Mr Owain Lloyd-James

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Mr Owain Lloyd-James Powered By Docstoc
					Mr Kenneth Fox
Clerk of the Culture, Media & Sport Committee
House of Commons
7 Millbank
London SW1P 3JA

17 January 2006

Dear Mr Fox

Select Committee on Culture, Media and Sport inquiry on Protecting, Preserving
and Making Accessible our nation’s heritage

The Society welcomes the Committee’s choice and timing of its inquiry on
Protecting, Preserving and Making Accessible our nation’s heritage, which offers an
opportunity for Learned Societies and others in the voluntary sector to identify
priorities in advance of the forthcoming heritage White Paper. The inquiry represents
the first independent review of Government performance on actions outlined in The
Historic Environment: in A Force for the Future (AFFOF), which was published over
five years ago (2001), and which, despite its age, remains the current Government
policy statement. The Society particularly also welcomes the multidimensional scope
of the inquiry, which includes both historic environment and museum/archive aspects
of the cultural heritage.

Founded in 1707, the Society is charged by its Royal Charter of 1751 with the
‘encouragement, advancement and furtherance of the study and knowledge of the
antiquities and history of this and other countries’. Its membership comprises an
elected college of around 2,300 Fellows from the fields of archaeology, art and
architectural history, material culture studies, museology, archives and heritage
management. Fellows serve in senior positions in universities, museums, libraries,
archives, professional bodies, local authorities, national heritage agencies, as well as
in private practice.

The Society is a registered charity and leading non-Government organisation working
in the cultural heritage sector. The Society is an active member of the Archaeology
Forum and Heritage Link, umbrella bodies of national NGOs concerned with the
investigation, management and interpretation of the historic environment. It also
advises the All-Party Parliamentary Archaeology Group (APPAG).

The Society awards grants from its own funds for academic research and the
conservation of historic buildings. It is also an Accredited museum and holds a pre-
eminent collection of paintings, prints, manuscripts and artefacts together with the
country’s leading research library for archaeology and the cultural heritage. It also
maintains for public enjoyment Kelmscott Manor in Oxfordshire, the former country
home of William Morris, Fellow, and leader of the English Arts and Crafts

Thus as a leading national Learned Society, research sponsor and publisher and as a
museum, library and archive, the Society is actively engaged in all areas of debate on
the heritage and cultural property. One of the Society’s strategic aims is to influence
policy making in the national and international heritage. Its independence of
government and of any vested sectarian interests makes it uniquely placed to
encourage and facilitate public debate on the management, conservation, presentation
and public understanding of the heritage. The depth and breadth of knowledge and
expertise among the Society’s 2,300-strong Fellowship gives it the authority to speak
on key issues of policy and delivery.

Q1. What the Department for Culture, Media and Sport should identify
as priorities in the forthcoming Heritage White Paper

1.       A key priority is the reform of the current regimes for designations and
consents, which will unify the various registers of historical assets, both for listed
buildings and for Scheduled Monuments. The Society s has consistently supported a
holistic approach to understanding, protecting and managing the historic environment,
together with the enhancement of local delivery currently being promoted by English
Heritage (EH). We are anxious that the outcomes of EH’s Heritage Protection Review
will be available to inform the drafting of the White Paper. The Society is also
looking for assurances that any new regime will be properly resourced, both centrally
and at local level.

2.      Damage to archaeological sites by deep ploughing through the Class Consents
system remains one of the most critical issues in national heritage conservation.
Recent deep ploughing of areas of the Roman city of Verulamium, one of the
Society’s key associations through its former President, Sir Mortimer Wheeler,
revealed the flaws of the current Class Consents system. Reform of the Class
Consents regime should form part of the White Paper proposals.

3.     The White Paper also presents an opportunity to review the current provisions
for Conservation Areas and their resourcing, together with a more inclusive
consultation on valuing significance by local communities.

