FEEDBACK FORM
Contact Name and Organisation: Tracy Nettleton, Head of Strategy, Policy and
Heritage, Brecon Beacons National Park Authority
General Comments;
Firstly, the report says that it explores Options for the delivery of historic environment
conservation services in Wales, but it doesn’t. It discusses various options in relation to
Built Heritage Conservation, and it makes mention of the role of the Archaeological Trust
and that there are additional archaeologists in Wales separate to the Trust system
(National Parks, Denbighshire etc.) but it does not examine different options for the
delivery of archaeological conservation services in Wales, other than perhaps moving
existing curatorial Trust staff into new Conservation hubs, trusts or bodies, or the trusts
absorbing conservation officers. Surely a chance to review and appraise options for
delivery of Local Historic Environment Conservation Services in Wales should also include
a full and frank appraisal of the delivery of archaeological conservation service, including the
model already in place and additional options, their strengths and weakness etc and not
just take it as read that the status quo position for archaeology should be maintained or
amended without full consultation, discussion and consideration of the options.
1. Do you agree with the core and wider functions of Conservation Officers
detailed in Paragraph 2.13? Is there anything you would add or remove from
either a) core functions, or b) wider functions?
a ) In the main this is a good reflection of the core functions however it does not include
enforcement as an issue or the work relating to serving Urgent Works Notices or Repairs
Notices. These two areas of work can have a significant impact on the protection of the
historic environment. They can also take up a considerable amount of time.
National Parks are special purpose Local Authorities, with statutory duties under the 1949
National Parks and Access to the Countryside Act, and under the 1995 Environment Act.
Under these two pieces of legislation National Park Authorities have statutory duties,
these are:

To conserve and enhance the special qualities of the National Park – including its
historic environment and cultural heritage

To provide opportunities for members of the public to access and enjoy the special
qualities of the National Park.
This means that in respect to the conservation of the historic environment (built heritage
and archaeological heritage) National Park Authorities have different priorities to other
local authorities. These statutory duties and different priorities may only be served
through having in-house specialist staff in both archaeological and built heritage
conservation, because a standardised approach across the rest of Wales (whatever
Page 1
approach is adopted) may not be able deliver the specific outcomes that National Park
Authorities require in terms of their statutory purposes.
Therefore the core functions need to reflect the statutory purposes for which National
Parks were set up.
b) The wider functions should also include the negotiations with Building Control whether
in the National Park or in local planning authorities. It is more difficult in National Parks as
Building Control sits within the constituent UA’s
2. Do you agree with the strengths and weaknesses for service delivery listed in
Section 2 for the various delivery organisations? Is there anything you would
add or remove?
It is essential that the Historic Environment service sits within the planning function of an
organisation in order to play an integral part in policy formulation, implementation and
regulation, through the DC and enforcement services. It is true that Conservation Officers
will gain more breadth of experience within the Planning Department but it works the
other way as well. It helps DC officers to have direct specialist advice so that they also
increase their knowledge of the historic environment and its issues.
In rural areas it is very important to have local knowledge as many of the listed buildings
are isolated and good relationships with owners is an effective way of gaining buy in to the
philosophy of conserving the historic environment. This can have the knock on effect of
reducing the necessity of taking enforcement action and can also lead to superior
outcomes.
The position of conservation of the historic environment within LPA’s is very much
influenced by local responses and priorities of members. In National Parks it is central to
fulfilling the 1st statutory purpose and therefore less influenced by political pressures.
There are resourcing and capacity issues that tend to be due to lack of funds rather than a
lack of will.
The level of financial and staffing resources does affect the speed and depth at which
conservation of the historic environment can be achieved. However, a great deal of staff
time is spent on dealing with the overly complex process and inherently weak powers
given to LPA’s and National Parks to accomplish conservation. For example, the ability to
tackle the lack of repair to a listed building or significant buildings within conservation areas
is too complex and ultimately too weak to quickly protect these buildings.
As the report note many heritage officers are singleton posts and this can and has led to
significant capacity issue for example when the officer is off on long term sick. While
agreements, whether formal or informal with other authorities can be put in place and this
Authority has used this option to provide cover, it only works if there is capacity in the
other Authorities. In our experience this is a significant problem as the capacity is limite.
In terms of conservation officers being in a silo this may be the case in some Authority’s.
However we would argue that it is more about the cultural ethos of the organisation
rather than where within the organisation the Heritage Officer is located. Specifically it is
often highways department budgets that are an issue in terms of conservation where
Page 2
funding has to be targeted at best value and the hardest wearing materials. These are not
necessarily the most aesthetic or suitable materials for a conservation area but unless
legislation indicates that highways must use suitable materials in conservation areas then
this is unlikely to change.
Building Regulations can also be an issue as applying the regulations is all that is required of
these particular officers and not the issue of conservation. Whether the officers are in the
same organisation or not will not really alter this although cooperation would improve.
More joined up legislation would have a far greater benefit.
