Memorandum submitted by the Council for
British Archaeology
The Council for British Archaeology is an educational
charity working throughout the UK to involve people in archaeology
and to promote appreciation and care of the historic environment
for the benefit of present and future generations. We have a statutory
role as one of the national amenity societies consulted on listed
building proposals.
CBA has a membership of 620 heritage organisations
and c10,000 directly subscribing individuals of all ages. Our
institutional members represent national, regional and local bodies
encompassing state, local government, professional, academic,
museum and voluntary sectors. We work with a network of CBA Groups
at the regional level in England, and with their national counterparts
in Scotland and Wales, CBA Cymru and the Council for Scottish
Archaeology. Our role as a statutory consultee is supported by
a network of c 120 expert volunteers who visit and advise on local
proposals that include demolition of listed buildings.
The Select Committee's inquiry into the heritage
is both timely and wide-ranging. In this submission we focus on
the CBA's core mission to involve people in archaeology and by
this means to promote appreciation and care of the historic environment.
There are a number of other important issues for the archaeological
community and the heritage sector in general, which are covered
in the evidence presented to the Committee by the Archaeology
Forum, by Heritage Link and by the Joint Committee of National
Amenity Societies. CBA has also contributed to their submissions.
What the DCMS should identify as priorities in
the forthcoming Heritage White Paper
1. We welcome the opportunity that the Heritage
Protection Review presents for reform of the existing statutory
framework for designation; the unification of consent regimes;
the introduction of Heritage Partnership Agreements; and enhanced
local delivery of heritage services provided by local government.
Much-needed revision of related planning policy guidance will
also be welcome in the context of the modernised planning system
and reorientation of other aspects of public policy to bring about
more sustainable communities. CBA has consistently advocated an
holistic approach to understanding and protecting the historic
environment, based on involvement and action by people at the
local level, and believes that both the integrated approach and
the enhancement of local delivery being promoted by English Heritage
and DCMS are timely and important.
2. As a body with UK-wide remit, CBA notes
with concern that there has been little indication of how these
reforms will be implemented in Wales. Here the arrangements for
delivering heritage services are significantly different. It appears
that no model has yet been developed for implementing HPR in Wales
and the heritage sector in Wales remains largely uninformed about
the aims of these reforms. It has not benefited from a shared
dialogue through seminars and workshops like those organised by
DCMS in England as part of the HPR process; no assessment of existing
capacity or pilot studies are taking place in Wales in parallel
with those for England. CBA hopes that the White Paper will address.
— A framework for implementation of
HPR in Wales to ensure that Welsh and English systems for protecting
and managing change in the historic environment are congruent
and consistent across national borders (particularly in terms
of local delivery and integration with the planning system) and
also to accommodate the different mechanisms for providing heritage
services that have evolved in Wales.
3. It is clear that the implementation of
these fundamental reforms in heritage protection will require
substantial resources for delivery, as the initial pilot projects
are showing, but there is confidence that they should ultimately
bring about a more effective approach to managing change in the
historic environment at national and local level. The challenge
will be to secure the resources that are needed to implement the
proposed reforms. The CBA identifies the following issues as ones
that we believe should be a priority for DCMS in formulating the
White Paper.
4. Resourcing for local authorities
The enhancement of local delivery for heritage protection
is the most effective means by which to ensure that changes in
the historic environment are managed so that local people can
be involved actively in protecting and caring for heritage assets.
Our belief in this is supported by the experience of our local
volunteers, agents and regional CBA groups; and by recent research
bringing together the experience of those working in community
projects, such as the Castleford Conference—Whose Heritage
is it Anyway?— in 2005.
5. If local authorities are to become the
principal means of delivering a more locally responsive, integrated
system of managing change for the historic environment, then they
will need to increase their capacity and levels of skill. The
initial HPR pilot work and recent surveys of local authority services
for the historic environment in England (for conservation, for
archaeology services and for Historic Environment Records) show
that some local authorities do not have appropriately skilled
staff or access to relevant specialist expertise and information.
Where it exists, it is often spread too thinly to be effective.
