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BRITARCH  March 2000

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Subject:

CBA initial response to EH review (long)

From:

Mike Heyworth <[log in to unmask]>

Reply-To:

Mike Heyworth <[log in to unmask]>

Date:

Mon, 20 Mar 2000 10:56:15 +0000

Content-Type:

text/plain

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Parts/Attachments

text/plain (779 lines)

	
As promised in an earlier email, here is the CBA's initial response to the 
review of English heritage policies being carried out by English Heritage. 
We expect to have further opportunities to comment during the course of the 
review, not least because our President, Dr Francis Pryor, is on the 
Steering Group.

Mike



Graham Fairclough
Historic Environment Review Co-ordinator
Room 208
English Heritage
23 Savile Row
London
W1X 1AB
17 March 2000

Dear Graham,

Government Review of Policies Relating to the Historic Environment

I enclose our comments on the proposed scope of the Review and issues to be 
covered.  Please note that it has not been possible to undertake a thorough 
consultation within the CBA for this, so the suggestions made are somewhat 
provisional.  We have tried to outline issues that need to be considered.

As a general point, like many others, we do consider this a very short 
timescale to tackle a very large number of issues that have considerable 
complexities of inter-relationships.  We understand from Alan Howarth's 
letter (para13) that the Review will lead to a statement setting out future 
development of strategy, and specifying action to be taken.  We would 
suggest therefore that a key part of the review will need to be to 
highlight where further detailed consideration or research is needed, and 
how that might be done.

We note that in various respects there seems to be some discrepancy or 
change of emphasis between Alan Howarth's letter and the Invitation to 
Participate, which we have noted in the response (eg the issue of maritime 
archaeology and the need to consider implications for the 2002-2004 
CSR).  To some extent this is reflected in how we have presented our 
comments (largely based on section 2 of the Invitation to Participate).

As regards the structure of the Review, there appear to be four ways that 
the issues have been grouped so far:  Alan Howarth's letter and its Annex, 
the list of issues that Review must address, the over-arching themes, and 
the remits of the Working Groups.  It is rather difficult to see a clear 
direction for the Review from this.  The distinction between issues and 
overarching themes is potentially helpful in principle, and we do not have 
any particular suggestions for whether the cake might be divided in a 
different way (any division will throw up problems).  But given the short 
time-scale, there might be merit, for purely practical reasons, if the ways 
the findings are likely to need to be presented (perhaps anticipating the 
way that new policy might itself be structured?) was more clearly reflected 
in the process of the Review.  Perhaps that is the intention, but if so it 
might be helpful for it to be made clearer in the guidance given to the 
Working groups.  All this will doubtless depend on how the Steering Group 
see the process working - perhaps it is a point for the first "steer"!

Yours sincerely,

George Lambrick
Director


The Council for British Archaeology

GOVERNMENT REVIEW OF POLICIES RELATING TO THE HISTORIC ENVIRONMENT
INITIAL CONSULTATION

THE CBA

The CBA, which has a membership of c.5500 individuals and 500 
organisations, is the principal UK-wide non-government organisation that 
promotes knowledge, appreciation and care of the historic environment for 
present and future generations.  This response represents our initial view 
of the issues to be addressed and we look forward to making further input 
to the Review as it progresses, and to assist in wider consultation.

THE NEED FOR THE REVIEW

The CBA very much welcomes the Government's commitment endorsing the 
principles of PPG15 and PPG16 as the basis for developing policy towards 
the historic environment.  These documents contain fundamental principles 
concerning
* the all-pervasiveness of the historic environment
* the need for a mixture of regulation and policy to cover such a wide remit
* the vital importance of having adequate information for informed 
decision-making
* the recognition that conservation is about achieving a sustainable 
balance of preservation and change.

However, not all of these, or other aspects of the two PPGs are put into 
practice as effectively as they might be, or receive the recognition or 
weight they deserve in terms of implementation.  We also believe that these 
two essential pieces of planning guidance should be seen within a more 
over-arching policy.  We suggest that the Government's document on 
sustainable development for the UK, A Better Quality of Life provides a 
framework of wider principles relating to public interest and participation 
to which policies for the historic environment could make a much greater 
contribution than has yet been recognised.

