Memorandum submitted by the Association
of Local Government Archaeological Officers
SUMMARY
— The historic environment is an irreplaceable
asset, and a key component of people's "sense of place".
— ALGAO members are responsible for
the conservation of over 90% of England's archaeological resource.
— There should be a firm commitment by
government to adequate resourcing of local authority historic
environment services.
— The White Paper should include a commitment
to Statutory status for Local Authority Historic Environment Record
Services. This is necessary to ensure that all of the historic
environment is adequately conserved and that there is public access
to information about the historic environment.
— The White Paper should propose better
protection for statutory and non-statutory archaeological sites.
— The role of English Heritage after the
new heritage protection system is introduced in 2010 should be
made clearer and more explicit.
— English Heritage should be adequately
resourced to fulfil its strategic role.
I write on behalf of ALGAO (the Association
of Local Government Archaeological Officers) in response to the
invitation for submissions to the above inquiry by the Culture,
Media & Sport Committee. This submission has been prepared
specifically for the inquiry and our response follows the questions
and areas of interest that you have set out. ALGAO will be very
happy to provide amplification of any points if required, and
to provide supplementary or oral evidence if this would be helpful.
The role of the Association of Local Government
Archaeological Officers (ALGAO)
ALGAO is the national body representing local
government archaeological services on behalf of County, District,
Unitary and National Park authorities. ALGAO co-ordinates the
views of member authorities (110 in total) and presents them to
government and to other national organisations. It also acts as
an advisor to the Local Government Association on archaeological
matters.
Individually, in the course of their work for
their Authorities, our members are responsible for archaeological
records, archaeological inputs to the development planning process
and to agri-environment and forestry consultations, the conduct
of rescue excavations and their subsequent publication, the management
of archaeological sites and landscapes, and liaison with local
voluntary heritage groups, museums and other bodies. We thus have
a key role in the protection of the country's historic resources,
and through our members we are closely in touch with current developments
(and pressures) in the sector. Our evidence below is informed
by this experience.
THE IMPORTANCE
OF THE
HISTORIC ENVIRONMENT
Britain's historic environment, and in particular
the physical fabric of its archaeological sites, field boundaries
etc, represents a non-renewable resource. Many of its components
(round barrows, hillforts etc) have survived for thousands of
years, but can be destroyed in a single afternoon, or slowly destroyed
by processes of attrition. Individual sites of more recent date
such as castles or mills preserve valuable and irreplaceable archaeological
information, but, perhaps more importantly still, both they and
the heterogeneous sites, features, field boundaries and so on
that make up the fabric of our towns and our agricultural landscapes
contribute a very substantial part of what is perceived subliminally
as "sense of place", as has recently been recognised
by the Secretary of State for DCMS.
However, the continuing survival for future
generations of this rich resource is dependent upon our preventing,
now, its destruction by current activity. Decisions made now last
for all time. Unlike our stewardship of the natural world, losses
now can never be made good in the future by "restoration",
"enhancement" or by breeding programmes or habitat improvement.
The protection of our heritage has to be achieved both formally
and informally—both by mechanisms such as the planning process
and by engaging the intuitive enthusiasm of local communities,
landowners and others. The potential of the historic environment
as a resource for all can and should be expanded and enhanced.
In all such tasks our members play a key role.
This background informs the following response:
What should the Department for Culture, Media
and Sport identify as priorities in the forthcoming Heritage White
Paper?
— Support for local authority historic
environment services.
For the majority of the areas of work outlined
above, the brunt of the task (well over 90%) of protecting the
archaeological resource is borne by our members in local authorities.
Indeed, if the proposals of the Heritage Protection Review are
implemented, local authorities will also be taking responsibility
for casework and consent procedures relating to Designated sites
(Scheduled Monuments). It is clear that a strong body of public
service archaeologists is necessary to deliver even the basic
conservation essentials outlined above, as well as the important
outreach agenda. The workload of local authority archaeologists
has already expanded substantially in recent years (ALGAO 2005[4]),
but under current conditions of financing for local government,
historic environment services are coming under increasing pressure.
Some services that have been standard bearers for public service
archaeology are at this present moment threatened with savage
cuts. We would therefore argue that a proper mechanism for protection
of the historic environment can only be achieved by a firm commitment
by government to adequate resourcing of local authority historic
environment services.
— Statutory Status for Historic Environment
Record Services.
