CONSULTATION RESPONSE: HISTORIC TOWNS FORUM and
ASSOCIATION OF SMALL HISTORIC TOWNS AND VILLAGES OF
THE UK
Consultation Questions
Chapter 3: The Charity
1 The consultation outlines the benefits of the new model for the National Heritage
Collection. Do you:
Somewhat disagree with the proposed benefits 
2. If you either strongly or somewhat disagree with the proposed benefits why is this?
Looking at each of the stated benefits in the document in turn:
(a) The decline in the condition of the Collection will be reversed. The additional money
from the Government will eliminate the priority defects and the charity’s increased
income will ensure that by the time the funding agreement ends, the charity will have
the financial ability to maintain the Collection properly. Without the additional
investment, the level of conservation defects would continue to rise and some
properties would deteriorate beyond repair.
Much of the above is based on assumptions – statements like the ‘decline of the
Collection will be reversed’ and ‘the charity’s increased income will ensure that … [it]
will have the financial ability to maintain the Collection properly’ are based on
untested assumptions in the business plan. Under the terms of the proposed licence
to manage the Collection’s management will revert back to the Commission if
obligations are not met. There is concern that, in the event that the Charity’s
business plan assumptions are proven to be too optimistic, and the reversion of the
management arrangements takes place, this would severely impact on the residual
budget for Historic England.
This benefit does not necessarily lead to a requirement for the establishment of the
Charity and could be met by the government making a similar investment under the
existing English Heritage structure.
(b) Clearer separation from the other responsibilities of the Commission and greater
independence from Government will make it easier for the charity to access sources
of funding from third parties, helping to increase the financial resilience of the
management of the Collection.
Would agree that the separation and greater independence would make it easier to
access funding from other sources although the extent by which this is proven to be
the case is debateable.
(c) Visitor and member figures will grow substantially above a status quo baseline,
attracted primarily by the new exhibitions but also by the improved basic offer. This
means that more people – including more young people – will be able to engage with
the history of England.
As with (a) above, this is based on, as yet, untested assumptions so that what is
meant by ‘substantially’ and whether this will be sufficient to deliver the expected
benefits remains to be seen. The reference to more young people becoming
engaged with the process seems to be unsubstantiated.
There is a risk that the need to achieve financial independence will lead to income
generating facilities and entertainment events which will spoil the integrity and
character of the place which is intended to be protected..
(d) Greater autonomy from Government means the charity will be able to plan more
effectively for the longer term as it will not be as constrained by Government
spending controls and cycles as English Heritage is at present. It will be able to carry
forward surplus at year end. Greater freedom will enable the charity to enjoy a more
flexible and strategic approach to managing the properties and generating income.
Agree
(e) The charity will not be constrained by Government restrictions on marketing and
promotion as English Heritage is now, allowing for more effective business
development.
Agree
(f) The charity will contribute to economic growth by enhancing England’s attractiveness
to domestic and foreign tourists.
Agree but, with adequate investment, the existing English Heritage model would do
also. This benefit is not unique to the new model.
3. Are there any further benefits that could be delivered by this model?
In answer to Questions 3 and 4 (below), most of the key benefits and opportunities
for earned income are as set out in the consultation paper. However, in terms of the
quantum corresponding to these opportunities, there are a number of examples
where existing trends are assumed to continue, e.g. in relation to increasing
membership and visitors. Little account appears to have been taken of diminishing
returns and the possibility that there may not be a direct link between improved
assets directly leading to greater numbers of members and visitors. This leads to the
question as to what happens when market saturation is reached, possibly well before
the anticipated levels? Would this lead to the revocation of the licence and a return
to direct management of the National Collection by the Commission with the
consequence of placing Historic England’s budgets at risk?
4. Are there any other key opportunities for the charity to increase earned income in addition
to those outlined in the consultation? (please tick the appropriate box)
Don’t know
5. If yes what are they?
6. What aspects of the current service provided to the public by English Heritage in relation
to the National Heritage Collection is it important that the charity maintains?
It is vital that the new charity should focus on the conservation of the National
Collection for the current and future generations. However, the charity should also
act as the showcase for the principles of good practice espoused by its sister
organisation, Historic England. In other words, the National Collection should act as
exemplars for other owners of historic buildings to follow.