We are concerned that various initiatives to streamline and modernise 
regulation are in danger of weakening long-term conservation.  The historic 
environment should not be seen as a barrier to progress and change.  Its 
conservation should be seen as the means to shape change in ways that 
retain for the long-term an attractive, distinctive, cherished and valued 
environment in which people live and work or visit.

We therefore very much welcome the Review, and applaud the view that it 
should be visionary in character.  In particular we urge that its remit should:
* Review immediate needs and initiatives within a genuinely long-term view 
(consonant with its subject matter)
* Avoid having too narrow a scope in terms of geography, subject matter or 
the specific remits of the two Government departments to which it reports
* Be prepared to grasp important medium- to long-term issues for 
legislation, policy development and definition of government 
responsibilities, even though parliamentary time may currently be very limited.

The Review represents an opportunity to promote well-thought out 
modernisation of policy towards the historic environment in ways capable of 
enriching and reinvigorating fundamental values of long-term conservation 
of the fabric of the historic environment and sustainable access to it.  We 
believe that a core goal should be to show how policy in this area can make 
a major contribution to wider goals of quality of life and sustainable 
change.

SCOPE OF THE REVIEW

Geographical Scope

The Department's commissioning letter to English Heritage, and the 
Invitation to Participate appear to indicate that the Review only applies 
to England.  If so, this is regrettable given that several issues that need 
to be addressed are inevitably UK-wide.
* DCMS has a UK-wide remit for various matters relating to underwater 
archaeology, World Heritage Sites and the National Heritage Memorial Fund.
* MLAC, with responsibilities for museum collections and archives also has 
a UK-wide remit
* A significant proportion of legislation and policy that applies to 
England is UK-wide, or has closely parallel and equivalent regulations/ 
policy guidance in Scotland, Wales or Northern Ireland

We also note the July 1999 concordat between DCMS and the Scottish 
Parliament, which states:  'The Secretary of State and the Scottish 
Ministers accordingly undertake to ... seek to involve each other at the 
earliest stages of policy formation on all topics where there is a 
reasonable expectation that a policy initiative might be extended to cover, 
or might affect, the other's responsibilities... to ensure that both 
parties are kept abreast of developments in policy, practice and 
legislation, including discussion with third parties, in areas where there 
is, or could be, an interface.'

We recommend that the Review should
* Cover issues that remain UK-wide responsibilities
* Involve consultation about general issues, responsibilities and 
legislation with relevant non-English statutory bodies and any voluntary 
bodies not represented by a UK-wide organisation
* Take into account differences in legislation, policy and practice in 
Scotland, Wales or Northern Ireland that provide valuable insights for 
English and UK policy
* Similarly, take account of international practice where relevant.

Policy Time-scales

We note that the Invitation to Participate (section 3.0 a and b) envisages 
two main timescales, a 25 year vision, and 10 year Agenda for Action.  We 
note that Alan Howarth's letter specifically (para 6b) refers to the 
Comprehensive Spending Review for 2002-2004, and the need to consider 
resource implication.  We would therefore suggest that a 5-year timescale 
for new initiatives - especially with respect to areas of interaction with 
other departments' responsibilities - should also be a definite output of 
the Review.

More generally, we believe that the Review needs to recognise that 
conservation of the historic environment is for future generations - 
time-scales that are relevant stretch far beyond 25 years into the 
unforeseeable future.  In the light of this, policy needs to be 
precautionary to allow for unforeseen development of approaches in three ways:
* Recognising the fundamental primacy of safeguarding historic fabric and 
integrity - albeit inevitably subject to varying degrees of survival, 
change and adaptation, but within very long perspectives of past change, 
not only short term needs
* Allowing for continuation of the trend towards greater attention and new 
approaches being applied to conservation in ways that are as yet 
unrecognised - just as we are already working with concepts hardly 
recognised 25 years ago
* Recognising that views on what constitutes the historic environment 
change and that new elements are usually recognised and championed first by 
specialist enthusiasts, commonly in the voluntary sector, not government.

A 25-YEAR VISION

We offer the following idea for the 25-year vision:

If the historic environment is all-pervasive, then it must become 
all-pervasive in attitudes and approaches to environmental issues among 
organisations in both the public and private sectors and in heightened 
public awareness.

