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HERFORUM  April 2008

HERFORUM April 2008

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Subject:

Re: Heritage Protection - the elephant in the room

From:

David Evans <[log in to unmask]>

Reply-To:

Issues related to Historic Environment Records <[log in to unmask]>

Date:

Fri, 18 Apr 2008 11:01:04 +0100

Content-Type:

text/plain

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Parts/Attachments

text/plain (359 lines)

Eminently sensible
Quick note(s), under 2 I don't know how a HER can call itself a HER if
it doesn't include Parks gardens Local Lists etc.
What new role?

David Evans
Historic Environment Record Officer
Planning and Environment
South Gloucestershire Council
Civic Centre 
High Street
Kingswood
BS15 9TR
Phone: 01454 863649
fax:       01454 865173

-----Original Message-----
From: Issues related to Historic Environment Records
[mailto:[log in to unmask]] On Behalf Of Mike Shaw
Sent: 18 April 2008 10:44
To: [log in to unmask]
Subject: FW: Heritage Protection - the elephant in the room

I am forwarding some comments from Sue Whitehouse, one of the few
Conservation Officers actually willing to participate in the debate over
statutory HERs.
 
Mike

________________________________

From: Sue Whitehouse
Sent: Fri 18/04/2008 09:50
To: Mike Shaw
Cc: [log in to unmask]
Subject: RE: Heritage Protection - the elephant in the room


Mike
 
Don't know if you are feeding any of my comments into the debate but
here are my observations on the latest offering
 
2. I don't think it is woolly really.The cost benefit analysis
undertaken last year into the provision of statutory HERs came to the
conclusion that the status quo was the best option rather than imposing
a different regime - so the Bill is in effect saying business as usual
chaps but where new unitaries are being created and an old county is
being split there is provision for joint working. This part of the Bill
could be clarified by direct reference to Unitary authorities. 
 
3. I am surprised that including conservation areas (of any kind),
registered parks or Local List buildings should be considered an issue
for HERs. I though this should be standard practice anyway. I note that
CAs are excluded from the list of things that should be in a HER but
hope this was just an oversight and will be added later. The concept of
the archaeological CA is new although it has always be possible to
include important archaeological sites in CAs and archaeology should be
an issue addressed in any appraisal. I suspect this is another area
where EH will need to review their guidance. The issue of buildings and
curtlages is something the archaeologists will need to talk to the
conservation officers about. On our planning GIS we have buildings,
curtilages and a buffer zone around each listed structure. This is an
issue the FISH folk should be taking up especially as we will need to
ensure consistency between planning GIS systems and HERs.
 
4. Many local authorities do have established criteria for local lists
if they have one (this isn't new as it is already established practice
although not statutory)) - the challenge for many will be establishing
criteria for archaeological sites of special local interest and the need
for districts without archaeologists to liaise with archaeologists at
county level to make this happen. Lots of bridge building will be
required in some areas where relationships are poor. Also note that all
of this information will HAVE TO BE on planning GIS systems too so there
will be a need for close liaison between HERs and those who manage
corporate GIS systems.
 
5. Archaeologists should note that planning information systems already
have to deal with keeping records of LBC and planning permissions which
go back to the 1940s in some cases depending on the efficiency of the
systems each authority operates. The issue in not that HERs need to
contain histories of consents - they need to be able to network with
local authority planning managment systems but the HER will be the
repository for more detailed information derived from any interventions.
Dare I say - the HER should just be one of may databases linked to the
corporate GIS of each local authority in a given area.
 
6. This is no surprise surely!
 
7. The resource implications are considerable but everyone has been
avoiding facing up to this because if anyone really worked out how much
it will really cost then statutory status would never have made it into
the Bill
 
Sue
 

________________________________

From: Mike Shaw 
Sent: 17 April 2008 15:35
To: Sue Whitehouse
Subject: FW: Heritage Protection - the elephant in the room


 

________________________________

From: Issues related to Historic Environment Records on behalf of
Robinson Ben
Sent: Thu 17/04/2008 15:05
To: [log in to unmask]
Subject: Re: Heritage Protection - the elephant in the room



Hello there Victoria,

You may find that folk are still digesting it all! There was a very
useful ALGAO England meeting in London yesterday, at which some of the
relevant clauses in the draft Bill were discussed. Just some quick
lunchtime HER thoughts from me, for what they are worth:

 

1. Guidance on statutory HERs will be published in early May. This will
no doubt describe the provisions that HERs will need to have in order to
comply with statutory requirements. Thereafter, it seems that the new
Act will be supported by all manner of supplementary guidance on various
aspects (i.e. designation criteria, management agreements, etc.). I
expect it to be like the 1979 Act in this respect - strongly supported
(shored up?) by at least 30 years worth of evolving guidance! 