The objectives outlined above require both a
critical mass of good quality and committed staff (for which see
further below) and also a sound information base to inform this
work. This base is provided by the network of Historic Environment
Records (formerly Sites and Monuments Records) created and maintained
by local authorities since the 1970s. Government has made statutory
status for Local Authority Historic Environment Records a key
element of its 2004 proposals for the White Paper in the publication
Review of Heritage Protection: The Way Forward. This says
that all local authorities should be required either to maintain
an Historic Environment Record (HER) or have access to one. We
strongly urge that this provision (which is in itself revenue-neutral)
be included in the White Paper.
— A commitment to the protection of
non-statutorily protected archaeology, both above and below-ground,
that is at least as good as the present system provided by Planning
Policy Guidance Notes 15 and 16 (PPGs 15 and 16).
Only a relatively small proportion of nationally
important archaeological remains (including buildings) are protected
by statutory designations. The rest, as well as regionally and
locally important archaeological sites, are protected in part
through the planning system, both through Environmental Assessment
and Development Plans and, in advance of development, following
the guidance in PPG 16. It is vital for the conservation of this
resource, which includes over one million known sites, that the
provisions of PPG 16, especially that preservation of archaeological
remains in situ is a material consideration, are retained
in any new legislation. Both PPG 16 (Archaeology and Planning)
and PPG15 (Planning and the Historic Environment) are due to be
replaced by a new Planning Policy Statement, although this seems
to be stalled at present. It is essential that the provisions
of the earlier PPGs are not weakened, and indeed we would wish
to see the force of this "advice" strengthened by government,
particularly with regard to the public dissemination of the results
of work carried out under the provisions of the PPGs.
There is also considerable potential to enhance
the protection of archaeological remains, including nationally
important remains, by more effectively using provisions within
the current regulatory framework for planning. These could include,
for instance, local authorities being encouraged to remove some
Permitted Development rights in circumstances such as where this
could enhance the protection of nationally important remains that
are not covered by statutory designations. However, there would
need to be a clear steer from government to encourage local planning
authorities to maximise use of such measures.
— Greater rationality and consistency
in the system for the protection of nationally designated archaeological
sites.
The present Heritage Protection Review (to which
we are contributing) may change the processes for designation
and consents, but without a more fundamental reform of what is
permitted and what is not, many sites (even those acknowledged
by Scheduling to be sites of national importance) will continue
to suffer irreversible degradation. The principal, longstanding
issue here is the system of "Class Consents", which
provide exemptions from the general restrictions imposed by Scheduling
of archaeological sites and which continues to allow damaging
activities such as ploughing on some protected sites—although
permission for a farmer to erect a single fence-post on a Scheduled
Monument still requires formal approval from the Secretary of
State!
— Positive measures for the protection
and management of designated and non-designated rural archaeological
sites.
For archaeological sites and landscapes whose
survival is not directly affected by the development process,
we would wish to see a firm commitment to the continued (and expanded)
use of the principles of agri-environment schemes such as Environmental
Stewardship and Tir Gofal and Tir Cynnal in Wales in seeking to
ensure the proper management of archaeological sites in the farmed
landscape.
— DCMS should support the characterisation
approach.
The technique of "characterisation"
(the analysis of the visual and historic qualities of landscapes
or townscapes) is a relatively new concept for the historic environment
but it has considerable potential to improve the effectiveness
of conservation policy and casework, especially for the important,
currently non-designated parts of the historic environment which
make up over 90% of the whole. For example, the characterisation
of the 19th and 20th century historic built heritage of urban
areas could allow much better, and faster, decisions to be made
about its conservation. The White Paper should therefore consider
the potential of characterisation to complement the proposed system
of national and local designation.
— DCMS and English Heritage should
ensure that local government is fully engaged in the process of
preparing new legislation, including appropriate representation
on management/agreements and executive bodies.
ALGAO is fully committed to the introduction
of new legislation as proposed in the Government Statement Review
of Heritage Protection: The Way Forward. However, we believe
that its success will be dependent upon the active engagement
of local government—which will be required to deliver much
of the new system—in the drafting of the legislation.
— English Heritage should provide appropriate
advice and support to local government with emphasis on the value
of informed decision-making and pre-determination assessment.
It is important that English Heritage should
continue to provide appropriate advice and support for local government,
and that its capacity to do so should be expanded rather than
diminished. English Heritage's expertise in the area of archaeology
should not be further weakened.
The remit and effectiveness of DCMS, English Heritage
and other relevant organisations in representing heritage interests
inside and outside Government
— DCMS needs a better and more effective
role working with ODPM on planning and local government issues,
and with Defra on rural ones. We are conscious that the voice
of DCMS within government is not always as powerful as the well-being
of the historic environment would require. DCMS's resources are
limited, and the Committee's following question reflects our own
concern at the potential for changing demands within the department
to weaken the emphasis on the historic environment.
