2. Exploring UK Policy and Its Impact on Archaeology: Findings from Heritage Counts 2016 Data
(in England)
Ā£21.7 Billion
Gross Value Added (GVA)
Ā£18.4 Billion from Heritage
Tourism by domestic/intāl
visitors
328,700 people employed
in heritage
Ā£9.6 Billion
Repair & maintenance in
construction sector output
3. Exploring UK Policy and Its Impact on Archaeology: Cuts
RESCUE Monitoring Cuts Online. 2018
From ~2010 onwards..
University Department Cuts 2
Archaeology Units 7
Museum Closures 45
Museum Cuts 81
Local Authority Cuts 122
4. Exploring UK Policy and Its Impact on Archaeology: Cuts
2004-05
96,045 students
Down by
89,610 students
2013-14
Students Numbers for Historical & Philosophical Studies by HESA
6. The Historic Environment Protection Reform Group Consultation (2016)
A Heritage Sector (not Government) consultation run by the Heritage Environment Forum
The Rural Planning Review: call for evidence (2016)
Exploring more streamlined planning system in rural areas to benefit farming and rural businesses, and to support economic growth.
The Neighbourhood Planning Act (2017)
Was under consultation in 2016. Sought to ensure planning conditions requiring developers to take action before work were only used when strictly
necessary, but in a way that makes sure heritage/ environmental safeguards remain in place through the TPCA 1990
The Museums Review (2016)
The first in a decade to examine museums on how museums/galleries can āthriveā
Heritage2020 (2016)
An initiative that focuses on where collaborative working can deliver benefits for understanding, protecting and engaging with the Historic
Environment in England.
The Raynsford Review of Planning (2017)
Set up to identify how the government can reform the English planning system to make it fairer, better resourced and capable of producing
quality outcomes, while still encouraging the production of new homes.
The National Planning Policy Framework (2015-2018)
The consultation on proposed changes to national planning policy was published on 7 December 2015. The first consultation closed on 22 Feb
2016. We have also recently had another Consultation on the NPPF which closed last week on the 10th May.
Exploring UK Policy and Its Impact on Archaeology: UK Consultations
7. Exploring UK Policy and Its Impact on Archaeology: Brief Background
PPG16: Planning and Archaeology
8. PPG16: Planning and Archaeology
Exploring UK Policy and Its Impact on Archaeology: Brief Background
A:The Importance Of Archaeology
3. Archaeological remains are irreplaceable. They are evidence - for prehistoric periods, the only evidence - of
the past development of our civilization.
6. Archaeological remains should be seen as a finite and non-renewable resource, in many cases highly fragile
and vulnerable to damage and destruction.Appropriate management is therefore essential to ensure that they
survive in good condition. In particular, care must be taken to ensure that archaeological remains are not
needlessly or thoughtlessly destroyed. They can contain irreplaceable information about our past and the
potential for an increase in future knowledge.They are part of our sense of national identity and are valuable
both for their own sake and for their role in education, leisure and tourism.
8.With the many demands of modern society, it is not always feasible to save all archaeological remains.The
key question is where and how to strike the right balance.Where nationally important archaeological remains,
whether scheduled or not, and their settings, are affected by proposed development there should be a
presumption in favour of their physical preservation.
9. Exploring UK Policy and Its Impact on Archaeology: Brief Background
PPS5: Planning for the Historic Environment (March 2010)
Brought together PPG16
and PPG15 which
covered listed buildings
and Conservation Areas
10. Exploring UK Policy and Its Impact on Archaeology: Brief Background
National Planning Policy Framework (2012)
11. Exploring UK Policy and Its Impact on Archaeology: Brief Background
Planning Framework
Law
ā¢Town and Country Planning Act 1990
ā¢Planning (Listed Buildings and Conservation
Areas) Act 1990
ā¢Planning and Compulsory Purchase Act 2004
Planning Policy
ā¢Development Plan
ā¢NPPF
ā¢Planning Practice
Guidance
Advice
ā¢Good Practice
Advice
Other documents ā¢Conservation Principles
12. Exploring UK Policy and Its Impact on Archaeology: Brief Background
Planning Framework
National: Central
Government ā¢NPPF
Regional: GLA
(London Only)
ā¢London Plan: Spatial Dev't
Strategy for Greater
London
Local: LPA
ā¢The Local
Plan
Area: Parish/Town
Councils,
Designated
Neighbourhood
Forums
ā¢Neighbourhood Dev't
Plans/Orders, Community Right
to Build Orders
13. Exploring UK Policy and Its Impact on Archaeology: Brief Background
National Planning Policy Framework (2012) ensured:
Section 128: The applicant (developer) must provide sufficient information in order to assess the historic
environment impacts of their proposed development.
