Consultation responses: Future priorities for and delivery of the Aggregates Levy Sustainability Fund - April 2008 to March 2011 (Defra 2008)	Consultations index
Submission from ALGAO:England Consultation on the future priorities for and delivery of the Aggregates Levy Sustainability Fund - April 2008 to March 2011 Introduction The Association of Local Government Archaeological Officers:England (ALGAO:England) is part of the over-arching ALGAO:UK. It is the national body representing local government historic environment services on behalf of County, District, Unitary and National Park authorities in England. ALGAO:England co-ordinates the views of English member authorities (94 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association on historic environment matters. Context of the consultation: A number of pieces of current or proposed legislation, guidance and policy provide an over-arching context for the Aggregates Levy Sustainability Fund (ALSF). These are outlined below to provide a context for the ALGAO responses to the questions asked by the consultation. The European Landscape Convention (ELC) is relevant to the landscape character of aggregates production. It defines landscape as "an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors"; UK Government has undertaken, under the terms of the ELC, to "integrate landscape into any other policies with possible direct or indirect impact on [it]". The ALSF provides Defra and participating bodies with an ideal opportunity to demonstrate UK Government's firm commitment to delivering ELC. ALSF provides an opportunity to demonstrate implementation of the European Landscape Convention through a detailed and quantifiable programme of landscape management, protection and planning projects promoting sustainability and delivering integrated community benefits. There is a need to recognise the fundamental inter-relationship between the natural and cultural aspects of landscape, as contained within Minerals Policy Statement 1 (MPS1), which acknowledges that identification and exploitation of environmentally acceptable minerals reserves is a fundamental basis for sustainable planning, for both the natural and historic environments. The presumption in favour of the preservation in situ of listed buildings, scheduled monuments and other nationally important archaeological remains, and their settings, underlines the importance of having a sound evidence base for decision making. ALSF provides an opportunity to establish and develop, in the context of sustainable planning, the strategic evidence base for sustainable extraction in line with MPS1 in ways that cannot be achieved by focussing on the duties of specific developers or local authorities. The planning White Paper: Planning for a Sustainable Future proposes some significant changes to the planning process, including more meaningful-community and stakeholder involvement, which will require a comprehensive evidence base that is fit for purpose for decision making - and critically, to inform discussions being held as early in the process as possible. ALSF provides an opportunity to ensure that an appropriate, integrated evidence base is established to improve efficiency and speed up the delivery of consistent, informed planning decisions. The Draft Heritage Protection Bill contains some specific areas with potential relevance to aggregates extraction, should the proposals become law. These include Heritage Partnership Agreements for owners and managers of complex assets (for example large landholdings with multiple historic and nature conservation assets); the development of local authority Historic Environment Records as the primary evidence-base for informing developers, communities and planners; and the broadening of the types of historic 'structures', including marine, that may be designated. ALSF provides an opportunity to create capacity to assess and research the impacts of the proposed legislation and to inform provision of guidance and capacity building to local authorities and industry to enable transition to the proposed new heritage protection regime. Question 1: Do you agree with these aims and the overarching themes for the programme? ALGAO considers that the aims and over-arching themes for the programme, as defined in the consultation document, give a clear direction to the programme and cover all the relevant aspects of aggregates extraction. Question 2: Do you agree with the proposals for the quarries theme? ALGAO supports the over-arching aims of Theme 1 but would make the following points: Strategic environmental performance activities It is important that high quality historic environment information is available to the minerals planning process, for Strategic Environmental Assessments and for Sustainability Appraisals. The relatively limited number of strategic archaeological resource assessments of areas that are or may be proposed for extraction have already proved extremely cost-effective. Comprehensive coverage of these assessments should be encouraged and used to enhance local authority Historic Environment Records. An important output of the archaeological resource assessments that the ALSF has so far supported has been to reveal that in some places, such as river valleys, erosion and sedimentation have obscured the nature of the archaeological resource. This has in turn demonstrated that some areas that had previously been considered barren archaeologically have been shown, in fact, to have a high potential for both archaeological and palaeoenvironmental remains. Sufficient funding needs to be made available through the ALSF process to continue the development of integrated historic environment databases to inform strategic planning in aggregate areas. Their availability will reduce the environmental footprint of the industry and deliver sustainability by reducing the historic environment risk associated with winning aggregates; provide value for money through the cost-effective methodologies employed in such work; and have direct benefits in rural areas, not least through providing information to raise awareness and understanding within communities and re-connecting them with their heritage. ALGAO considers that to achieve these positive ambitions the proposed sum of £0.5m to be made available to English Heritage should be increased to £1m per annum. Repair and conservation of important historic features and support for unanticipated important discoveries during quarrying ALGAO understands that the average annual expenditure through the EH-dispensed Fund has been c. £325,000 pa. While