This requires a substantial boost to education, engagement and 
participation of young people and adults throughout society.

It requires more support for and involvement and partnership with the 
voluntary sector at national regional and local level.

It requires consolidation and clarification of legislation and 
policy;  positive action in a wide range of government and public bodies 
through better administration, more specialist staff, budgets, better 
training, revision of procedures;  and positive action to make care of the 
historic environment a green issue for business, subject to environmental 
auditing.
It requires much better Government inter-departmental working practices.

HOLISTIC DEFINITION

The historic environment is how Society collectively, consciously or 
intuitively, values aspects of the environment that reflect the past and 
contribute to people's quality of life.
* "The historic environment" is not separate from the environment as a whole
* It is the abundant, all-pervasive record of changes in people's long-term 
social, spiritual and economic relationships and their interaction with all 
parts of the environment

A genuinely holistic definition has significant implications:
* If it is all-pervasive, it affects all branches of Government
* If it is how the environment reflects long-term processes of change that 
continue into future, it has a vital role in helping to manage future change
* If the historic environment is defined as part of people's collective 
recognition of their cultural heritage, it has implications for how policy 
in England relates to the UK-wide and international context of people's 
interests.

CONDITION OF THE HISTORIC ENVIRONMENT AND SUSTAINABILITY INDICATORS

The results of the MARS study showed that more attention particularly needs 
to be given to the management of archaeological sites monuments and 
structures - especially in the agricultural sector.
* Insufficient resources are being put into the management of historic 
sites and features.  The greatest impact could be achieved by firmly 
incorporating this into the realignment of agricultural policy and support 
mechanisms.
* The lack of budgets for the implementation of World Heritage Site 
Management Plans needs to be addressed.
* Various initiatives (eg work holidays, conservation volunteering, 
adopt-a-monument schemes) suggest possible means of expanding existing 
means of fostering voluntary and public participation in active conservation.

Despite the Buildings and Monuments at Risk Survey audits, there remains 
much to be done before it could be claimed that the condition of the 
historic environment is being adequately monitored.

The Government's provisional idea for sustainability indicators (the number 
of Grade I and II* buildings at risk) is woefully inadequate for the 
historic environment as a whole.
* What indicators might be used to monitor changing character of the 
historic environment as a whole, and historic distinctiveness of places in 
particular?
* Are there specific indicators that would reflect more general effects on 
the historic environment?
* What indicators would reflect how people's attitude to conservation may 
alter - whether the way that people wish to alter the historic environment 
becomes more sensitive to retaining its fabric and character, improving its 
maintenance or enhancing its setting?
* What would be an equivalent set of indicators to those being developed 
for bio-diversity?

Cost-effective methods need to be found for monitoring condition and 
developing sustainability indicators.
* Technical approaches might include more use of air photography, including 
integrated multi-disciplinary environmental monitoring as practiced in 
Northern Ireland is a possibility that warrants investigation.
* Partnerships with the voluntary sector are particularly worth 
considering, since a common feature of such initiatives would be to fulfil 
wider policy aims of encouraging public involvement with environmental 
sustainability.
** The CBA is carrying out a review funded by DCMS of the potential for 
using its national database of all listed building applications involving 
demolitions as a means of monitoring thematic and geographical trends, 
potentially capturing both attitudes to conservation and the outcomes of 
regulation.
** There are a number of volunteer based schemes (eg in Leicestershire, and 
Scotland) that provide possible models that might be developed into a 
national Monuments Watch scheme developing a standard, commonly accepted 
methodology and data reporting standard for use by trained volunteers.

THE ROLE OF THE HISTORIC ENVIRONMENT IN MODERN AND FUTURE CULTURE

People's awareness of the past, and their appreciation and sense of care 
for the historic character of the places where they live and work or which 
they visit, underpin their sense of cultural identity, pride of place and 
celebration of the diversity of the cultural heritage.  They thereby make 
major contributions to people's quality of life.
* The effective promotion of knowledge and understanding, conservation and 
intellectual and physical access to the historic environment is founded 
upon active communication and participation amongst all sectors of society.
* If the historic environment is neglected then local regional and national 
identities and distinctiveness suffer, and people's quality of life becomes 
more impoverished
* Britain has always been a multicultural society with problems of social 
or economic disadvantage and the historic environment potentially offers a 
greater depth of perspective and new insights to help people understand 
such issues
* The multi-faceted skills needed for archaeological investigation and 
study can offer worthwhile avenues for individuals of widely differing 
backgrounds to discover their own aptitudes and interests.
* In these ways the historic environment can provide a vehicle for wider 
social and cultural enrichment and rehabilitation.