Section 128, 141, 169: The LPA should maintain or make available an HER to provide relevant information to
an applicant, who should then make any evidence from their assessments available to HER
Section 129, 132: The significance of a heritage asset and its conservation should be weighed against the
wider benefits of the proposed development. The more important the heritage asset the more weight will be
given to its conservation and enhancement
Section 133, 134: Substantial or total loss of a designated heritage asset should be wholly exceptional
unlessā¦overwhelming public benefits outweighs loss/harm
Section 135: The degree of harm to the significance of a non-designated heritage asset will be balanced
against the merits of the proposed developmentā¦
Section 139: Non-designated heritage assets of equal significant to Scheduled Ancient Monument..subject to
same policy considerations
14. 14Exploring UK Policy and Its Impact on Archaeology: NPPF
NPPF: Old versus
New
2012
2018
Pursuing sustainable development involves seeking positive improvements
in the quality of the built, natural and historic environment, as well as in
peopleās quality of life, including (but not limited to):
ā making it easier for jobs to be created in cities, towns and villages;
ā moving from a net loss of bio-diversity to achieving net gains for
nature6
ā replacing poor design with better design;
ā improving the conditions in which people live, work, travel and take
leisure; and
ā widening the choice of high quality homes.
These objectives should be delivered through the preparation and
implementation of plans and the policies in this Framework; they are
not criteria against which every decision can or should be judged.
Planning policies and decisions should play an active role in guiding
development towards sustainable solutions, but in doing so should take
local circumstances into account, to reflect the character, needs and
opportunities of each area.
15. The presumption in favour of sustainable development
11. Plans and decisions should apply a presumption in favour of sustainable development.
For plan-making this means that:
a) plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible
flexible to adapt to rapid changeā¦
ā¦unless:
ā¢ the application of policies in this Framework that protect areas or assets of particular importance provides a
strong reason for restricting the overall scale, type or distribution of development in the plan area7; or
ā¢ any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed
against the policies in this Framework taken as a whole.
For decision-taking this means:
c) approving development proposals that accord with an up-to-date development plan without delay; or
d) where there are no relevant development plan policies, or the policies which are most important for determining
the application are out-of-date, granting permission unless:
ā¢ the application of policies in this Framework that protect areas or assets of particular importance provides a clear
reason for refusing the development proposed7; or
ā¢ any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed
against the policies in this Framework taken as a whole.
Exploring UK Policy and Its Impact on Archaeology: NPPF
NPPF 2018
16. Exploring UK Policy and Its Impact on Archaeology: NPPF
NPPF 2018
56. Planning conditions should be kept to a minimum and only imposed
where they are necessary, relevant to planning and to the development to
be permitted, enforceable, precise and reasonable in all other respects.
Agreeing conditions early is beneficial to all parties involved in the
process and can speed up decision making. Conditions that are
required to be discharged before development commences should be
avoided, unless there is a clear justification20.
20 When in force, sections 100ZA(4-6) of the Town and Country Planning Act
1990 will require the applicantās written agreement to the terms of a
pre-commencement condition, unless prescribed circumstances apply.
17. Exploring UK Policy and Its Impact on Archaeology: NPPF
NPPF 2012
Historic environment
169. Local planning authorities should have up-to-date evidence about the
historic environment in their area and use it to assess the significance
of heritage assets and the contribution they make to their environment.
They should also use it to predict the likelihood that currently unidentified
heritage assets, particularly sites of historic and archaeological interest, will
be discovered in the future. Local planning authorities should either
maintain or have access to a historic environment record.
170. Where appropriate, landscape character assessments should also be
prepared, integrated with assessment of historic landscape character,
and for areas where there are major expansion options assessments
of landscape sensitivity.
