The Welsh perspective

• Legislative context and background to the review
  in Wales

• Designations, listed building consent and partnership agreements

• Records

Welcome, introductions and general background to the review in Wales - Marilyn Lewis, Director of Cadw

Mrs Lewis welcomed delegates to the seminar and was pleased that a wide range of organisations were represented including local authorities and national parks, amenity societies, archaeological groups, Government agencies, interested organisations as well as Welsh Assembly Government officials from Cadw. Particular thanks were given to colleagues - Emma Brown and Jim Burke - from the Department of Culture, Media and Sport (DCMS) who had come to set the scene of the proposals as they related to England. Some invitees had told Cadw that they would have liked to attend, but that the date was not convenient. Cadw would therefore ensure that there was feedback from the day, and a seminar report would be produced and distributed which would enable written representations to be made. Similarly, Cadw would be discussing the issues further with colleagues in the Assembly Government since some of these matters would extend beyond the remit of Cadw.

2. The view had been expressed that an earlier seminar in Wales would have been helpful. However, it was not possible for Cadw to arrange one at an earlier date because there was no certainty when Ministers wanted to issue a White Paper - and the Culture Select Committee was also looking at the matter. However, as soon as it was announced that there would be an UK Government White Paper in the autumn, Cadw had moved to ensure that there was an early consultation seminar in Wales to allow time for views that would be considered to inform the drafting of the White Paper.

3. Mrs Lewis explained that the reform of the heritage protection system was one of the UK Government's strategic aims for the sector. The current protections had built up over many years - the first legislation for ancient monuments dated back over a century. We commonly referred these days to the 1953, 1979 and 1990 Acts - and others. Unlike other subject areas, however there were not regular Heritage Acts. The existing legislation was therefore arguably durable, although there were in contemporary society different expectations. We needed to be more open and accountable. We needed a system that reflected these changes in society to take us into the future and be fit for purpose for a number of years to come.

4. The perception was perhaps that while particular parts of the heritage protection process worked well the system as a whole was considered by some to be confusing and complex, especially for the general public. For property owners in particular, the systems of listing and scheduling were perceived as being secretive and unfair. The Government's proposed reforms were designed to tackle these issues by streamlining regulation and introducing greater openness and flexibility to the system as a whole.

5. There was support for change. Separate consultations were carried out in 2003 in England and Wales and the report produced in Wales after that consultation indicated that many supported an agenda for reform - especially in those areas that made the system more open and accountable. It was against this background that the UK Government was proceeding with its heritage protection proposals. The misplaced view had been expressed that legislative changes applied to England only, and not Wales. However, the fundamental principles of transparency, streamlining regulation and accountability were shared by Ministers in England and Wales and a joint White Paper and Bill were envisaged. Given that the current legislative framework was the same for both countries and that some heritage assets crossed boundaries, it was anticipated that many of the new measures would apply in each country.

6. However, there were currently differences in approaches and application in Wales and these must be reflected in the proposals for Wales. It was proposed to have a specific section to cover Welsh needs and proposals in the forthcoming White Paper and this seminar centred upon discussing the Welsh perspective. The seminar though was not about decisions. At this stage, although Ministers had indicated general principles and headline reforms, details were still to be determined. This seminar was about ideas, sharing experience and dialogue to ensure that views were expressed and taken into account in considering the best way forward for Wales. It was critical that delegates, and others working in the historic environment in Wales, took advantage of the opportunities to contribute to this process.

7. It was important to consider the Welsh context against the background of developments in England. Some of the measures we would want to replicate because they make sense for circumstances in Wales, but others might not suit our circumstances and we would need to develop our thinking on these through the course of the day and in the weeks and months to come.

The Review in England - Emma Brown, Department for Culture, Media and Sport

8. Ms Brown said that she was pleased to attend the Welsh seminar to be able to talk about the Heritage Protection Review (HPR) as it related to England, so that it might help inform discussion about what might happen in Wales. Although the prospect of a Welsh seminar had been considered for some time it had been delayed because the overall time-scale of the White Paper had slipped. But it was timely now because things have moved on with the outcome of pilot projects in England so there was more of an insight into how the proposals might work in practice - although much still remained to be decided.

9. Paradoxically, this was both a joint and separate process. Joint because the primary legislation is on an England and Wales basis and a joint White Paper was planned - but separate because there was flexibility in operation to allow for different circumstances in Wales.

10. The context for the HPR in England developed from two key policy documents, though there was also a quite separate policy review undertaken in Wales. The first was Power of Place published in 2000. This was a sector-wide review of policies relating to the historic environment in England, led by English Heritage.

11. Power of Place underlined how much people valued the historic environment, and how much they thought it contributed to their quality of life. It emphasised the importance of effective partnerships for managing the historic environment and made a large number of recommendations aimed at central government, local government and the heritage sector about how to develop these partnership and improve our management of the historic environment.

12. The Government's response to Power of Place was A Force for our Future and was published in 2001. This confirmed a lot of the findings of the Power of Place report and underlined that the historic environment was valued both for its own sake and for the wider contribution it made to other policy agendas.

13. A Force for our Future set out five Government objectives in relation to the historic environment:

• That there was firm leadership and partnership in the sector, with a sound knowledge base
• That the full potential of the historic environment as a learning resource was realised
• That the historic environment was accessible to everybody
• That it was effectively protected and sustained
• That its importance as an economic asset was harnessed.

14. The HPR was the Government's means of achieving the objective in relation to effective protection. It was though also worth noting that delivering an effective heritage protection system would provide an important stepping-stone to achieving the other four objectives.

Planning reform and the historic environment

15. Of course, the historic environment does not exist in isolation, and the HPR in England was not only a DCMS project, it was also an important part of the UK Government's planning reform agenda. As research carried out for Power of Place showed, the historic environment was central to providing a sense of community for many people. This sense of community was an important building block in developing sustainable communities - places where people wanted to live and work, both now and in the future.

16. The 2005 Planning Act had made sustainable development the statutory purpose of planning. The effective protection and management of the historic environment was a key means of achieving this sustainable development. Engaging people and communities in decisions about the environment in which they lived was another key aim of planning reform. The historic environment was one of the most powerful catalysts for this involvement. People wanted a say in how historic buildings and sites around them were maintained, used and developed because they cared about them.

Why reform?

17. There were specific reasons behind the proposed reforms. In 2003, DCMS published a consultation document on reforming the heritage protection system in England - and there was a parallel exercise in Wales with ideas for change. The consultation in England identified three key drawbacks to the current system.

18. First, as a result of being built up piecemeal over time, the heritage protection system was considered over complex. There were a variety of different designation systems, which operated to different criteria and were administered in different ways by different people. These different designation systems were linked to different levels of protection and regulation. To illustrate this a photographic slide was shown for St Leonard's Infirmary in York, which illustrated how complex it could get when sites had multiple designations.

