APPENDIX 29
Memorandum submitted by the Council for
British Archaeology
1. THE COUNCIL
FOR BRITISH
ARCHAEOLOGY (CBA)
Founded in 1944, the CBA is an educational charity
which works to promote the study and care of Britain's historic
environment, to provide a forum for archaeological opinion, and
to improve public interest in and knowledge of Britain's past.
The Council has an institutional membership of 485 local, regional
and national societies, museums, universities, and archaeological
bodies, an individual membership of 4,500, and a Young Archaeologists'
Club of some 2,200 children and schools. The CBA is also a network,
with 11 regional branches in England, CBA Wales, and a counterpart
in Scotland, the Council for Scottish Archaeology.
1.1 This memorandum has been prepared by
senior staff, in consultation with the Council's Honorary Officers,
members of our Executive, and Committee Chairs.
1.2 Archaeology is more than digging. From
its inception, the CBA has had a strong concern for all aspects
of the historic environment, from the beginnings of Britain's
human life some half a million years ago to the 20th century.
This concern is exercised through publications, both popular and
scholarly; a magazine, British Archaeology; campaigns;
casework and participation in relevant public inquiries; conferences;
educational projects; grants schemes; and an information service
which last year handled some 6,000 enquiries from the public.
1.3 By tradition the CBA has been a pioneering,
opinion-forming body. Industrial archaeology (from the 1950s),
the concept of historic town designations (1960s), archaeology
in local government, and the integration of archaeology with the
care of churches and secular buildings (1970s and 80s) all owe
much to the CBA's influence. The CBA has also been in the vanguard
of those who have argued for an inclusive approach to heritage
which values what is local, typical and characteristic as much
as that which is exceptional, rare or outstanding. With a perspective
that spans more than half a century, and being the only heritage
body that embraces both the public and private sectors, the CBA
is well placed to contribute to this inquiry.
1.4 The historic environment is the contemporary
environment in which we all live and work. It enriches daily life.
It is an educational resource, a cultural and economic asset.
As the Commitee knows, Britain's cultural tourist industry is
worth billions. The historic environment is also irreplaceable;
archaeological sites, landscapes and historic buildings do not
regenerate. Good stewardship is thus a long-term business, calling
for effective partnership between national and local structures
and stability in centres of expertise which it would be neither
practical nor economic to maintain in other ways.
1.5 Successful stewardship also calls for
public involvement, not as spectators or bystanders who are told
by experts what they can or cannot touch, or what is interesting
and what not, but as active participants in the study and cherishing
of local surroundings. The existence of the Heritage Lottery Fund,
with its underlying aims of fostering popular access and participation,
is thus strongly welcomed. We ask that what follows be read in
that context.
2. PROVISION
FOR THE
CARE AND
UNDERSTANDING OF
BRITAIN'S
HERITAGE
The Heritage Lottery Fund (HLF) cannot and should
not be considered apart from the wider context within which it
operates. In parallel, at national level, stand English Heritage
(a non-executive agency, with a statutory remit) and its near-equivalents
in Scotland, Wales and Northern Ireland ("near", because
these are executive agencies). These bodies have roles which embrace
conservation policy, strategy and grants, archaeology and the
built environment. They also manage national monuments, and have
a significant educational remit. Beside them (but not in Northern
Ireland) stand the Royal Commissions for historical monuments
in England, Scotland and Wales (hereafter RCHME, RCAHMS and RCAHMW,
respectively13[15].
Established by Royal Warrant, their task is survey, aerial reconnaissance,
record and interpretation, and in particular the maintenance of
the National Monuments Recordsdatabases of the historic
environment. There are other bodies with less direct but significant
roles, most obviously the Countryside Commission. In terms of
grant-giving, the HLF well exceeds the annual capacity of all
of these put together.
2.1 At local level, but in Britain not yet
universally, there are services devoted to the provision of archaeological
and other conservation advice within the planning system and for
purposes of public advice and explanation. These are mainly based
in local government, often at county level (where counties still
exist), but also now sometimes in unitary, district or borough
authorities14[16].
Common to almost all of them is the Sites and Monuments Record
(SMR); a historic environmental database for the area concerned.
The importance of the SMRs cannot be exaggerated; the information
they contain is needed to inform planning decisions, guide interpretative
and conservation strategies, and for purposes of education, comprehension
and local involvement. It needs to be recognised that SMRs are
not simply computerised lists; the information they hold requires
mediation (for contextual or explanatory purposes) which in turn
calls for continuity of knowledge of the area concerned. More
than this, SMRs must be dynamic, organic institutions, to be constantly
updated and revised in the light of new information and understanding.
2.2 The national conservation agencies rely
heavily on local government provision, to which many front-line
conservation responsibilities have been devolved (cf PPGs 15 and
16). At a time when expectations and demands are rising, not only
in relation to the planning process but also (and, in the present
context, most relevantly) in connection with public explanation,
advice, community involvement and projects, it is a matter of
concern that local government resourcing is generally falling.
The range, quality and continuity of local government heritage
provision is suffering disproportionately.