In addition to this, the Charity should ensure full access to the National Collection and
well informed interpretation and advancing of the public’s knowledge about its
heritage assets.
There is a concern that investment will be focused on those places which attract high
numbers of visitors and have most potential for income generation. It is important that
more remote and less visited sites are also properly cared for and conserved, even if
they do not generate much income..
7. What are the opportunities to further enhance the services that will be offered by the
charity?
The services that will be offered by the charity will, undoubtedly, be enhanced by the
capital investment. However, clarity is needed about the arrangements following the
expiry of the initial 8-year licence. Although reference is made to this, there is a lack
of clarity – merely saying that arrangements will be put into place. There is no doubt
that short term licencing hinders long term investment.
8. Do you agree that the suggested charitable objectives are broadly the right ones?
Yes but see below
The charitable objectives do not seem to be stated in the consultation document but
presumably they will be based on the charitable purposes.
Whereas these are broadly the right charitable objectives, it may be very difficult to
overcome the perception that the charity remains a government agency, particularly
given the continuation of the name, which will possibly inhibit philanthropic giving.
Although this could be viewed as merely a marketing issue, it could be catastrophic
in terms of the ability of the new charity to deliver its objectives.
The general public will continue to interface with the new charity in the way that they
generally do with the Properties in Care arm of the present English Heritage. The
new Historic England will continue to have an interface with a more professional
clientele as does the Conservation and Planning arm of the present English Heritage.
The general public are unlikely to be aware of the breadth of the present English
Heritage functions and so may not appreciate the significance of the new model.
Also, clarity needs to be added about the independence of the charity in relation to
additions to the National Collection. To what extent would trustees have to exercise
fiduciary discretion to refuse new properties and would they be able to acquire
properties from third parties on their own discretion. Again, any perception that the
Charity is an agent of the Commission which, in turn, is a government agency may
have an adverse impact on its fund raising ability.
The priority given to public enjoyment of the collection is understandable but there is
a danger that the integrity and special character of sites can be spoilt or
compromised by inappropriate provision of facilities for visitors.
9. If no, what changes to them do you think should be made?
See above
10. Are the proposed success criteria to measure the performance of the charity and to
ensure that the benefits are realised the right ones? (please tick the relevant box)
Yes but see 11 below
11. If not what else should be included in the success criteria?
The emphasis on financial independence is understandable and reasonable but the
primary criterion should be protection and conservation of the collection. As referred to
above the imperative to achieve financial independence by 2022/23 may lead to
development and commercial events which raise short term income but spoil the
character and special nature of the sites, which are the very things which should be
protected and are likely to be appreciated and valued even more in the future. We have
seen growing interest in history and heritage in recent years. England has a unique
collection of heritage assets which are likely to have high financial value in the future only
if there special nature is protected.
Clarity needs to be added as to what happens if these success criteria were not met.
Chapter 4: Historic England
12 We are interested in the views of respondents to the proposed future opportunities and
priorities for Historic England. Are these the right priorities and opportunities? Is there
anything missing?
Looking at these in turn:
(a) A broad vision
The separation of functions is welcome, as is the move towards more cooperative
working with owners and developers. Effective partnership working can benefit all
parties. However, Historic England must still be an effective guardian, ensuring that
places of special importance for historical, architectural, archaeological or landscape
reasons are appropriately protected.
The wider benefits of heritage management in relation to our quality of life and
heritage led regeneration’s contribution to sustainable development of our towns and
the economic growth of the country is recognised in the introduction to the
consultation paper’s chapter on Historic England. It is, perhaps, to be regretted that
the opportunity has not been taken to re-assign the new Historic England to both the
Department of Culture Media and Sport and the Communities and Local Government
department. This would have cemented the heritage sector into mainstream
planning and regeneration, in line with other current initiatives such as the
amalgamation of the former Conservation Area Consent regime into the main
planning permission process. This would have recognised the wider value of
heritage beyond its cultural value.
Historic England will need to have the funding and appropriately qualified and
experienced staff, able to work cooperatively with other parties, especially in the
wake of such substantial reductions in local authority conservation staffing.