19. The infirmary was both scheduled and listed at grade I. Underneath the infirmary were the remains of Roman Interval Tower, (which was included in all the designations); it sat in a grade II registered garden, which also contained St Mary's Precinct, which was scheduled. This complexity meant that any works that might be needed were a bureaucratic nightmare. Scheduled monument consent was administered by DCMS, with advice from English Heritage; listed building consent was administered by the local planning authority with advice from English Heritage in certain cases.

20. Linked to this complexity was a perceived level of secrecy and poor provision of information and, until last year, owners were not routinely told whether their building was being considered for listing. Even where information was not being withheld, it could be hard to get hold of and seemed even harder to understand.

21. Second, the system was slow and expensive for everyone involved. In England, the average time taken to process a listing application was six months, though for complex cases it could be a matter of year; and processing an application for scheduling took around four months. The time taken to process consents was much shorter, with most local authorities achieving the eight week target, and the new Planning and Compulsory Purchase Act helped to speed up some elements of the process. But time-scales associated with the system could still involve considerable costs for owners, managers and those involved in development. Ms Brown understood that the system generally operated at a more accelerated pace in Wales.

22. Finally, the system was regulatory and burdensome. It was a system that was considered to be very good at saying 'no', but was less good at encouraging the effective management of sites. The number of separate consent regimes, combined with planning permission, involved huge amounts of paperwork. The Department for Communities and Local Government (DCLG) was introducing a standard application form which would help streamline the system in England, but there was much more scope for rationalisation.

Aims of the review

23. Responses to the 2003 consultation exercise in England supported the conclusions about the current heritage protection system. There was a clear and consistent call for reform from across a number of different sectors. The aim of the HPR was to design a new system that was:

• Open - so that it was easy for people to understand and to become involved in
• Simple - so, that it was more streamlined and efficient
• Democratic - so people, including owners and managers, had the opportunity for their voice to be heard in the protection process
• Accountable - so decisions could be justified.

Principal reforms

24. But what did these aims mean in practice? The recommendations following the consultation in England were set out in a decision document that was published in 2004.

25. DCMS wanted to introduce a Unified Register of Historic Sites and Buildings of England. This Register would unify the currently separate designation systems of scheduled monuments, listed buildings, registered parks, gardens and battlefields, and World Heritage Sites into a single process, administered by a single organisation - responsibility for designating would be transferred from DCMS to EH. As an interim measure to improve the system, EH had already taken over the administration of the listing system, although DCMS still made the decisions.

26. Creating the new Register was not as simple as joining the existing lists together and there would be new statutory definitions of historic assets accompanied by new selection criteria for each type of asset to back up the new unified Register.

27. Prior to designation, EH would begin consulting on applications to designate. This provided the opportunity for those with knowledge of the site to provide information relating to whether the site met the statutory criteria for designation. Previously, the first some owners might have known of a listing application was a letter to confirm that the property had been listed, so this development went a long way to opening up the system.

28. Understandably, there was concern that telling people about an application to designate before a decision was made, may lead the less scrupulous to damage their property, destroying any special interest, so it could not be listed. Therefore, DCMS was considering the introduction of interim protection and how this might complement or replace the current Building Preservation Notice system.

29. The new Register would fundamentally change the way in which sites were described and mapped. Ms Brown understood that in Wales list and scheduling descriptions were far more comprehensive than in England, where many were considered inadequate. This was illustrated by the list description for Canterbury Cathedral (grade I listed and a World Heritage Site) but where the description was only seven lines long.

30. The new style Register entries would be more comprehensive, indicating why they had been designated and why they were considered to be of special architectural or historic interest. This would improve people's understanding of historic sites around them or in their care, information vital to those applying for and processing consent applications. The pilot projects demonstrated how helpful these were when drawing up Heritage Partnership Agreements (HPAs). The list description for one of the pilot projects at a London underground station indicated areas that were not of special interest. This made it clear to owners and the planning authority that works carried out there would not need to be given the same level of consideration as other areas, therefore reducing unnecessary consent applications or enquiries.

31. A clear description, with a summary of why the site was important, would also play a crucial role in the new statutory appeal process. Currently, a review of a listing decision could be requested, but this was made to DCMS, which was responsible for designation. EH would be responsible for the designation; and so the new right of appeal would be to the DCMS Secretary of State. The basis of an appeal would be either that there has been a mistake in the process; or that the site did (or did not) meet the criteria for designation.

32. DCMS was also considering revising the grading system for new items on the Register and whether it would be appropriate to introduce it for archaeological sites - potentially merging grade I and II*.

33. The new Register would provide the opportunity to remove dual designations and there would be a local section, to include conservation areas and other locally important sites.

34. DCMS was also committed to ensuring that all local authorities in England should have access to HERs. Extending provision of the HERs would provide a vital resource to planning authorities and historians and as an educational resource. Meeting a defined national standard, HERs would link to DCLG's e-planning to aid planning authorities' knowledge of the historic environment, and benefit environmental stewardship schemes.

35. The second element of the reforms in England related to the management of the historic environment. The key proposal was the integration of separate regimes of scheduled monument consent (SMC) and listed building consent (LBC) into a new unified heritage consent. This would not mean that all historic assets were treated in exactly the same way. That would be inappropriate and impractical. DCMS needed to ensure that the consent allowed sites in use to change and adapt in a way that their special interest was not compromised; but archaeological sites and monuments, where it was assumed that major change was undesirable would be under closer supervision - similar to scheduled monument consent now.

36. This was demonstrated to be a useful approach at another pilot, Kenilworth Castle. Here, there were a range of designated structures on the site, and the new unified designation system clearly distinguished below ground archaeology and monument structures from standing buildings that were either in use or were capable of adaptive re-use, replacing the current confusing overlaps of listing and scheduling. On the basis of the definitions of these different assets in the new Register, it had been possible to match the regulatory regimes to deliver either detailed scrutiny of repair and maintenance at one end of the scale or more dynamic change of use and adaptation at the other.

37. The proposal in England was that local authorities would administer this new consent, with involvement from EH as appropriate. It would also be taking this opportunity to review the class consent for ploughing. DCMS also wanted to introduce a new management option for historic sites called Heritage Partnership Agreements (HPAs). These would be statutory agreements between the owners and managers of sites, local authorities and, where appropriate, EH. They would set out a vision for the management of the site over a period of 5-10 years including conservation principles underpinning any work on the site, a schedule of minor works that would not need individual consents, and an assessment of major works that would need consent.

