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Submission
from ALGAO:Cymru
Matthew Coward
Cadw
Welsh Assembly Government
Plas Garw
Nantgarw
CF15 7QQ
Dear Matthew,
DRAFT HERITAGE
PROTECTION BILL
I am writing
as Chair of the Association of Local Government Archaeological Officers:
Cymru (ALGAO:Cymru), the Welsh national group of the Association
of Local Government Archaeological Officers:UK (ALGAO:UK). The Association
provides a forum representing archaeologists working for, and providing
services to, local authorities and national parks throughout the
UK. In Wales its members are senior professional archaeologists
providing advice on archaeological conservation and management including
the provision of Historic Environment Records and development control
services to Unitary Authorities.
ALGAO:Cymru
continues to welcome and support this reform of heritage protection
on its legislative passage. We would like to thank Cadw for their
recent presentations at Treftadaeth 08 which were very helpful in
clarifying the process and timetable of the draft bill.
It is recognised
that the Bill is currently in draft and there are various elements
of the proposed legislation that are still to be completed. It is
also recognised that the Bill is intended to provide a framework
that will allow flexibility in how heritage protection is delivered
across the UK. We understand that further guidance and secondary
legislation will address the specific implementation, processes
and procedures which will be required to achieve this. Accordingly
our comments at this stage are of a general nature.
We await further
guidance concerning specific arrangements envisaged for Wales, in
particular details relating to HER provision. ALGAO:Cymru are keen
to work with Cadw and the Welsh Assembly Government in developing
guidance documents building on the current strengths of the historic
environment sector in Wales and developing practical and economically
viable solutions to the delivery of integrated Local Authority Historic
Environment Services.
The aspirations
and principles of the Heritage White Paper were warmly supported
by ALGAO. However, the provisional nature of the Bill means that
uncertainty remains over delivery of the reforms and what these
will mean to members on the ground. An integrated vision for the
future delivery of heritage protection in Wales has yet to be articulated
and the group is concerned that given the legislative timetable
there will be few opportunities to contribute to its development
before the Bill is put to parliament.
ur principle
concerns at this stage relate to:-
- The continued
administrative fragmentation of the consent regime for Heritage
Assets between Cadw and LPAs. This has the potential to perpetuate
a lack of joined up thinking regarding the management of different
aspects of the Historic Environment.
- The need
for clarity concerning the future relationships between Local
Authorities, the Welsh Archaeological Trusts and Cadw / WAG in
the provision and maintenance of historic environment services.
- The encouragement
and support needed from Cadw and WAG for the delivery of integrated
historic environment services by Local Authorities in Wales. It
is important that the depth of historic environment skills and
experience available to Local Authorities grows. Joint working,
support and training between WAG, Local Authorities and Welsh
Archaeological Trusts is considered a vital part of this process.
- unding -
whilst in England it has been recognised that there will be an
additional cost in delivering the proposed reforms and there is
a commitment from DCMS to address the funding gap the fact that
there is no similar recognition in Wales is a cause for concern.
Should you
require any additional information or clarification of the above
comments please do not hesitate to contact me as I would be delighted
to discuss them further with you.
Yours sincerely,
Louise
Austin Chair ALGAO:Cymru
Consultations
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