Memorandum submitted by Surrey County
Council Heritage Conservation Team
Surrey County Council Heritage Conservation
Team wishes to make the following representation on the Bill,
in particular its associated Impact Assessment.
Surrey County Council is a County Council responsible
for the provision of education, social services, environment and
community services. The Heritage Conservation Team (hereafter
SCC HCT) is part of the council's Cultural Services provision,
and is responsible for heritage development control, the county
Historic Environment Record, and the Portable Antiquities Scheme
in the county. If enacted the team would be the part of the county
council most directly influenced by the Bill, and the part of
the council with the direct responsibility to undertake the new
requirements of the Bill.
SUBMISSION
1. SCC HCT broadly welcomes the Bill, which
it feels should help enhance the protection, understanding and
enjoyment of the historic environment.
2. It should be noted that SCC HCT also
contributed to the comments on the Bill submitted by ALGAO (the
Association of Local Government Archaeological Officers) to the
Committee and to DCMS. SCC HCT is in support of and agreement
with the detailed commentary on specific provisions of the Bill
made in the ALGAO submission. Such comments are not repeated here
but should be considered passim to this county specific comment.
However, SCC is most strongly concerned about the financial provisions
and proposals of the associated "Impact Assessment".
In particular, SCC is concerned that:
(a) The transfer of listing and scheduling
processes from the Secretary of State to English Heritage is considered
by DCMS to be "non-monetisable" at this stage (Impact
Assessment, page 14). SCC HCT is; [i] of the opinion that such
a process is, or could be, monetisable by this stage in the legislative
reform process; [ii] concerned that no specific guidance has as
yet been provided as to the reorganisation, if any, of English
Heritage in the light of this devolved responsibility, and in
particular the role of local government in this devolved structure;
[iii] concerned that such a process will, rather than leading
to annual financial savings (estimated to be c.—£198,000:
Impact Assessment, page 14), in fact lead to a substantial rise
in costs, which may have to be bourn at the local government level.
(b) The introduction of a new formal right
of appeal against designation decisions by English Heritage (Impact
Assessment, page 15) will lead to a substantial rise in workload
and thus costs, which may have to be bourn at the local government
level, and that such workloads and costs have not been fully problematised
or monetised by DCMS at the level of local government.
(c) The introduction of a new combined Heritage
Register (Impact Assessment, pages 16-17) will lead to a substantial
rise in workload and thus costs, which may have to be bourn at
the local government level, and that such workloads and costs
have not been fully problematised or monetised by DCMS at the
level of local government. Also, that the new Heritage Register
will include substantial new heritage assets, including registered
parks, gardens and battlefields, for which there is generally
a lack of specific skills to manage at the local government level,
and that DCMS and its partners EH and HELM have not sufficiently
problematised or monetised the training programme that will be
required to challenge this skills shortage.
(d) The introduction of a new unified consent
regime (Impact Assessment, pages 17-18) will lead to a substantial
rise in workload and thus costs, which may have to be bourn at
the local government level, and that such workloads and costs
have not been fully problematised or monetised by DCMS at the
level of local government.
(e) The introduction of new asset management
arrangements—provisionally known as Heritage Partnership
Agreements (HPA's)—(Impact Assessment, page 19) will lead
to a substantial rise in workload and thus costs, which may have
to be bourn at the local government level, and that such workloads
and costs have not been fully problematised or monetised by DCMS
at the level of local government.
(f) The introduction of a statutory duty
on county councils to create and maintain an Historic Environment
Record (HER) (Impact Assessment, page 20-21) will lead to a substantial
rise in workload and thus costs which will have to be bourn at
the local government level, and that such workloads and costs
have not been fully problematised or monetised by DCMS at the
level of local government. Also, that the new statutory HER's
will include substantial new heritage assets, including registered
parks, gardens and battlefields, for which there is generally
a lack of specific skills to manage at the local government level,
and that DCMS and its partners EH and HELM have not sufficiently
problematised or monetised the training programme that will be
required to challenge this skills shortage.
3. Overall, SCC HCT is concerned both by
the lack of financial as well as management detail as regards
the proposals highlighted in sections 2a.-2f. SCC HCT is most
concerned that DCMS and its partners EH and HELM have not sufficiently
problematised or monetised the management, transfer and training
programmes that will be required to assist local authorities in
meeting their new responsibilities, particularly the programme
of transfer of responsibility from DCMS to English Heritage, which
may prove to have a major impact upon local government level heritage
services. SCC HCT most respectfully urges the Committee to request
that DCMS publish detailed financial and structural breakdowns
of these proposals at the earliest opportunity, in order to enable
local government heritage services such as SCC HCT to bet prepare
for the proposals of the Bill. SCC HCT also most respectfully
urges the Committee to request that DCMS ensure that in particular
that any funding provided for such a process is [a] sufficient
in quantity and duration; [b] "ring-fenced" in order
to ensure it reaches the appropriate level of service within local
government. SCC HCT considers the currently proposed costings
for the proposals highlighted above to be worryingly inadequate.
SCC estimates that the total costs involved in such a programme
to be far higher than currently suggested in the Impact Assessment
(page 29), by a factor of at least 50%. As a consequence, SCC
most humbly suggests that DCMS should plan to directly assist
local government heritage services in meeting such new and enlarged
responsibilities as laid out under the Bill through the award
of both one-off and ongoing financial support for at least five
years, ring-fenced in order to ensure such monies reach the appropriate
level. In addition, SCC HCT most humbly appeals the Committee
and DCMS to take into consideration other, non-financial needs
of local government heritage services in the light of the Bill,
particularly the provision of capacity building (eg facilities
such as enhanced GIS provision) and training (eg in new areas
of remit such as parks, gardens and battlefields). SCC HCT is
concerned that, without a combination of direct and indirect financial
and non-financial support over at least a five-year period, protected
down to the appropriate level, local government heritage services
such as SCC HCT will struggle to meet the new responsibilities
proposed in the Bill.
June 2008
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