 

2. There is some apparent wooliness in the Draft Bill regarding where
HERs should sit. County Councils, national parks, and single tier
districts, city boroughs, etc. (i.e. generally equates to 'Unitary' and
higher tier authorities) will be required to maintain HER, second tier
authorities will not. Although there is scope for local arrangements,
joint agreements, etc. Again, the May guidance may help to sort this
out. 

 

3. The official Register of Heritage Assets will be compiled and
maintained by EH, but then provided to LPAs and HERs, which then have a
responsibility to disseminate information when asked. This implies a
greater need for consistency, accuracy and up-to-dateness, in sharing
information between national and local authorities. This implies that
HER structures must be capable of supporting the crucial aspects of the
data structure of the 'Register'. They will need to support
'archaeological conservation areas' (a hitherto unmentioned designation)
and sites of 'special local interest', along with the parks, gardens,
battlefields, open spaces, buildings and curtilages, etc. I think
spatial standards are going to be really crucial here. 

 

4.	LAs will have to come up with robust criteria for defining sites
of 'special local interest'. Intended designations have to be notified
to landowners, along with amendments such as changes in extent etc.
Owners can appeal. We will not be able to just put something on the HER
and call it 'special'. I think it is only a matter of time before the
various classes of 'asset' 'Registered', 'Special Local Interest',
'Registerable but not Registered or of special local interest' (i.e.
most HER stuff), are used to inform/dictate planning and conservation
responses. I can envisage arguments about whether sites that have not
been designated should be subject to pre-determination evaluation, for
example. The pressure will be on to get sites registered in order to
protect them from undesirable actions. 

 

5.	With regard to management of information about 'assets'; given
that class consents can be issued (not by LAs, but by EH), specific
consents issued (by LAs and EH), and individually customised management
agreements can be created for each asset or group of assets (between LAs
and owners/operators), and people can obtain 5 year certificates of
immunity from Registration, I think that the will be a great need to
ensure that the histories of consents and consultations are recorded
accurately and comprehensive along with the more physical aspects of the
asset information. Listed Buildings, for example, very often have much
more complex histories of consent, alteration, etc. (i.e. big files in
big filing cabinets) than Scheduled Monuments. These are crucial to
casework. Some Conservation Officers have expressed concern that HERs
will not cope well with this requirement.   

 

6.	Those HERs who are responsible for serving several planning
authorities will have to make sure that the HER info is all available
when needed - probably along with its accompanying specialist advice for
those disciplines not represented in the recipient LPAs. The Bill places
some responsibility on LPAs who do not maintain HERs to use HER
information (and I suppose this will be mirrored in forthcoming planning
guidance eventually), but the mechanisms for this, or the relative
burden of responsibility, are not yet defined. Nevertheless, I think
that that the terms of the Bill will be helpful in securing service
levels agreements, or other financial support.   

 

7.	My overall impression is that the long overdue and welcome fully
statutory status for HERs brings with it considerable obligations to
tighten up recording practice, standards and service delivery in certain
areas. Some (?!) of the resource implications have been identified in
the regulatory Impact Statement. 

 

Cheers,

Ben Robinson

 

________________________________

From: Issues related to Historic Environment Records
[mailto:[log in to unmask]] On Behalf Of Bryant, Victoria (ACS,
Archaeology Unit)
Sent: 17 April 2008 13:30
To: [log in to unmask]
Subject: Heritage Protection - the elephant in the room

 

Dear All

 

I have had no response  to my request for thoughts/concerns etc on the
practical implications of the Bill on our jobs (see below in red). It
would seem to me that whilst the Bill is "a good thing" there are
implications for HERs which we will have to start thinking about now
because it take years to set up systems and guidelines. The Bill will be
modified but I get no impression that its going to be rewritten or
junked - am I mistaken?

 

Some issues for us could be  

Will Exegisis be commissioned to develop new modules to deal with our
new roles? 

What about those of us with different software - how do we need to
modify it? 

For those of us in County HERs how can we develop stronger links with
Conservation officers in Districts? 

What kind of guidance/lead will English Heritage be providing?

Anyone got any ideas about how we decide what archaeological sites are
of  "special local interest" with everything that entails.

 

Victoria

 


"I know that most of our comments on the proposed legislation will be
fed through ALGAO but I would be very grateful to hear from any one who
has started the process of addressing the practical issues raised by the
Bill.  For instance what do you think about

necessary changes to software
new relationships with conservation officers including data transfer and
access
staffing implications of increased bureaucracy at least in the early
days"

 

 

 


Victoria
Victoria Bryant MA MIFA
Historic Environment Record Manager
Worcestershire Historic Environment and Archaeology Service

  

 
 
 
 
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