— English Heritage needs firmer support
and guidance from Government, with joint sponsorship from DCMS,
ODPM and DEFRA, concerning both its role and that of the sector
across a wide range of policy areas.
— English Heritage needs to develop
a clear and consistent voice for conservation of the historic
environment in partnership with local authorities. There should
be explicit recognition that the conservation of over 90% of historic
environment is the responsibility of local government.
— The structure of English Heritage
should be reviewed as the respective roles and relationships of
the regions and the centre remain opaque.
The balance between heritage and development needs
in planning policy
In our experience, comparatively few conflicts
between conservation and development are incapable of resolution
if there is an adequate policy framework and early consideration
of historic environment issues by potential developers and others.
However, the new LDF-focussed planning system currently lacks
strong policy guidance from Government and English Heritage for
the historic environment, while recent research by ourselves (PLANARCH
200[5])
demonstrates the current weakness of the Environmental Impact
Assessment process, despite its potential to address such issues
well. We therefore believe that the following points should be
addressed by Government:
— Within the "new" planning
system, the weight that should be applied to historic environment
considerations, and the points in the plan preparation process
at which it should be explicitly integrated, should be made more
clear. Local Planning Authorities are currently adopting a wide
range of models in the preparation of new Strategic and Local
Development Framework Plans, and it is our perception that not
all are addressing historic environment issues in a way that will
provide the coherence of the best of the "old" Strategic
and Local Plans. While some general guidance has recently been
prepared by English Heritage and its partners, there is a need
for explicit guidance to be issued by ODPM and DCMS on this.
— There should be closer scrutiny of
the adequacy of the historic environment elements of Environmental
Impact Assessments (EIAs). The results and recommendations of
the important PLANARCH research in UK and Europe on the effectiveness
of EIAs with respect to the historic environment should be used
to inform this process (PLANARCH 2005[6]).
— Utilities, statutory undertakers
and public bodies need to be better regulated. Their activities
should be brought within the regulatory regime which pertains
to other forms of development.
— The conservation of the historic
environment needs enhanced recognition in the government's Sustainable
Communities Plan.
— As discussed above, the role of the
historic environment in providing a sense of place for local communities
needs to be recognised and articulated by Government and included
within government policy on the creation of Sustainable Communities.
At present, consideration of the historic environment by government
is inconsistent and generally poor within the Growth Areas and
Pathfinder Areas of the Sustainable Communities Plan. Best practice
for the consideration of the historic environment is currently
provided by the Thames Gateway Growth Area.
— Finally, the need for consideration
of the non-planning based impacts upon the historic environment
must be borne in mind.
Access to heritage and the position of heritage
as a cultural asset in the community
— The role of the historic environment
as a cultural asset should be explicitly recognised in the Heritage
White Paper. The DCMS document The Historic Environment: A
Force for Our Future discusses this, and we hope that firm
proposals will be put forward to develop this theme.
— The national network of local authority
Historic Environment Records (HERs) provide a key means by which
the pubic can gain access to information about the historic environment.
Information from HERs is also actively used to promote sense
of place and stewardship of local heritage by communities. Statutory
Status for HERs (see above) together with continued support from
HLF and others is necessary to develop this role particularly
in respect to the Community Planning agenda.
— We would in passing like to remark
that while the concentration upon the `new' audience for heritage
is understandable and proper, some of our members are also conscious
of the need to ensure that isolated indigenous rural communities
should equally not be left to feel disenfranchised.
— The economic potential of the historic
environment should receive explicit recognition in the White Paper,
linked to developing measures and mechanisms such as Heritage
Counts, the annual State of the Historic Environment report.
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
— English Heritage should be resourced
appropriately to enable it to fulfil its obligations as lead agency
working in partnership with local authorities and other agencies.
Specific resources should be made available for delivery of the
Heritage Protection Review.
— English Heritage has seen below-inflation
increases in its funding in recent years, and should not suffer
further diminution in its resources. Recent changes have obliged
it to move away from some of its proper duties before any formal
provision for other bodies (ie local government) to cover its
present casework responsibility has been set in place. Our members
are conscious of having to fill this gap. The role of English
Heritage and its relationship with local authorities after 2010,
when the new Heritage Protection system is due to begin, needs
to be made clear.
— Funding regimes should recognise
that the historic environment is an asset which is experienced
on a daily basis by all members of society. Enhancement of public
awareness of and participation in the richness and diversity of
that environment will lead to greater social cohesion, local pride
of place, enhanced protection and crime reduction. Impacts such
as the London 2012 Olympics or the sharing of Lottery funds will
be mitigated if the importance of the historic environment to
all endeavours is explicitly recognised.
