Review of Heritage Protection: The way forward

A response from RESCUE – The British Archaeological Trust

RESCUE – The British Archaeological Trust welcomes the publication of the Review of
Heritage Protection: The way forward as representing a generally positive contribution to the
future of the Historic Environment in England. The response to the consultation document (over
five hundred separate contributions) demonstrates the widespread concern over issues related to
the historic environment. A similar level of concern amongst the general public was in evidence
when English Heritage commissioned a public opinion survey as part of the preparation for the
publication on Power of Place. In spite of the shortcomings of this document and of then
subsequent Force for our Future, there can be no doubt that issues around the Historic
Environment are of significance, as acknowledged in the Foreword to the Review.
While generally welcoming the publication of the Review and of the measures which
are proposed within it, RESCUE does have a number of concerns, the majority of which relate to
areas upon which the Review is silent. Given that the Review will structure a programme of
government action (including legislation) it is of concern that there are such silences within it on
these issues. The following notes are intended to highlight areas where RESCUE considers that
further action is necessary and where we will continue to press for changes in existing policy and
the establishment of new and innovative policies. Attention is also drawn to specific cases in
which the commitments apparently given in the Review are contradicted by active government
policy whether at the local or national level.

Introduction
Context for the review
References to the importance of the Historic Environment are still 'instrumental' in the
terms defined by Tessa Jowell in her recent essay Government and the value of culture – briefly
summarised, it would seem that while we can have 'art for art's sake' the protection of the
Historic Environment seems to have to be justified in terms of wider policies and anticipated
outcomes; (egeneration, tourism, education etc) rather than for its own sake. RESCUE would
like to know how this apparent lack of consistency can be justified, particularly given the level of
interest in and concern for, the Historic Environment as measured by the public opinion survey
undertaken during the preparation of Power of Place. Clearly education, regeneration and
tourism are important issues and the Historic Environment can and should make a central
contribution to them, but there remains the issue of research which is fundamental to any
consideration of the Historic Environment. Research underpins and, in a very real sense, creates
the Historic Environment by bringing knowledge and understanding of it into existence through
the application of investigative and interpretative techniques to the material traces of the past.
We still need a clear commitment to research and this is lacking in the document as presented.
Some acknowledgement that Universities and Colleges have a role here would have been
welcome, particularly as the Research Assessment Exercise (which acts to structure university
research) is currently underway.

Decisions
Short-term package
 The proposals for short-term measures, while they are to be welcomed, place the
responsibility for a great deal of work on English Heritage. RESCUE is concerned that this
additional responsibility will not be reflected in an increase in funding for the organisation or
even in a reversal of the severe cuts which have been made in the last ten years. If no additional
funding is to be forthcoming, where will the further cuts necessary to fund the additional work
fall? RESCUE also notes that most of the short-term proposals concern standing buildings - will
the extra spending required come from cuts elsewhere in the E.H. budget? Specifically, will the
emphasis on buildings be at the expense of archaeology? If so, this will have to be regarded as a
negative outcome from the review exercise as a whole
The review of class consents is to be particularly welcomed, especially with regard to the
effects of ploughing. But will there be an increased commitment to prosecution (or, should I say
some commitment to prosecution as it is singularly lacking at present) where damage is done to
monuments or where changes of use occur in spite of Scheduled status?

Longer-term package
It is regrettable (although the practical problems have to be acknowledged) that the
longer-term package is to be delayed - in the interim we can expect to see an increased level of
destruction as the development industry races to ‘beat the clock’. How will this threat be dealt
with?
The commitment to the statutory provision of Historic Environment Records is to be
welcomed, but will extra funding be made available to ensure that they are able to carry out their
responsibilities effectively. Although not specifically included in this review, it is worth noting
that the archives resulting from archaeological survey and excavation are as much a part of the
Historic Environment as are standing buildings and scheduled sites - where is the protection for
these assets? It is to be anticipated that if local authorities are to be compelled to establish and
maintain H.E.R.s without increased resources, then cuts will fall elsewhere - most probably on
local and regional museums which will, in practice, mean that the current campaign of cuts and
sackings will continue and will probably increase. RESCUE has outlined the concerns of its
members in relation to these issues in a series of letters to DCMS but has yet to receive a
satisfactory response and meanwhile the programmes of closure and sacking are continuing
apace. Without a reversal of this policy the principle of 'preservation by record' (which is
fundamental to P.P.G. 16) will cease to operate effectively and a crucial and central part of the
Historic Environment (the archives resulting from archaeological excavation and survey) will
become inaccessible and unusable, to the detriment of our understanding of the Historic
Environment as a whole. The archives resulting from excavation and survey are as much part of
the Historic Environment as is a standing building and it is a matter of great concern that there is
nothing in the Review to suggest that the DCMS acknowledge this important fact.

