for the nation" the Macclesfield Psalter is just one recent
example of the importance of this last resort funding stream,
which generated a truly remarkable expression of public interest.
24. In addition, it is undoubtedly the case
that museums have successfully acquired many important objects
through the Acceptance in Lieu scheme. We believe there is scope
for the principle to be extended to other forms of tax liability
in addition to inheritance tax, as proposed in the Goodison Review
(2004). We support proposals made by the Museums Association for
an additional scheme of gift aid in kind, whereby objects deemed
of pre-eminent importance could be off-set against other tax bills,
thereby encouraging people to donate objects to museums during
their lifetimes. This would also have the advantage of fostering
long-term philanthropic relationships between donors and acquiring
institutions.
25. We urge the establishment of an independent
commission on the state of public collections, their resourcing
and their relationship to the historic environment.
Q6. What the roles and responsibilities should
be for English Heritage, the Heritage Lottery Fund, local authorities,
museums and galleries, charitable and other non-Governmental organisations
in maintaining the nation's heritage
26. Role of NGOs: AFFOF in 2001 counted
"including and involving people" as one of the five
specific Government objectives for realising the full potential
of the nation's heritage assets. We are yet to see this initiative
materialise. Of primary concern to the Society is the role and
influence of NGOs in the heritage sector, which range from Learned
Societies and professional bodies to specialist interest groups.
This voluntary community operates close to the ground and is sensitive
to public opinion and interest. Its memberships are seeking to
encourage active participation by citizens of all backgrounds
in the cultural heritage. We urge DCMS, other relevant government
departments, local authorities and EH to engage more effectively
with NGOs to create a more inclusive working environment. The
Government should consider whether NGOs could get more involved
in delivering some public services. Knowledge of issues and locality
may pay dividends for greater public engagement.
Q7. Whether there is an adequate supply of
professionals with conservation skills; the priority placed by
planning authorities on conservation; and means of making conservation
expertise more accessible to planning officers, councillors and
the general public
27. Like others, the Society recognises
that the work of Conservation Officers and other professionals
in the historic environment, such as archaeologists, in local
authorities is hampered by low pay, low status and lack of a career
structure. In addition, we acknowledge the urgency of an effective
and robust continuous professional development programme for all
those working in the historic environment and cultural property,
both vocational and non-vocational. The building of skills in
local communities will remain a vital objective for some time
to come. It is the job of national agencies to support the professional
bodies and voluntary organisations to achieve this.
17 January 2006
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