RELATIONSHIP TO NATURE CONSERVATION

There are no purely natural habitats uninfluenced and unexploited by past 
generations in Britain, so ecological habitats are intimately bound up with 
the historic character of the environment and the evidence of people's past 
interaction with the environment.  This relationship is complex, and not 
always in harmony.
* Holocene geology (peat deposits, colluvium alluvium) contain vital 
evidence of long-term human impact on the environment, even though they may 
contain no artefacts or archaeological deposits
* Ecological habitats reflecting traditional land management (woods, ponds 
hedges, walls, pastures, hay meadows, commons, heaths etc.) make a major 
contribution to the historic character of the countryside
* Archaeological and historical evidence often provides explanations of the 
origins and management of wildlife habitats that are relevant to 
maintenance of biodiversity today
* Undisturbed ecological habitats often contain well-preserved archaeology
* Well preserved archaeological sites and buildings often have rich 
ecological habitats
* Valued ecological habitats can develop on destroyed archaeological sites 
and demolished buildings; and recent buildings and monuments now regarded 
as part of the historic environment may be developments that destroyed 
ecological habitats
* Creation, enhancement or protection of ecological habitats can destroy 
archaeology
* Archaeological investigations, site maintenance and building repairs can 
destroy and disturb wildlife habitats and species
* The huge literature now available through environmental archaeology could 
be used much more to inform issues of long-term changes in biodiversity

This complexity of overlapping interests in the same basic environmental 
resources demands further integration.
* There is a need to clarify responsibility and develop a policy for 
protection of holocene palaeo-environmental deposits
* There is a need for more cross-fertilisation on ideas for sustainability 
and diversity indicators.
* The Review should address the need for more integrated environmental 
management systems in public and other organisations responsible for 
managing large areas, including the relative availability of internal 
professional ecological and archaeological advice within key Government 
agencies, public bodies and government-subsidised companies.

INSTRUMENTS FOR PROTECTION AND ENHANCEMENT

A holistic approach to the historic environment implies recognition that 
much of present policy stems from legislation that originates in 19th 
century concepts of preservation.  The still dominant site-protection based 
legislation should come to be seen much more as just one important strand 
of a more holistic suite of mechanisms for promoting conservation, 
education and public involvement with the historic environment.  But the 
all-pervasive approach currently suffers serious shortcomings in practice.
* There is a need to develop much stronger links between historic character 
assessment to local perceptions and interest, eg at parish level (many 
parishes representing long-term social and land-use entities, as well as 
being the lowest tire of government)
* Given that "historic character" is not static, but the product of ongoing 
change, how might it inform what kind of future change might be suitable 
for an area?
* The aspirations of PPG15 regarding the non-designatory approach to the 
all-pervasive historic character of the environment, are not matched by 
practical application of this policy in terms of assessment and policy 
development for sustainable change in regional, structure and local plans, 
or development control.  The concept appears to carry little weight in 
planning inquiries.
* As part of developing all-pervasive approaches, the review must address 
how all government departments and public agencies, not just DCMS and DETR, 
will engage with policies for the historic environment.

A medium to long term vision could be for all-embracing legislation of the 
type found in other countries, covering the whole historic environment 
(countryside and urban character, areas of particular interest, 
palaeo-environmental deposits, sites, monuments, buildings, places 
associated with traditional practices and events, portable 
antiquities).  In this context it is relevant to ask:
* How far does current provision fall short of international standards (eg 
in respect of licensing excavations and trade in portable antiquities)?
* How far does the piecemeal accumulation legislation and policy that we 
currently use inhibit clarity and coherence in the administration of policy?
* Is legislation beginning to lag so far behind current thinking that it 
does not adequately support modern approaches to the historic environment
* Can some legislative change be incorporated into forthcoming rural and 
urban development and agricultural legislation?

