English Heritage consultation – questions and clarifications please.

ConsultationI have been travelling around with the English Heritage New Model DCMS consultation paper in my bag for a while, gradually annotating and adding question marks in various places.  There has also been some useful academic debate with colleagues which has informed my reaction (rather than response) to the consultation.

To be honest, I think a positive or negative view is hard to settle on at the moment due to the lack of detail in the consultation proposals. What is most interesting though, for the heritage policy academic, is that each of the home countries (England, Wales, Scotland) now seem to be persuing their own forms of heritage policy and management.  There is a rich seam of study emerging!

Questions and requests for clarification arising from the English Heritage New Model consultation document and consultation process by DCMS. February 2014

The proposals present a radical shift in the operational management of the Government’s historic environment service, and present an outline plan for the next 8 years primarily designed to taper out direct funding of the management of the National Collection of sites and monuments to a new charity. This short-term timeframe contrasts sharply with the celebration of 100 years of the 1913 Ancient Monuments Act, and gives no indication of a wider context for the historic environment in England for the long term, nor commitment to renewing Government policy for the historic environment as both Scotland and Wales have done.

The majority of the consultation document is taken up by the proposals for the new property management charity, leaving Historic England looking rather like an afterthought and left to “business as usual”, though with wider questions on its longer term funding and effectiveness within a relatively weak DCMS stable. At face value, Historic England will refocus around the basics of the 1983 National Heritage Act which created the Commission in the first place, and changes have therefore been proposed which go to great lengths not to require any legislation. The “voice” of DCMS as the policy lead is muted, and it has been observed that the single public consultation event run was dominated by English Heritage rather than DCMS. The fact that EH has led on pursuing these changes, highlights the need for a fundamental review of the effectiveness and capacity within DCMS, and by implication the future ability of Historic England as a cross-Government advisor. To leave thinking around the implications for development of Historic England to the NHPP (National Heritage Protection Plan) process, as currently seems to be the case seems to miss an opportunity to reassess the status quo in a much changed economic, political and social landscape since HBMCE’s initial creation. There is a higher level

Whilst the proposals have potential merit and benefits, there are a large number of underlying assumptions which must be questioned, as well as vagueness requiring much further detail to be published in order for a full appraisal and judgement of support to be made.

What is particularly interesting to note is the lack of substantive press coverage on the proposed changes. Given the shift in management is broadly comparable with previous proposals for British Waterways (which was turned from a public corporation into a charity, as the Canal and River Trust with transfer of large land/waterway assets), and the Forestry Commission (which saw major public outcry as a potential “selling off” of public woodlands), the little attention has been directed to the £80m grant to create the new charity to improve public access and conservation backlog rather than the finer detail and implications for the actual management of England’s historic environment. It would therefore be beneficial for the DCMS to publish any consideration or “lessons learnt” from these equivalent changes in terms of the wider public policy delivery landscape and operational context.

With regards to the new charity:
A fundamental point to be addressed is that no business case has been published for the new charity. English Heritage Commission minutes have been getting less and less informative over the years, due to delay in publishing on the website and the lack of detailed reporting of decisions with redactions based on commercially confidential considerations. It could be argued that there is already a lack of transparency around how decisions are made, so it is important that the details of the business case and underlying assumptions are published in full for review. The argument around confidentiality I would argue is specious given the push for tourism organisations to work far more closely together in the sector, and the potential opportunity for heritage charities to share best practice in business development by sharing insights, evaluations of opportunities and other commercial data with a view to improving the overall heritage tourism business model. Transparency around the commercial opportunities which are seen internally for English Heritage sites may also enable new partnerships and investments, and drive further efficiency and effectiveness in the sector allowing greater reinvestment in the core conservation purpose.

Further details surrounding the assumptions of membership and admission growth are required. These seem to be optimistic, and despite better performance in recent years, the growth curve graph presented looks to be plateauing. What modelling has been done in the light of wider tourism / attractions development data at a UK and European level? It is acknowledged that cultural tourism remains a strong sector in both visitor motivation and spending data, but the sector is challenged by new entrants (in terms of attraction focus and regional growth in other parts of the World). Equally, what risks have been taken into consideration. If another foot and mouth disease outbreak were to occur, the tourism figures could be radically altered.