38. The intention was that these HPAs would improve relationships between the organisations involved in protecting and managing sites, and would streamline the current consent process. HPAs were likely to be time consuming to negotiate, implement and monitor and would not be suitable for all sites. But they might be very useful for large, complex sites, or for a number of similar assets under the same ownership.

38. HPAs were not though a replacement for planning permission for major works. They were designed to cover foreseeable works with a description of how the works were carried out. If the duty holder did not intend to carry out the works in the way specified in the Agreement, then consent would have to be applied for. If works were not carried out as specified, and separate consent had not been gained, then the usual legal framework would apply and enforcement action could be taken. The pilot projects in England had shown how effective they could be.

The Cornish Bridges pilot

39. A series of bridges, crosses, and milestones owned by Cornwall County Council as the highways authority but with input from 3 district councils was considered as a pilot because they had been cumbersome to manage in the past.

40. The current systems were inconsistently applied - some of the assets were listed, some scheduled and some both. One bridge had 2 list entries, one for each end of the bridge, in different parishes with different names and grades. Scheduling did not fit well with bridges that were still in use - likewise, listing did not sit well with monuments such as milestones and crosses because they were redundant. Processing the consent applications could take some time and many of them were repetitive - for example, minor works for vegetation clearance took around four months to approve; this became more problematic when bridges were damaged - some were on Cornwall's tourist trail and they were not designed for modern traffic. One bridge was damaged four times in one month, which could result in a lot of repetitive paperwork.

41. The documentation of the assets was reviewed. Dual designations were resolved and new style Register entries were drawn up, with a description of the asset and a 'summary of importance' - an explanation of why the site met the criteria. The planning authority and EH drew up a HPA, with assistance from the Milestones Society.

42. The HPA had a conservation framework. This set out the principles for managing the asset, a list of the assets included, the works covered by the pilot with a clear description of how works should be carried out, and works not covered by the Agreement. As a result the elapsed time in place for decision making could reduce from three months for scheduling to two days; and for listing from two months to two days.

43. There had been other less quantifiable benefits. The technical rigour of the works specification ensured that work was carried out to a high standard, working relationships and communication between partners, and within the council, had improved and the Agreement demonstrated to the public the council's commitment to maintaining its historic assets to a high standard.

Other proposals - short term

44. These changes would not require a change in the law to make them happen. Given this, the English review also involved a number of short-term changes to improve the current system that could be made within existing legislation.

44. The first short-term measures were a series of changes to the current listing system that would be implemented over the course of 2006. In 2005, DCMS transferred responsibility for the administration of the listing system to EH. EH was due to introduce a number of improvements to the system - such as new notification and consultation arrangements, and the provision of new information packs to the owners of listed buildings.

45. The second short-term proposal involved changes to the current criteria used for assessing buildings for listing. In 2005 DCMS launched a consultation exercise setting out revised criteria that were designed to fashion a more open system by making listing decisions easier to understand. DCMS planned to publish the analysis and revised criteria with the White Paper.

Other strands

46. In addition to the main review process DCMS had also undertaken two separate reviews - one of the ecclesiastical exemption from listed building controls, and a second on the marine historic environment.

47. In terms of the ecclesiastical exemption, it was worth considering that historic churches account for 45% of Grade I listed buildings in England. The review in England concluded that there was a strong case for the ecclesiastical exemption to continue in its present form, but that the rest of the system governing the protection of church assets would need to reform along the same lines as the HPR.

48. The proposed heritage protection reforms, particularly improved designations and HPAs, had the potential to bring real benefit to church sites. As a next step, DCMS had set up a small number of pilot projects in partnership with the Church of England to look in detail at how a revised protection system might work alongside the ecclesiastical exemption.

49. The separate review of the marine historic environment had considered how a simpler, more open and flexible system might be delivered in light of the particular needs of the marine environment - where ownership, use, access and mapping could all be more complex than on land. A key issue had been that much marine protection legislation was UK-wide, as opposed to the land reforms. With colleagues in Wales, Scotland and Northern Ireland, DCMS had been considering how to balance this UK-wide issue against the desire to see as much commonality as possible between terrestrial and marine systems.

50. The marine review's two working groups had been looking at the issues of definitions and designation, and salvage and were finalising their reports.

Local authorities

51. It was important not just to change the designation and management of historic assets, but also to streamline the administration relating to them. Inevitably, in England, EH would be instrumental, but local authorities would also play a key role as administrators of the new heritage consent, and as negotiators in heritage partnership agreements and DCMS needed to ensure that local authorities were equipped to do this.

52. DCMS had carried out research in England that looked at current variations in models for delivering historic environment services at local level, and assessing the capability of these models to deliver the HPR reforms. This had been encouraging and had thrown up lots of examples of local authorities that were already collaborating to deliver historic environment services in innovative ways. It also highlighted that for local authorities that were already strong supporters of the historic environment (the historic environment champions), the proposed reforms were seen as an extension of current practice. For local authorities with little focus, it was more challenging.

53. Similarly, while the research highlighted some concerns in local authorities about resources, in general there was widespread support for the principles of the reforms. District councils in particular saw these as an opportunity to take greater ownership of the management of the historic environment, so the research had found very little support for sub-regional pooling of services.

54. While concerns had been expressed about resources, these were primarily about start-up costs rather than ongoing management of a new system. HPAs would be optional for local authorities and whilst they would have the new equivalent of SMC to administer, current levels of consent applications worked out at an average of no more than four per authority. The heritage protection review represented a very helpful opportunity to clarify Government expectations in terms of local historic environment services and to help create a useful 'job description' for local authorities in relation to historic environment services.

Timetable

55. DCMS intended publishing the joint England and Wales White Paper later this year - the timetable had been pushed back because there had been a recent Culture Select Committee inquiry in England into heritage, which was due to report in June 2006. It was sensible to consider its comments before any new legislative proposals were published.

56. Assuming that UK Parliamentary time was secured DCMS envisaged that new legislation could be introduced in the 2007/08 Parliamentary session and implementation in 2010.

57. To conclude, DCMS was very positive about the HPR. Responses to the consultation in England had shown a huge amount of support for its proposals, and a system could be delivered that brought real benefits to everyone involved. This had been borne out by the EH pilots, and good progress was being made towards the White Paper.

58. This was though a complex set of reforms. It was essential that people, both the public and professionals, were aware of them, understood them and were convinced of their value. This seminar was a very important step in the communication process.

Designations, listed building consent and partnership agreements - Laurence Burr, Cadw

66. This seminar was about helping the Assembly Government decide how the ideas which have been described for England, or some variation of them, could operate sensibly in Wales to improve and strengthen the existing heritage protection arrangements. It was important to consider that further in the area of designations, listed building consent and Heritage Partnership Agreements.