— However, as emphasised above, the
bulk of day to day work in the care of the historic environment
is carried out by local authority staff—both archaeologists
and conservation officers. The pressures on the budgets of local
authorities is having a very negative effect on these services
at just the time when the value of the historic environment is
being recognised more than ever before, and arguably this factor
is more important for the overall care of the nation's heritage
than those mentioned in the Committee's question. We would hope
to see this acknowledged by government.
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
— English Heritage must remain the
lead agency for historic environment policy. It has an important
strategic research and standards role which should be enhanced
and it should develop partnerships links with, and support of,
local authority historic environment services.
— The Heritage Lottery Fund should
maintain its programmes which facilitate considerable beneficial
work within the historic environment by the independent sector.
Specifically, smaller programmes such as Your Heritage and the
Local Heritage Initiative have contributed much to enhancement
of local awareness and amenities and should continue to be fostered.
We are aware of a number of excellent pieces of community archaeology
and heritage research that have been made possible by LHI grants,
and now hope that after its impending demise this (less daunting)
model of access to modest grants will be continued under another
grant heading.
— The review (DCMS 2004[7])
published by DCMS in 2004 has addressed the issue of the division
of responsibilities between English Heritage and HLF.
— The role of local authorities in
the protection and promotion of our heritage is discussed throughout
this paper. The Heritage Protection Review proposes major impacts
upon local authorities. Resource provision for these impacts needs
to be determined.
— DCMS has shown a welcome awareness
in recent years of the needs of Museums & Galleries and the
continued development of the renaissance in the regions programme
would be welcome. DCMS support for the Portable Antiquities Scheme
(PAS) should be sustained but there needs to be greater awareness
that local authority historic environment services are much more
broadly based than merely recording and, where possible, curating
artefacts and that, if government wishes to both develop audiences
and engage currently disadvantaged groups, it needs to support
these broadly-based services through local government initiatives.
There needs to be closer integration between the work of the PAS
and mainstream archaeological services.
— We are conscious of the increasing
pressure upon museum storage capacity as a result of the increase
in rescue excavation of recent years. Posterity will not be well
served if material "rescued" from development sites
is not in the future well stored and accessible for study. This
is a major continuing problem for the museum sector, which impacts
directly upon our capacity to ensure that programmes of excavation
necessitated by development are completed for the public benefit.
— There is a long-standing and important
strand of volunteer and charity engagement in archaeology which
has shaped the modern discipline. For example, the role of bodies
such as the Council for British Archaeology and its sister amenity
societies in reviewing applications for Listed Building Consent
is written into statute, while all these bodies serve the subject
by their informed comment on government proposals. Traditionally,
the publication of archaeological reports (without which no excavation
or survey can really be said to be completed) has been very largely
in the hands of charitable scholarly or local (mainly county-based)
societies, and this is a role they continue to play despite increasing
pressures on resources. At a local level, local societies, whether
technically charities or not, form the framework for much amateur
and volunteer effort, and can provide the springboard for other
community and outreach endeavours. This element of the national
and local archaeological scene should be cherished and supported
and enabled to forge stronger links with local authority historic
environment services.
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
— ALGAO, together with English Heritage
and the sector as a whole, recognises that there is a skills shortage.
English Heritage has sought to address this by initiatives such
as the Archaeology Training Forum. Such initiatives need continued
support, together with encouragement to local authorities to enhance
training.
— The problem goes deeper than just
a skills shortage, as there is a considerable problem of retention
of competent professional staff. There is a real need for building
absolute capacity within the public heritage services as a whole,
both in expertise and in actual numbers. For good and positive
reasons workloads are increasing, and this should be explicitly
recognised and addressed.
— Historic environment conservation
will not be taken seriously by local councillors, or indeed by
the general public, unless greater emphasis is placed upon its
importance by government. Historic environment professionals have
worked hard in recent years to demonstrate that work within this
sector is not a constraint upon development but actually enables
and enhances sustainable development. It is a positive discipline,
working with one of the nation's greatest assets. It deserves
explicit government recognition of its proactive and important
role in helping to create a modern and dynamic society.
19 January 2006
4 Local Authority Archaeological Services: Report
on staffing and casework 1997-2003. ALGAO 2005. Back
5
Cultural Heritage and Environmental Impact Assessment in NW Europe,
PLANARCH 2005. Back
6
Cultural Heritage and Environmental Impact Assessment in NW Europe,
PLANARCH 2005. Back
7
Review of the Structures of Government Support for the Historic
Environment in England. DCMS/PKF May 2004. Back
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