It would also be helpful for EH to publish the analysis of change in subsidy per visit within the national collection. The effects of altering staffing / opening patterns is noted, and it would be instructive for the sector to see how the performance of the portfolio has been “turned around” in the recent past. This may allow for further critical analysis of assumptions about investment potential and performance.

Further explanation needs to be provided on why it is felt that there are restrictions on investment (beyond year end carry over). The current restrictions on growth need to be explained, in comparison to the activities that seem to be possible in the structures operated by the national museums. How will the new structure create freedoms which cannot be created by other means? What happens to the current EH trading companies for example?

The charity is to be created as a public corporation: does DCMS have this power? Why is a public corporation, when British Waterways in becoming C&RT has moved away from this structure through a Trustee Settlement to a Charity and Community Interest Company? The question on restrictions needs to be explained in respect of this type of organisational vehicle being used. Perhaps a more fundamental point of question is whether an “independent” charity is in fact being created at all? A public corporation is still effectively falling within the family of Government organisations.

With regard to the English Heritage brand: has a full evaluation been made of the brand equity? What are the implications for established value of brand equity in licensing it to a new body? Will the license provide clear parameters for maintaining / enhancing brand equity?

Capital investment in sites: whilst welcome, which sites will be invested in, what will be undertaken, and will further detail be provided on the expected returns on investment? Who will own the physical / capital assets invested in at sites? Will it be the charity or the Commission? Are there implications for ownership of intellectual property (IP) in property development or enhancement of visitor services and interpretation? In providing for effective management of the charity, will documentation on property management be transferred to the charity (rather than remaining as ‘public record’ within the current English Heritage Archive)? What happens to the current stock of English Heritage shops – how is it being transferred to the new charity?

Can further detail be provided on the conservation backlog. Recent figures are not available, and it is unclear that the proposed £80m endowment will actually be able to cover the necessary costs. What consideration has been given to the availability of professionals to undertake this work, and is there any knock on effect with regard to identified conservation skills shortages already in existence.

Organisational form: alternative management arrangements have been under consideration in both Scotland and Wales recently. It is noted that options appraisal has been published in Scotland for the merger of Historic Scotland and the Royal Commission: the text suggests that other options have been looked at – why have these not been published? For example, given there is a tried and tested public corporation model in existence in the form of Historic Royal Palaces, what consideration has been given to the relationship of HRP to these changes, or opportunities for HRP or other bodies to manage the portfolio? What consideration has been given to commercial companies being able to bid to run the portfolio (e.g. Continuum Group or Merlin), or other charitable bodies? This has been hinted at in recent coverage of the changes in Third Sector magazine online http://www.thirdsector.co.uk/news/1228759/English-Heritage-charity-licence-tendered-externally-eight-years/?DCMP=ILC-SEARCH

The argument behind keeping the collection in a single management structure is also not clear, given that the majority of the sites are free entry and there is therefore little likely effect on membership benefits or perceptions. The text notes that the profitable sites (a definition of profitable would be useful) could be ‘transferred easily’ – this therefore needs further explanation.
Modelling of the membership and income generation targets need to unpacked further. The correlation between growth in membership and rise in non-membership admissions also needs to be squared in terms of one income stream potentially effecting the other. Performance of allied commercial activity such as the holiday cottages, catering and events also needs to be factored in.

Issues around the accountable officer also need to be explained further. In the consultation document as it stands, the responsibilities and relationships seem to be slightly unclear and potentially problematic. Transparency in accountability is paramount, and this therefore needs much more explanation, particularly where there may be a situation of ‘dual’ trustees.

There is no doubt that much thinking and analysis has gone into the proposal, but it is a shame that the consultation document does not provide the level of evidence or analysis required for a critical appraisal in the public realm. It is hoped that much more information will therefore emerge lest we create a problem which has to be unpicked or shored up economically in a few years’ time. At the moment it is difficult to present a clear view of support or dissent from the proposal.

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