18. From MainTextTo Footnoteā¦
Exploring UK Policy and Its Impact on Archaeology: NPPF
2012
2018
139. Non-designated heritage assets of archaeological interest that
are demonstrably of equivalent significance to scheduled
monuments, should be considered subject to the policies for
designated heritage assets.
20. Exploring UK Policy and Its Impact on Archaeology: NPPF
The use of the term āHISTORIC ENVIRONMENTā
Has Been
Deleted
From the Current Draft NPPF
41 Timesā¦.
22. Exploring UK Policy and Its Impact on Archaeology: Museum Review
The Mendoza Review wants museums to:
ā¢ Helping adapt to todayās funding environment
ā¢ Improving the curation and management of collections so that they are
accessible to the public
ā¢ Growing and diversifying audiences
ā¢ Ensuring museums contribute to the priorities of the local area
ā¢ Delivering cultural education
ā¢ Developing future leaders
ā¢ Diversifying the workforce of museums
ā¢ Increasing digital capacity and using digital technology to create innovative
and engaging exhibition content
ā¢ Working internationally
Great ā now show me the money!
23. Exploring UK Policy and Its Impact on Archaeology: Museum Review
258m
221m
200
210
220
230
240
250
260
270
2010/11 2015/16
Annual Local Govāt Spending on Museums
in England
Annual Local Gov Spending on Museums (England
24. Exploring UK Policy and Its Impact on Archaeology: Museum Review
The Museums in the UK
2017 Report
shows that
at least 76 museums have
closed since 2005,
with
64 of those having closed
since 2010.
The majority of closures
since 2010 are due to local
authority cuts.
25. Exploring UK Policy and Its Impact on Archaeology: What To Do?
Have
Your
Say
Understanding:
Provide Diverse
Views
Awareness:
Know what is
changing
Evidence:
Support a
statement
Research:
Highlight issues
27. Exploring UK Policy and Its Impact on Archaeology: Conference
Confirmed Speakers:
Georgina Holmes-Skelton, Head of Government Affairs at National Trust
Gail Boyle, Senior Curator, Bristol Museum; Council, Gloucestershire Archaeological Society; Chair, Society
for Museum Archaeology, Trustee, Treasure Valuation Committee
Chris Patrick, Conservation Officer at Birmingham City Council
Victoria Bankes-Price, Policy Advisor at Woodland Trust
Rob Lennox, Policy Advisor at CIfa
Editor's Notes
Ok so hello and welcome. Today I really just wanted to use this opportunity to highlight some changes happening in the political landscape which affects archaeology, and museums as wellā¦
While the title says UK ā Iām really actually focusing a lot on England.
Iām going start off with a very quick overview of the state of arts and culture, and move onto a brief background of archaeology in the planning system for those who may not know about it, and then will really just go through two consultations that have occurred recently to demonstrate the changes that are impacting our workā¦
On this slide we see RESCUEās monitoring cuts that they are publishing online. Itās not really accurate - im not sure how often they update it, but it still demonstrates the dire situation we see ourselves in. Obviously Austerity and the tightening of the public purse strings have had and continue to have a considerable impact on delivery of local services.
As most of us know, since 2010 when the Government introduced its deficit reduction programme, public sector budgets fell dramatically. In the 2016 Budget, the Chancellor announced further cuts of Ā£3.5bn to public spending by 2020. This is on top of the 7.8 per cent cuts weāve already seen since 2010 (IFS, 2015).
Local authorities in England lost 27 per cent of their spending power over five years from 2010 to 15 (JFR, 2015). Some services, such as planning and āsupporting peopleā have seen cumulative cuts of 45 per cent (JFR, 2015).
The Local Government Association highlighted almost half of all councils ā 168 ā wont receive any core central government funding by 2020, and that local councils will see central funding fall by 77% by that time.
Theyāve also said Councils cannot run vital local services on a shoestringā and added āeven if they stopped filling in potholes, maintaining parks and open spaces, closed all childrenās centres, libraries, museums, leisure centres, turned off every street light and shut all discretionary bus routesā there will still be a Ā£5.8bn funding gap in 2020.
So far we've seen thousands of staff laid off, closed libraries, museums and leisure centres, and cut grants to charities and arts bodies.
