Memorandum submitted by the Association
of Chief Archivists in Local Government (ACALG)
I am writing on behalf of ACALG, the Association
of Chief Archivists in Local Government, which is the professional
body for the heads of local authority archive services in England
and Wales.
We welcome the opportunity to comment on the
draft of this important piece of legislation and welcome the need
it recognises and regularises to protect heritage by a wider definition
than the present "built structures" approach. The opportunity
to redefine Historic Assets and create recognised historic environment
records (HERs) which can now include sites and scatterings of
archaeological finds is an important one and will, we hope, ensure
the more effective preservation of the heritage.
Looking at the draft specifically as archivists
working for local authorities including the planning authorities
who will be required to create and maintain the HERs, we would
suggest that it may well be useful to specifically include, possibly
at 213(1) a specific requirement to ensure the preservation of
content superseded from the HER, but which is worth retaining
for historical purposes. My understanding is that at present such
information is not removed from the existing Sites and Monuments
Records (SMRs) or Listed Building Schedules but merely noted as
superseded. We would suggest that at some point for operational
purposes the HERs will be migrated to new systems, or simply "tidied
up" and that at such a time there is a risk that older data
no longer required will be dumped. Specific inclusion in the legislation
would reduce this risk.
We would also take this opportunity to remind
the Committee about the rather serious difference between the
level of protection afforded to buildings and the heritage environment
and the lack of protection afforded to "portable heritage"
and most specifically archive collections. These can be as enmeshed
with the identity and history of a community as any building or
landscape, but have little if any protection in most cases other
than the refusal of an export licence if they are perceived as
being over a certain monetary value. We do not suggest that the
processes already existing and widened and strengthened by the
proposed legislation would be the appropriate means to do so,
but suggest this is a question which merits a further consideration.
At present the archive room of an historic building can have protection,
but the contents of the room do not even though they relate to
the fields the estate and house are on or the people who lived
and worked there. Even within the narrower scope of the current
proposed legislation it could realistically be maintained that
the HERs would be incomplete without the information contributed
to them from archives. We would suggest that this anomaly should
be looked at.
June 2008
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