Provision is variable between authorities and there are few standards
in place for benchmarking performance. English Heritage with DCMS
and ODPM are jointly undertaking research to address the resource
implications of HPR for local services in England. There is likely
to be a need for a significant level of new investment, but a
realistically achievable one. For example, an assessment of the
resources required to bring all existing Historic Environment
Records in England (c100) to a common level of basic provision
was estimated in 2004 at up to £7 million.
6. We would like to see positive provision
in the White Paper to respond to the findings of the research
into enhancing local delivery including:
— a duty for local authorities to provide
historic environment conservation services with appropriately
skilled staff to an agreed service standard;
— a duty for local authorities to have
access to an Historic Environment Record meeting a national standard;
— recognition of the resource investment
required to deliver the modernisation of local heritage management
services and commitment to securing this.
7. Reform of the Class Consent regime is
also expected to form part of the White Paper proposals. The national
Monuments at Risk Survey (1998) highlighted the impacts that agricultural
activity continues to have on archaeological sites. An English
Heritage pilot exercise in 2004 in the South West, which contains
over a third of all scheduled monuments in England, showed that
nearly a quarter of all scheduled monuments were at high risk.
The main risk of damage is from ploughing.
8. We recommend that the White Paper include:
— Provision to reform the Ancient Monuments
(Class Consents) Order, and early action to remove the Class I
consent and to replace it with a requirement for formal consent
to be sought to continue agricultural, horticultural, and forestry
works that affect land designated as nationally important archaeological
sites.
The remit and effectiveness of DCMS, English Heritage
and other relevant organisations in representing heritage interests
inside and outside Government
9. Historic environment interests cut across
several Government Departments and it continues to be a challenge
to achieve collaboration and cross-connection between strategic
policies and programmes. English Heritage, with the support of
DCMS, has made significant progress in working actively with key
Departments and their agencies in recent years. The success of
joint initiatives and collaboration with DEFRA is exemplified
in the results of last year's Heritage Counts showing the
very important contribution that Environmental Stewardship and
other agri-environment schemes delivered through DEFRA are making
to the protection and effective management of change in the rural
environment. However, it is disappointing to see publication of
key strategies from Government agencies that still do not recognise
the heritage dimension—for example, the Environment Agency's
recent strategy for protection of the marine environment, in which
there is no reference to protection of the marine historic environment.
10. As the drafting of Marine Bill goes
forward in 2006 on the heels of the White Paper for heritage protection
CBA would like to see
— effective collaboration between DCMS,
DEFRA and other relevant Departments to ensure that protection
of underwater cultural heritage is appropriately covered in the
Marine Bill in new statutory provisions and a marine spatial planning
framework.
— DCMS support for aims of the Burlington
House Declaration and in championing the adoption of the UNESCO
Convention on the Protection of Underwater Cultural Heritage.
11. Since the creation of Heritage Link,
independent heritage bodies have been able to coordinate their
action through a single umbrella organisation. The voluntary sector
in the heritage is a significant and large community whose engagement
is fundamental to delivering Government's programme for sustainable
communities, but its interests are not adequately represented
by DCMS or by English Heritage.
— CBA would like to see the resources
and skills needed by communities and local amenity groups being
championed at the national level and for Heritage Link to receive,
not only a place at the table, but the resources it requires to
be effective on behalf of independent heritage organisations.
The balance between heritage and development need
in planning policy
12. Positive progress is being made in getting
across the message that managing change in the historic environment
need not be an area of conflict with development. English Heritage's
advocacy through its "constructive conservation" campaign
is having an impact. One of the areas where there has been, however,
a disappointing failure to recognise the value and potential of
heritage has been in the Government's housing market renewal Pathfinder
projects. We continue to be very concerned at the way in which
traditional terraced housing in the north of England, valued by
local communities and capable of sustainable re-use, are being
condemned for large-scale demolition. Some of these programmes
have not addressed the views of local people properly or taken
a balanced view of the alternatives to demolition and new building
in the context of sustainable development and communities. The
ODPM's Housing, Planning Local Government and Regions Committee
looked at these issues last year (Empty Homes and Low-demand
Pathfinders, April 2005) and found that Pathfinders need to
consult better with local communities and to include refurbishment
of existing housing so that the heritage of the areas is preserved
and forms the basis for regeneration.
13. A new Planning Policy Statement for
the historic environment, to replace PPG15 and 16 is a priority,
although there is currently no timetable for introducing this.