67. Ms Brown touched on what some people had perceived as the degree of secrecy attached to the system, and the paucity of information. She also described the importance in England - which we share in Wales - of engaging people in the processes and ensuring that when decisions were made which affected them they were done so openly. In this way those affected would understand the reasons for that decision and had the opportunity and the means with which to challenge it.

68. In the course of the accelerated listing resurvey Cadw recognised early on
that it had to try harder to give owners more information about the importance of their buildings when listed. That is why, a decade or so ago, Cadw decided that it should change and add to the format of list descriptions to provide more information about what made a building important and why it was listed. This was in addition to responding to requests from local authorities and others to provide more descriptive narrative of a building's principal features to better inform development control decisions.

69. An example of this new fuller style description was illustrated in an example of Ardwyn Nursery and Infant School, Welshpool, which was listed in 1996. The expanded justification statement was written to provide the education authority with clear guidance on the building's importance and to inform its approach to future works. Delegates were asked for their views on this approach and whether it needed further refinement. It was also for consideration whether this principle should be extended to those buildings listed before 1996 - some, 9,000 or so - which currently did not have listing justifications. As in England, practice in Wales has been, when applicable, to distinguish those parts of buildings which are not of special interest. An example of this was the Cyncoed Methodist Church in Cardiff, which had some parts that were of less importance than others. It would be helpful to know whether this was an approach that Cadw should develop further.

70. Cadw had also progressively introduced fuller and more informative scheduling entries, again with the intention of better describing the importance of a site. There had also been some changes in the level and frequency of contact with owners. During the survey, contact with owners ahead of listing was the exception rather than the norm. This approach was fuelled by concerns that, as elsewhere, some unscrupulous owners might, on being given notice of listing, carry out precipitate works. Where contact with an owner was necessary perhaps to assess the interior of a building for listing and there was some concern about the owner's intentions towards it Cadw would bring forward a building for spot listing and send informal notification to the owner afterwards.

71. Most recently however Cadw had begun formally to advise owners of a request to list and inviting comments explaining, with supporting material, the purpose of listing and what the implications of statutory protection would be if confirmed. In the case of the relatively few listings undertaken since the end of the survey this direct approach had not generated any particular concern as to a building's integrity and this seemed set to become a formal part of procedures. But it would be helpful to know from delegates experience whether Cadw needed to guard against possible losses through applying some interim measure of protection perhaps in the way that had been touched upon. Interestingly for proposed schedulings, Cadw had always consulted owners of monuments identified for scheduling and this was a practice it would continue. Cadw knew of no example where advance notification of scheduling had led to the loss of important remains.

72. Emma Brown had mentioned changes to the listing criteria and the work being undertaken in England. In Wales, we had not thought it appropriate to revisit these while the survey remained incomplete to avoid introducing any inconsistencies in the selection process. However, now that it had finished the Assembly Government would want to look at this area in the light of evidence emerging from England. It would be helpful to have delegates views on this to ensure that the criteria continue to capture the distinctiveness of Welsh buildings and evolve over time so that they remained relevant.

73. There was currently no statutory appeal process against designation decisions. Cadw's practice had long been however to act as if there was, and, when owners had objected it had assessed the appeal as objectively and independently as possible - often involving a different inspector not otherwise involved in the case. But for some owners the absence of a statutory right of appeal had been a significant matter of principle and one that they told us was at odds with their human rights. Ministers in the Assembly Government were sympathetic to this and wanted to provide a statutory right of appeal. The dilemma for Wales - unlike England, which had the benefit of EH at arms' length from Government - was to whom should the right of appeal be made. Was it right that an appeal was made to the Assembly Government when it was the Assembly itself which designated the asset. This arrangement might not be thought to provide sufficient independence. Cadw had no settled view on how this would best be applied in a way that provided appellants with the confidence that their appeals were being evaluated properly and we would welcome suggestions.

74. One idea Cadw was considering was that if appeals were to be made to the Assembly then it might invite an appropriately experienced body - at arms length from the Assembly, but linked to it - to advise on the appeal while retaining the adjudication role to the Assembly. We should be glad of suggestions as to who and how this role might be performed. One idea - and it was no more than that - was to invite the Assembly Government's newly reconstituted independent advisory bodies the Historic Buildings Advisory Council and the Ancient Monuments Advisory Board to advise. Delegates were invited to express their views on that.

75. Mr Burr referred to the suggestion that a unified consent should be sought from local authorities. In the case of listed building consent applications, Cadw received some 1,000 notifications annually of consents authorities were minded to approve. Notification was to provide the Assembly with the opportunity to call in applications for its own determination. In practice few were called in and those that were, were those which gave rise to issues of particular significance or controversy. Applications to authorities for consent to works to listed buildings presented some particular issues in Wales where the level of local authority expertise was thinly spread. The idea that local authorities should be a one stop shop for consents had clear attractions in terms of ease of application, but in Wales this might be more difficult to pursue than in England where there were differing traditions with regard to local authority involvement in the consent process.

76. In the case of listed building consent it had been an objective of Cadw for a number of years to build up at local authority level an increased awareness and understanding of the issues which confronted the management of a designated property. That was why we had encouraged, amongst other things, each authority to establish its own Buildings at Risk Register and it was comforting to know that most now had. But the concept of listed building consent delegation had proven less attractive with only four authorities currently enjoying a right to determine certain applications in its area. It was for consideration whether, against this background, the time was right to embrace in Wales the sort of changes for consent to works to buildings envisaged in the HPR. The principal difficulty, which seemed to have prevented a greater take up of delegation in Wales, was the absence of experienced or qualified conservation officer staff at local authority level. So in these circumstances, and in the light of the proposed reforms outlined in the HPR package, were there any other approaches which suggested themselves?

77. The HPR reforms described proposals to introduce management type agreements to improve and speed up decisions on the multiple designated sites. It was for consideration how much of this could usefully be applied in Wales as it did not, by and large, have the complex sites of the sort that had been described in England. The principle may though have some application in relation to those estates, which enjoyed multiple designations. Cadw would be glad to know how delegates saw all of this applying to Wales. Local authorities already had the option of discussing with owners a forward programme of anticipated works to identify any difficulties and to review these with the owner to ensure that the formal application process was taken forward as painlessly and as quickly as possible.

Historic Environment Records - Richard Avent, Cadw

78. As had been explained, the current proposals envisaged the new heritage consent regimes being administered at the local authority level as part of the wider consent process. Although viewed as one heritage consent, it would have separate strands according to the type of asset. Hence SMC would continue to have the same force as at present with emphasis on the continued long-term preservation of the site.