The impact of these cuts is definitely felt in the heritage sector: there's been a 27 per cent cut in Historic England and English Heritage spending since 2014, and a 35 per cent reduction in Local Authority Historic Environment staff since 2006.
Ok so here I briefly want to mention the scrapping of Archaeology A-levels which obviously lowers archaelogyās profile, but also I wanted to address the growing concerns of both a steady decline since 2011 in the number of university applicants taking up archaeology degrees, as well as a general turn away from the humanities as a subject with a drop of 6.7% between 2005 to 2014 according to HESA (Higher Education Statistics Agency)
IN 2016 we saw a 4% decline in UK applicants overall from the previous year, but really also we see ā both here and in the US ā a move away from the social sciences and humanities towards STEM subjects (UCAS).
I also wanted to mention a quote in 2014 from the Secretary of State for Education just to highlight the mindset in government in seeing archaeology as uneconomical and drilling in this idea that the arts and humanities can't provide employability. Nicky Morgan suggested
āif you didnāt know what you wanted to doā¦then the arts and humanities were what you choseā while āsubjects that keep young peopleās options open and unlock doors to all sorts of careers are the STEM subjectsā (Gov.uk, 2014). So a clear comment about opportunities and employability, and a clear dismissal of the really great transferable skills that subjects such as archaeology offer without necessarily having a linear career path.
Meanwhile Historic England says thereās an existing skills shortage in the workforce leading to concerns we canāt meet the needs of proposed infrastructure projects.
(The two uni cuts it shows are the closure of the Institute of Archaeology and Antiquity in Birmingham Uni and redundancy threats to the department in Bristol.)
Ok ā so ā what else is happening. These two DCMS papers!
I wanted to flag these up because theyāre recent, and relevant.
The Culture white paper came out in 2016 and was basically the first white paper for culture in more than 50 years and actually only the second ever published. The first being Jennie Lee's WhiteĀ Paper āA Policy for Arts ā First StepsāĀ in 1965.
So this one was seen to be the latest contribution to public support for art and culture, and does actually mention the historic built environment.
It was what led to the Review of Museums in England, which Iām using as a ācaseā later on ā but was criticised for being ātoo much gobbledegook and bland generalityā and ālacking focus.
Also, Ed Vaizey ā who was Minister for Culture and the Digital Economy at the time ā was also criticised for not being honest about the threat to Englandās cultural landscape from local authority cutbacks, brought about by the reduction in grants from central government that i mentioned earlier. Instead, inside youāll see Vaizey promoting āCommercial Academy for Culture to improve and spread commercial expertise in the cultural sectorsā and pledged culture for everyone. So ā very fluffy ā but meaningless in a practical sense.
The Heritage Statement, which came out last December at the Heritage Alliance AGM ā was actually a bit more interesting.
It talks about creating a 'HeritageĀ Councilā to āwork across all Whitehall departmentsā ā which was actually a recommendation made by APPAG when it first formed some 15 years ago.. so people like Lord Renfrew were glad to see it finally made into a DCMS policy document.Ā
We still need more clarity on what exact form/function the 'HeritageĀ Council' will have, and I do know itās something Heritage Alliance is keeping track off. They've just recently announced its core members which are the usual suspects such as Heritage Alliance, Historic England, the National Trust, HLF and so onā¦Ā
One thing i should add is in its launch, the then Minister of Culture was very pro-tourism so it may be that that's the underlying thread of this heritage council with tourism being one of the fastest growing industries.
Ok so onto changing policy. Um, a little warning - the slides from here on are text heavy...
So this slide is just to give an idea of some of the consultations and calls for evidence that have happened over the past two yearsā¦
Basically, a lot of change to planningā¦
Iām not going to cover all of them ā only the National Planning Policy Framework which you can see at the bottom, and then really briefly the Museum Review just to get the other end of the spectrum.
But the others are relevant as well and if you search online you can find responses from various groups or see its progressā¦there was actually just one open for two months, closed on the 10th, about revising developer contributions to development..but I donāt know the details about that but sounds pretty significant considering archaeology is largely funded through developed .