The new system

Management and control for items on the register
Reference is made to DCMS and ODPM 'continuing' to work together. This would seem
an unusual choice of words, given that co-operation has not, hitherto, been a characteristic of
these two departments, as witnessed by the St Pancras Cemetery affair. It is to be hoped that
there will be a greater commitment to communication and an integration of response between the
two departments as a result of the changes outlined in the Review but this is something that will
need to be monitored. Elsewhere a greater spirit of co-operation is required - the issue of the
looting of the wreck of HMS Sussex by a branch of the Ministry of Defence and an American
treasure hunting and salvage company looms large here.

The rural historic environment

The review of the class consents issue is particularly welcome and the contribution of the
English heritage 'Ripping up the Past' initiative should be noted here. Unfortunately a major
omission lies in the area of the renewal of old mineral extraction planning consents (ROMP)
which are currently threatening sites in Derbyshire and on Dartmoor, not to mention the
Thornborough Henges. It is most regrettable that the Review is to be silent on this issue. Given
that much of the stone and other material quarried under these consents is linked with road and
house building, the issue of the expansion of house building in the south east is of particular
concern in this regard, with the demands of the south-east literally consuming other areas of the
country, including some of our most valuable and sensitive landscapes. Can we expect co-
operation between the DCMS and the ODPM in this area?

Protection at regional and local level

PPG 15 and 16
The ongoing delay to the (highly secret) revision of these documents should be noted
here and the continued negative impact of the control exerted by the development industry on
archaeology is to be regretted.

Conservation areas and local lists

Once again, the commitment to communication between the DCMS and the ODPM is to
be welcomed, but the poor record of the ODPM in respect of archaeology means that we will
await the outcome of their deliberations with some concern. How far will the views expressed in
the responses to the consultation weigh when up against the demands of the development
industry?

Resources
In our contribution to the consultation document, RESCUE drew particular attention to
the lack of resources available to conservation staff and the Field Monument Wardens and is
pleased that this issue has been tackled. The proposed response will have to be assessed once the
results of the pilot studies are known, but for the interim it should be noted that a good deal of
expertise exists in the private sector, a direct result of the competitive tendering regime enforced
under PPG 15 / PPG 16. Should some mechanism for an input from the private sector be
considered? Clearly a scale of fees would be needed to prevent consultants from over-charging,
but this should not be impossible, given the existence of established wage rates in E.H. and in
local authorities which can be used to set limits on consultancy fees.

Training
The issue of the skills and training has been highlighted by many bodies and individuals
(particularly in connection with the ongoing destruction of the skills base in local and regional
museums) and it is good to see the issue addressed at last. Increased resources are needed in this
area, particularly for E.H. but a rolling back of the programme of sackings and dismissals
instituted by local authorities in respect of museums would be welcome here.

Historic Environment Records

The acknowledgement of the importance of Historic Environment Records is most
welcome and the commitment to make them a statutory responsibility is particularly welcome
(assuming that increased resources are made available for their maintenance and staffing, as
noted above). Only the inclusion of the phrase ‘or have access to one’ raises a slight concern.
Will local authorities be able to use this to evade their responsibilities?
Once again (see above) there is an emphasis on the instrumental role of the Historic Environment
in terms of education and this is fine as far as it goes, but Historic Environment Records are also
a key research resource and this element should be acknowledged in their establishment, mission
statements and raison d’etre. It is inadequate to say that ‘good decisions about the historic
environment can only be based upon good information’ without acknowledging that the source
of ‘good information’ is high quality, innovative research and that this requires an appropriate
level of input. Here again, some recognition of the role of the Research Assessment Exercise in
structuring research within colleges and universities would be appropriate.

General points
There is also a general point to be made regarding the Review as a whole. The orientation of the
Review seems to be primarily towards buildings and the built environment (although, to be fair,
much of what is said does cover buried archaeology as well) and in this reflects the emphasis in
both Power of Place and Force for our Future which drew considerable comment when these
documents were published. RESCUE is concerned that this emphasis will lead to a diversion of
resources from archaeology and towards standing buildings