79. By way of background, in Wales last year Cadw processed 100 scheduled consent applications. This figure had remained largely unchanged over recent years despite the fact that the number of schedulings increasing by between 110 and 120 per year. These days most scheduled monument consent applications were for positive works or those that had a largely neutral impact on the site. 20% also involved successful applications to Cadw for grant aid, sometimes also involving advice, particularly on the conservation of upstanding masonry, from Cadw's specialist Inspectorate and architectural staff. These consent and grant processes were dealt with by Cadw, as an integrated process. Some of these grant cases were also among the 40% of last year's applications for SMC which were made by local planning authorities and which, by analogy with the existing listed building consent arrangements, would need to be determined by the Welsh Assembly Government under any devolved arrangements.

80. An issue that needed to be considered was how the remaining 60 or so scheduled monument consents per year would be administered by local authorities bearing in mind that, currently, only three authorities - Wrexham, Denbighshire and Blaenau Gwent - and two of the three National Parks - the Pembrokeshire Coast and Snowdonia - had in-house archaeological expertise. Alternatively, there may be a view that the number of applications was too small to justify delegation and that Cadw should continue to perform this function.

81. If Wales followed along the same lines as England, Cadw would maintain the Register of Historic Sites and Buildings of Wales, which would probably, also be accessible locally via the Historic Environment Records (HERs). The HERs would then play an important role in delivering the new arrangements at the local level. In England, most HERs were located within local authorities that were statutory bodies while in Wales the regional HERs were based within the four Welsh Archaeological Trusts, which were registered charities and did not have a statutory status. Some Welsh local authorities and National Parks had their own historic environment records although seemingly these appeared to concentrate on listed buildings.

82. The Royal Commission on the Ancient and Historical Monuments of Wales maintained the National Monuments Record for Wales. It had also established an embryonic maritime database for Wales. Cadw had digital databases for its records of Scheduled Ancient Monuments, Listed Buildings and Historic Parks and Gardens, and Amgueddfa Cymru - National Museum Wales has a digitised database for its collections. In recent years these three national organisations and the Welsh Archaeological Trusts had worked together to implement a Strategic Framework for Records Relating to the Historic Environment of Wales. One of their aspirations was to establish a common web portal to all these records.

83. In addition to their existing heritage management and development control roles, the HERs would underpin any new arrangements for local delivery of the HPR review proposals by providing high quality, electronically accessible records. To do this all records within the HERs would need to be comprehensive, of a high standard and consistent in terms of data standards. They should also be available on line via the Trusts' websites and accessible through a common web portal. Work was already under way in Wales, much of it funded by the Royal Commission, to help the Trusts achieve the first benchmark standard in the Historic Environment Records: Benchmarks for Good Practice, published by English Heritage and the Association of Local Government Archaeological Officers but these were likely to undergo revision in the near future. The Royal Commission was also leading the way in establishing consistent data standards.

84. One issue for consideration involved what one might call the interoperability of databases at the local level. All four regional Trust HERs had well-developed records of archaeological and other historic sites which were used on a daily basis for development control advice to local planning authorities. Over recent years much of the site data in these records had been enhanced through field validation undertaken as part of a series of Cadw-funded projects. As far as was known, local planning authorities relied on their own databases and, where these had been compiled, local buildings at risk surveys, for their historic buildings work, particularly listed building consents.

85. Under the proposed arrangements the data on all the assets to be covered within the unified consent regime would reside in the regional HER which would contain, or have access to, the databases of nationally-designated assets. However, as opposed to England, the HER would not itself reside within the local authority. One of the issues to be considered was how all of this might work in practice - how comfortable local authorities might feel in moving away from the use of in-house databases to a more integrated regional HER.

86. A rather more difficult issue which still had to be resolved on the wider HPR review front was how a maritime database was to be accommodated and used in Wales if, following the results of a separate review, it was decided to include maritime assets within the new Register and consent processes.

87. Finally, the whole issue of record enhancement in Wales needed to be linked to providing long-term security for the Trusts' records and the Government's statement that it would consider making access to a historic environment record a statutory requirement of all local authorities. The way this might be implemented in Wales, where the main records were not held by statutory bodies, needed further consideration and may be another of the issues for discussion.

• Powers of enforcement - it was noted that no reference had been made to enforcement powers and whether these might be included in an eventual White Paper. It was not intended that enforcement would be an issue in the White Paper and the powers would remain as now.
• Local authority resources (lack of) - in England a research study had been undertaken to assess the capability of local authorities to handle the additional responsibilities and work envisaged in the HPR reforms. There were no plans to replicate this research in Wales and it was for consideration whether there would be any value in doing so until such time as decisions of principle had been taken on what additional responsibilities it might be appropriate to delegate local level.
• Wider historic environment agenda - it was right that consideration should be given to devolving decision making to a more local level to enable the Assembly Government, and Cadw, to consider wider issues of strategy and move the historic environment into other areas such as the economic and sustainability agendas. It was noted that in its forward work plan Cadw was focusing on how it could create a climate where the value of the historic environment could be recognised in wider policy areas.
• English pilot studies - delegates found the results of the Cornwall pilot study interesting and questioned whether the results of the other pilot projects would be made public. It was noted that DCMS intended to publish the results of the most advanced pilot studies (not necessarily the best, or most successful) at the time of the publication of the White Paper. It was likely that eight pilot projects would be reported on at this time.
• Scheduled monument consent - the numbers of applications dealt with annually in Wales quoted did not take into account the intended review of class consents, following which, the number of SMC applications which might need to be dealt with might increase. Before delegation it would be necessary to make a more detailed assessment of the numbers involved following the class consents review. It was recognised that this was the case, and that there would be claims for compensation relating to ploughing. Cadw would also consider how it might encourage farmers to consider less damaging ploughing techniques.
• Historic environment service - there was a need to ensure that local authorities had adequate skills and training to deliver an holistic historic environment service before placing with them the responsibility to do so. However, in England, it was undecided how this might translate into additional resources from central Government. It seemed evident that local authorities would not - and this was evidenced by the experience in Wales of delegation of listed building consent applications to the local level - take on additional responsibilities until they were obliged to do so by the covering legislation.
• Locally important buildings - although not addressed in great detail in the presentations, the value of local lists of historic buildings was considered to be a fundamental part of the Register and this would be addressed further in the White Paper. It was recognised that this was important in any drive to building community capacity within the historic environment and in engendering a sense of pride of place.
  

Group Discussions

89. Three breakout groups were organised for the afternoon session of the seminar, each looking at distinct areas of the HPR. The following points are intended to provide a flavour of the discussions entered into and the issues which prompted most discussion. Discussions within the different groups were managed and evolved in a different way and it is therefore not practical to reflect these in a consistent pattern.