2.3 There is a community of interest amongst
the CBA, HLF, national agencies, Royal Commissions and local services
in seeking to conserve, record, comprehend and promote understanding
and enjoyment of the historic environment. Equally, despite desirable
overlap on public explanation, each of these bodies has a distinct
primary role. Hence, while we welcome the advent of the HLF, we
are concerned at evidence of avoidable confusion and overlap at
both strategic and tactical levels.
2.4 We welcome the HLF because of its unparalleled
capacity to make financial input to the aims of conservation,
comprehension and enjoyment mentioned above, and because its arrival
has forced a timely review of principle and objectives which puts
strong emphasis on direct public benefit. Our anxiety stems from
evidence that the confusion derives from more than teething troubles,
and that the efforts to address it are consuming resources of
several organisations that would be better spent on their primary
tasks rather than administrative turf wars.
3. STRATEGIC
ISSUES
The main strategic problem goes back to the
establishment of the HLF. The CBA recalls the guarantee offered
publicly by the former Prime Minister at an English Heritage conference
that Lottery funding would be an extra, and not a substitute,
for existing public resources devoted to historical conservation
at national and local levels. It is cynical, and a particularly
cynical inversion of "additionality", for the previous
and present governments to explain cuts to English Heritage and
Royal Commission direct funding, and to local government overall
funding, as something different.
3.1 The result of these cuts is the weakening,
reduction and fragmentation of the infrastructure which historical
conservation needs in order to inform, help crystallise, monitor,
and derive best-long-term-value from the one-off capital grants
which are the essence of HLF delivery. The HLF must also enforce
rules of additionality for its new Revenue Grants Scheme, so this
cannot compensate for services, normally local government-based,
which have either never got off the ground for lack of resources
or have recently been cut.
3.2 Conserving a sustainable historic environment
is a long-term task which requires stable local and national organisations
that embody adequate critical masses of expertise and information
systems serving clear objectives. How and why the satisfaction
of this requirement is becoming increasingly difficult may be
beyond the scope of the Committee's inquiry, but the effects are
not, because the resources at the disposal of the HLF are so relatively
vast. The position of museums, County Record Offices, local SMRs
and archaeological and historic building services, is particularly
fragile. Undoubted and accumulating assets, they are also non-statutory
and vulnerable to cuts visited upon "soft" environmental
services. Such reductions have disproportionately large effects
because they squander years of public investment by destroying
continuity of knowledge and scattering skills which cannot be
reassembled. HLF bidders need such services to inform and guide
their projects, yet we are reachingin some areas, have
reacheda position where resources available for permanently
accessible basic services have vanished, while large resources
for atomistic short-term projects remain available. This is irrational,
and harmful to the heritage.
3.3 Welcome as it is, therefore, the very
scale of the HLF's capacity is skewing a systematic approach to
the structural/strategic and long-term local problems by concentrating
what is now the vast bulk of an otherwise shrinking set of grants
budgets on large ad hoc customer-led initiatives. It is also forcing
the HLF to create a substantial independent policy structure of
its own in parallel with those of the existing major players,
rather than a structure which dovetails into and further helps
develop an existing shared set of means and ends. Nationally,
we ought to have a situation in which the agencies and Royal Commissions
are adequately resourced to lead on conservation and information
provision, respectively, while the HLF works broadly within those
frameworks while also acting as the conscience of public benefit.
We would argue that what is actually happening is that national
bodies are on occasion expending considerable effort in dressing
up under-resourced "core" activities to look "non-core"
in Lottery bids of their own, with consequent distortion and illogicalities
that create inbuilt problems if the bid is successful. Parallels
to this phenomenon can be found at local level.
3.4 In the absence of a clear, well-adjusted
framework within which the HLF can work, this will get worse,
with reductions in the funding available to the HLF and a continuing
increase in demand leading to fairly arbitrary decisions between
otherwise acceptable applications, perhaps based more upon national
distribution or political considerations rather than conservation
need. This would matter less if the grants budgets and means of
delivery for the other bodies, especially local government, had
not been drastically reduced. For example, while the HLF's recent
prioritisation of public benefit aspects of SMRs is entirely welcome
in the abstract, it will achieve little if the revenue-based infrastructure
of SMRs continues to buckle under the stresses of development
control work and reductions of local government funding.
3.5 The corollary of such examples is dispiriting:
those local services which remain in reasonable health, and some
of the national conservation agencies themselves, are better placed
to make successful bids to the HLF than others who are arguably
more deserving. In result, we have a climate in which the minority
strong remain able to grow stronger, while those most in need
of reinforcement or encouragement are going to the wall.
3.6 This closes a circle, for the HLF was
never intended to sustain or reinforce conservation infrastructure
at all. We agree with the principle that it should not, but in
a climate which incongruously manages to combine feast and famine
it must be a question for how long it will be possible or reasonable
to sustain the principle of public responsibility for necessary
services when de facto the HLF's presence has inadvertently
begun to dilute and confuse it. Given the choice between an imaginative
but short-term project for the enhancement of local ponds, and
ensuring the stability and quality, or even survival, of local
conservation services, one would surely back the latter.
