CELG(4) HIS
72
Communities, Equality and Local Government Committee
Inquiry into the Welsh Government’s Historic Environment
Policy
Response from Ymddiriedolaeth Addoldai Cymru / Welsh Religious
Buildings Trust
Thank you for the opportunity to
submit our views on this subject.
Ymddiriedolaeth Addoldai Cymru
Welsh Religious Buildings Trust (WRBT) was established as an
independent charity by Cadw to take into care redundant
non-Anglican religious buildings that are exceptional examples of
Wales’ religious built heritage. The Trust also endeavours to
provide advice and assistance to those responsible for caring for
the religious built heritage in Wales, as its resources allow. The
WRBT currently owns six redundant nonconformist chapels and is in
the process of acquiring another. The Trust receives limited core
funding for day-to-day running costs and basic overheads for its
buildings from the Welsh Government via Cadw; other income is from
grants and donations. All the Trust’s buildings are either
awaiting repair or are in the process of being repaired in phased
programmes, and once repaired will be made available for community
use and public access. The Trust’s main office is in the
schoolroom of Capel Peniel, a grade I listed chapel in Tremadog.
The Trust currently has a staff complement of 1.6 (full time
equivalent).
In May 1993, the Welsh Affairs
Committee of the House of Commons in its report The Preservation
of Historic Buildings and Ancient Monuments recommended, inter
alia, the setting up of a Redundant Churches and Chapels Fund for
Wales. Cadw subsequently established a working party specifically
to review the issue of redundancy amongst Wales’ rich
heritage of nonconformist religious buildings. The working party
reported in 1996, and recommended the setting up of a new
charitable trust to acquire and care for redundant non-Anglican
religious buildings of significance for the benefit of future
generations, and to act as an advisory body and information source.
Cadw subsequently invited the Wales Council for Voluntary Action to
manage the creation of the WRBT, which was incorporated in November
1999.
In respect of caring for
redundant Anglican churches in Wales, the Representative Body of
the Church in Wales has established an arrangement with the Friends
of Friendless Churches, which is based in London. Similar bodies
caring for redundant religious buildings in the United Kingdom are
the Churches Conservation Trust, dealing with redundant Anglican
churches in England; the Historic Chapels Trust, which deals with
redundant non-Anglican buildings in England; and the Scottish
Redundant Churches Trust.
Consultation
Questions:
How appropriate and
successful are the current systems employed by the Welsh Government
for protecting and managing the historic environment in
Wales?
- The current legislative and
guidance framework for the historic environment, a hybrid of
Westminster legislation and Cadw guidance, has evolved over decades
and is now under review. The subject matter is complex and the
mechanisms are understood by professionals working in the historic
environment field, although perhaps less so by the general public.
There is scope for streamlining. However, whilst there may be some
merit in making any new framework more easily understood by the
general public, the Trust would be concerned at any dilution of
existing processes and guidance; rather, the existing framework
should be strengthened.
- The Trust believes that Cadw
could be more outward facing in terms of its message and purpose,
so that the systems employed by the Welsh Government for protecting
and managing the historic environment are seen as relevant, and are
being undertaken by and on behalf of the people of Wales and its
communities, rather than the danger of being perceived as being
imposed upon them.
- Cadw could provide more advice
and guidance and undertake a more proactive educative and standard
setting role. Cadw could usefully build on the foundation of its
accessible and informative website Maintenance Matters! to
disseminate advice, guidance and advocacy more widely, so that the
‘person in the street’ has a better understanding of
the issues.
- Cadw’s general website now
seems to carry less information on policy issues, technical
guidance, and information in general than previously. It may be
that Cadw wants a site that is more welcoming to the general
visitor, and if so, it should create a parallel sector/technical
site, similar to Historic Scotland’s new Technical
Conservation website to provide more technical and policy
advice.