4.      In addition, the timing of the White Paper should have the effect of
accelerating the review of the non-statutory Planning and Policy Guidance Notes
(PPGs), which represent an opportunity to improve best practice in the quality,
delivery and communication of developer-led archaeological interventions.
Accelerated progress on the revision of the frameworks that dictate the current
character of developer-led archaeology will ensure:
    o greater public benefit through requirements to store, conserve and display
       artefacts recovered during fieldwork; and to involve the public in excavations
       in their neighbourhood and to open sites for visitors;
    o a greater research dividend through requirements to analyse, research and
       publish excavation results in forms accessible to the archaeological
       community and the wider public;
    o a greater quality of work, through encouragement of planning authorities to
       specify that archaeological work must be carried out in accordance with
       accredited standards and led by accredited organisations or individuals

   o better management of historic buildings through a requirement for
     investigation and recording of buildings damaged or destroyed in
     development, including archiving and publication of the results.

5.       As Professor Richard Bradley FSA has argued in a seminal lecture recently
given to the Society, and now available on the Society’s website (, it
is now time to move on from the increasingly arid philosophy of ‘preservation by
record’, which dictates so much of the PPG16 environment. It is time to seek ways of
expanding the accessibility and audience for post-intervention client reports (the so-
called ‘grey literature’). As a research resource, the value of this primarily descriptive
record is compromised by its inaccessibility and labour-intensity of use. Through
Professor Bradley’s lecture (itself the outcome of an Arts and Humanities Research
Council grant), the Society has initiated a debate on how to improve the quality of
research outcomes from development-led field archaeology and to create a resource
that researchers will want and be able to use efficiently. Greater capacity building will
be required to realise this ambition but one which, though supporting the facilitating
role of the Learned Societies, such as ourselves, could be achieved.

6.       Finally, on the subject of developer-led archaeological intervention, the
Society would like to register its concerns about the current curatorial provision for
the results of the planning process. There is an increasingly serious crisis looming
concerning the availability and resourcing of adequate storage space for the new
archives generated by work undertaken under the PPG 16 regime. The direct result of
this is to imperil the effectiveness of the principle of ‘preservation by record’, which
is so fundamental to the current system. It also makes the use of those archives by
curatorial staff and by scholars difficult or impossible and so may preclude their value
in contributing to knowledge and to public enjoyment. The Society notes the
development of the London Archaeological Archive and Resource Centre in Islington
as a model approach to this widespread problem (itself enabled by a HLF grant).

7.       The Society strongly supports the enhancement of the existing Sites and
Monuments Records into comprehensive local services, in the manner of Historic
Environment Records (HERs), as recommended by APPAG in its 2003 report Current
State of Archaeology in the United Kingdom (recommendation number 3). These
facilities should be made statutory with additional funding from Government to
ensure all local authorities maintain and provide access to them and that they meet a
standard level of content and service delivery around the country. HERs should also
exploit the latest electronic technology to ensure they act as portals for widest public
access. It is worth noting that Article 2 of the Valletta Convention (European
Convention on the Protection of the Archaeological Heritage 1992), ratified by the
UK government in 2000, requires States Parties to make provision for the
maintenance of an inventory of ‘archaeological heritage’.

8.      Apart from improvements to the heritage protection system, the White Paper
also provides an important opportunity to assess the role and contribution and
capacity of the voluntary sector in the management of the nation’s heritage. We are
looking for a new inclusive approach with resources that will encourage participation
and build skills in national bodies and local communities.

Q.2. The remit and effectiveness of DCMS, English Heritage and other
relevant organisations in representing heritage interests inside and
outside Government

9.      The Society regards the historic environment and cultural property as central
to the social and economic fabric of the nation, to community cohesion and to the
quality of life for all our citizens. As our sector’s umbrella bodies have urged, the
heritage represents a positive force for change and regeneration. However, Fellows of
the Society are concerned about the relatively low priority given to heritage in a
Government department that administers increasingly competing sectors, particularly
with the demands of 2012 in prospect. We anticipate that discussions and
consultations surrounding the 2007 Comprehensive Spending Review will test the
commitment of DCMS to its heritage responsibilities.

10.     DCMS needs to play the champion role more effectively and more publicly.
The APPAG Report of 2003 identified the lack of leadership in Whitehall this as a
major weakness of effective policy making on the heritage. The Society continues to
support the thrust of APPAG recommendation (number 1) that the DCMS establish an
inter-departmental Committee on the historic environment, at Ministerial level, which
would coordinate policy in this area. For instance, such an initiative may avoid the
blight that has characterised the pace of the PPGs reviews, which represent a
relatively low priority for DEFRA, the lead body in this case.