Designation - Facilitator: Frank Olding

Grading

• If there was going to be a hierarchy between the assets, why get rid of Grade II*.
• There would be a resource issue about regrading Grade II* buildings unless they all automatically became grade 1 and then were reviewed over time.
• The presumption was that the meaning of Grade II* tended to be that the interior was good and/or there was good historical association with it, so it was more than Grade II but did not quite merit Grade I.
• Was Grade II* confusing to some people because it had not been clearly explained - would it be better to clarify meaning?
• Was it just the name that was confusing?
• If we still needed three grades, why not change it to Grade 1, 2 and 3 or Grade 2, 1A and 1B?
• Would sites on the local list have a 4th grade?
• The new system would need to clarify, whether, and to what extent, the site was protected.
• How would the hierarchy relate to appeals in the planning process?

AGREEMENT: The new system should retain a hierarchy with greater clarity on what the grades were and what they meant. The hierarchy was valuable when managing the site.

Grading of Scheduled Ancient Monuments (SAMs)

• All SAMs should be Grade I because they were of national importance - although the group recognised there was a hierarchy for listed buildings which were of national importance.
• Some SAMs were scheduled "on a hunch" and so it was unclear how important they were and difficult to make a judgement how important they were.
• It was recognised that, for example, Stonehenge was more significant than a single barrow on Dartmoor and therefore should be regarded differently.
• SAMs could have similar bands to buildings, with a proportion of grades allocated to a number of sites.

AGREEMENT: There should be grading for SAMs.

Register of parks and gardens

• Parks and gardens should be part of the statutory Register.
• A number of parks and gardens were not included in the current Welsh Register because it was a voluntary arrangement.
• What would happen to those who previously did not want to be on the Register? Would they be forced into Registration? There would need to be a right of appeal.
• People had chosen not to be on the Register because of security fears.
• What about Registering landscapes?
• Could locally important gardens be on the local list?

AGREEMENT: This was a good opportunity to look at all types of historic assets and the discussion group was broadly in favour of inclusion on the statutory Register. If the park or garden was in local authority ownership then it should automatically be on the Register and not be subject to the voluntary arrangement extended to others.

Consultation and interim protection

AGREEMENT: There should be consultation and a system of interim protection because people would damage properties to prevent registration. A value could not be placed on the historic environment and therefore if structures or buildings were of value they should be protected.

Appeals

AGREEMENT: If there was prior consultation, then there should be the right of appeal.

Other matters:
It was recognised that there was no battlefields register in Wales but should one be developed then it should be included in the Register.
Consideration should be given to whether conservation areas required a grading system because some might be more important than others.
There were challenges with ecclesiastical exemption because some denominations had better resources than others to maintain their sites and it was hard to justify the exemption in the longer term.
Marine archaeology must continue to be considered on an UK wide basis and have consideration for the DEFRA marine bill.

Records - Facilitator: Richard Avent

The workshop was attended by ten delegates (three local authorities, four Welsh Archaeological Trusts, one RCAHMW and two Cadw).

A paper - reproduced at Annex B - was distributed to workshop members to facilitate discussion.

There was general agreement that the Welsh Archaeological Trusts' Historic Environment Records would need to be brought up to the same standards as had been identified for the Historic Environment Records in England before implementation of Heritage Protection Review proposals. It was recognised that local authorities and national parks currently had their own databases for servicing historic buildings' work (particularly listed building consent applications) and these databases might also be linked into other related work. Assuming these were fit for purpose, it was unlikely that local planning authorities would wish to change their arrangements in the light of the Heritage Protection Review and rely exclusively on the Trusts' Historic Environment Records. However, the Historic Environment Records would have an additional duty in providing information (and possibly advise) on scheduled monument consent applications and other work related to the unified consent regime. It was noted that in Wales there was no national Buildings at Risk register, but a number of local planning authorities held local lists. There may be scope for these lists to be shared, for example on HERs, and that local authorities which did not have registers might be required to do so.

The workshop held the view that a key to the new working arrangements would be ready access to the main databases (Historic Environment Records, National Monuments Record of Wales and national register) via a common web-portal. Both further development of the Historic Environment Records and the web-portal to bring them up to Heritage Protection Review standards would require additional funding.

There was general agreement that a statutory requirement should be placed on local authorities to maintain historic environment records themselves or, if they were unable to do this, then through the agency of others. In Wales, such an arrangement could cover in-house maintenance of historic buildings' databases and service level agreements with the Archaeological Trusts to maintain the wider historic environment record.

Consents - Facilitator: Edward Holland

Delegation of the consents system

Are the current systems good at saying 'no'?

• Reality is 'yes, but' in majority of cases, or simply 'yes'.
• In Flintshire 88% of LBC applications were approved.
• Legislative terms implied negativity.

Is full delegation to local planning authorities desirable or should alternative arrangements be made?

• With regard to archaeology and SMC, the Welsh Archaeological Trusts existed to support local planning authorities so a regional mechanism existed, with Cadw acting as arbiter and planning authorities making initial decisions. This structure did not cause any problems in principle and provided accountability and expertise. It was thought that these existing mechanisms could work well.
• In-house local planning authority provision would bring with it major resource implications and potential conflict of roles with Cadw pending, such as with any new appeals process.
• There was a need for 'skills audit' within local and national park authorities in archaeology/historic buildings.
• It was thought that archaeologists within the planning structure could provide a lot of 'local value'.
• It was noted that only four local planning authorities in Wales had listed building consent delegation. Having the expertise to manage the consent process was quite a different matter to deal with the rest of the process that involved enforcement and administration.
• Some unease was expressed about the involvement of local/regional/national tiers in one 'accountable' system.
• It was noted that the first point of contact within the planning authority was usually the development control officer, who had little or no expertise in the historic environment. Cadw must look at resource issues.
• It was thought that there should be legal obligation for Welsh local planning authorities to have archaeologist/listed building expertise before delegation could be put in place successfully.
• With variable administrative procedures in-house in local planning authorities, there were possible resource implications that would prove difficult to overcome, regardless of the availability of conservation expertise.
• On the issue of grading scheduled ancient monuments, it was thought that if all the grades were delegated for local determination, then Cadw would have no future role to play.
• The availability of the necessary skills and expertise were fundamental to any process of delegation to the local level. It was questioned how the new system might deal with or responded to on going skill levels or staff changes.
• There was some discussion about to what degree should delegation to local planning authorities be optional. If there was a statutory duty for local planning authorities to lead in the provision of a comprehensive heritage service then it should bring with it an automatic funding provision.
• It was recognised that Cadw needed to be sufficiently resourced to 'monitor' and 'manage' the designation process.
• Historic Parks and gardens were non-statutory designations at present. Statutory controls only existed when developments were planned and this was not considered to be enough.
• It seemed to make sense that, within the system of ecclesiastical exemption, SAMs should fall within the faculty system when buildings were within the curtilage of the church.
• There may be potential for conflict between 'regional' consent conditions and national grant conditions.
• In the case of buildings in ownership of the State it was questioned what exemption processes would be followed under the HPR.
• A way would need to be found on how to identify extra resources needed to deal with the implications of the review - could WLGA have a role?