First Iām going to give a little background to archaeology in the planning system to bring everyone up to date with what Iām talking about. And I also want to add that commercial archaeology ā or development-led archaeology ā employs over 4000 archaeologists according to CIFAās annual report, and in another report by Landward Research, the commercial archaeology sector was the biggest employer of archaeologists, at least in 2013 when the report came outā¦
HERITAGE2020
There are five strategic themes of: Capacity Building, Constructive Conservation and Sustainable Management, Discovery Identification and Understanding, Helping Things to Happen, and Public Engagement. The vision and priorities for each of these themes are set out in the Framework document that was finalised in 2014. 1.3 At the end of 2016, Heritage 2020 ran its first consultation exercise. The consultation took the form of an online survey that sought to: ļ raise awareness across the historic environment sector of the Heritage 2020 initiative ļ gain input into the initial areas for action that had been identified by each of the five working groups ļ involve the wider sector in the Heritage 2020 initiative. 1.4 The consultation ran from 25 November to 20 December 2016. It was publicised through social media, at Heritage Day and through The Heritage Allianceās e-newsletter, Heritage Update. There were 55 respondents from people working at a wide variety of heritage organisations as well as freelancers and anonymous individuals. 1.5 The responses are summarised in this document under the five Heritage 2020 themes. The full responses have been made available to the Heritage 2020 working
NPPF
The previous Conservative Government of the 2015-2017 Parliament made a number of changes to the planning system in the Housing and Planning Act 2016, and the Neighbourhood Planning Act 2017 with the aim of speeding up the delivery of new homes. Changes to the planning regime for onshore wind turbines were also made in the Energy Act 2016, aimed at giving local communities a greater say about these developments. It also made a number of Budget announcements and published a number of consultations on planning reform. The most recent and most wide-ranging of these was the Housing white paper, Fixing our broken housing market, published in February 2017. The Government consulted on its proposals in the white paper, but had not issued a response before the 2017 general election. Responding to it and making changes will therefore be task for the new Government. Many of the planning related proposals in the white paper would be done by making changes to the NPPF. Some of the headline proposals from the white paper include: ā¢ giving local authorities the opportunity to have their housing land supply agreed on an annual basis and fixed for a one year period; ā¢ further consultation on introducing a standardised approach for local authorities in assessing housing requirements; ā¢ changing the NPPF to introduce a housing delivery test which will highlight whether the number of homes being built is on target; ā¢ increasing nationally set planning fees; and ā¢ further consultation on introducing a fee for making a planning appeal. Before the general election, in February 2017, a new consultation on planning and affordable housing for build to rent was published. The Government also published the report submitted by the Community Infrastructure Review Group
WHATS THE NPPF ā Introduce itā¦
Ok so very quickly.
In November 1990, the government basically put archaeology into the planning system by publishing a landmark guidance note for planning officers and anyone involved in the planning process called, Planning and Policy Guidance note 16Ā Archaeology and Planning and more commonly PPG16.
If you look through it, it very clearly mentions the importance of archaeologyā¦
and within it secured almost all of the advances made during the ārescueā era of British archaeology in the 1970s and 80s while reducing our reliance on state funding.
Here we see it very clearly saying archaeological remains are irreplaceable, and that thereās a presumption in favour of their physical preservation - which is now a presumption in favour of sustainable development.
Fast forward 20 years and PPG16 along with PPG15 gets consolidated into PPS5.
However PPS5 ā which aimed to promote the value of the historic environment ā didnāt really have the time to have much impact before being replaced by NPPF. Ā
With the 2008 Crash, the UK construction industry was devastated and so the 2010 Coalition government began their bonfire on both the quangos and regulation.
So what followed was the The National Planning Policy Framework (NPPF) which replaced PPS5, and dilutes a lot of principles laid out in PPG16.
So the we're revising came out in 2012 - and it basically streamlined the planning process ā it made it simple ā and it also supported localism or a sort of decentralisation of power. ..
What was positive about the NPPF is that it actually embedded archaeology and heritage, meaning it went in a core document of planning rather than a side guidance noteā¦
it also said that planning policies and decisions should reflect and promote relevant EU obligations and statutory requirements ā so for heritage, that's Valetta, Florence and Faro Conventions.Ā
Some of the negatives was that it virtually removed the emphasis of public engagement and archives and somewhat added to the idea that archaeology is an issue to be resolved.