- Although the WRBT was
established at the behest of Cadw, there is a lack of resources
being provided to the Trust to undertake the work that Cadw expects
of it. This places a great strain on Trustees, who have taken
personal responsibility for redundant buildings in a poor state of
repair, but which are, however, a vital part of our national
heritage.
- Grant budgets do not seem to be
set until well into the financial year, which has obvious
repercussions. The WRBT do not know at what level within the Welsh
Government this delay occurs. Our direct experience of Cadw staff
has been excellent, and we greatly value their assistance and
positive outlook. It appears to us that Cadw may well be
under-resourced for what the Welsh Government as a whole requires
of it.
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)?
- The Welsh Government needs to be
more proactive in promoting the built heritage of Wales in general.
This needs long-term policy objectives and funding commitment, and
should not be led by short term objectives. We are accountable for
the stewardship of our heritage whilst it is in our
generation’s care.
- Cadw aspires to be the champion
of the historic environment in Wales. It does promote its own
projects very well, and is making good use of its own property in
care. However, the Trust believes that Cadw should be much more
greatly concerned with the sector as a whole. The RCAHMW seems to
be undertaking focussed work on the historic environment in Wales
in general. For example, it fell to the RCAHMW rather than Cadw to
undertake research to produce the first clear knowledge database of
the extent of Wales’ nonconformist built
heritage.
- Cadw may well even appear to be
open to the perception of a conflict of interest, in that although
it presumably has a remit to promote the whole sector and all
historic buildings in Wales, the current emphasis does seem to be
on Cadw’s own estate. Consideration should be given to
separating the policy, regulatory, advisory and awareness-raising
functions of Cadw from its role as an operator of important
heritage sites, which are also highly successful visitor
attractions.
- We know of the Heritage
Minister’s Historic Environment Group, and it seems to have
an interesting and useful work programme. However, the Trust cannot
be alone in not seeing the fruit of this work, either in the form
of reports or minutes. We would urge that its work be more widely
disseminated. We wonder whether the Group should be more formally
constituted, with an oversight role (of Cadw’s overall
long-term strategic direction and vision) as well as an advisory
remit to the Minister.
How well do the
policies for the historic environment tie in with wider Welsh
Government policy objectives (such as the regeneration of
communities)?
- Although the principle of
regeneration through heritage has been introduced, there is still
the perception that our heritage is an add-on, a luxury that can be
attended to after all the more ‘important’ issues have
been dealt with. It is not integrated.
- Although some good work has been
done on the value of heritage to the economy, (e.g. Valuing the
Welsh Historic Environment 2010) these efforts appear sporadic
rather than systemic.
- We wonder if there is the
necessary policy capacity within Cadw to be working across
Government on integrating issues dealing with the historic
environment into cross cutting policy areas.
What would be the
advantages and disadvantages of merging the functions of the Royal
Commission on the Ancient and Historic Monuments of Wales with the
functions of other organisations, including Cadw?
- We understand that the abolition
of the RCAHMW is being considered, in order to deal with budgetary
issues over the next two, three or four extremely difficult years.
This seems to us to be an extremely short-term measure with
possible extremely long-term consequences. We cannot see the
advantage of simply merging the functions of the RCAHMW with the
functions of Cadw without a proper and thorough review of the whole
sector.
- We note that the Minister has
established a working group to create a process whereby the core
functions of the RCAHMW could be merged with other organisations,
including Cadw. We cannot understand why this review has been
initiated at the same time as the commencement of the consultation
process that will lead to the Heritage White Paper and subsequent
Heritage Bill. We do not know if the working group will be
producing a report and, if so, whether it will be published and any
recommendations subject to public consultation.