11.     DCMS needs to improve its effectiveness for engaging with the respective
professional and voluntary sectors on policy. Recently, English Heritage has been
distracted by internal restructuring and has failed to engage constructively and
consistently with the voluntary community. Confusion remains widespread about the
new structures and the points of delivery. The lack of consultation on the recent
published EH Research Strategy 2005-2010 is a case in point. Few, if any, of the
national Learned Societies were involved in its formulation. The Society would like to
see more open meetings and seminars such as the recent touring presentations on the
Heritage Protection Review. EH should be more forceful in supporting the voluntary
sector to develop and contribute to research and management agendas. In addition, it
would be helpful if EH would assist NGOs, such as the Society, to play a more active
part in hosting debates for the sector on key policy issues. With its independence of
government and central location, the Society is ideally placed to facilitate this
engagement. A capacity-building funding stream would be welcome here. Altogether,
we would urge EH to develop a more inclusive approach to research strategy and
policy development.

Q3. The balance between heritage and development needs in planning

12.     We question the on-going tension between preserving the old versus building
the new, which portrays heritage not as an asset but an obstacle. Fellows urge a more
mature debate about the contribution of historic assets to development and
regeneration of communities. Adaptive reuse of heritage resources can also provide a
sense of stability and continuity for people and communities that helps to counteract
the climate of disruption exacerbated by economic globalisation (Heritage in Europe:

absorbing the pace of change, Europa Nostra European Policy Forum meeting,
Brussels, December 2005).

13.    The Committee is urged to recognise the threat to the heritage in designated
regeneration or renewal areas, which side-step normal planning controls. The Society
would wish to avoid a repeat of the recent St Pancras cemetery debacle, where
archaeologists were barred from the site by developers working on the Channel
Tunnel Rail Link terminus under the CTRL Act 1996.

Q4. Access to heritage and the position of heritage as a cultural
asset in the community

14.      Volunteering is the lifeblood of the sector in Britain (Volunteering and the
Historic Envionment, Heritage Link, 2003). The Society could not open William
Morris’s home at Kelmscott without the support of 60+ volunteers who man the
office, shop and restaurant and who lead the public around the site. Our heritage
environment needs to discover new ways of enabling non-professionals to get
involved in all areas of activity and to encourage greater public participation.

15.   DCMS needs to maintain its vision for Power of Place (DCMS 2000), which
emphasised the significance of locality and the importance of heritage for local
communities in terms of identity building.

16.     Government, together with the heritage community, urgently needs to address
issues of diversity in the sector, which is notoriously narrow. Voluntary and
community bodies are best placed to work with Government on the issue.

17.     Once more, the need for outreach to local communities amplifies the need to
make rapid progress on the reviews of the PPGs, with a view to improving outcomes
of development-led excavation for public benefit and improved local understanding
(see para 4 above). Equally, local authorities must be properly resourced to enable
outreach and educational activity.

Q5. Funding, with particular reference to the adequacy of the budget
for English Heritage and for museums and galleries, the impact of the
London 2012 Olympics on Lottery funding for heritage projects, and
forthcoming decisions on the sharing of funds from Lottery sources
between good causes

18.     We understand that some £3.3bn has been allocated to around 18,000 projects
since the inception of the Heritage Lottery Fund, with archaeology alone benefiting
from some £90m of lottery proceeds. In addition to the conservation benefit, the HLF
has also most crucially enabled ordinary people to get involved in their local heritage
and to make decisions about its future.

19.     Funding for the heritage remains one of the central issues for the entire sector,
particularly in the face of threats to the allocations from the Heritage Lottery Fund
and pressure on Government to divert grant support for English Heritage and the
regions in favour of London sport-related needs. We believe, however, that the
Olympics in 2012 represent a huge opportunity for the UK to showcase its heritage

assets and cultural property to the world. Government needs to invest in the
opportunity for that legacy, not waste it. To this end, HLF share of lottery funding
must be protected and at least maintained at the present level.

