INQUIRY INTO THE WELSH GOVERNMENT’S HISTORIC ENVIRONMENT POLICY

CELG(4) HIS 49

Communities, Equality and Local Government Committee

Inquiry into the Welsh Government’s Historic Environment Policy

Response from Ruperra Castle Preservation Trust

Consultation Questions

1. How appropriate and successful are the current systems employed by the Welsh Government for protecting and managing the historic environment in Wales?

I would say that the first point of criticism has to be the fact that Cadw is not at 'arm's length' to the Welsh Government. Cadw’s role has been perceived to be diminished since it became an Advisory Body and was no longer an independent Executive Body. This independence of its paymaster is essential in order to protect the heritage and function effectively. I appreciate that there are often pressing, conflicting needs of economics, regeneration etc. but if the advocate for the socio-economic and other benefits of heritage is not forceful enough, these value- added benefits can be swamped in the mix.

There is lack of clarity about Cadw's role, both internally and externally, i.e. Cadw officers can find themselves in difficulties explaining what they are not/allowed to do, whilst many Local
Authority Planners and Conservation Officers are confused about their relationship to Cadw, when to consult them, how much power Cadw has and its role and status etc. This confusion has improved with the series of Built Heritage Forums. The role of English Heritage is much better defined and its powers are considerably greater.

I know that Cadw is not allowed to write/say that they 'object' to proposals, they can say that the proposals will seriously damage/harm the building etc. but this is often misinterpreted as not objecting by some LPA's. It adds to the sense that they are operating with one arm
tied behind their backs.

The level of funding and therefore staffing is substantially lower than EH proportionately, this impacts on the ability to respond adequately to applications, enquiries and record keeping and general custodianship of the built heritage.

Eventhough there has been a resurvey, relevant new information may require a building to be assessed again for Listing- this can prove extremely difficult to achieve.

Finding out if a building is Listed through the Historic Wales website is quite a difficult process.There is no equivalent of EH's online database of listed buildings with descriptions and images, nor the range of guidance docs.

There is confusion over the statutory requirements, as some aspects of heritage law have Welsh legislation whereas there are areas that are not covered by legislation or guidance e.g in the Ruperra Castle Inquiry the EH's guidance for enabling development had to be used.

The Planning Authorities; some do not have qualified Conservation Officers. The situation has improved for planning applications online.
The LPA's are not chased up on enforcement issues

As for the system of Ecclesiastical Exemption in Wales -it is not a legal requirement to provide Statements of Need and Significance.
There is no equivalent of the C of E's Churches Building Council or their excellent online guidance: http://www.churchcare.co.uk/

Finally, as the inclusion of Parks and Gardens on the Cadw/ICOMOS Register is a voluntary one, and at the discretion of the owners, there are some significant omissions. This voluntary arrangement is reflected in the consultation process and can fail to protect sites from insensitive development due to limited input solicited from the relevant amenity societies and Cadw. There is a need for statutory protection for historic parks and gardens on the Register, and for statutory consultation arrangements with Cadw and amenity bodies on planning applications affecting register sites. Encouragement of the understanding and appreciation of historic designed landscapes through heritage government bodies such as Cadw and the Royal Commission, the archaeological trusts and amenity organisations such as the Welsh Historic Gardens Trust will do much to raise their profile within the wider community.

2. How well do the WG’s policies promote the historic environment in Wales?

Cadw and RCAHMW separately fulfil these roles successfully through their superior quality publications, calendar of events and interpretation projects. But there is always room for encouragement of the understanding and appreciation of historic sites through bodies such as Cadw and the Royal Commission, in tandem with the archaeological trusts and amenity organisations, to raise their profile within the wider community

3. How well do the policies for the historic environment tie in with wider WG policy objectives?

There have been positive steps in the last few years towards achieving this, for instance with ‘Wales: A Better Country, The Wales Spatial and Environment Strategy’, ‘Valuing the Welsh Historic Environment’, ‘The Welsh Historic Environment :A Strategic Statement’ and the imperative for Design and Access statements to accompany planning applications but the policies need to be widened to offer protection to the lower graded, local landmarks that are highly valued and hugely important in terms of the impact on the community for social cohesion, civic pride, distinctiveness, opportunities of regeneration and tourism.

4. What would the dis/advantages of merging the functions of the RCAHMW with the functions of others like Cadw?

The Royal Commission on the Ancient and Historical Monuments of Wales (RCAHMW) maintains the National Monuments Record for Wales. It has an excellent record of publicising and promoting details of that archive through its very successful and easily accessible tv programmes, website and publications. In this way it draws in a new audience and helps others to understand the importance of our heritage.

Cadw is the WG’s guardian for protecting, conserving, regulating and promoting our historic environment. It is tasked with the stewardship and care of the physical and material aspects of the historic environment which it also interprets very successfully. There is the further statutory function of attending to the stock of listed buildings in Wales through the planning process whenever changes to the buildings are proposed.

The functions of Cadw and RCAHMW may seem to be similar with some overlaps but close analysis of these functions shows that the focus is different as is the consequent related expertise.

There may be an advantage to sharing administration but the very distinctive and separate identity and work of the two bodies would be disadvantaged by a merging of them.

5. What role do LA’s and 3^rd. Sector organisations play in implementing the WG’s historic environment policy and what support do they receive in this respect?

Time precludes me from dealing fully with this question but I would like to voice, as a trustee of the Ruperra Castle Preservation Trust, our dismay at the inability of Caerphilly County Borough Council to protect this important site.

Burnt out in 1941 the Castle has remained a neglected ruin. Over the years, the castle and outbuildings have deteriorated. In 1998 it was purchased by a developer along with 17 acres of land and listed outbuildings and its famous glasshouse. An application to build houses on the site was rejected by Caerphilly CBC in 2008. The rejection was upheld in December 2009 by the WG after a Public inquiry. The Inspector warned of the danger of this building reaching it’s tipping point, the situation is now critical.

This site ought to be one of the most protected in Wales, comprising as it does a Scheduled Ancient Monument and Grade II* Listed Castle, its Grade II Listed outbuildings and glasshouse, a Grade II Listed historic landscape and gardens and a setting within a Conservation Area.

It illustrates more than any other site in Wales, the limitations of the heritage protection system in Wales.

The Trust grew out of the earlier Ruperra Castle Conservation Trust (set up in 1996) which became the Ruperra Conservation Trust after the purchase of Coed Craig Ruperra in 2000. Six of the trustees of RCT set up RCPT in 2008 to concentrate on the planning proposals for the Castle site.

Elaine Davey (Trustee of Ruperra Castle Preservation Trust).