(b) Constructive conservation
The embodiment of the principle of constructive conservation into the development
and heritage management process has already proved to be successful and its
restatement in the consultation is welcomed. Clearly the balance between ‘sensitive
and ‘commercial’ development needs careful consideration but, by and large, the
present wording of the National Planning Policy Framework is considered to have
given local authorities and the present English Heritage sufficient capacity to achieve
this.
(c) Better services
This is welcomed although it is noted that the proposed Historic England’s services
are to be ‘largely’ funded from taxation. In the present circumstances of depleted
local authority resources, it is essential that the services remain free of charge if they
are to be fully used and, hence, heritage assets protected. An introduction of a
charge would suggest that the input of Historic England becomes an added extra
rather than something which is integral to the development and heritage
management process. It also ensures a unity of standard across all local authorities.
(d) Saving heritage at risk
This is welcomed although the note made under Qu 8 above is pertinent in relation to
the independence of the new charity and the obligation of the trustees to accept
additions to the National Collection.
(e) Looking to the long term
The importance of partnership working in its widest sense is welcomed and is already
recognised throughout the full range of services at local government level. Clarity
about the reference to ‘reviewing’ the landscape for heritage services is needed.
13. Are the proposed success criteria to measure the performance of Historic England the
right ones? (please tick the appropriate box)
Yes but see below
The success criteria follow on from the proposed benefits set out in the consultation
paper about which the following points are made:

The benefit arising from a clearer focus emerging from the new model is
accepted.

The stated benefits relating to owners and developers getting a more responsive
service and the heritage at risk continuing to be bought back into economic use
do not necessarily follow from the new model but should be an aspiration of the
existing organisation.

The benefit relating to a more visible and accessible resource for the general
public may be a benefit but this remains to be tested.

The final benefit regarding the charity no longer having a call on the resources of
the commission assumes that there would not be a proportionate decrease in the
Commission’s budget to reflect the new charitable arm being self-financing. It
also avoids addressing a situation whereby the new charity’s licence is not
renewed or is revoked due to poor performance in which case the accountability
of both new organisations would become linked again through the Commission’s
budget.
14. If not what else should be included in the success criteria?
15. Should the National Heritage Protection Plan form the basis of the business plan for
Historic England? (please tick the appropriate box)
No 
16. If no – why not? Whereas the NHPP should form a principal part of the business plan for
Historic England, it should not be exclusively based around it. Positive heritage
management and heritage led regeneration can offer so much to the quality of people’s
life and the potential for local and national economic growth. The present English
Heritage Corporate Plan 2011-2015 recognises this through its 4 strands – Achieving
excellence by understanding, by valuing, by caring, through enjoying heritage. Even if
the focus on properties in care is extracted, it leaves key roles for Historic England that
go beyond the protection emphasis that is set out in the NHPP. The danger is that the
new organisation is seen purely as an agency that stands in the way of change (as the
working title of the National Heritage Protection Service for Historic England suggested).
Heritage management can offer a range of positive benefits that need to be celebrated at
both national and local level.
17. Are there any further points you would like to add in relation to the consultation?
No
About you section
18. Are you responding as an individual or on behalf of an organisation?
Part of an organisation.
19. If you are responding on behalf of an organisation what best describes the type of
organisation?
Organisation representing visitor attractions/tourism
Organisation representing owners of historic assets
Organisation which represents volunteers/communities
The Historic Towns Forum and the Association of Small Historic Towns and Villages represent
over 300 members including local authorities, civic societies, town and parish councils,
individuals and other organisations.
20. If you are responding as an individual are you an existing English Heritage member and/or
volunteer? Yes
21. Are you an owner of a listed building?
No
30 Department for Culture, Media and Sport
Name Dr Noe:l James
Job title Director
Organisation Historic Towns Forum/ASHTAV
Telephone number 07947 521567
Email address htf@kellogg.ox.ac.uk
Postal address HTF, Kellogg College, 60-62 Banbury Road, Oxford, OX26PN
Please tick this box if you DO NOT want your responses to be made publicly available. I would
like to be kept in contact on the English Heritage new model programme. Communication will
be through either DCMS or English Heritage. Your data will not be used for any further
purposes.
(please tick the appropriate box) Yes No