Subject: Re: CADW failures – Revised Report (10 August 2026) From: Sion Buckler Direction: sent Date: Fri, 28 Aug 2026 04:56 UTC Institution: Welsh Government / Cadw Refs: none Archive id: gm-1a046b9c74c62b02 ------------------------------------------------------------ Dr Wigley, One further point has arisen from my continuing examination of the archival material which I would like to place on the record before you respond to my previous correspondence. I was recently directed to material held at Glamorgan Archives to *Glamorgan-Gwent Archaeological Trust (GGAT) planning papers concerning Great House Farm*. If I recall by the longstanding Llandough Council Clerk, who retired the day he finally replied to my FOI's. The references state that the property had previously been described as a *“county treasure”* and that this was recorded in GGAT documentation in connection with the development process. I am presently tracing the underlying GGAT document so that I can establish its precise file reference, author and date before relying upon the wording as a primary citation. I therefore do *not* ask Cadw to accept the “county treasure” description as an established fact at this stage. The significance of the material is instead that it identifies another potentially important body of *professional archaeological documentation concerning Great House Farm which appears to pre-date, or be contemporaneous with, the demolition and development process*. This is relevant to the question I raised in my previous email: *Can Cadw establish from its surviving records what pre-existing archaeological information concerning Great House Farm was actually considered in reaching the December 1988 conclusion that the site was “not of sufficient archaeological interest”?* I appreciate that Cadw may now be unable to answer that question. If so, that inability should be distinguished from evidence that the information was not available or was not considered. I also wish to make one clarification concerning the additional Llandough material I mentioned previously. I am *not* seeking to bring the architectural or listing status of St Dochdwy’s Church within the scope of my Great House Farm enquiry. The church is relevant only insofar as the archaeological evidence concerning the wider Llandough site may assist in understanding the archaeological context in which Great House Farm was assessed. The focus remains exclusively on *Great House Farm and the December 1988 spot-listing decision concerning that building*. The evidential position I am attempting to establish is therefore increasingly precise: 1. What professional architectural and archaeological evidence concerning Great House Farm existed before December 1988? 2. What of that evidence can Cadw establish was considered by the 1988 inspector or decision-maker? 3. Where Cadw cannot establish this because the assessment records no longer survive, can that evidential limitation be expressly acknowledged? I will continue separately with Glamorgan Archives/Heneb to identify the underlying GGAT “county treasure” reference and will provide the precise citation once established. Please treat this email as a further supplementary note to my existing submission rather than as a new FOI request. Yours sincerely, Sion Buckler (Ret'd Sergeant) On Thu, 27 Aug 2026, 15:52 Sion Buckler, <[email redacted]> wrote: > Dear Dr Wigley, > > Thank you for your response and for the further clarification concerning > the surviving Cadw records and the historic retention arrangements. > > Having considered your response alongside the evidence set out in my > report of 10 August, I think it is important to distinguish between two > quite separate propositions: > > 1. *Cadw has released all records concerning the 1988 assessment which > it can now locate*; and > 2. *the surviving records establish the evidential and administrative > basis upon which the December 1988 decision was made.* > > Your response appears to establish the first, but not the second. > > That distinction is important because the surviving evidence is > exceptionally limited: two photographs. The absence of the underlying > assessment papers means that a number of historically significant questions > cannot now be answered from Cadw's records. > > I am therefore asking for clarification of the position rather than asking > Cadw to recreate records which no longer exist. > 1. What the surviving record establishes > > Could Cadw please confirm whether the following is an accurate description > of the present evidential position: > > *Cadw's surviving records do not establish the evidential or > administrative basis of the December 1988 decision not to list Great House > Farm. In particular, the surviving records do not establish what evidence > was considered by the inspector or decision-maker, whether the H.J. Thomas > RCAHMW survey of 26 April 1974 was considered, whether the relevant > SMR/GGAT archaeological material was considered, what inspection findings > were recorded in December 1988, or whether any internal recommendation or > consultation took place.