The redrafting of guidance will be an important opportunity to
emphasise the social and economic benefits of managing change
to enhance the heritage and to strengthen the existing guidance
in a number of areas.
— The new PPS should reinforce the
message that the key to unlocking the potential of the historic
environment as an asset in regeneration schemes is an understanding
of the existing historic character of an area together with the
local community's aspirations.
14. PPG16 has been highly successful in
establishing the principle that development in archaeologically
sensitive places must be properly informed by impact assessment
and evaluation as part of the design process; and that the costs
of this necessary preparation should properly form part of the
responsibility of those wishing to make changes that have an archaeological
impact. As a consequence, the balance of funding for archaeological
work has moved from a situation where there was almost entirely
public funding pre-PPG 16 (1990) to one where the private sector
is now the principal funder of archaeological work in England.
— The new PPS should be robust in extending
the principle of pre-application impact assessment to the historic
built environment as a whole, particularly to ensure that the
precautionary principle currently applied to development affecting
archaeological sites also applies to proposed changes in the historic
built environment.
Access to heritage and the position of heritage
as a cultural asset
15. CBA works to promote the full public
benefit of archaeological work and historic research, with positive
action to enable people to take part in local discoveries and
to learn, enjoy and gain understanding about the history of their
communities. Archaeological investigation and research is done
in the name of the public interest in our diverse cultural heritage
and can only be justified if public benefits flow from it. This
aspect is not covered by the existing planning guidance and its
absence has been a barrier to achieving private sector support
for publicising and promoting public involvement in archaeology,
despite the huge appetite for it demonstrated in television and
media coverage of archaeology.
— We recommend that the new PPS should
include guidance on the importance of communicating the results
of discoveries about local heritage and of promoting and increasing
local involvement with the process of discovery. It should emphasise
the important public benefits and positive outcomes of constructive
partnership between heritage conservation and development.
16. More widely the sector has much to do
to extend and diversify participation. The preliminary results
of the DCMS "Taking Part" survey provide good indications
of the high level of active public interest in heritage activities;
it also shows that some groups in society are excluded from taking
part. We need better understanding of the barriers to participation
and of the success factors in projects and programmes that have
worked well to extended participation. The CBA's National Archaeology
Days—since 2005, National Archaeology Week—have seen
steady growth over the recent years, with last year over 300 events
and participation by over 100,000 individuals. The CBA's network
of Young Archaeologist Clubs, with over 3,000 members, continues
to grow rapidly across the UK. We recognise ourselves the need
to diversify and extend participation in both these areas. It
is only by working at the grass roots level we can achieve the
fundamental changes in access to archaeology that we seek.
17. Breaking down barriers will come gradually
and it will take sustained investment of effort and resources
to create exciting opportunities to stimulate a new generation
of participation. While we look to DCMS and English Heritage for
support in this, the sector now relies almost entirely on the
Heritage Lottery Fund and other Lottery Fund distributors. In
this respect, the work of the HLF has made an outstanding contribution
to the heritage in general with c£3 billion invested since
1995. Overall HLF estimates that it has funded about 330 archaeological
projects totalling £115 million, a large proportion of which
went to a relatively small number of major projects. Major beneficiaries
have been national projects such as the Portable Antiquities Scheme
(supported through the CBA's Portable Antiquities Working Group)
which has drawn thousands of members of the public into reporting
and learning about their discoveries. Another important area that
has benefited is the enhancement of local authority Historic Environment
Records. However, it is through the small-scale projects, funded
through the Local Heritage Initiative (LHI), Young Roots and Your
Heritage programmes that many valuable local and community archaeological
projects have been supported.
18. CBA is concerned about the closure of
the LHI programme this year and the current uncertainty about
the future of Lottery Funding for heritage good causes. Though
there has been an excellent start in developing community archaeology
projects through LHI and Your Heritage, contributing to the gradual
widening of access that CBA advocates, the concern is that this
will now fall away. Archaeology has benefited from a fraction
of HLF's overall investment in heritage—less than 0.05%
of the total money disbursed for heritage good causes. Some would
argue it has seen less than its fair share of investment, which
is surprising given that it is the ideal subject to draw in new
participation and enthusiasm for the heritage and a bridge discipline
that can lead into many other areas of citizenship and learning.