It also began the over emphasis of designated heritage assets, perhaps to the detriment of non-designated heritage assetsā¦
And, you could say there was no real commitment in it for publishing results, beyond lodging an archive with a local museum.
So just to give an idea of legislation.
The NPPF is a framework which sits under the laws, Planning Act 1990 and the Planning and Compulsory Purchase Act 2004.
So there are Laws, or Acts ā
Planning Policy such as the Framework,
Advice ā such as good practice notes and so on
The NPPF is not a statutory document. Itās not planning law ā itās planning policy. Which means breach of it is not unlawful. Itās basically there to explain planning legislation, and is a guidance in a way.
Perhaps itās here I should mention two things which you may hear about..
In 2008 the introduction of the Community Infrastructure Levy (CIL) was secured under Section 106 of the Planning Act 2008. This is basically about negotiations and costs related to the impact and effects of development. The Community Infrastructure Levy is a a planning charge to help deliver infrastructure to support development in the area.
And this slide puts it into the various tiers of government
Ok so here what we're looking at is what the NPPF from 2012 ensured, and what has been removed in the recent draft. The consultation for the draft closed last thursday and Government is aiming to have something out by the summer.
Here's a list of relevant policy to the historic environment. All the red bits have now disappeared from the revised version, with the black text being moved around to footnotes or edited in some way.
The NPPF 2012 caused a lot of concern in how it really squashed explicit mentioning in policy towards the protection of the historic environment into a simplified framework. And now, 5/6 years on, we're seeing it getting squashed even more...
You can argue that different local authorities work in different ways to implement the framework, but if cuts are ruining services it's pretty hard to maintain things that can easily fall under the radar.
So here I'm just going through some of the text and marking out differences between the previous one that came out in March 2012 and the proposed draft that came out a couple of months ago.
The previous NPPF explicitly said that applications for planning must be determined in according with the development plan āunless material considerations indicate otherwiseā. In the new revised version we see the removal of a lot of references to the natural and historic environment ā sometimes put into footnotes. If you look in the previous NPPF it mentions material consideration 38 times, and in the new one only 20 times ā I should add that material consideration isnāt āmaterialā as in earth or anything, but can be a guidance consideration. For example, the NPPF is a material consideration for planning, or more commonly hear of, the PPG16 had mentioned archaeology as a material consideration in determining planning. So it's a sort of loss of a reference point perhaps.
Whatās on the slide are two paragraphs from old and new ā again one explicitly mentioning the natural and cultural environment, biodiversity, and so on, whereas in the new one theyāve removed the footnote referring to section 70(2) of the Town and Country Planning Act (which emphasised material considerations could override policies) and replaced it with a very vague strange paragraph talking about how the framework can be used loosely.
I should also add that theyāve removed the second bullet point on achieving net gains for nature as well as the footnote to the Natural Environment White Paper, the Nature Choice: Securing the Value of Nature (2011)ā¦
So ā again ā thereās a sort of oversimplification we see with the draft ā they donāt even clearly define sustainable development (whereas the previous one explicitly defined it using the UN definition of meeting the needs of the present without compromising the ability of future generations to meet their own needs.) Theyāve also removed explicitly mentioning āfive guiding principlesā which include living within the planetās environmental limits and the use of science and so on..
Here on the slide, is the presumption in favour of sustainable developmentā¦
The bit i've marked in red at the bottom - basically what it's saying is that development should by default be approved where policies are quote on quote out-of-date, but doesnāt specify what constitutes an out-of-date policy.
It seems to mean that all development needs to conform to existing policy and if local policy has conflicts with any new policy it should be considered āout-of-dateā. Basically theyāve put a āuse byā date on local policy declaring it invalid.. making it a new rigid and inflexible automatic grant of permission when LPAās are unable to demonstrate a constant housing supplyā¦
So again i'm just bringing up little changes that make a difference. I've also highlighted Footnote 7. That footnote points us to protected sites that are considered able to justify rejecting development. It lists Birds and Habitats, designated Sites of Special Scientific Interest; the Green Belt, Local Green Space, Areas of Outstanding Natural Beauty, ancient woodlands or trees, and designated heritage assets but basically refers us to ANOTHER footnote (footnote 55) within the footnote for 'other heritage assets'. And i'll explain why that' s relevant in a few slides...