* > > If that is correct, I would be grateful if Cadw would confirm it expressly. > > I am not suggesting that the absence of records proves that those matters > did not occur. Equally, however, the absence of records means that Cadw > cannot now establish that they did occur. > > That is the central evidential limitation created by the loss of the 1988 > working papers. > 2. The 1974 H.J. Thomas RCAHMW survey > > Your response says: > > "we are unable to determine whether or not the 1974 survey was taken into > account at the time." > > That is a particularly important clarification. > > The RCAHMW survey was not a document subsequently created in response to > the dispute. It was a professional survey undertaken on 26 April 1974 and > recorded architectural features including the late-17th-century > construction, Type A sub-medieval cross-passage plan, substantial timber > framing and the barrel-vaulted cellar. > > I therefore ask Cadw to confirm simply: > > *Cadw cannot now establish from its surviving records whether the > inspector or decision-maker responsible for the December 1988 assessment > had considered the H.J. Thomas survey before concluding that Great House > Farm was "not of sufficient architectural merit".* > > If that is Cadw's position, I will record it as such. > 3. The archaeological evidence > > The same issue appears to arise in relation to the archaeological > assessment. > > My report identifies evidence predating December 1988 concerning Roman, > Iron Age and medieval activity at the site, including the recorded SMR > material and the 1978–80 archaeological investigations. > > I appreciate that the later 1994 excavation cannot simply be projected > backwards and treated as evidence which Cadw necessarily possessed in 1988. > > The relevant question is narrower: > > *Can Cadw now establish, from any surviving record, what archaeological > information was actually considered when the December 1988 conclusion was > reached that the site was "not of sufficient archaeological interest"?* > > If it cannot, please confirm that this cannot now be established. > > This would avoid conflating the later archaeological discoveries with the > separate question of what information was available to Cadw in 1988. > 4. The July "YYY" coding > > There remains an important unresolved point concerning the July 1988 > photographs. > > Cadw has previously explained that the "YYY" coding indicated that the > building did not meet the listing criteria. The photographs were taken on > 29 July 1988. > > The contemporary press report of 3 December 1988, however, records Cadw as > saying that it was then "considering" asking the Secretary of State to > protect Great House Farm as a listed building and that an inspector would > visit that weekend. > > I appreciate that the records necessary to resolve this may no longer > exist. > > Nevertheless, could Cadw confirm whether it can establish: > > - what "YYY" specifically represented within the July 1988 process; > - whether it was a final assessment or provisional coding; > - whether it was applied by the July inspector; > - whether the July assessment was subsequently reviewed in December; > and > - whether the December inspector had access to the July photographs or > any associated assessment. > > If none of these matters can now be established, I would be grateful for > that to be confirmed rather than inferred. > 5. Identity of the December decision-maker > > One further factual gap remains. > > Can Cadw establish the identity of: > > - the inspector who undertook the December 1988 inspection; and > - the person who made or authorised the decision communicated on 5 > December 1988 that Great House Farm was not of sufficient architectural > merit and archaeological interest? > > If the relevant individual(s) cannot now be identified from surviving > records, please confirm that. > > This is not a request for personal information beyond what would > ordinarily form part of the historical administrative record. It is simply > an attempt to establish whether the decision itself can still be attributed > to an identifiable office-holder. > 6. The retention explanation > > I also wish to clarify an important qualification in your latest response. > > You state that current colleagues have advised that, based on their > knowledge of the systems then in place, unsuccessful listing files were > *"likely"* to have been retained for approximately three years. > > I understand that this is necessarily a reconstruction of historic > practice because the relevant records no longer exist. > > Could you therefore confirm whether Cadw has located: > > - a 1980s retention schedule; > - a disposal or destruction policy applicable to the relevant records; > - a disposal schedule; > - a destruction certificate or log; > - a transfer/accession record to RCAHMW or another repository; or > - any other contemporaneous record showing what happened to the Great > House Farm material. > > If none has been located, I would be grateful if Cadw could state > expressly that *the approximately three-year retention period is an > account of the general historic practice as presently understood by current > staff, and not documentary evidence establishing that the Great House Farm > records were actually destroyed after three years.