Opportunities to be involved in archaeology are appealing to people
and provide a route to appreciating the wider historic environment
and local heritage, and ultimately for building capacity for community-led
heritage initiatives and decision-making. The limitations of the
voluntary sector's capacity have been a factor in the limited
take up of the HLF's offer of support.
— Public appetite for taking part in
and enjoying archaeological discovery continues to be keen; it
offers a route to a broad-based community participation in the
heritage. CBA believes the recent modest investment in community
archaeology through HLF needs to grow substantially to bring the
full social and educational benefits that can flow from this area
of keen public interest.
— There is limited capacity in the
voluntary sector in archaeology to develop the projects and programmes
that HLF could fund, and we need investment in a programme of
facilitation and training to enable local groups to make their
ideas for projects into a reality.
19. Archaeology and education:
CBA champions the important role of archaeology
as a subject in education and as a resource for lifelong learning.
We support moves to promote learning outside the classroom and
an understanding of the whole historic environment as part of
this: the built and the "natural", contemporary and
historic. Securing the interest and enjoyment of young people
is one of the best ways in which we can ensure the protection
and appreciation of the historic environment in the future. We
note with concern the gradual decline of provision for archaeology
and heritage courses in continuing education which has traditionally
supported the strong voluntary sector in the heritage.
— Government needs to support subject
communities like archaeology in training for new and practising
teachers in how to use the whole historic environment as a resource
and to promote learning outside the classroom.
— We need recognition of the special
needs of continuing education within the funding frameworks for
higher education and support for funding courses that contribute
towards active communities and quality of life.
Funding, with particular reference to the adequacy
of the budget for English Heritage and museums and galleries,
the impact of 2012 Olympics on Lottery funding and the future
share from Lottery sources between good causes
20. Funding for English Heritage has declined
year-on-year in real terms over the last five years, while the
proportion of DCMS funding going to other areas of its responsibility
has risen steadily. At the same time partners with whom English
Heritage is working under other Departments have seen significant
rises in their budgets, eg Countryside Agency and English Nature.
Our perception is that the harder the heritage sector tries to
work to deliver the Government's agenda (and English Heritage
has successfully addressed the Quinquennial Review's criticisms
of its operation) the more resources are withdrawn from its work.
The restructuring of English Heritage, HPR and now relocation,
have tended to deflect energies significantly from its core conservation
and research work into necessary strategic activities; a period
of stability is badly needed for consolidation and to deliver
HPR, the objectives of its new corporate plan and the new strategic
research programmes currently under consultation.
21. The impact of English Heritage's consistently
diminishing resources on archaeological research and development
has been noticeable, though to some extent masked by the Aggregates
Levy Sustainability Fund (ALSF), which is distributed through
English Heritage. Heritage Lottery Funding in archaeology has
been primarily directed at encouraging access and education but
has not been invested in the research-led fieldwork necessary
to advance knowledge in some areas of the discipline. Strategic
and capacity building work in professional archaeology falls outside
the terms of reference of both of those sources of funding (ALSF
and HLF) and does not attract finance through the private sector.
There are therefore key areas of archaeological research and development
for which English Heritage continues to provide the principal
support.
22. Intense pressure is consequently being
placed on English Heritage's Historic Environment Enabling Programme
and National Capacity Building Programmes from all parts of the
sector, not least in response to modernisation in other areas
of public sector. Local authorities, for example, have been given
attractive financial incentives to deliver online planning to
Government targets, but the impact of this on the ability of the
heritage sector to respond and engage with community-led planning
are only just being considered. The costs of equipping the heritage
sector with the capacity to respond to modernisation of the planning
system are being met not by ODPM or by local authorities but from
the charitable funds of amenity societies and from English Heritage's
steadily declining resources for grants.
23. ALSF and HLF sources of funding for
archaeology and for the heritage in general are coming under 10-year
review and are potentially vulnerable in the future, particularly
given the switch of focus that is expected in preparation for
the Olympics in 2012. CBA is most concerned about the possible
long-term consequences for archaeology in England should the decline
in English Heritage's grant-in-aid continue, particularly in view
of the additional resource that the organisation needs to deliver
the reforms of Heritage Protection Review.
