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A short advice note in response to the current messages regarding HERs and FEPs from Ken Smith at ALGAO.

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Colleagues

Please forgive this missive coming via Mel but I am not linked in to HER Forum.

I have been made aware of an amount of recent e-mail traffic regarding FEPs, sparked in part by the unfortunate developments in Northamptonshire.  I would like to make the following general points, and then some specifics to try and enable people to handle better the demands that providing responses to FEP enquiries are making.

General:

1.      Don’t panic!  No-one expected everything to run smoothly from the off.  There is a review period at the end of the first year at which all the issues will be visited, including those surrounding the provision of data to you, to enable you to make your response, and your ability to provide advice.  It is vital that we review our collective experiences of the first year and approach Defra/RDS in a corporate manner as ALGAO, and hopefully in partnership with EH, rather than try and make individual statements or gestures.  The strength of our arguments will lie in a corporate approach, rather than individual developments that will either weaken our case or allow the issues to be picked off individually.  We won’t get away with trying to provide SMR data alone because it is the advice that is needed, and for which payment is made.  Provision solely of HER data will mean that it doesn't’t go into the FEP.

2.      There is some research about to go ahead which will attempt to create automated extraction methods, and will look at refinements for pro forma layouts.

3.      We need to look at how many large holdings come in and try and plan accordingly - one in a year is perhaps manageable, large numbers are not.  However, it is not worth changing the way that all FEPs are dealt with if there is only a small number of large holdings overall.  If we are getting multiples, and can demonstrate that this is the case, then other arrangements will need to be made with Defra.

4.      This raises the issue of monitoring, which has not previously appeared on the radar.  It would be extremely useful to me, and those of us trying to represent your best interests, if you were able to log the number of your consultations, how long they take and how big they are.  If you could do half-year returns to Caroline Ingle ([log in to unmask] <mailto:[log in to unmask]>) this would help us make a case to Defra/RDS, as well as monitoring how things are developing across the year - whether there is an increase in consultations, whether there are peaks and troughs and so on.  It would be very useful if the data were available from the beginning of this January.  If they are not, then could people start monitoring from the end of next month?

5.      The payments of £75 and £150 were always only going to be a contribution towards the cost of responding to a FEP consultation.  They were never intended to be a full payment for such a consultation.  The important thing is that, for the first time, Defra is making a payment for archaeological advice, acknowledging that there is a cost.  We then need the information on numbers, time taken and size of holding, to make a case for increased payments.  Please remember also, it is up to you how you respond, insofar as the expectation has always been that the response would be a desk-based one (whatever the drawbacks might be).  If you make a site visit, then that is your choice.  The payment is for the advice, regardless of how it is generated.  Equally, of course, it is legitimate to ask for payment where there is nothing to be said archaeologically.  You have consulted your records and have given your advice.

Specific/practical points:

1.      Tell people who supply imperfect maps that the FEP will not be dealt with unless the map is legible and coherent.  The consultation window does not begin until the appropriate information has been provided.  Don’t chase up maps once you have asked for them.  It is their responsibility to provide appropriate data.

2.      Site visits (in addition to the above) - be pragmatic, they are not essential for HLS and are not within the scope or capacity of the majority of HERs, even if they have a HECA in place.  The FEP, from the HER point of view, has always been envisaged as a desk-top assessment - you can only provide the information you have and you will never have a complete dataset.

3.      If the area to be commented upon is full of archaeology and needs lots of different management recommendations etc., then indicate all of the parcels or main areas of archaeological interest and then recommend option PAH (a management plan).  You should explain that the archaeology is so complex it requires a management document of its own and that the FEP compiler should come back to you for guidance when the plan is done/about to be done.

4.      Try and make use of the Large Scale Archaeological feature code- HO4 - it is not necessary to itemise every small recorded unit within a management option area.  Indicate the main one/s then briefly mention in notes what you have done.

5.      When contacting Defence Estates or the National Trust, you are simply undertaking a notification process, you are not obliged to collate or include their information.  They can supply direct to Defra if you feel it is too time consuming to co-operate.  This has to be down to local circumstances, your relationship with those organisations and your ability to take on this work.  You are not obliged to do anything more than notify them.

6.      Make arrangements with cross-border colleagues. In line with our Service Standard agreement, we should only submit one consultation which combines information from the two (or more) HERs.  The ALGAO position is that the HER with the largest part of the holding should take responsibility for compiling the response and take the single payment for that work.  The scheme can only make one payment.  The assumption is that in the fullness of time, there will be a balancing up, with cross-border work going one way, then another.

7.      Don’t be afraid to call your regional RDS Historic Environment Advisor and ask for advice - amongst other things, it’s what they are there for.  On the other hand, if you are really desperate, you can get in touch with me ([log in to unmask] <mailto:[log in to unmask]>)!