Having in-house expert advice is essential for the efficient and effective operation of all
aspects of the built environment service. We experience significant issues in undertaking
our responsibilities as a planning authority whilst other functions remain with the unitary
authorities, for example building control. In this National Park the issues are exacerbated
as there are 9 constituent Unitary Authorities. Any proposal to place heritage advice
outside of the organisation would have a detrimental effect on the quality of the service
and therefore on the historic environment.
However, joint working, advice and sharing expertise is actively pursued wherever possible.
For example Monmouthshire County Council and Merthyr Tydfil County Borough Council
have both provided cover to the National Park for long term sickness absence and we have
collaborated with Powys County Council in terms of the provision of a Conservation Area
Improvement Scheme. Willingness in not the issue, but rather the capacity to do so.
Cadw
It is agreed that Cadw could provide a significant amount of expert advice if resources
allowed for it. Experience would indicate that the willingness in there, but that scarce
resources and capacity are an issue.
The issue with the delegated powers is that it has to be a named officer and in our
experience it isn’t the best use of the heritage officer’s time to be processing application. It
is more efficient for the applications to be processed by a development control officer with
the Heritage Officer to be a consultee. It would be preferable in our view if the delegated
powers could be given to a ‘suitably qualified officer to act as expert advisor’.
If this were to happen then Cadw officers wouldn’t have to spend much of their time
overseeing minor alterations to Grade II listed buildings and could be more available to give
much needed advice on Grade I and II* listed building and to drawing up more strategic
guidance.. It would also allow Cadw officers the ability to provide the time for valuable
pre-application advice.
Obviously a list of what did need to be referred to Cadw would need to be drawn up, for
example, substantial demolition. It could be similar to the one used by English Heritage but
with the priorities for Wales reflected in it.
This would massively speed up the decision process which can irk applicants. A quickened
system will also help in discouraging unauthorised work as this is often cited as a reason
for not applying for consent.
Page 3
Unfortunately the description set out in Section 2 is too simplistic and does not really
represent the reality of the situation.
The present delivery model, of course, has draw backs, but much of that is because the
legislation is not strong enough in certain areas and has therefore led to problems with
implementation. Instead of a wholesale change in the model it might be more cost
effective if the legalisation was strengthened to raise the profile of the historic environment
services and give more backing to LPA’s to prioritise resources.
Para. 2.27 states that the role of archaeologists in Wales outside the Archaeological Trusts
is seen as complementary to the services provided by the Trusts. But seen as
complementary by whom? I would dispute that these different services are
complementary. Although much can be achieved with local authority archaeologists and
archaeologists at the Archaeological Trusts working together and collaborating where
there are common aims and objectives, there are areas of work where it is not a
complementary relationship but where they work independently, and a service in provided
in-house to a local authority that it is entirely separate to and independent of any of the
work of the Archaeological Trusts. For example, local authorities such Snowdonia NPA
that provide in house archaeological advice on planning applications completely
independently of their local Archaeological Trust. The Brecon Beacons NP is also bringing
archaeological advice on planning applications in-house beginning in April 2013.
RANKING OF OPTIONS
1= Preferred Option
6= Least Preferred Option
Option
Option 1a
Regional Collaboration by Negotiation
and Agreement
Ranking
(1 to 6)
1
Reasons
As explained above
Option 1b
Regional Collaboration on a Formal,
Constituted Basis
4
This would dilute the connection with the locality and not
provide a better service with more resource
Option 2a
Regional Hubs
5
The same as 1b but considerably worse as it would take the
decision making out of local area
Option 2b
Regional Historic Conservation and
Archaeology Hubs
6
Again this is similar as 2a but the cost would also be
considerable in travelling and staff time to provide any form
of service
Option 3a
Expansion of the Existing Welsh
6
Again this is similar as 2a but the Trust were not set up for
this and would struggle to provide this service
Page 4
Archaeological Trusts
Option 3b
Creation of Historic Conservation
Trusts
6
Again this is much like 2a and 2b - expensive and the local
connection and knowledge would be lost
Use the Table below to score the options using the following system:
 where the option performs very well and  where it performs reasonably well.
Option 3b
Option 3a
Option 2b
Option 2a
Criteria
Option 1b
Option 1a
The number of ticks in each column will give you an overall score for that option.
Outcome: Customers are satisfied with the service provided
The option has the capacity to provide a timely service
Locally informative/skilled advice will be available
Integration with planning and other local authority services
The provision of consistent advice across Wales
Outcome: Historic resources are conserved
The option has the capacity to provide an effective service
Locally informative/skilled advice will be available
There is integration with planning and enforcement services
The provision of consistent advice across Wales
Outcome: The cost of provision of historic conservation
services is contained at current levels
Degree of control over costs/governance
The level of IT/back office support required by the option
Services are spread geographically (cost implication)
Complexity of arrangements (formal/informal)
Outcome: Historic conservation services delivered & sustained
Local governance issues
The option enables staff cover between authorities (leave, illness)
Services are spread geographically (delivery implication)
Complexity of arrangements (formal/informal)
Collaboration potential
TOTAL SCORE
We have not scored any of the options as none of them really address the issues in a
satisfactory way and does not deal with the separate issue of National Parks.
Page 5