Apart from overhauling legislation in the medium to long term, there is a 
short-term need to rationalise and clarify the multitude of sometimes 
overlapping provisions and policies that currently apply, and linking this 
to improved public involvement.
* The Review needs to examine how to bridge divisions that stem from 
separate strands of legislation where they still tend to inhibit holistic 
thinking and practice, and clear, efficient communication of overall policy 
to the public.
* How could policy promote more effective public participation in the 
processes of characterisation and development plan preparation?
* Consideration should be given to whether there might be advantages in 
bringing PPG 15 and PPG 16 together into one set of guidance.
* The application of PPG15 and PPG16 rely on the maintenance of adequate 
historic environment records (SMRs Lists etc) and specialist advisers 
within local government.  If policy is to rely on these services, the 
provision of such services needs to be statutory.
* There is a need to rationalise legislation and its administration 
regarding maritime archaeology in territorial waters and trade in portable 
antiquities, both of which involve international conventions subject to 
other policy reviews, but need to be seen within this broader framework.
* The major changes in policy towards agriculture and the rural economy 
must include proper coverage of archaeological issues in new 
agri-environmental arrangements and cross-compliance;  replacement of the 
agricultural class-consent provisions for Scheduled Ancient Monuments with 
a conservation management-based approach;  improved protection for historic 
boundaries and other features in the countryside.

Simplifying or streamlining planning and statutory controls should not be a 
matter of reducing scrutiny or weakening controls.  The issues should be 
considered within the context of the whole planning process.  The following 
offer some possible ways forward:
* Greater specialist input is made to early stages of national policy and 
planning formulation (including better mechanisms for early and active 
liaison on policy development with independent representative professional 
and voluntary bodies)
* Provision of better, fuller advice on historic environment issues as part 
of process of allocating land for development (eg conservation plans in 
development briefs)
* More conservation input into design briefs
* Development of better approaches to historic environment appraisal of 
carrying capacity at national, regional, local and site-based level 
(addressing different aspects of broad historic character down to detailed 
site conservation issues)
* Building limits of acceptable change models into assessments of historic 
character
* Better training for caseworkers advising planning authorities
* Much stronger clearer and more helpful guidance for developers and 
others, including clearer standards of information needed for decision-making
* Better mechanisms for early and active casework liaison between relevant 
authorities and developers (and others proposing landuse change)
* Adequate resources are available to national and local authorities 
responsible for regulation to respond promptly and work efficiently 
together, especially in complex cases
* Improving mechanisms for handling cases involving multiple strands of 
historic environment legislation and policy.

The Review should address issues of influencing the sustainability of 
private sector developers and other businesses that have an impact on the 
historic environment.
* What is the potential role of fiscal instruments (eg "green taxes") in 
relation to the historic environment? - There is clear consensus on the 
desirability of equalisation of VAT for buildings, but the case for (and 
implications of) green taxes in relation to other issues (eg minerals and 
peat, nitrates, etc.) is in most cases not as obvious, and indeed could be 
counter-productive.
* The Review could also consider how responsible approaches to the historic 
environment might be more widely instilled in private sector businesses (eg 
through Government procurement requirements).

HERITAGE AND ECONOMIC GROWTH

The Review should seek to identify "virtuous circles" of economic and 
social benefit in regeneration and tourism in both rural and urban areas, 
and how these might be promoted.

As a general principle we consider that a largely seamless approach should 
be adopted to the greenfield/ brownfield debate, so that real pros and cons 
of alternative strategies can be weighed up in the allocation of land for 
different uses in national, regional and local planning.  While in general 
we do not disagree with the general thrust of policy, there has tended to 
be a failure by Government to recognise various implications for the 
historic environment:
* the significant industrial or other archaeological conservation value of 
many brownfield sites, and their interest for urban wildlife.
* the complications of brownfield sites where significant industrial or 
other archaeology or historic buildings are situated in contaminated areas
* the relatively degraded character of some "greenfield" areas that have 
been under very intensive agriculture and peripheral development.

The Review should seek to identify how proper consideration of the historic 
environment can be integrated more fully into the implementation of the 
strategic allocation of brownfield and greenfield land for housing and 
other regeneration.