good practice guidance, predictive modelling toolkits and strategic resource assessments will, increasingly, reduce the need for support of this nature, there will not be a significant reduction in the short-term of the next three years. There is no other readily available source of funding for this need. Without access to resources, these irreplaceable and previously unknown archaeological sites of national significance will be destroyed without record. Expenditure of this nature would be in addition to works on structures, sites and buildings threatened by past quarrying activities. These projects provide public benefit, often occur in partnership with habitat restoration schemes, and provide links between the quarries and communities themes. Provision needs to be made for support via the EH-dispensed Fund for appropriate outreach and communication strategies related to these activities. This would also reflect synergies with and provide support for the proposed planning reforms and their proposals for enhanced community and stakeholder engagement. ALGAO considers that, in order to achieve the above, the proposed sum of £0.5m to be made available to EH needs to be increased to £1m per annum. Question 3: Specifically on the carbon reduction proposals, do you have any views about how The Carbon Trust should select the companies with which it works? ALGAO supports the proposals but considers that selection should not just be about easy wins but should tackle some of the more-intractable problems. Consideration should be given to creating an award scheme or something similar that would act as an environmental quality mark for those who are successful and could become a 'must-have' for the industry. Question 4: Do you agree with the proposals for the marine theme? ALGAO is pleased to note that the marine theme continues to be addressed by this proposal. To maximise the benefit of projects, ALGAO would suggest that a mechanism needs to be developed that ensures that wherever an ecological or environmental mapping project is undertaken through Cefas, then English Heritage should be consulted as early as possible in the development stage, to ensure opportunities for gathering historic environment data are not overlooked (and that this process should be reciprocated for any appropriate historic environment projects that EH develops). Question 5: Do you agree with the proposals for the resource use theme? ALGAO considers that there exists a major opportunity to enhance carbon emission savings and reduce the demand for primary aggregates for construction, by rehabilitating and conserving historic building stock and delivering more-sustainable use of resources. More needs to be made in these proposals for the Fund of the opportunities to reduce new construction requirements in general by recycling rather than replacing buildings (along with their integral aggregates and the embodied energy contained within their materials and structures). Given the carbon dioxide emissions from dwellings (c. 23% of national output) and energy use within those buildings, there is a major opportunity to provide ALSF-funded research into reduction of emissions, reduction in energy use and how this can be achieved through the sustainable use of resources, including recycled materials, while taking into account the differing conservation requirements of designated and non-designated buildings. ALGAO considers that this is an essential area of research that the Fund should engage with and that EH should have an initial allocation of £0.25 per annum. to begin this research. Question 6: Do you agree with the proposals for the transport theme? ALGAO agrees with the proposals for the transport theme. Question 7: Do you agree with the proposals for the communities theme? ALGAO agrees generally with the proposals. However, the conservation and repair of locally significant monuments and artefacts was a new element for EH, initiated only in 2007. Significant successes were achieved in that year, enabling communities to re-establish links with monuments in their landscapes. ALGAO is therefore very disappointed that provision is not apparently being made for continuation of this strand and strongly recommends that it should be reinstated as an element of the EH-dispensed Fund, with a starting provision of at least £0.5m per annum. Additional questions: Question 8: Do you agree with the way the funding has been split? If not how would you split the funding and why? ALGAO does not agree with some aspects of the proposed split of the funding. Please refer to the responses to questions 2, 5 and 7. These can be summarised as: Theme 1 - Quarries: English Heritage allocation should be increased from £1m to £2m per annum. Theme 3 - Resource use: English Heritage should receive an allocation of £0.25m per annum. Theme 5 - Communities: English Heritage should be enabled to build in the results already achieved, through an allocation of £0.5m per annum. Question 9: Are there specific issues that should receive attention or more emphasis? ALGAO considers that the Fund has been put to significant and cost-effective use, dealing with the legacies of work associated with aggregates production which were undertaken during the pre-PPG16 era (before 1990) when resources for adequate post-excavation and publication were not available. The analysis and publication of these archaeological sites, using the latest scientific techniques, has proved to be a major contribution to the understanding of England's heritage. However, there remains a small number of nationally significant projects that still need to be brought to conclusion, published and made available for wider public benefit. ALGAO considers that an additional £0.25m per annum should be made available to EH to enable this work to be progressed towards an appropriate conclusion. Question 10: Are the organisations we have selected to deliver the funding the right ones? ALGAO considers them to be the appropriate organisations to deliver the Fund. Question 11: Are there alternative ways to meet the objectives of the Fund more efficiently? ALGAO considers that one additional way would be through enhanced publicity and popular presentation of the results of many of the projects, to raise awareness of the fundamentals of climate change and its mitigation, as well as of the Fund and what can be achieved through it. I hope that you find the above comments useful. Please don't hesitate to contact me if you require any further comment, clarification or explanation. Yours sincerely Ken Smith Vice Chair, ALGAO:England Consultations index