This next slide is also from the draft..
I thought this was really interesting ā it's a sort of manifestation of a rolling back of government - which to me demonstrates a really neoliberal laissez faire approach within today's politics and economy. Basically, in order to put on a pre-commencement condition on a planning application, APPLICANTS themselves have to agree and accept it! Which seems to me to be an extraordinary case of conflict of interest.
Footnote 20 does mention āunless prescribed circumstances applyā, but the Government hasnāt set out what these so called prescribed circumstances are.
Pre-commencement conditions are part of a planning process that by definition must be undertaken BEFORE development, before destruction. And the question is ā why hasnāt archaeology been automatically exempt in this new addition to decision-making in planning?
Um, so this here is the deletion of paragraphs 169 and 170 of the existing NPPF. It basically sets out the policy requirement for local authorities to use up-to-date information on the historic environment to help predict the likelihood or potential of unidentified heritage assets showing up on future projects. They also require local authorities to have access to HERs and encourage the preparation of landscape character assessments.
SO these sort of policies are absolutely crucial to the way local authorities manage the likely occurrence of discovering unknown archaeology or heritage features during the development process.
It also supports them in providing the appropriate and timely assessment and management of discovering unknown features.
Elements of these two statements have sort of been added loosely to parts of the glossary of all places, completely downgrading its importance, and failing to address concerns of undiscovered heritage assets within the planning process at an early stage. It also doesn't really offer us much should archaeology be found on a site post-commencement of development worksā¦
These paragraphs have been replaced with a single sentence saying the conservation of wildlife and cultural heritage are important considerations.
So here - i've mentioned that a lot of policies are moving to footnotes. Thereās a lot of downgrading the importance of policy provisions by putting it into the footnote particularly if they are policies about how to when to refuse development. So immediately - a very clear statement the NPPF is pro-development. Which is not a bad thing - but there's a balance.
So here - this is the famous footnote 55 from a few slides back - the paragraph i've put a red cross next to is the main text policy from 2012 that has been removed and put into the footnote.
I just want to read it. It says Non-designated heritage assets of archaeological interest, that are demonstrably of equivalent significance to scheduled monuments.
So - not really giving too much attention to non-designated sites unless they are on the same bench as designated sites.
Ok moving quickly to the Glossary. As i mentioned some whole bits of main text are now here - specifically about access to HERs (which if you remember was in paragraph 169 that I showed as entirely removed)
First ā with āArchaeological interestā you can see that theyāve removed the last sentence.
Theyāve also actually removed the entire definition of the Historic Environment as wellā¦which is odd.
Then, Historic Environment Records are now considered resources instead of services. The question is really whether this reduces the scope and importance of HERs and whether it loses the link between HERs and their accompanying archaeological and conservation advisory services.
So - concluding the NPPF ā references to the āhistoric environmentā has been cut from 85 to 44 times. And what seems to be going on is really a progressive slow move away from one mindset into this minimalist mindset towards planning.
A lot of people argue that the natural and historic environment will never be removed from planning. If we think about it, it's only been in planning since 1990 in the UK - and since that time we see cuts in funding, support and institutional memory through staff cuts, and real changes in actual 'mission statements' and roles.
So to me - as everything - there is trade offs. Even the UN sustainable development goals have trade offs - or a sort of mutual exclusivity between some of them - so the question is - why can't it disappear. what's stopping it?
Ok quickly moving on to the Museum Review ā this was a consultation for the end of 2016. It was open for 2 months only ā they did get over 1600 responses to their online survey, and 30 written submissions from industry experts, museums, charities, funding bodies and other organisations.
The team analysed the responses and over the next couple months provided recommendations to Government in the Mendoza Review ā written by Neil Mendoza (a former banker) ā in 2017.
The inquiry was commissioned by government in response to the 2016 Culture White Paper that i showed earlier and it called for āa wide-ranging review of national, local and regional museums, working closely withĀ Arts Council England (ACE)Ā and theĀ Heritage Lottery Fund (HLF)ā.
