FAME has responded to the English Heritage New Model consultation. Though we have no objection in principle to the proposed new model, we have expressed our concerns about its financial viability, and stressed the need for greater engagement with development-led archaeology and closer integration between national and local archaeological services.

English Heritage New Model Consultation

Response from the Federation of Archaeological Managers and Employers

The Federation of Archaeological Managers and Employers (FAME) represents around 50 archaeological practices providing advice and specialist services to commercial clients and developers throughout the UK. Our members employ around 2,000 archaeological staff, and include commercial consultancies, universities, local authorities and charitable trusts.

Since its establishment in 1983, we have worked in close partnership with English Heritage in managing, investigating and promoting England’s historic environment, and we welcome the opportunity to comment on the proposed New Model for the organisation.

Chapter 3: The Charity

1. The consultation outlines the benefits of the new model for the National Heritage Collection. Do you:

Somewhat agree with the proposed benefits

2. If you either strongly or somewhat disagree with the proposed benefits why is this?

We have no objection in principle to the proposed separation of English Heritage into Historic England and the new charity. We recognise the potential benefits in providing a clearer separation between its statutory heritage protection duties and its duty of care to its properties, and the greater autonomy and freedom to generate additional sources of income that this will potentially provide to the new charity.

We are however concerned that, in the absence of a detailed business plan, it is not possible to be sure that the financial projections for the new charity are realistic. The heritage attraction market is inherently unpredictable and, should these projections prove over-optimistic, we are concerned that any shortfall in projected revenue will be sought from the already hard-pressed heritage protection grant-in-aid, the level of which has not been settled beyond 2015/6. We are also concerned that, as the owner of last resort, Historic England may be called upon to take back into care properties at risk, thereby reducing its resources still further. In our view it is vital that a detailed business plan be developed for the new charity as a matter of urgency.

3. Are there any further benefits that could be delivered by this model?

–

4. Are there any other key opportunities for the charity to increase earned income in addition to those outlined in the consultation?

–

5. If yes what are they?

–

6. What aspects of the current service provided to the public by English Heritage in relation to the National Heritage Collection is it important that the charity maintains?

The charity should continue to work in partnership with others to improve the care, accessibility, understanding and enjoyment of its properties. Most importantly, it should continue to give heritage conservation an equal priority to visitor appeal, and should prepare publicly-accessible Conservation Management Plans for all its properties.

7. What are the opportunities to further enhance the services that will be offered by the charity?

–

8. Do you agree that the suggested charitable objectives are broadly the right ones?

Yes

9. If no, what changes to them do you think should be made?

–

10. Are the proposed success criteria to measure the performance of the charity and to ensure that the benefits are realised the right ones?

Broadly yes.

11. If not what else should be included in the success criteria?

The preparation of Conservation Management Plans for all its properties

Chapter 4: Historic England

12. We are interested in the views of respondents to the proposed future opportunities and priorities for Historic England. Are these the right priorities and opportunities? Is there anything missing?

We welcome the recognition of the social, economic and environmental benefits of the historic environment, and its contribution to achieving sustainable economic growth (4.2). We would particularly welcome a statement from government reiterating its commitment to valuing the historic environment, and hope that achieving this would be among the priorities for Historic England.

It is essential that Historic England takes the lead in championing the historic environment, and in providing robust, impartial and authoritative advice and advocacy to local and national government, landowners, developers and infrastructure providers. However, its capacity to do so has been severely eroded by progressive cuts in grant-in-aid since the 2010 spending review, and we are extremely concerned that there is to be no real terms increase in its grant-in-aid to 2015/16, and no assurances about its budgetary settlement thereafter.

In our view it is vital that the level of grant-in-aid to Historic England is maintained, and is ring-fenced during the transitional period towards self-sufficiency of the new charity.

Historic England needs to engage more closely with development-led archaeology. The consultation acknowledges (4.13) that the publication of PPG16 in 1990 led to the growth of an ‘active private sector in archaeology’. Indeed, the overwhelming majority of archaeological research in the UK is now undertaken, not by universities, volunteers or the national heritage agencies, but by public and private sector archaeological practitioners in advance of development. Estimates vary, but the value of the development-led archaeological market in the UK almost certainly exceeds £100m per annum.

One unfortunate consequence of this sea-change has been the marginalisation of English Heritage from a highly significant body of new archaeological work. This is exacerbated by such work being governed by policies formulated, not by DCMS but by DCLG, and in our view Historic England would be more closely engaged with such work if it were an executive agency within DCLG. Regardless of this, it is imperative that Historic England regains its strategic role at the centre of national archaeological endeavour. This may be achieved by, for example, promoting research into market analysis and intelligence, supporting the synthesis, assimilation and dissemination of the results of development-led research and, wherever possible, adding value to development-led work.

13. Are the proposed success criteria to measure the performance of Historic England the right ones?

Yes

14. If not what else should be included in the success criteria?

–

15. Should the National Heritage Protection Plan form the basis of the business plan for Historic England?

Yes, but see below

16. If no – why not?

Not in its present form. The NHPP needs to develop into an overarching National Heritage Framework, maintained by Historic England, below which the detailed business and action plans of individual organisations (such as English Heritage, FAME and others) would stand. It should be a high-level, strategic document, providing a broad agenda for the historic environment sector, and any or all of those organisations (or individuals) with an interest in it. It should provide the hooks on which detailed organisational plans may be hung, enabling a clear connection to be made between the work of those organisations and national strategic objectives. Many of the more detailed activity areas and initiatives within the current NHPP would form the basis of organisational plans for Historic England and, to a lesser degree, English Heritage. The framework would also act as an advocacy document for government and opinion formers outside the sector.

17. Are there any further points you would like to add in relation to the consultation?

The consultation makes surprisingly little reference to English Heritage’s long and distinguished tradition of promoting capacity building and partnership with local authorities.

It does however acknowledge that the new model presents an opportunity to ‘review the landscape for heritage services’. This is particularly pertinent in view of the concurrent review of the future of local government archaeological services, initiated by Ed Vaizey MP, Minister for Culture, Communications and Creative Industries, in response to the serious reduction in their capacity due to budgetary pressures on local authorities.

In our view this concurrence provides a once-in-a-generation opportunity to review fundamentally the relationship between historic environment services provided at local and national levels. There is a very strong complementary between Historic England’s core roles of maintaining a national data archive and providing advice on the designated historic environment and those of local authorities to maintain Historic Environment Records and provide advice on the (largely) undesignated historic environment.

In the face of diminishing local authority resources over the past five years (4.13) and its likely continuation for the foreseeable future, we believe that there is now both a need and an opportunity  of both –  to develop new models of collaborative working, service sharing and even the pooling of resources, between national and local historic environment services. Such models would require major cultural changes at both national and local level, but would have the potential to harness the strengths of strategic perspective and national consistency with those of local knowledge, responsiveness and accessibility (4.8).