Heritage Partnership Agreements

• The group considered whether partnership agreements were worthwhile in Wales. It was thought that the size of site was actually immaterial, since many smaller sites could be equally complex. It would be important that the legislative provision was not too prescriptive and allowed for local determination of the agreement depending on the circumstances.
• The group questioned how sites and buildings owned by local planning authorities would be determined. Wider partnerships would be needed in such cases to ensure a consistent approach to buildings and these could include planned maintenance. The issue needed careful thought. Could Cadw be a partner in such agreements?
• The view was expressed that there needed to be clearly defined formal arrangements on management agreements.

Maritime Archaeology

• The group questioned who would deal with designations and consents in maritime archaeology, and if greater planning authority involvement was envisaged then there would need to be a process of 'up-skilling' to achieve that.
• It was not clear whether parks, gardens/landscapes would be placed on the new register.

Next steps

90. It is intended that this seminar report will be distributed widely to those individuals and organisations that attended on the day, and also those who were not able to do so. The report is also to be published on the Cadw website - http://www.cadw.wales.gov.uk. There is an open invitation for organisations and individuals throughout Wales with an interest in the Heritage Protection Review to submit their comments to Cadw so that these might be taken into account in the drafting of the White Paper. Comments by the end of August 2006 can be sent to:

Matthew Coward
Policy and Administration Branch
Cadw
Plas Carew, Units 5/7 Cefn Coed
Parc Nantgarw
Cardiff CF15 7QQ

Email: Matthew.Coward@Wales.GSI.Gov.UK

91. In line with the Welsh Assembly Government's Welsh Language Scheme this seminar report is being produced in English only.

Cadw
June 2006

Annex A Position Paper

Purpose

The purpose of this paper is to summarise the background to the review of heritage protection and outline the key proposals for reform. It also seeks to highlight differences in practice and procedure between England and Wales and to raise points and options as a prompt for discussion on the way forward in Wales. These are part of an ongoing process which started with consultation in 2003, is continuing with this specific seminar for Wales and any issues raised in follow up correspondence and will culminate in a UK Government White Paper setting out proposals for new legislation.

Background

2. New primary legislation is being considered for the protection and management of historic assets in Wales and England. Consultation papers on draft proposals setting out ideas for new legislation were issued separately in each country in 2003, along with an additional consultation for maritime sites and, in Wales, an independent review of the arrangements for ecclesiastical exemption. A summary of the responses to the consultation on protection of terrestrial designations in Wales is on Cadw's web site at http://www.cadw.wales.gov.uk/upload/resourcepool/31348.htm

3. In the light of the consultations, it is proposed to issue a joint England and Wales White Paper in autumn 2006. This will include a section specific to the needs and circumstances of Wales. There will be a bid for a legislative slot for a Heritage Protection Bill in the 2007-2008 UK Parliamentary session.

4. Ministers in England and Wales have yet to determine the detailed content of the White Paper. This will be informed by comments expressed already in the light of the 2003 consultations, together with the outcome of pilot projects in England. It was considered that the experience gained from the range and different types of pilot areas in England would read across to Wales. This will be supplemented for Wales by comments arising from this Welsh seminar on 7 June with any additional follow up correspondence or action.

Aims and main proposals

5. The principal aim of the proposed reforms is to simplify and rationalise the current designation regimes and associated consent procedures and to provide for more openness and accountability.

6. The main elements of the reforms are

• A register of historic sites and buildings bringing together the current regimes for listed buildings, scheduled monuments, registered parks and gardens and battlefields (only in England) and incorporating World Heritage Sites
• A statutory right of appeal against designation decisions
• A unified consent process based on an integrated designation regime, bringing together scheduled monument and listed building consents, which could be administered at the local level
• Heritage partnership agreements consisting of optional statutory management agreements for more complex sites, again being delivered at the local level
• A new network of Historic Environment Records to act as the first point of reference for information on historic assets and to inform the management of change
• Review of the Class Consent relating to cultivation on archaeological sites.
  
  Welsh perspective
  
  7. Although the aims and objectives of the reforms are the same for England and Wales, in practice there will be flexibility to arrange separate provisions in the new legislation given the differences of approach and application to heritage protection in Wales. The Heritage Protection measures will also take account of the introduction of new legislative powers anticipated for Wales on enactment of the new Government of Wales Bill.
  
  8. In considering what provisions should be made for Wales, the Assembly Government will be looking at options taking in the different circumstances and arrangements applying in Wales. A key difference is that in England, it is envisaged that many of the new reforms will be administered by English Heritage, a Government sponsored body, for which there is no equivalent organisation in Wales. In Wales, Cadw is fully part of Government as the historic environment division of the Welsh Assembly Government.
  
  9. Other areas where there are marked differences in the arrangements between Wales and England are

• The all-Wales listed buildings survey was completed at the end of December 2005, with some 30,000 listed buildings.
• By 2010, Cadw will have largely completed the scheduling enhancement of all known archaeological sites in Wales, along with many new sites discovered through the Uplands survey
• There is a perceived lower overall level of specific conservation expertise within some local authorities in Wales.
• Apart from in three authorities, there is no local authority-based archaeological expertise in Wales and only two of the three National Parks have archaeological staff.
• Welsh Historic Environment Records (HERs) - formerly known as SMRs - are located within the Welsh Archaeological Trusts that do not have statutory powers.
• Cadw's Register of Historic Parks and Gardens Register was compiled on a voluntary basis
• There is a specific Register of Historic Landscapes in Wales
• There is currently no Register of Historic Battlefields in Wales.

