CELG(4) HIS 12
Communities, Equality and Local Government
Committee
Inquiry into the Welsh Government’s Historic
Environment Policy
Response from Rob Scourfield
Thank
you for the chance to comment on the above. I respond to your
questions as follows:-
How appropriate and successful are the current systems employed by
the Welsh Government for protecting and promoting the
historic environment in Wales?
- In
terms of the legislation and guidance pertaining to listed
buildings and Conservation Areas, we find that the existing
guidance and legislation has stood the test of time well. The
listed building descriptions - much better than those in
England – are detailed and clear. There are weak spots
however, as follows:-
-
Structures that are dually listed and scheduled. There should
either be a re-think on the relevant designations, or a legislative
mechanism whereby a LPA has an enforcement role. This involves
buildings with a potential for reuse, such as Napoleonic Forts or
domestic ruins.
- The
Register of Landscapes and Gardens should have full statutory
status.
-
Clearer advice (e.g. in a policy annex) needs to be given to those
applying for listed building consent, drawing together the
‘bones’ given in TAN 12 and the ‘flesh’ in
the 2008 amendment of the GDO with regard to the preparation of
Design and Access Statements.
- The
Conservation Principles need inclusion within any new guidance
– and should be made clearer. If well-handled, this may
highlight the wider appeal of the historic environment, as opposed
to the ‘architectural’ and ‘historic’.
- The
duty of care of owners of protected buildings/sites needs to be
made clearer.
- Wales
has a very high stock of pre-1919 buildings with a tiny % being
protected. Nothing is made of unprotected traditional
buildings – the ‘ordinary’ which characterize the
landscape of Wales – and represent a vast resource of
embodied energy.
- In
terms of systems, it must be said that we have noticed a downturn
in Cadw’s capacity to perform basic functions, both due to
staff cuts and the changing agenda of Cadw towards ‘heritage
tourism’ . In the case of this Authority, I give the
following examples:-
-
Listed building control ‘delegation’. Award of this has
been pending for over six months, despite Cadw’s desire to
promote delegation to LPAs across Wales.
-
Grants. Budgets for LPA townschemes/Conservation Area schemes are
still not confirmed for this financial year.
The systems for delivering key functions such as funding and advice
have served us well in the past, but systems fail without adequate
staff. On a more positive note:-
- Cadw
has recently been proactive in a number of key issues such as
buildings at risk, and townscape characterization. This is
welcomed.
- The
biannual Built Heritage Forums held for Building Conservation
Officers remains a popular and valuable exercise.
-
Regionally-based officers e.g. the archaeologists – provide
an excellent service
How well do the Welsh Government’s policies promote
the historic environment in Wales (for instance, in terms of
interpretation, accessibility, attracting new audiences and
tourism?
- There
is a strong perception that Cadw’s closeness to the Welsh
Government precludes it from championing the environment which it
is charged to designate and regulate. In terms of Cadw-managed
sites, the standard of interpretation and access provision is
excellent – and Convergence funding will assist in bringing
in new audiences. Outside of this, one struggles to see what Cadw
has achieved in this respect. The RCAHMW has done far more to
promote the built heritage of Wales through their publications, tv
series (e.g. Hidden Histories) and their on-line database, Coflein.
To a lesser extent, the regional Archaeological Trusts have had
success e.g. in local projects and their on-line information.
Whatever the WG’s policies in promoting the historic
environment may be, they have achieved little, and Cadw’s
approach is an inclusive one – centred on Cadw sites and
ignoring the ‘ordinary’
How well do the policies for the historic environment tie in
with wider Welsh Government policy objectives (such as the
regeneration of communities?
- The
perception is, very poorly. There are two extremes in terms of
regeneration ‘on the ground’ – the run-down
historic urban areas (where old houses are seen as a hindrance),
and the over-provision of second homes (where old houses are beyond
the reach of many locals). Both scenarios share the common problem
of stagnation, and the problem needs tackling from both ends in
terms of regeneration.
Environmental factors need better integration too. We are pleased
to note the progress on the Welsh Building Regulations, and the
growing recognition that our historic building stock is valuable in
terms of embodied energy, and that the existing ‘one size
fits all’ approach is detrimental. There are positive links
between conserving energy and conserving buildings and this must be
made more of. At present, the two are often seen as a conflict.
Similarly, biodiversity issues need better integration.
What would be the advantages and disadvantages of merging the
functions of the RCAHMW with the functions of other
organizations, including Cadw.
-
Superficially, the integration of the information service with the
delivery of policy objectives would seem a positive step.
Outweighing this would be the danger that the unique information
service would be submerged within a culture and legal remit that
currently seems to preclude the overall promotion of the heritage
of Wales. This would place the 100-year old database at risk, as
well as the media outreach so well demonstrated by the RCAMHW. The
database is unique and apparently not transferable e.g. to the NLW
– it, as well as Coflein does not conform to WG systems and
practices – so, even to maintain the existing databases
within a merger would hardly be cost-effective.
There is certainly a need for closer links between Cadw and the
RCAHMW, but any merger should allow the latter to continue its
existing functions without undue political interference. There is
also a need to address areas of duplicity between the regional
Archaeological Trusts and the RCAHMW – which currently causes
much confusion in the planning system.
What role do local authorities and third sector
organizations play in implementing the Welsh Government’s
historic environmental policy and what support do they receive in
this respect?
- LPAs
are effectively the conduit between national (and wider) government
policy, and the communities we serve through the implementation of
local policies. LPAs receive some strategic support, but their
‘heritage’ capacity is typically minimal. As such, most
LPAs can only concentrate on core statutory functions. Cadw has
encouraged regional forums of heritage expertise within the public
sector, but the mixed results are all to do with capacity. The
biannual Built Heritage Forums organized by Cadw are a success, as
is Cadw’s buildings at risk initiative.
What is needed is an intermediary body that is collectively owned,
developed from English (Heritage Alliance) and Scottish (Built
Environment Forum) models. At present, the gulf between LPA officer
(usually under-resourced) and the political agenda of Cadw is far
too great.
I hope the above is of some use.
Rob Scourfield
Building Conservation Officer
Pembrokeshire Coast National Park Authority