- Two previous inquiries on the
work of the RCAHMW have reported favourably, both on the quality of
its work and value for money achieved: in April 2011the Welsh
Historic Environment Assessment Exercise noted that “this
exercise has not highlighted the significant areas of duplication
and overlap that might have been anticipated”.(Section 12
p70) and previously in 2010 The Report On The Citizen-Centred
Governance Review Of The Royal Commission On The Ancient And
Historical Monuments Of Wales noted “that once the full
extent of the outputs of the organisation became clear, and
throughout the review we were continually impressed by the amount
the organisation does on this budget.” (Section 9.4
p31)
·
It appears to us
that those best placed to propose any changes initially would be
the Commissioners themselves, a body possessing considerable
subject, institutional and administrative expertise, with
subsequent input and response from the Welsh Government, including
a thorough consultation process.
·
There is a general
need for greater coherence and more joined-up strategic thinking
across the heritage sector in Wales, accompanied by the provision
of guaranteed long-term resources from the Welsh Government. For
example, there may be advantages in bringing together the functions
of the RCAHMW, the four Archaeological Trusts and some parts of
Cadw as a new arm’s length Welsh Government sponsored body,
on the lines of Amgueddfa Cymru National Museum Wales or Llyfrgell
Genedlaethol Cymru National Library of Wales. These issues should
be considered in the context of the consultation process associated
with the forthcoming Heritage White Paper and subsequent Bill, and
should be subject to thorough public scrutiny and
consultation.
What role do local
authorities and third sector organisations play in implementing the
Welsh Government’s historic environment policy and what
support do they receive in this respect?
- Local authorities are the layer
between Welsh Government and communities across Wales. We have the
impression of a wide variation in standards and resourcing from
authority to authority. Often there is a lack of capacity to do
much more than meet minimal statutory requirements, and where there
is a lack of expertise, it results in a lack of confidence and
imagination. Unfortunately, it seems that ‘heritage’ is
seen by many local authorities as an add-on, a luxury if there is
enough money left, rather than a core issue of identity and
well-being.
- The Built Heritage Forum of
local authority conservation officers is in our view an asset,
taking advantage of the opportunity to have all in Wales in one
room. This should be built upon, to create tight cohesive networks,
and be provided with adequate resources.
- Consideration should be given to
sharing expertise across authority borders e.g. building
conservation expertise.
- Many historic assets are owned
and managed by third sector bodies – from small local
charities, through the religious denominations to the National
Trust. However, it is a fragmented field. Some work was undertaken
in 2008/9, initially with the support of Cadw, on creating an
historic environment network for Wales, with a role roughly similar
to the Heritage Alliance in England or nearer to home, Wales
Environment Link. A working party comprising representatives of the
National Trust, Civic Trust for Wales, and Institute of Historic
Building Conservation amongst others made a firm proposal to Cadw
towards setting up such a network but Cadw decided not to support
it. We are not aware of any further progress. Such a network would
assist the work of your committee – it was only by chance
that this Trust became aware of your consultation. An historic
environment network would at the very least provide a clearing
house for contacts, communication and consultation.
- The Welsh Government should play
a more proactive role in relation to the third sector. For example,
many examples of our remarkable religious built heritage are at
risk, or soon will be, and the situation requires a systematic
appraisal, with strategic recommendations, bringing together the
religious denominations, local authorities, and other interested
parties. Such work was undertaken by the now abolished Historic
Environment Advisory Council for Scotland, who published in 2009 a
Report with recommendations on the long-term conservation of the
ecclesiastical heritage in a time of demographic change. Cadw
was briefly engaged in discussions with the various nonconformist
denominations together with this Trust during 2008/9, but these
failed to make progress.
- As a third sector organisation
set up by Cadw we feel that we do not receive sufficient resources
in order to undertake the immense amount of work required to try to
secure an active and useful life for the buildings that we are
acquiring. There is a shortfall both in capital and revenue
funding. Trustees believe that Wales’ nonconformist built
heritage is at least as important to Wales’ national identity
as the Edwardian castles, and yet in comparison it receives limited
resources. Many of these buildings are now at risk, and we should
not be seen by future generations as being the generation that let
their heritage slip through our fingers.
- We note that the committee has
not asked for a response on the role on private owners of heritage
assets, and how they interact with Government policy.