* > > That is an important distinction for the historical record. > 7. What I am seeking from Cadw > > I am not asking Cadw to speculate about matters for which the documentary > evidence has disappeared. > > Indeed, the purpose of my report was deliberately to separate: > > > > *what is established; what is a reasonable inference; and what can no > longer be verified because the records do not survive.* > > Your latest response is helpful in establishing the third category. > > I would therefore be grateful if Cadw could confirm, insofar as its > records permit, the following concise position: > > *The surviving Cadw records relating to the December 1988 Great House Farm > assessment consist of two photographs. Cadw cannot now establish from > surviving records the detailed evidential or administrative basis of the > decision, including whether the 1974 H.J. Thomas RCAHMW survey or relevant > archaeological records were considered. Cadw has not located records > establishing the disposal or transfer of the missing assessment material, > and the approximately three-year retention period represents the best > present understanding of historic practice rather than documentary evidence > concerning the disposal of this particular file.* > > If that accurately reflects Cadw's position, I would regard that > clarification as extremely useful. > 8. Historical record and next steps > > I will separately approach Heneb concerning the Historic Environment > Record, as you have advised, and will pursue the question of any > appropriate heritage interpretation or marker with the relevant local > authority. > > I also appreciate your clarification that Cadw cannot require or > facilitate installation of a marker. > > My purpose in continuing this correspondence is therefore narrower than > seeking to reopen the FOI request. I am seeking to ensure that the > historical record does not inadvertently suggest that the absence of > surviving records means that the basis of the 1988 decision has been > established. > > On the evidence presently available, the more accurate position appears to > be that *the decision is documented, but its underlying evidential and > administrative reasoning is no longer recoverable from Cadw's surviving > records.* > > That is a significant historical finding in its own right. > > Thank you again for your assistance. I would be grateful for confirmation > of the above points, particularly the status of the 1974 survey, the July > "YYY" coding, the identity of the December decision-maker, and the > evidential basis (if any) for the disposal of the missing records. > > Yours sincerely, > > Sion Buckler (Ret'd Sergeant) > > On Thu, 27 Aug 2026, 13:21 , <[email redacted]> wrote: > >> Dear Mr Buckler >> >> >> >> Thank you for your latest correspondence dated 10th August in relation >> to your initial freedom of Information request (ATISN 27021) submitted in >> June 2026, which has been escalated to me for response. >> >> >> >> As stated by my colleagues, I can confirm that all records we hold have >> been released to you. We do not hold any further records relating to the >> content or disposal of the historic records you have requested. >> >> >> >> To confirm, colleagues in the records office have clarified the historic >> retention position to the best of their knowledge. Given that the issue >> relates to an historic record retention policy, and that no records >> regarding this are available, it is not possible to say exactly what CADW’s >> retention arrangements were over 38 years ago. However, based on their >> knowledge of the systems in place at the time, current colleagues have >> advised that it is likely that records of unsuccessful listings were only >> retained for a short period, usually about 3 years. This has since changed >> and current retention policy in relation to unsuccessful listings is to >> retain the files indefinitely, reviewed every 5 years. >> >> >> >> In relation to your question *‘Did Cadw’s 1988 assessment of Great House >> Farm fully account for the independent professional evidence then >> available- particularly the H.J. Thomas RCAHMW survey of 1974- and if not >> why not?’