Memorandum submitted by Historic Environment
Record Officer, Southampton City Council
These comments and queries concern the additional
burdens on HERs resulting from the Heritage Protection Bill, and
the funding of those burdens.
The Impact Assessment states in a few places
that DCMS and EH will meet the cost of additional burdens to local
authorities in respect of HERs (eg paragraphs 8, 11, 12 and 44).
However this clearly refers to post-implementation funding—Table
6 (page 21) has all "one-off" costs falling in Year
1 post-implementation. There is no mention of additional funding
prior to implementation of the Bill.
Due to past underfunding, most HERs have considerable
backlogs of archaeological and historical data not yet entered
into the database. In many local authorities the development control
process with respect to archaeology still depends to a large extent
on the knowledge of individual staff members, to supplement information
on the HER or fill gaps in the data. It would seem from the Draft
Bill and associated documents that all such information will need
to be on the HER database if the archaeological resource is to
be protected—if the HER is to include all registrable heritage
assets of local special interest (Draft Bill, Note 258) and if
special archaeological interest is to provide the flag for PPG16
to apply (EH Commentary, Note 100). In addition, listed buildings
and locally listed buildings will need to be on the HER. The Bill
and associated documents do not mention a transition period after
implementation during which the full force of the Bill will not
apply. Is this an oversight? Or must we assume that registrable
heritage assets will not be fully protected unless they are on
the HER at the time of implementation? It the latter is the case,
much work will need to be done in the years before implementation,
to clear the backlog of archaeological, historical and buildings
data, on top of keeping the HER up-to-date with information from
new archaeological sites. Further guidance is needed from English
Heritage as to what will need to be on the HER and when this must
be achieved by.
Other resource implications for HERs are as
follows:
— Owners must be consulted before
sites of local special interest are added to the HER. This will
presumably need to be done prior to implementation.
— The requirement for the HER
to be available on-line will have significant cost implications
apart from the obvious cost of new IT systems. Extra staff resources
will be needed to bring existing records up to a sufficient standard
for public display.
— Significant IT requirements
with respect to: (1) putting the HER online; (2) extra software
licences for additional staff; (3) making the HER interoperable
with Corporate GIS and back office planning systems, which may
not be interoperable one-with-the-other (referred to in DCMS Draft
HER Guidance, paragraphs 20 and 32).
— Outreach (Note 42) will be an
extra burden for some smaller HERs (although many larger HERs
already engage in outreach). For instance, publishing a HER leaflet
is likely to increase the number of enquiries from members of
the public.
If there will be additional burdens on HERs
prior to implementation, will Central Government/English Heritage
funding be available for this? If not, the work must be funded
by local authorities and HERs will each need to make a business
case for increased resources. This will only be accepted and included
in business plans if the framework for assessing the performance
of HERS (the EH/ALGAO Benchmarking) is in place and is being monitored.
Otherwise the HER will be just one of many competing requirements
on local authority funding.
June 2008
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