Very briefly - i want to look at some facts and figures about museums. We could claim that Museums are at the heart of national and local culture, but theyve really been starved of funding over the past decade. The report itself states Museums contribute to a range of social priorities, including health, education, community engagement, and social inclusion.
They're alsoĀ actually visited by more than half of the population at least once a year, and three in Britain - the British Museum, the National Gallery and the Tate Modern - are among the top ten most popular in the world.Ā
They're actually a great contribution to the economy, the UK branding campaign, and to a sense of placemaking. But still - total Government funding has remained largely flat for the last decade.Ā
Between 2005 and 14, the Museums Association tracked more than 40 closures, with those funded by Local Authorities most at risk because of pressure on council funding.Ā
So the Mendoza Report actually depressingly opens with the line: āIt is unlikely that there will be significant additional money available for the sector in the immediate future,ā and so āThe main thrust of the recommendations is simple to ensure that we use existing funding in the best way possible.ā
It calls for the creation of a Museums Action Plan by September this year that would be designed to āhelp Englandās museums and galleries thrive and growā.
And it also actually even suggests that Britain should stop building new museums to ensure that the ones that we have can survive. The idea behind it is basically that
Institutions across the country are struggling to make ends meet and rather than investing in new infrastructure the money should be used to fix the historic buildings that house collections or help digitise collections for the modern age.Ā
Though backed by the Museums Association, it did cause some controversy. Keiran Long, A former V&A curator, responded that new museums are as "essential as bus stops, job centres or town halls to the communities they serve".Ā
The Government is expected to respond with an action plan for museums by September.Ā
There is definitely a gap between the Government ambition on what they want from museums and what they are actually setting out to deliver and support .
So here are the nine key priorities the Review recommends to be included in the Museum Action plan...
It's pretty shocking actually - the philosophy seems to be do so so much more with so so much less. Baffling. ā Helping adapt to todayās funding environmentā Improving the curation and management of collections so that they are accessible to the publicā Growing and diversifying audiencesā Ensuring museums contribute to the priorities of the local areaā Delivering cultural educationā Developing future leadersā Diversifying the workforce of museumsā Increasing digital capacity and using digital technology to create innovative and engaging exhibition contentā Working internationally
Where's the money? Here is how much less we are actually talking about.
This was published by the Department for Communities and Local Government (DCLG) confirming the decline in local authority funding for museums and galleries in England. You can see that spending fell from Ā£285m to 221m per year over a five year period (2010/11 -2015/16).
Adjusted for inflation, it represents a wopping 31% real-terms decrease between 2010 and 2016.
So we're talking severe reduction in staffing levels and in overall inability to do any basic front house tasks let alone the nine priorities we just saw!
Again, according to the Museums Association, since 2010 64 museums have closed across the UK nearly all because of cuts in public funding. Some councils have even flogged off things from their museumsā collections to supplement the shortfall in the central government subvention.
Sad.
Ok - so. Feeling down? depressed? annoyed? invigorated? Bored??
Well - you'll be pleased to know that changes dont need to happen without some noise.
Personally, id go as far as say that being involved in consultations - providing your evidence and raising the issues - is probably more important that voting.
These things sometimes feel that they write themselves - but they dont. Whoever is putting the pressure on and making the case, is the one who gets written into these things.
So get involved, there are lots of organisations and groups consistently putting pressure on government from things such as international students and their contribution to the UK, to acknowledging the importance of the arts, or HERs, and so on.
Nowās the time. Government is in minority in parliament without the DUP, so opposition is in a good position to pull on those issues and threads and ask the questions that need asking.
A quick flag up of a consultation closing in August that was announced last week if you're interested ā
A few months ago there was an Open Letter written by RESCUe about concerns with the rejection of the polluters pay principle, the precautionary principle and the preventative principleā¦
This is one of the UK documents in which some heritage organisations claimed those principles could be embedded into.
As far as I know ā not much has ever been mentioned about the historic environment by Gove with this future bill.
So ā this may be a good opportunity to flag that up.
And also, I'm a big believer in being involved with consultation - which is part of the reason AHRC Heritage and RESCUE are pulling together this conference in October.
These are just some of the speakers, we're waiting on a few more responses.
It would be great to see you there so mark it in your calendars!