Work by both the voluntary sector (Catalytic Conversion, SAVE, 1998) and 
English Heritage (The Heritage Dividend 1999) have shown how the historic 
environment can act as a catalyst for several different aspects of public 
policy to be brought together within a very positive and high quality 
regeneration that has lasting value and considerable economic and social 
benefit.  The schemes already developed have effectively piloted the 
approach and indicate the value to be gained from much larger scale support 
from public funds as a major plank of the Government's regeneration 
initiative.

A similar approach is now needed for the rural environment as policy moves 
away from agricultural subsidy towards broader, more environmentally 
sensitive support for rural economies.  We would suggest that the Review 
examines:
* Whether more flexible and sensitive planning policies coupled with 
realigned agricultural support would allow more sensitive re-use of farm 
buildings for small scale business rather than domestic use, potentially 
reducing current pressure forcing unsympathetic conversion by allowing very 
small scale new build development
* What scope there is for developing a diversified market for the products 
and services of activities based on traditional skills, crafts and 
activities capable of building successful rural regeneration which is both 
environmentally sustainable and capable of reinforcing to local character, 
identity and diversity.

TOURISM

Tourism is a key sector for both the urban and rural economy, within which 
the assets of the historic environment play a lead role.  Tourism is the 
UK's largest employer and earns 12.8 billion.  Many if not most visitors 
both from abroad and from within the UK come to enjoy our scenery, historic 
places and rich cultural history - the real splendour of which is its 
diversity, quality, and ubiquity.  We suggest that the Review should 
consider interlinked issues of:
* The importance of ensuring effective conservation of the historic 
character of the environment in general, and its regional diversity in 
particular, as  means of enhancing overall visitor experience
* Developing a clearer strategy for assessing the capacity of places (from 
wide areas down to individual sites) to absorb tourism
* Avoiding (and where appropriate reduce) the 'honey pot' effect of some 
key attractions where visitor pressure can be significantly detrimental
* Dispersing tourism more effectively to spread benefits more widely, 
considering what opportunities historic places may offer in relatively 
economically deprived areas.

An area of tourism of growing concern is the possible impact of the growing 
industry of foreign (mainly UK-USA) metal detecting holidays, which appear 
to be resulting in significant loss of unrecorded antiquities.  This can be 
contrasted with the potential positive benefits of encouraging more public 
participation in conservation activity through work holidays of the type 
run by National Trust and BTCV.

A common requirement of all the issues of economic growth is the need to 
develop much more comprehensive methods of assessing capacity for change in 
relation to key historic characteristics of areas.

INSTITUTIONAL STRUCTURES AT NATIONAL REGIONAL AND LOCAL LEVEL

It is clear that there should be no further significant re-organisation of 
English Heritage for some time, but there is a serious issue of whether EH 
is in the right department of Government:
* Far more policy initiatives and government consultations relevant to the 
historic environment emanate from DETR than from other departments, 
including DCMS, and they depressingly frequently fail to cover the historic 
environment issues properly
* An objective review of EH's principal areas of activity and statutory 
functions would almost certainly indicate that it would sit most naturally 
with DETR.
* This view is likely to be enhanced as closer working relationships 
develop between national and local government within the regional framework
* A holistic view of the historic environment would be more likely to 
become embedded into government under a DETR umbrella fostering more 
effective collaboration between all relevant environment and planning 
agencies.

There remains significant concern at dwindling archaeological services at 
local level.
* It is likely that many of the recommendations of the Review will envisage 
enhanced national-local partnerships for the implementation of policy, with 
consequential implications for local government resources.
* There is a need for Government to define a minimum level and range of 
historic environment services that local government is expected to provide, 
and to make these statutory, so that they are less prone to being cut.
* The possibilities of providing some services from regional level might be 
considered - at present this would take them out of clear democratic 
accountability, and potentially would lose vital local contact, which if 
anything policy should be seeking to strengthen.

