Subject: Re: Acknowledgement from the Culture, Communications, Cymraeg and Sport Committee From: Sion Buckler Direction: sent Date: Thu, 17 Sep 2026 16:24 UTC Institution: Senedd Refs: none Archive id: gm-1a0b02f7e35332ab ------------------------------------------------------------ Haidee, Thanks. I am also asking the Senedd to consider whether the circumstances surrounding the demolition of Great House Farm, Llandough-juxta-Penarth, and the subsequent planning and heritage history of the site warrant independent scrutiny and, ultimately, a public inquiry or Senedd committee inquiry. I am not asking the Senedd to determine a private property dispute or to decide legal questions that properly belong before the courts. My concern is the conduct, decision-making, record-keeping and accountability of public bodies responsible for heritage protection, planning and local government. The surviving evidence presents a series of unusually important questions. Great House Farm was professionally surveyed by the Royal Commission on the Ancient and Historical Monuments of Wales in 1974. In December 1988, Cadw was considering the building for emergency spot-listing, with a contemporary report stating that inspectors were due to visit and consider the case. The European Commission of Human Rights records that the Convention application had been introduced on 3 May 1988; BP obtained possession on 29 November 1988; demolition began on 6 December 1988; and the application was not registered by the Commission until 12 December 1988. The evidence therefore establishes a very compressed sequence in which emergency heritage protection was being considered, domestic interim relief was refused, possession was obtained and the building was then destroyed within days. That chronology does not, by itself, establish coordination, deliberate suppression or unlawful conduct. It does, however, warrant investigation. There are several specific questions which I believe require answers from an authority independent of the present local authority: 1. What information and records were actually considered by Cadw when the 1988 spot-listing decision was made? 2. Was the 1974 RCAHMW architectural survey considered, and if not, why not? 3. What communications took place between Cadw, South Glamorgan County Council, BP Properties Ltd, the courts and any other public bodies during the critical period immediately preceding demolition? 4. What consideration was given by the local planning authority to the available statutory powers of preservation in circumstances where demolition was imminent? 5. Why was the building destroyed before there could be an independent retrospective architectural examination of the fabric? 6. How should the later archaeological evidence, including the discovery of approximately 1,026 burials in 1994, be understood in assessing the historic significance of the site and the adequacy of the earlier decision-making? I recognise that this later discovery cannot retrospectively prove that the 1988 listing decision was unlawful. 7. A 1989 planning document appears to describe the site as having formerly contained Great House Farm “(a listed building)”. I ask that this apparent discrepancy be investigated and reconciled with the 1988 Cadw decision. 8. What records relating to these decisions still exist, where are they held, and have reasonable steps been taken to preserve and disclose them? I am particularly concerned that the destruction of the physical building in December 1988 permanently removed primary architectural evidence which could otherwise have been examined independently. I also ask the Senedd to consider the wider public-interest question: whether the present mechanisms for accountability are adequate where a historic building is destroyed during a period of rapidly developing legal, planning and heritage proceedings and significant questions remain about what information was available to decision-makers. I would therefore ask the Petitions Committee to consider accepting a petition on this subject and, where appropriate, referring the matter to the relevant Senedd committee or committees for investigation. I would also welcome consideration of whether an independent public inquiry, committee inquiry or other form of external investigation would be appropriate. I am prepared to provide the underlying documents, chronology, court material, heritage records, planning documents and correspondence supporting these questions. I am not asking the Senedd to adopt my conclusions. I am asking that the evidence and unanswered questions be examined independently and that the relevant public bodies be required to account for what they did, what they knew, and what records exist. Please confirm the appropriate route for submitting this formally to the Senedd and whether the material can be referred to the Petitions Committee for consideration. Yours faithfully, Sion Buckler (Ret'd Sergeant) Royal Signals Cyber/Electronic Warfare Professional and Life Member On Wed, 12 Aug 2026, 10:13 Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg a Chwaraeon - Culture, Communications, Cymraeg and Sport Committee, <[email redacted]> wrote: > Dear Mr Buckler, > > > > Thank you for your further correspondence and for clarifying the purpose > of your submission. > > > > I understand the distinction you draw between seeking a review of the > original 1988 decision and raising broader concerns about record-keeping, > archival practice, and public accountability. However, the Committee's role > is to scrutinise and hold the Welsh Government and associated public bodies > to account in relation to policy, governance, and the use of public > resources. > > > > While I appreciate the broader administrative concerns you have > identified, the issues raised in your correspondence arise from a specific > historical case. The Committee does not have a role in reviewing or > overseeing day-to-day operational decisions taken in individual cases. > Accordingly, the Committee is unable to take forward the matters raised in > your correspondence. > > > > If you wish to pursue concerns regarding the management, retention or > preservation of historical records, these matters are most appropriately > raised with the relevant public authority or archival body responsible for > those records. Similarly, concerns regarding the administration of a public > body should be pursued through that body's complaints procedure and, where > appropriate, with the Public Services Ombudsman for Wales. > > > > Thank you for taking the time to write to the Committee and to set out > your concerns in detail. > > > > Yours sincerely, > > > > Haidee > > > > *Haidee James* > > *Ail Glerc, Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg a Chwaraeon,* > Senedd Cymru > > *Second Clerk, Culture, Communications, Cymraeg and Sport Committee,* > Welsh Parliament > > [phone redacted] *Rhagenwau|Pronouns:* hi – she/her > > > > > > *From:* Sion Buckler <[email redacted]> > *Sent:* 11 August 2026 16:57 > *To:* Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg a Chwaraeon - Culture, > Communications, Cymraeg and Sport Committee <[email redacted] > > > *Subject:* Re: