Memorandum submitted by the Institute
of Historic Building Conservation
1. INTRODUCTION
1.1 Background
1.1.1 This is the evidence of The Institute
of Historic Building Conservation (IHBC) to the Culture Media
and Sport Committee Inquiry on Caring for our Collections.
It supplements the IHBC's evidence on Protecting, Preserving
and Making Accessible Our Nation's Heritage, 2006. It has
been prepared specifically for the Committee.
1.1.2 The IHBC welcomes the opportunity
to address matters not covered in its previous evidence, but which
are of increasing concern to its members.
1.1.3 We would welcome the opportunity to
appear before the Committee, and to explain the issues noted and
exemplified briefly below in more detail.
1.2 Content and Key Issues
1.2.1 In this evidence we respond to the
questions in Caring for Our Collections, and also provide
an IHBC response to points raised in paragraphs 139-141 of the
Committee's Report on Protecting, Preserving and Making Accessible
Our Nation's Heritage, 2006. Notably, we point to:
(a) major funding issues which go beyond
the "one-off" task identified by the Committee in paragraph
141;
(b) major concerns, linked to threats of
loss, in relation to accession, management and curation of hard
copy and digital archives;
(c) the need for linked management and record
systems at local and sub-regional level; and
(d) failures on the part of DCMS to take
a holistic approach to the cultural heritage, to promote the historic
environment within arts and culture strategies, and to integrate
record-keeping for the heritaqe into government priorities and
resourcing.
2. EVIDENCE
2.1 Funding
2.1.1 Issues of particular concern to IHBC
in this context are:
(a) The lack of funding for existing hard
copy archives which are under threat of disposal (Planning records,
Building Plan and Notice Drawings, etc).
[eg Cambridge City Council Building Plan and
Notice Drawings dating back to 1890, under threat of disposal
due to lack of storage space; Peterborough City Council significant
loss of conservation records ditto].
(b) The lack of recognition and resourcing,
by DCLG in succession to ODPM, of archiving and records management
within and supporting planning and historic environment functions.
[eg consequent failures at Cambridge City
to get support for bids (successive years) for staff and project
funding for urgently-needed digital data capture and management].
(c) The needed for these archiving activities
to be funded as core activities, essential to support the Heritage
Protection Review (HPR), and not dependent on the Heritage Lottery
Fund.
[these activities have to be ongoing, rather
than project-based].
2.2 Acquisition/disposal
2.2.1 Information, in both hard copy and
digital forms, is essential to support both the Heritage Protection
Review and good conservation practice. In this context, the IHBC
is concerned at:
(a) the lack of government guidance on retention/disposal
(a) a bare minimum of information being retained:
eg listed building application forms and consents retained on
microfiche, but not the plans which are essential to enable assessment
of whether lawful works have been carried out;
(b) retention/disposal decisions not being
made by informed professionals—see (f) below];
(b) the implications of this lack of guidance
for information systems to support HPR;
[eg loss of hard copy records, plans needed
to inform proposals and allow assessment, etc];
(c) the HPR focus on digital media, rather
than a holistic approach founded on the management and archiving
of primary records;
[a holistic approach would involve integrated
management of data, with key primary records held in archive form,
property records held by owners (essential for Heritage Partnership
Agreements, and Conservation and Management Plans) and local planning
authorities, and the HER serving as the digital index to, and
interpretation of, this spectrum of records. Archived primary
records will need to continue to be held in non-digital form.
Digital media do not enable the comparison, essential for assessment
of building projects, of multiple plans at full size].
(d) the lack of permanence of digital media
and access to them;
[(a) uncertain
durability of CDs/DVDs;
(b) systems vulnerability to changes in hardware/software;
(c) systems failing: eg the ORION system,
presented to the IHBC Annual School in 1998 as an ideal way of
recording and managing work on historic buildings, no longer exists];
(e) server and other hardware capacity issues,
and costs, arising from large volumes of data (including photos,
plans etc) contained in records relating to historic sites;
[(a) insufficient
capacity on Cambridge City Council Planning server for current
photo and plan storage needs;
(b) increased information storage needs to
support Conservation Area appraisals, management and review as
required by Best Value Indicator BV 219];
(f) risks of loss of archived records (hard
copy or digital) through destruction by unaware hands;
[Cambridge City: loss of data relating to
still-extant listed building consents, and unauthorised works,
through microfiching by admin staff;
Fenland: loss of digitally-held data relating
to Article 4 Directions, due to wiping by IT staff];
(g) the resource costs involved in ensuring
appropriate professional input into archive management and disposal;
[(a) informed professional
input is needed for sifting and assessing what information should
be retained as primary archive, what to be digitised, and what
to be discarded;
(b) ongoing professional input is need to
ensure management and updating of records, replacement of deteriorating
media, adaptation to new hardware etc;
(c) Cambridge City: expectation that Conservation
team takes charge of its own data sets, including the above additional
activities, and training, but with no extra resources].