Many wider Government goals of participation and involvement could be 
achieved through stronger collaborative partnerships between statutory, 
academic and professional organisations and the voluntary sector, at 
national, regional and local level.
* Government policy should clearly recognise the strength of existing 
networks in this area and the value of nurturing and supporting them 
further as a means of achieving its wider objectives of enhancing quality 
of life.
* Policy towards the voluntary sector should seek to support existing good 
work where it still has potential to fulfil and develop shared strategic 
objectives more effectively, as well as encouraging new initiatives.
* There is scope for developing such involvement to assist in research, 
conservation and education and access.

FRAMEWORK OF NEW RESEARCH, DATA COLLECTION AND EVALUATION TO GUIDE FUTURE 
ACTION

We believe that there is a wide range of issues concerning needs for 
research, data collection and evaluation.  Research is vital to 
understanding, and we cannot manage what we do not understand.  There is a 
more general need to reconnect the professional, academic and voluntary 
sectors in ensuring that research is effectively executed and communicated.

While we would not expect this Review to cover the work of the Archaeology 
and Humanities Research Board or other Research Councils, it is worth 
noting that there are important areas of common interest, given the work 
supported by English Heritage and the contribution that developer-funded 
archaeology makes towards research.
* In terms of academic funding, there is an emerging gap in provision for 
large- and medium-scale projects (whether in Britain or elsewhere)
* English Heritage should continue to support relatively pure academic 
research related to the historic environment in England.
* There is a particular need for works of synthesis to pull together the 
results of PPG16-related investigations funded by developers:  this might 
be a subject for hypothecated expenditure of revenues from green taxes (eg 
if the suggested minerals tax were introduced), or EH funding if not viable 
commercially.
* The PPG15 issues are much more whether sufficient record is being made 
listed buildings undergoing alterations that significantly change their 
fabric;  there is currently no means of knowing fully what PPG15 related 
recording has been done nationally.

An area of research that deserves continued support, are thematic studies 
covering broad topics, geographical areas or classes of site or 
building.  This type of work can:
* usefully link enhanced knowledge of the past to conservation policy
* achieve recognition for threatened types of building, structure or field 
monument that in future will be valued as records of particular aspects of 
the country's past
* feed into policies for diversification of tourism.

As regards research needed to support policy development more generally, 
there are several areas that we have mentioned above which require further 
research for policy to be developed adequately - for example:
* Developing sustainability indicators
* Relationship to and coverage of the historic environment in Local Agenda 
21 straegies
* Limits of acceptable change models
* Carrying capacity appraisal at national, regional, local and site-based level
* Rural regeneration models and pilot studies
* Green taxes and other fiscal measures in relation to the historic environment
* Development of a generally supported approach to issues of setting
* Linking characterisation approaches to community perceptions for 
different types and scale of characterisation
* Development of standard methodologies for archaeological condition 
assessment
* Approaches to archaeological risk assessment

There is a continuing need for technical research related to conservation 
policy issues likely to arise directly from other government policy 
initiatives.  A principle should be established that such research should 
be funded by the relevant government department/ agencies responsible for 
the activity representing the source of impact
* a currently active example is the long over-due MAFF-funded study of 
archaeology in arable landscapes
* an urgently needed example would be a DETR or EA supported study to 
investigate ways of reducing the impact of remediation of contaminated 
ground, within the context of increasing re-development of brownfield sites.

The role and potential of the voluntary sector in undertaking or assisting 
with research needs to be addressed - there are numerous good examples 
within each of the areas outlined above, and there is a wide feeling that 
there is more that could usefully be achieved through partnerships that 
would also achieve many wider goals of participation and involvement.

INTELLECTUAL AND PHYSICAL ACCESS:  FORMAL AND INFORMAL EDUCATION

More public involvement and engagement through education and access is 
fundamental to a healthy, all-pervasive recognition of heritage issues.

Alan Howarth's letter asks what new initiatives might be developed to 
encourage young people to take more interest in the historic 
environment.  At national level, English Heritage and the CBA together have 
between them maintained a sustained, and increasingly effective effort over 
many years to promote archaeology (ie the historic environment generally) 
through formal and informal education.  This has been on the basis of very 
limited resources, and until recently, often in the face of very limited 
interest from Government.  The specific recognition of this as an issue for 
the Review is therefore very welcome.
* Rather than developing new initiatives, a first priority should be to 
consider what might be achieved by building on existing long-term national 
initiatives such as the CBA's Young Archaeologists' Club and EH's 
educational activities, that continue to be under-resourced, and therefore 
under-developed.
* At local level more could be done to develop educational activities by 
providing more support encouragement and incentives to locally based 
professional and voluntary archaeological organisations, historic building 
groups, community and environmental trusts, museums and others.
* More needs to be done to develop initiatives that cover the whole 
historic environment, eg through looking at urban or rural historic 
character and how it is reflected in styles, spaces, relationships and 
details.