Acknowledgement from the Culture, Communications, Cymraeg > and Sport Committee > > > > Dear Ms James, > > Thank you for your considered response. > > I understand and accept that the Committee does not have a remit to > adjudicate upon an individual dispute, determine whether a historical > decision was lawful, or direct Cadw to reopen a particular case. My > submission was deliberately framed so as not to ask the Committee to do any > of those things. > > I would, however, respectfully clarify one point, because I am concerned > that the nature of the request may have been characterised more narrowly > than intended. > > The attached report expressly states that it is *not a legal challenge, a > forensic proof of wrongdoing, a complaint seeking adjudication, or a demand > for reversal of the 1988 decision*. Its stated purpose is historical > record correction, archival explanation and administrative acknowledgement. > In particular, it asks for an explanation of why almost none of the records > concerning the 1988 assessment survive, whether that reflects the > applicable record-retention arrangements, and whether the surviving > independent evidence should be properly reflected in the permanent public > record. > > The central issue therefore extends beyond the merits of the individual > 1988 listing assessment. > > Cadw's 2026 FOI response confirms that an assessment took place, but that > only two exterior photographs now survive; the assessment report, reasons > for refusal, site notes, internal recommendations and consultation > correspondence are no longer available. The report does not assert that > this proves wrongdoing. Rather, it identifies a straightforward > public-administration question: *how can the adequacy and evidential > basis of an irreversible public heritage decision be understood or > scrutinised when the underlying administrative record no longer survives?* > > That seems potentially relevant to the Committee's stated function of > scrutinising the administration and accountability of Welsh Government and > associated public bodies, even if the Committee cannot itself determine > whether the 1988 decision was correct. > > I am therefore not asking the Committee to investigate the Buckler > family's historical dispute with BP, adjudicate upon the 1988 decision, or > direct Cadw to reverse anything. The specific administrative questions > raised in the report are instead: > > 1. What record-retention arrangements applied to the 1988 assessment? > 2. Why do the assessment report, reasons, site notes and consultation > records no longer survive? > 3. Were the records destroyed under an applicable retention policy or > other authority, and were they considered for transfer to the appropriate > archival institution? > 4. Is the present position consistent with Welsh Government/Cadw > expectations for the preservation of records concerning significant > heritage decisions? > 5. Are current arrangements sufficient to ensure that comparable > heritage assessments, particularly where a building is under imminent > threat of demolition, are properly documented and retained? > > These are not questions that require the Committee to determine the rights > of either party to the original dispute. They concern *administrative > practice, institutional record-keeping and the ability of the Senedd and > the public to scrutinise decisions taken by public bodies*. The report > specifically asks Cadw to explain the archival position and review its > current record-keeping practices for this reason. > > I would therefore be grateful if the Committee could reconsider whether > the broader administrative and accountability issue falls within its > scrutiny function, even if the Committee cannot examine the underlying > individual dispute. > > If the Committee considers that it nevertheless cannot engage with the > matter, I would appreciate clarification as to *which Senedd or Welsh > Government scrutiny, oversight, archival or complaints mechanism is > considered appropriate for raising a documented concern about the absence > of the administrative record of a historical Cadw decision and the > implications this has for public accountability*. > > For completeness, I should also emphasise that the report itself > deliberately recognises the limits of the surviving evidence. It does not > claim that Cadw acted unlawfully or in bad faith, and it expressly > acknowledges that the absence of the 1988 working papers means that the > assessment cannot now be reconstructed definitively. > > My objective is therefore quite limited: *to ensure that the surviving > evidence is preserved, that the archival gap is properly explained, and > that the public record accurately distinguishes what is established from > what can no longer be verified.* > > I hope that clarification assists, and I would be grateful if you could > confirm whether the Committee is able to consider the matter from that > wider public-administration and accountability perspective. > > Kind regards, > > Sion Buckler (Ret’d Sergeant) > Royal Signals Cyber & Electronic Warfare Professional and Life Member > > > > On Tue, 11 Aug 2026, 07:58 Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg a > Chwaraeon - Culture, Communications, Cymraeg and Sport Committee, < > [email redacted]> wrote: > > Dear Mr Buckler, > > > > Thank you for your correspondence and for sharing the forensic review of > Cadw's 1988 assessment of Great House Farm (Ty Mawr), Llandough. I > acknowledge the strength of feeling expressed in your letter and recognise > the longstanding concerns that you and your family have raised. > > > > The Committee’s role is to scrutinise the work of the Welsh Government and > associated public bodies, including holding ministers and public > authorities to account for their policies, administration and use of public > resources. However, the Committee does not have a remit to investigate, > adjudicate upon, or oversee individual complaints or dispute. Nor does it > have the powers to reopen historical decisions or direct public bodies to > undertake investigations into specific matters. > > > > The Committee is therefore unable to take on an oversight role in relation > to the issues you raise or to intervene in these matters. > > > > The matters you raise appear principally to concern the actions and > decision-making processes of Cadw in relation to a specific historical > assessment. Cadw are responsible for responding to requests for information > about their records and decision-making processes, and for considering any > representations made regarding the accuracy or completeness of the > historical record. > > > > Thank you again for writing to the Committee. > > > > Kind regards, > > > > Haidee > > > > *Haidee James* > > *Ail Glerc, Pwyllgor Diwylliant, Cyfathrebu, y Gymraeg a Chwaraeon,* > Senedd Cymru > > *Second Clerk, Culture, Communications, Cymraeg and Sport Committee,* > Welsh Parliament > > [phone redacted] *Rhagenwau|Pronouns:* hi – she/her > > > > > > *From:* Sion Buckler <[email redacted]> > *Sent:* 10 August 2026 22:46 > *To:* [email redacted] > *Cc:* [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] > >