Subject: Re: Statutory notice under Historic Environment (Wales) Act 2023 ss.194–195 — HER GGAT02038s still classifies Wales’s largest excavated early-medieval cemetery as “POST MEDIEVAL – Farm” From: Sion Buckler Direction: sent Date: Wed, 30 Sep 2026 04:01 UTC Institution: Welsh Government / Cadw Refs: RC26-0375 Archive id: gm-1a0f079948f7f7d7 ------------------------------------------------------------ Dear Cabinet Minister for Culture and Sport, This is a short supplement to my letter of 20 September 2026 on the historic environment record for Great House Farm / Tŷ Mawr, Llandough (NPRN 20182; HER GGAT02038s). It does not replace that letter. It does not ask you to adjudicate title. Three corrections to the letter of 20 September 1. A sentence in the middle of that letter was left unfinished. Please disregard it. Nothing in the requests depends on it. 2. The HM Land Registry letter forwarded by the constituency MP was dated 18 September 2026, not “yesterday”. On 27 September I wrote separately to HM Land Registry to correct a year I had used in earlier correspondence about titles WA231076 and WA240304. That correction is not a request to you. 3. I asked whether guidance under section 196 had been issued. Cadw’s published page now states that Historic Environment Records in Wales: Compilation and Use (2017) is issued as statutory guidance under section 196 of the 2023 Act. What I still need is confirmation whether that 2017 text has been substantively reviewed since sections 194 to 196 came into force on 4 November 2024, and the date on which the current guidance was issued under section 196 and laid before Senedd Cymru. I would also be grateful for confirmation whether the current guidance addresses primary classification of records and the behaviour of the public interface. What has happened since 20 September, relevant to the duties On 27 September I made a formal complaint to Heneb concerning the HER identifiers, classification and the 1978–1995 record. Steven Foulston acknowledged it on 29 September as investigating officer, with a five-week target. That is Heneb’s own process. It does not discharge the Ministers’ duties under sections 194 and 195. On 29 September the Royal Commission (RC26-0375) supplied the core description it says is used for GGAT02038s on Archwilio. That description is of a post-medieval farmhouse and barn. It records medieval finds, the 1974 survey and the demolition of 6 December 1988. The live HER also links the site to the separate 1994 excavation event, GGATE003875, which contains the excavation details and findings. The adequacy question in my letter of 20 September can therefore be put more precisely: whether the HER, taken as a whole, provides the details of relevant investigations and their findings required by section 194(2)(j), and whether the way those records are classified, linked and presented publicly is sufficient for that purpose. Cadw’s stage-one complaint on the 1988 listing decision remains open (ticket #628635887). That is a separate file. I mention it only so the two are not confused. The latest position is that the complaints investigation has commenced. The five requests in the letter of 20 September stand. The one that can be tested immediately remains the Archwilio silent-substitution question: whether an unresolved HER reference can silently resolve to a different record without warning. I will work to the published seventeen-working-day response aim from 20 September. If a substantive response will take longer, I would be grateful simply to be told. Regards, Sion Buckler (Ret'd Sergeant) Royal Signals Cyber and Electronic Warfare Professional and Life Member