In formal education the Review should consider the need for
* A review of how the National Curriculum integrates the historic 
environment and its contribution to sustainability into teaching a wider 
range of subjects, including citizenship
* More input to initial training and in-service training for teachers
* Continued development of educational resources for teachers
* Development of topics to address issues of social inclusion and 
multiculturalism, eg comparing evidence of the multi-cultural character of 
Britain at various times in the past (back to prehistory) with similar 
kinds of evidence about today's multi-cultural society
* Support for schools to ensure that children have more first-hand contact 
with the historic environment
* Continued development of structured vocational and professional training.

In informal education and involvement there remains scope for developing 
fuller partnerships with the voluntary sector, for example
* Projects to provide opportunities for young people over 14 and adults to 
gain practical experience in archaeology with professional support
* Archaeological projects to promote greater involvement and employment 
opportunities in archaeology for disadvantaged groups

More generally there is a need for more support to initiatives promoting 
initial training and continuous professional development across a very wide 
range of skills connected with researching, conserving and appreciating the 
historic environment, both among professionals and the voluntary sector.

A fundamental issue for the management of places for people to visit is to 
ensure that carrying capacity is properly considered, especially with 
regard to the survival of historic fabric, but also in terms of visitor 
enjoyment.  Support is likely to need to be given to partnerships with the 
voluntary sector in the management of some sites.  A more strategic view of 
physical accessibility is needed

INFORMATION SYSTEMS, RECORDS AND ARCHIVES, PUBLICATION

The range and inter-connectivity of information systems for the historic 
environment across the British Isles has recently been reviewed by the CBA 
for the Historic Environment Information Resources Network (forthcoming 
report, Mapping Information Resources).  This should be the starting point 
for developing a clear strategy for providing enhanced access and 
co-ordination amongst the plethora of systems that now exist.  This will 
need to be based on partnerships between the various bodies already 
involved, supported by Government.  Key recommendations are:
* Users' needs should drive future development of information services 
serving the historic environment
* Information services should be developed co-operatively working towards 
mutual accessibility and inter-operability recognising organisations' 
identified roles and shared goals
* There should be a central internet register of information services 
supported by providers
* A technical advisory facility should be established to promote data 
standards and structures that assist inter-operability, metadata standards, 
high quality dissemination of information
* There should be strategic discussion groups to ensure effective liaison 
on common issues, roles and relationships.

With regard to the storage and access to archaeological archives, recent 
CBA research in relation to publication user needs in archaeology shows 
that the primary archive remains a critical factor for any reassessment of 
results.  The curtailment of local authority provision in many parts of the 
country, coupled with the burgeoning amount of archaeological material 
being recovered through PPG16-related work raises serious issues for the 
long-term curation of this material.  This needs to be addressed through a 
co-ordinated strategic approach.  More generally there is a need to ensure 
that safeguarding primary archives and archaeological material supporting 
understanding of the historic environment remains a high strategic priority 
under MLAC.

Publication of archaeological reports should be geared to user needs, as 
recently reviewed in the CBA's study, Publication User Needs Survey 
(forthcoming).  Particular consideration needs to be given to raising 
public awareness and public access to PPG16-related archaeological 
investigations, by including in conditions a requirement to do more to 
communicate outcomes to the local community in ways appropriate to the 
circumstances (eg through formal or informal education, open days, 
exhibitions or non-technical reports deposited in local libraries).  We 
believe this to be part of fulfilling the public interest justification for 
such work.


---------------------------------------------------
Dr Mike Heyworth    Council for British Archaeology
Bowes Morrell House, 111 Walmgate, York YO1 9WA, UK
Tel: +44 1904 671417           Fax: +44 1904 671384
            http://www.britarch.ac.uk
---------------------------------------------------



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