*. As stated, all of the records we hold have been released to >> you under the FOI and are now a public record. As the release consists of >> only two photographs we are unable to determine whether or not the 1974 >> survey was taken into account at the time. >> >> >> >> In relation to question A, please see our previous emails of 2nd, 3rd, 10 >> th and 29th July, together with the above explanation of the historic >> and current retention policies. >> >> >> >> In relation to question B, content of the HER is managed by Heneb. Please >> contact www.heneb.org.uk in relation to adding information to the HER. >> >> >> >> In relation to question C, please refer to the FOI response provided on >> the 11th June 2026 which is a matter of public record and confirms >> Cadw’s position. >> >> >> >> In relation to question D, noted above. >> >> >> >> In relation to question E, Cadw are unable to require or facilitate the >> installation of a heritage marker at the site. >> >> >> >> Yours sincerely, >> >> >> >> Andy Wigley >> >> >> >> >> >> >> >> Dr Andy Wigley >> >> Prif Arolygydd – Pennaeth Arolygiaeth yr Amgylchedd Hanesyddol / Chief >> Inspector - Head of Historic Environment Inspectorate >> >> Cadw >> >> Dysgu, Cymunedau a Diwylliant / Learning, Communities and Culture >> >> Llywodraeth Cymru / Welsh Government >> >> Tŷ Ladywell / Ladywell House >> Y Drenewydd / Newtown >> Powys >> [postcode redacted] >> >> >> >> Ffôn / Tel: [phone redacted] >> Ffôn symudol / Mobile: [phone redacted] >> >> E-bost/ Email: [email redacted] / [email redacted] >> >> P Helpwch yr amgylchedd - peidiwch ag argraffu hon os nad oes gwir >> raid Help our environment - only print this if really necessary >> >> Rydym yn croesawu gohebiaeth Gymraeg. Cewch ateb Cymraeg i bob gohebiaeth >> Gymraeg ac ni fydd gohebu yn Gymraeg yn arwain at oedi. >> >> We welcome correspondence in Welsh. Correspondence received in Welsh will >> be answered in Welsh and corresponding in Welsh will not involve any delay. >> >> >> >> >> >> *From:* Sion Buckler <[email redacted]> >> *Sent:* 10 August 2026 22:46 >> *To:* Longford, Amy (LCC - Cadw) <[email redacted]> >> *Cc:* Cadw Planning <[email redacted]>; >> [email redacted]; DOUGHTY, Stephen < >> [email redacted]> >> *Subject:* Re: CADW failures – Revised Report (10 August 2026) >> >> >> >> Sirs/Ma'ams, >> >> I write further to my email of 9 August 2026 submitting a review >> concerning Cadw’s 1988 assessment of Great House Farm (Ty Mawr), Llandough. >> >> Please find attached (and linked below) a revised edition of the report, >> dated 10 August 2026. This version has been carefully restructured to >> present the same evidence in a more measured and administratively focused >> form. It is offered as a request for historical record correction, archival >> explanation, and administrative acknowledgement rather than as a forensic >> challenge. >> >> The revised document: >> >> • Clearly states what it is and is not; >> • Sets out the surviving independent evidence (principally the H.J. >> Thomas RCAHMW survey of 1974); >> • Notes the near-total absence of Cadw’s 1988 working papers confirmed in >> ATISN 27021; >> • Asks only for realistic, achievable administrative steps: explanation >> of the archival position, reflection of the surviving evidence in the >> Historic Environment Record, acknowledgement of the records gap, and >> consideration of a local heritage marker. >> >> It does not claim unlawfulness, seek compensation from Cadw, or demand a >> public inquiry. >> >> I hope this revised presentation is more palatable and will assist the >> relevant bodies in providing a constructive response. >> >> I look forward to your substantive response. >> >> Regards, >> >> Sion Buckler (Ret’d Sgt) >> Royal Signals >> Cyber and Electronic Warfare Professional and Life Member >> [email redacted] >> >> [phone redacted] >> Sganiwyd y neges hon am bob feirws hysbys wrth iddi adael Llywodraeth >> Cymru. Mae Llywodraeth Cymru yn cymryd o ddifrif yr angen i ddiogelu eich >> data. Os cysylltwch â Llywodraeth Cymru, mae ein hysbysiad preifatrwydd >> yn esbonio sut rydym yn defnyddio eich gwybodaeth a sut rydym yn diogelu >> eich preifatrwydd. Rydym yn croesawu gohebiaeth yn Gymraeg. Byddwn yn anfon >> ateb yn Gymraeg i ohebiaeth a dderbynnir yn Gymraeg ac ni fydd gohebu yn >> Gymraeg yn arwain at oedi. ----------------- On leaving the Welsh >> Government this email was scanned for all known viruses. The Welsh >> Government takes the protection of your data seriously. If you contact the >> Welsh Government then our Privacy Notice >> >> explains how we use your information and the ways in which we protect your >> privacy. We welcome receiving correspondence in Welsh. Any correspondence >> received in Welsh will be answered in Welsh and corresponding in Welsh will >> not lead to a delay in responding. >> >