3.7 For reasons given, such difficulties
and imbalances are not the fault of the HLF or its Trustees, but
rather the result of a strategic vacuum environment in which the
HLF operates. For this, in our judgement, the Department of Culture,
Media and Sport, and its Ministers, bear most responsibility.
Neither they nor those who advise them appear to have accepted
that local conservation services are almost everywhere under unreasonable
pressure, that in some areas they are in crisis and in others
non-existent, and that in result the conditions in which HLF funds
can be fruitfully and evenly applied are badly compromised. The
public leadership one would expect on these issues, at least to
the extent of admitting they exist, has not been noticeable. In
result, Ministers appear unaware of the scale or complexity of
the problems and have shown no inclination to address them. In
some instances they may actually be compounding them by themselves
entertaining the HLF as a source of funding for projects which
arguably belong with Government and the taxpayer.
4. TACTICAL
ISSUES
We have knowledge, both direct[17]15
and through the experience of some member organisations, of HLF
bidding. We have found the HLF's staff to be consistently helpful
and courteous in what is clearly a complex and onerous task. Our
following comments are thus made with the conviction that the
HLF's officers have been doing their best in the face of difficult
external circumstances and demands which are not always possible
to forecast. Historically, the frugality of the HLF's administration,
in one sense admirable, may have contributed to an impression
held both by ourselves and others that the Fund's own secretariat
has been under-resourced and over-burdened, with a consequent
tendency to "lose the place" on particular cases. More
recently this has changed much for the better, although the advent
of new arrangements for Revenue Grants, and the funding of archaeological
and educational projects (all thoroughly welcome) might introduce
fresh pressures.
4.1 Our further comments fall under five
heads:
i. The HLF, for reasons that lie outside
its own control, has been consistently inconsistent in the way
that it carries out its business. It has "moved the goal
posts" over the kind of project, the areas within which projects
may fall, and the kind of funding that can be expected. It has,
in the experience of some, failed to keep potential applicants
fully aware of these changes, with the consequence that time has
been wasted on both sides. For reasons given above (4) this may
be a criticism of the past.
ii. The bidding process is taxing. Understandably,
but paralysingly, the HLF insists on covering itself against every
possible eventuality in terms of the legal and financial conditions
of any grant. This leads to greater expenditure than necessary
on the part of bidders (in legal, accounting and other consultants'
fees). This must deter many good applications, and it can divert
effort and time from an organisation's ordinary programmes. This
may restrict the accessibility of the Fund.
iii. Many successful bids are, clearly, of
high quality. Some are equally clearly not so, and the external
observer is left with a sense of inconsistency about a process
which leads to a set of products where excellence and whimsicality
are randomly mingled.
iv. Instances are arising, largely for the
strategic reasons outlined in section 3, of sometimes massive
projects emerging without due regard for how they should relate
to existing arrangements. An example is the Local Heritage Initiative,
which was launched with an exhortation to create local information
systems and, apparently, only dim awareness of the network of
local Sites and Monuments Records which already exists, or indeed
the impact of HLI projects upon them. Significantly, the main
progenitor of the HLI is the Countryside Commission, which stands
outside the main circle of heritage agencies.
v. The present rules appear to deter educational
establishments from bidding. This may be to discourage bids from
large numbers of schools, but universities should be encouraged.
Standing as they do at the centres of communities and regions,
universities are well placed to develop work with the community,
and could act as umbrella organisations to co-ordinate work across
a region which links a number of smaller projects together.
5. SUMMARY
5.1 We welcome the advent of the HLF and
support its aims of encouraging public access and participation.
We particularly welcome the Fund's recently-acquired capability
to support archaeological and educational projects.
5.2 Conservation and comprehension of the
historic environment are long-term, continuing tasks which require
stable local and national organisations that embody adequate critical
masses of expertise and information systems serving clear objectives.
We do not believe these conditions are being generally met.
5.3 The HLF is operating against a background
in which essential local, and to an extent national, heritage
services are year-on-year being expected to do more with less.
Locally, the result is attenuation and fragmentation of the infrastructure
which historical conservation needs, both for primary heritage
management purposes and to derive best value from HLF-funded projects.
5.4 As things stand the HLF is powerless
to intervene in those areas where reinforcement is arguably most
needed. The reasons for that inability are understood, and the
underlying principle which dictates it strikes us correct. However,
the principle itself is now being jeopardised by disjunctions
between stated intention and actuality.
5.5 We believe that the difficulties and
imbalances we have outlined flow ultimately from a Government
policy on the historic environment which is inadequately focused.
We see little evidence that the Government understands this, or
the interconnectedness of the problems and issues which flow from
it.
July 1998
15 13 Their full titles are the Royal Commission on
the Historical Monuments of England, the Royal Commission on the
Ancient and Historical Monuments of Scotland, and the Royal Commission
on the Ancient and Historical Monuments of Wales. Back
16
14 In Wales, the principal SMRs are positioned in four independent
archaeological trusts. It is a matter of concern that local government
coverage for archaeology in Scotland remains incomplete. Back
17
15 The CBA is the recipient of a grant from the HLF for The
Defence of Britain, a project which enlists public participation
to contribute records to a database of Britain's 20th century
defensive remains. Back
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