20.     The White Paper also offers the prospect of finally dealing with one
outstanding negative anomaly, that is the VAT charged at higher rate for repair and
restoration, which continues to distort the sustainability and public value of historic

21.     Funding for national and regional museums is stretched to breaking point, to
the extent that many collections of significance are at risk, both through lack of care
and opportunities for public access. The problem is particularly acute at local
authority level. Standards of curatorial expertise are collapsing nationally due to job
cuts and lack of continuity planning. Museums, particularly those in local authorities,
lack sufficient staff with the skills and expertise they need to support active
programmes of research, collection and communicating to the public. The situation is
particularly acute in the archaeological sphere, which forms an important link in the
communication of interest and enjoyment of the historic environment to local
communities. The lack of capacity that was identified in the Renaissance in the
Regions report has not yet been remedied despite successive commitments

22.     Purchase funds are a particularly easy target for cuts when museums have to
make difficult choices in order to save money. Acquisition budgets have been
squeezed in real terms in recent years and are now at they level they were 20 years
ago. The virtual extinction of purchase budgets in local authority museums has
resulted in a very grave threat to the nation’s portable heritage. In 2002 museums
withdrew a stated interest in acquiring a total of thirteen important Treasure finds,
even though some were valued as little as £250. Such acquisitions are vital if local
communities are to benefit from the revised Treasure legislation.

23.     It is hoped that in any decisions on funding some priority might be given to
applications for assistance in purchasing works of art and cultural objects deferred
under the Review of Export of Works of Art regime (Waverley system). These are by
definition pre-eminent items relating to our national heritage. Given that the National
Heritage Memorial Fund (NHMF) has only £5m a year to spend since the launch of
the national lottery (and much less for the future after intervening to save
Tyntesfield), its designation as a fund of last resort has become meaningless. We
believe that the NHMF funding must be restored to a more realistic level. NHMF
assistance in ‘saving for the nation’ the Macclesfield Psalter is just one recent
example of the importance of this last resort funding stream, which generated a truly
remarkable expression of public interest.

24.      In addition, it is undoubtedly the case that museums have successfully
acquired many important objects through the Acceptance in Lieu scheme. We believe
there is scope for the principle to be extended to other forms of tax liability in addition
to inheritance tax, as proposed in the Goodison Review (2004). We support proposals
made by the Museums Association for an additional scheme of gift aid in kind,
whereby objects deemed of pre-eminent importance could be off-set against other tax
bills, thereby encouraging people to donate objects to museums during their lifetimes.

This would also have the advantage of fostering long-term philanthropic relationships
between donors and acquiring institutions.

25.     We urge the establishment of an independent commission on the state of
public collections, their resourcing and their relationship to the historic environment.

Q6. What the roles and responsibilities should be for English
Heritage, the Heritage Lottery Fund, local authorities, museums and
galleries, charitable and other non-Governmental organisations in
maintaining the nation's heritage

26.     Role of NGOs: AFFOF in 2001 counted ‘including and involving people’ as
one of the five specific Government objectives for realising the full potential of the
nation’s heritage assets. We are yet to see this initiative materialise. Of primary
concern to the Society is the role and influence of NGOs in the heritage sector, which
range from Learned Societies and professional bodies to specialist interest groups.
This voluntary community operates close to the ground and is sensitive to public
opinion and interest. Its memberships are seeking to encourage active participation by
citizens of all backgrounds in the cultural heritage. We urge DCMS, other relevant
government departments, local authorities and EH to engage more effectively with
NGOs to create a more inclusive working environment. The Government should
consider whether NGOs could get more involved in delivering some public services.
Knowledge of issues and locality may pay dividends for greater public engagement.

Q7. 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

27.      Like others, the Society recognises that the work of Conservation Officers and
other professionals in the historic environment, such as archaeologists, in local
authorities is hampered by low pay, low status and lack of a career structure. In
addition, we acknowledge the urgency of an effective and robust continuous
professional development programme for all those working in the historic
environment and cultural property, both vocational and non-vocational. The building
of skills in local communities will remain a vital objective for some time to come. It
is the job of national agencies to support the professional bodies and voluntary
organisations to achieve this.

I hope the Committee finds these responses of interest. We would very much
welcome the opportunity to expand on the issues raised when the Committee takes
oral evidence.

Yours truly

Dr David Gaimster
General Secretary & Chief Executive