2.3 The role of DCMS
2.3.1 The IHBC is concerned at the extent
to which DCMS has not achieved an effective lead in relation to
holistic management of the Heritage, and notably (for IHBC and
its members) in the failure to achieve effective links and synergies
with DCLG. This "silo" approach on the part of government
has potentially major implications for archiving, records and
information management in general, and particularly to support
the Heritage Protection Review. Particular issues of concern to
IHBC include:
(a) the failure to develop or promote coherent
and holistic data standards for the cultural heritage as a whole,
including the curation and dissemination of information relating
to its stewardship, as an integral part of arts and culture strategies;
[The data standards which have been developed
by English Heritage, DCMS, and ALGAO relate to archaeology, not
to the wider historic environment. The IHBC queried this approach
in its response to the DCMS Consultation on Historic Environment
Records, arguing for a radical holistic review of data standards
to match the radical (and concurrent) Heritage Protection Review
consultation. At the time of making that response, the IHBC was
unaware of the 1998 Council of Europe publication "Documenting
the Cultural Heritage" (ISBN 0-89236-543-9) which contains
standards relating to archaeological sites, cultural objects,
and historic buildings. These standards appear well suited to
an integrated approach to the cultural heritage; they have been
in existence throughout the lifetime of DCMS and the development
of its Heritage Protection Review];
(b) the failure to get DCLG recognition and
resourcing of archiving and records management functions within
local planning authorities;
[noted under 2.1.b) above];
(c) the lack of engagement with or influence
on the ODPM (and now DCLG)'s development and promotion of e-government
data management and standards, which give rise to incompatible
systems and standards, and militate against dialogue and exchange
of information between HERs and planning and historic building
record systems;
[Electronic systems promoted by ODPM and DCLG,
including PARSOL for planningapplications, CAPS Uniform and other
systems for process management, and NLIS (National Land Information
System) to support electronic property transactions, have all
been developed without reference to or compatibility with Exegesis,
MIDAS, OASIS and other systems developed by and for the archaeological
community to support Sites and Monument Records now Historic Environment
Records.
(a) CAPS Uniform and equivalent systems are
the key to managing proposals affecting the historic environment,
and the interactions involved (eg with Building Control) within
the e-government environment;
(b) CAPS has a module for Listed Buildings
(as yet not fully functional), but none for Archaeology or Conservation
Areas;
(c) CAPS has no scope for direct data exchange
with an HER, therefore requiring entry twice, on different systems,
of all record notes made;
(d) NLIS depends on accurate electronic provision
of property data, including designations; however not all authorities
have spatially captured their listed buildings, and very few have
captured listed building curtilages (vital for accurate provision
of information on legal constraints affecting properties). The
need for, and costs of, such capture appear to have been entirely
unanticipated by either DCMS or ODPM/DCLG];
(d) while recognising the efforts by DCMS
and EH to explore the potential synergies arising from core DCLG
and e-government initiatives (including Best Value Indicator BV
157 for putting information on the web; the requirements of the
Freedom of Information Act; Customer Access Strategies), IHBC
registers our concern at the major strategic and operational hurdles
still to be addressed if we are to build successfully on these
wider government initiatives;
[IHBC welcomes these efforts to respond to
and deal with issues which the Institute has been raising for
several years—notably in the 2005 Conference "Managing
the Historic Environment in the Digital Age" which it organised
in conjunction with the IFA—but there is still a very long
way to go];
(e) the consequent missed opportunity to
embed the management and dissemination of historic environment
information and records into e-government and other general government
activities, with the associated threat of creating a marginal,
potentially high-cost and inefficient mechanism;
[the IHBC has suggested that this potential
opportunity should be investigated as part of the HPR Strand B
investigations];
(f) the focus, in the Heritage Protection
Review, on the post-2010 digital environment without considering
migration costs (as noted in the Committee's report), or (not
noted in the Report) the costs of the associated archiving, and
records management needs and costs within local planning authorities;
[the HPR Strand B investigations have not
explored the costs of archiving material to be retained, or of
managed disposal; the investigations have focused on improving
existing HERs, not the full scope of records management including
by local planning authorities];
(g) the failure to explore, within the Heritage
Protection Review pilots, records management to support Heritage
Partnership Agreements;
[Records kept by owners are vital (as noted
by Lord Hankey, Chair of the 1999 Conference which introduced
the Conservation Plan approach among Cambridge Colleges) to their
awareness of the significance of heritage assets under their care
and hence to successful conservation. The HPR Pilots for Heritage
Partnership Agreements could have provided an ideal opportunity
for exploring issues and Possibilities elating to the management
of records, in both public and private hands, to support conservation
works. This key opportunity does not appear to have been taken.]
(h) the delays in liaising with DCLG to ensure
integrated archiving policies and standards for records generated
through the planning system;
[There has been no coherent support, or standards,
covering the generation of non-archaeological building records
generated by conditions on planning permissions or listed building
consents. English Heritage's recently-published Recording guidance
could provide the required basis, but as yet it remains little-publicised
and without support from DCMS or DCLG].
3. CONCLUSION
3.1 The IHBC has been, and is keen to continue,
working with the DCMS, DCLG, English Heritage, its fellow professional
bodies the IFA and ALGAO, and others to try to address the issues
noted above, in a holistic approach. It hopes that all involved
will be able to work together to shared and integrated standards
for the cultural heritage, developed to support HPR through a
combination of hard copy archives and digital media, and with
effective interchange between different record systems. This can
only happen if sufficient resources, as well as appropriate standards,
are made available.
28 September 2006
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