— Resources for capacity building and
training in the professional and the voluntary sector are a priority
for maintaining standards in research and practice. English Heritage
is the main funder of these. We would like to see its overall
grant expenditure restored in real terms to 2000-01 levels through
a corresponding increase in its funding from DCMS.
— Archaeology has received only a modest
share of the HLF's distribution of lottery funds (0.05%) and it
is essential to maintain this level of funding—which complements
that from developer-led and English Heritage projects—for
the continuing development of community archaeology, Historic
Environment Records and new local heritage research projects.
— The Cultural Oympiad, ahead of the
Olympic Games themselves and starting in 2008, is a unique opportunity
for Britain to showcase its cultural heritage and we look to DCMS
to secure an appropriate level of new resource for the growth
and infrastructure that will be essential to support a world-class
programme of events and opportunities for visitors to appreciate
UK's cultural heritage.
— It is imperative that the HLF retain
its share of funding, and its separate identity, to support the
cultural heritage sector through the Cultural Olympiad period
in the run up to the Games.
What roles and responsibilities should be for
English Heritage, the HLF, local authorities museums and galleries,
charitable and other non-Governmental organisations in maintaining
the nation's heritage
24. To summarise points made in the sections
above, the CBA believes that English Heritage has successfully
restructured to respond to the Quinquennial Review findings and
that a period of stability for delivery of its new strategic vision
and successful relocation is essential. Its role in relation to
the HLF was recently reconsidered and we see no reason to suggest
the need for a further review. We consider it imperative that
the HLF retain its separate identity and existing share of the
Lottery Fund for heritage good causes. It has a very successful
track record and has transformed the public perception of heritage
and the potential of others to make a real contribution to enhancing,
educating and participation through archaeology. Local authorities
clearly have a more important role than ever in local service
delivery for heritage protection reform (as above in 3.—5.).
25. We believe that the voluntary sector
and non-Governmental organisations have a key role to play in
complementing the work of all these organisations; but that it
is unrealistic to implement modernisation in public policy based
on community-led (ie voluntary and amenity group) decision-making
and participation, without assistance for the voluntary and community
sector to build the capacity and skills needed to engage with
a modernised planning and heritage management system. Heritage
Link's recently published research Why Consultation Matters
provides the evidence that local amenity groups can and do
have a role in influencing the protection and enhancement of their
local heritage but there are some serious barriers to engagement.
— There is an important role for non-governmental
and voluntary bodies to articulate the views and needs of communities
wishing to enhance and protect their local heritage.
— Communities and individuals want
to take part in shaping local decisions about the historic environment
but need access to the right information, understanding and skills.
The sector has the policies but has not yet developed the right
programmes to break down barriers to engagement.
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
26. This question applies equally to skills
for archaeology and for public outreach and engagement. The overview
of heritage sector skills carried out on behalf of Heritage Link
in 2005 highlighted skills gaps and skills deficits that have
been identified in recent studies across the sector. Surveys of
local authority conservation staff and archaeological service
staff reflect this picture in detail; shortages of skilled professionals
exist as well as skills deficits in new areas such as those required
for delivering the sustainable communities programme—public
engagement, consultation, facilitation and communication. The
demands of new local heritage service delivery under the HPR proposals
will make current shortages of skilled personnel more acute. While
the Archaeology Training Forum and English Heritage have put in
place a number of measures to begin to address these issues, in
conjunction with the relevant Sector Skills Councils, engagement
from the recently formed Creative & Cultural Skills is coming
only slowly.
27. In archaeology, a combination of low
pay and limited opportunities for career progression restricts
recruitment and results in low retention of trained practitioners.
We need support for the implementation of a vocational qualification
for practice, being developed through the Institute of Field Archaeologists,
and for a graduate entry-level training or apprenticeship scheme
to provide a route for career progression and to maintain a standard
for professional practice. Equally important, as emphasised above,
is skills development for those who want to participate on a voluntary
basis.
— Local delivery of heritage services
as part of heritage protection reform will require an increase
in skilled workforce and capacity building both in local authorities
and in local amenity and community groups. The sector needs positive
action from Creative & Cultural Skills to bring together leaders
in the conservation sector and to agree an action plan for skills
and qualification development.
19 January 2006
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