Specific issues for consideration in Wales

10. The seminar will wish to focus attention on the differences of approach and application above and discuss particularly the issues below in considering the way forward for Wales:

• In England, DCMS propose to expand and re-format designation descriptions to help develop a better understanding and appreciation of an historic asset and what makes it significant. Individual entries would become longer and would take time to prepare so a full Register of designations would not be an immediate or even short-term prospect. In Wales, all Welsh communities have been surveyed for listing and the scheduling programme is well advanced. All list descriptions, and scheduling descriptions since the 1970s, are to modern standards. Approximately 70% of listings and 35% of schedulings are accompanied by a formal justification. It is for consideration how far current designation descriptions need to be expanded.
• Should the present voluntary Register of Historic Parks and Gardens in Wales be incorporated into the proposed new unified designations Register? This would have statutory force and it is for consideration whether historic parks and gardens should be put onto a statutory basis
• A statutory right of appeal against designations - do consultees see a need to expand the current informal arrangements and to introduce a statutory right of appeal - to whom in Wales should appeals be directed?
• The proposal in England is to unify consent processes for buildings and monuments with delegation to local authorities. In Wales only four local authorities have applied for and demonstrated sufficient conservation expertise for grade II listed building consent delegation and expertise is generally not available to handle scheduled monument consents at the local authority level. Currently Cadw handles approximately 100 applications for scheduled monument consent per year, of which around 40% are from local authorities and 20% (including some local authority) are linked to Cadw grants. It is for consideration whether the key principles of integration and local accountability are feasible in these circumstances. It is for discussion whether full delegation to the local level is possible, whether alternative arrangements should be made or whether the existing arrangements should be maintained.
• A more integrated approach is advocated towards the management of historic assets. This could range from the type of management agreement that is currently adopted for single monuments to complicated management agreements entered into with major landowners and covering the complete range of historic assets. In England, English Heritage is envisaged as one of the major partners. It is for discussion in Wales whether Cadw could or should maintain this role or whether there are alternative approaches that might be preferred.
• There has long been a desire in England for local authorities to be statutorily required to maintain Historic Environment Records (HERS) and this would be included within the legislation. HERs would then be able to make the Register available at the local level as a core part of delivering many of the functions mentioned above. In Wales, HERs are held by the Welsh Archaeological Trusts who do not have statutory status. What arrangements should be made in Wales?

Other issues of common interest

11. Other issues arise from the proposed reforms which could be pursued administratively or still need further consideration

· Consultation with owners - the view has prevailed in previous discussions that prior notification of an intended designation to owners might lead to precipitate action that might damage an historic structure. In the interests of openness and accountability, it is proposed to introduce new standard consultation arrangements before designation with owners, amenity groups and local authorities. It is for consideration whether there should be interim protection for historic assets during the period of consultation.

· Designation grades - decisions have yet to be taken on gradings. One suggestion is that the existing grades should be consolidated from three to two and that this would cover scheduled monuments as well as listed buildings. Issues revolve around the virtue of the II* grade, whether its removal would devalue grade I buildings and how, in a unified system, grades could be applied to monuments.

Marine and Ecclesiastical

12. A separate UK-wide consultation took place on designation and other issues
relating to the underwater heritage. Inter-Departmental working groups will be advising UK Ministers and it is possible that the protection of marine assets will be taken forward on an UK basis. It is for discussion though whether proceeding on a Wales only basis is feasible or desirable.

13. An independent review of ecclesiastical exemption in Wales was carried out in 2004.It concluded that there was no need to change the arrangements but recommended a number of improvements in the practice of some denominations. With the introduction of a new unified Register, it is for consideration whether all historic assets, including those currently scheduled, should be subject to the exemption.

SUMMARY LIST OF QUESTIONS FOR CONSIDERATION IN WALES

• Is there a need for current designation descriptions to be expanded - if so, in what way?
• Should the present voluntary Register of Historic Parks and Gardens in Wales be incorporated into the proposed new unified designations Register?
• Should there be prior consultation with owners of intention to designate - should there be a system of interim protection?
• Should grades be applied to unified designations - what grades?
• · Do consultees want to see a statutory right of appeal against designation decisions - to whom?
• Is full delegation of the consent system to the local level possible or should alternative arrangements be made -and what?
• · Should there be formal arrangements for Heritage Partnership Agreements - how should they operate?
• What arrangements should be made for HERS in Wales?
• Should proposals for maritime archaeology proceed on an UK basis; is a system for Wales only feasible?
• Should the arrangements for ecclesiastical exemption extend to all designated historic assets on the proposed unified Register?
• Any other issues……..

Annex B Records Workshop: paper for discussion

The following need to be in place to deliver arrangements:

• HERs which have sufficient capacity and have achieved the required revised benchmark standard. Discussions on standards have been taking place elsewhere and can be carried over into Wales.
• An on-line National Register.

Some issues for consideration:

• Different HER arrangements in Wales but consistent arrangements across all four HERs
• Nature of existing local planning authority records, particularly for listed buildings work
• Are there any practical difficulties in having the HER remotely located from the local planning authority?
• Do existing records need to accommodate casework "histories" linked to LBC decisions or do they just consist of list descriptions, etc?
• How could statutory status for HERs be achieved?

Annex C List of Delegates

Dave Jump - Anglesey County Council
Julian Atkins - City and County of Swansea
Alex Glanville - Church in Wales
Bob Bowler - Newport City Council
Pat Martin - Caerphilly County Borough Council
David Swanson - Monmouthshire
Edward Holland - Monmouthshire
Richard Sumner - Wrexham
Elaine Davey - Victorian Society
Kathryn Hilsden - Powys County Council
Nick Lloyd - Vale of Glamorgan Council
Ian Thomas - Carmarthen County Council
Judith Leigh - SPAB Wales
David Priest - Civic Trust for Wales
Rob Scourfield - Pembrokeshire Coast National Park Authority
Emma Plunkett Dillion - The National Trust
Nic Wheeler - Pembrokeshire Coast National Park
Richard Cole - Vale of Glamorgan Council
D Thompson - Gwynedd Archaeological Trust
Anne Carter - WHST
Gwilym Jones - Snowdonia National Park Authority
John Ellis - Conwy County Borough Council
Phil Ebbrell - Denbighshire County Council
Dave Jump - Isle of Anglesey County Council
Gwilym Hughes - Cambria Archaeology
Lindsay Cuddy - Cardiff City Council
Simon Wardle - The Georgian Group
Tom Lloyd - Historic Houses Association
Frank Olding - Blaenau Gwent County Borough Council
Peter Jones-Hughes - Flintshire County Council
Melissa Howells - Pembrokeshire County Council
Ian Bartlett - Pembrokeshire County Council
Neil Sumner - Bridgend County Borough Council
Hilary Malaws - Royal Commission on the Ancient and Historical Monuments of Wales
Karina Kucharski - Wrexham County Borough Council
Geraldine Delaney - Cytal APT
Chris Martin - Clwyd Powys Archaeological Trust
Alison Swabey - Garner Southall Partnership
Louise Austin - Cambria Archaeology/ALGAO
Marilyn Lewis - Cadw
Richard Avent - Cadw
Jean Booker - Cadw
Stephen Gear - Cadw
Rick Turner - Cadw
Laurence Burr - Cadw
Alan Richards - Cadw
Lorna Lane - Cadw

Annex D Glossary of terms

DCMS - Department of Culture, Media and Sport
HPR - Heritage Protection Review
DCLG - Department for Communities and Local Government
EH - English Heritage
HPA - Heritage Partnership Arrangements
HER - Historic Environment Records
SMC - Scheduled Monument Consent
LBC - Listed Building Consent
SAM - Scheduled Ancient Monument