Consultation responses: Scottish Historic Environment Policy: Historic Battlefields (Scottish Government 2008)	Consultations index ALGAO:Scotland
Submission from ALGAO:Scotland SHEP on Battlefields Historic Scotland Longmore House Salisbury Place Edinburgh EH9 1 SH 23rd July 2008 Dear Sirs, Historic Battlefields SHEP consultation ALGAO:Scotland represents Local Authority and National Park archaeological services in Scotland and is part of the UK-wide organisation, ALGAO:UK. We welcome this opportunity to comment upon this latest Scottish Historic Environment Policy (SHEP) on Historic Battlefields produced by Historic Scotland on behalf of the Scottish Government and would like to offer the following comments and recommendations. Question 1: Do you agree that a policy for the protection and sustainable management of historic battlefields is necessary? If not, what alternative course of action would you suggest, and why? Our Historic Battlefields and the events that took place in and around them have changed and defined not only our national history but also our cultural identity. Our members have long been concerned about the future survival, management, promotion and interpretation of this important archaeological resource, especially in light of development pressures and unregulated metal detecting. Accordingly, a strong and comprehensive policy for the protection and sustainable management of our nationally significant historic battlefields is absolutely crucial. Consequently, ALGAO:Scotland welcomes Scottish Ministers recognition of the significance of our historic battlefields and supports their desire to establish a Scottish Historic Environment Policy (SHEP) for these nationally important sites. We would, however, wish to see the principles enshrined in this policy to cover all our significant 'fields of conflicts' such as sieges, massacres, skirmishes etc which have contributed to our history. In terms of sustainable management, we would also encourage the policy to restrict the use of metal detecting on such sites (as is the case on Scheduled Monuments) in light of the particular threat such activities have on, in particular later, Battle Sites. Furthermore, the Policy should make clearer reference to the importance of such sites to Local Communities, their wider landscape values and actively encourage their promotion and interpretation for education and tourism. Question 2: Do you agree with the scope and definition? If not, what changes would you propose and why? ALGAO:Scotland broadly supports the proposed definition. However, we do have some concerns about the scope and definition of which battles would be classified as 'nationally important' is too restrictive and should give weight also to broader significance and also include other types of conflict e.g. Sieges and Clan Battles. We therefore recommend that the Inventory proposed by this SHEP should list all significant 'fields of conflict' (significant being defined by meeting a series of basic requirements) and that they are categorized in terms of national or regional importance. The sites listed as of national importance being more comprehensively described and defined in terms of protection and management issues, with the regional examples described to a lesser extent. Question 3: Are there other reasons for valuing battlefields that should also be considered? ALGAO:Scotland supports the reasons described by HS for valuing battlefields but would also add the following: the value battlefields have contributed to popular culture (folklore, etc) the value battlefields can contribute to local education, social cohesion, community regeneration, socio-economics etc the value battlefields contribute to natural heritage interests the value battlefields contribute to public green space, access and recreation As paragraph 4.5 describes, battlefields hold a significant place in the national consciousness and have a strong resonance in Scottish culture. However, significantly they also have a strong resonance in local consciousness and culture. Indeed it is often local communities who have been the drivers in finding ways of interpreting and promoting the battle site on their doorstep which in many cases would not meet the defined 'National Criteria'. Accordingly, any Inventory should engage with the local community and allow local communities an opportunity to express their opinions as to which battlefields should be regarded as significant and, in their opinion, why it is significant to them. They must also be given the opportunity to determine what forms of development are acceptable and how that land should be managed for the future. If the onus is local government to manage the battle sites but they have no resources to research, interpret and/or promote the battle site then this role falls to the local community. It is then even more important that they are encouraged to be involved in this process from the start and once the Inventory and SHEP are in place, given the resources, support and specialist advice to help research, interpret and/or promote the nation's heritage on behalf of the nation. Question 4: Do you support the proposal to create a non-statutory Inventory of nationally important battlefields? If not, what alternative approaches should be considered? As there is no primary legislation in place for their statutory protection ALGAO:Scotland supports the creation of a non-statutory Inventory. However, this raises a number of concerns. The SHEP states that HS would compile and maintain the Inventory but that battle sites on the Inventory would then be managed principally by Local Authorities through the planning process with impacts upon an Inventory Battle-site afforded material consideration in the planning process. The non-statutory Inventory, therefore, would operate in a similar manner to the Inventory of gardens and designed landscapes. However, with increasing pressures on planning authorities there is a concern that if no support is given to Local Authorities the extra work involved in terms of creating policy frameworks, together with potential management and development impact plans could result in only a patchy uptake across Scotland. As a result battle sites would not receive the level of protection and management that they deserve. Question 5: Should an Inventory of Historic Battlefields be given the same status currently enjoyed by Gardens and Designed Landscapes within the planning system? Yes. Inclusion of a site in the Inventory will mean that it receives recognition and a degree of protection through the planning system. It is recommended that local communities be included in any public consultation on proposed inclusions and amendments to the Inventory. Question 6: Do you agree with the purpose of the proposed Inventory? If not, what changes would you suggest and why? In principle yes, as the purpose of the Inventory is to identify sites of national importance and to raise awareness of battlefields and their need for protection as an important part of the historic environment of Scotland. However, we would like to see some recognition of the remaining Battlefields/fields of conflict which would not merit inclusion on such a list but which nevertheless have an important role in regional/local history. Question 7: Do you believe that the criteria set out in Annex A are suitable? If not, what alternative criteria would you suggest and why? Yes. The flexibility of the approach to selection is welcomed and we agree that the ability to map boundaries is an essential criterion. Question 8: Do you agree with the proposed definition of the area of interest? If not, what changes would you suggest and why? As stated ALGAO:Scotland agrees with the proposed terms for defining the areas of interest. Especially we agree with the concept of defining a core area, where the fighting is thought to have taken place, and outer areas incorporating associated events and key landscapes and features which may be dispersed over a wider area. We would also like to emphasis the importance that archaeological research and fieldwork can play in this process, especially in defining such events and features. However, we are concerned that no specific mentioned is made of this in this section. Although we appreciate that historical research can go a long way in defining the location and extent of a battle site, a true picture of the battle site and its place within the landscape cannot be totally accurate without associated comprehensive fieldwork. Question 9: Do you agree that policies are needed for both the overall area of the battlefield and specific areas within it? If not, what changes would you suggest and why? ALGAO:Scotland agrees that policies are required for both the core and periphery areas and that this needs further discussion with the key stakeholders. It must be made clear that such polices relating to the outer area must not be seen to be weaker than those relating to the inner core. Both areas may incorporate visually sensitive areas and the importance of protecting the setting of the core and any key views of and from the battlefield should also form an important element to consider when looking at policies for the wider area. As well as developing policies that provide Inventory sites with protection there should also be policies that aim to promote a better understanding of their significance through interpretation etc. Accordingly minimum requirements for policy frameworks should be described in addition to the minimum acceptable standards for archaeological fieldwork. Question 10: Do you agree that best practice guidance would be useful? If so, who should lead in developing this? If not, what alternative approaches should be considered? ALGAO:Scotland agrees that best practice guidance will be absolutely necessary and we would welcome the opportunity to work closely with Historic Scotland and other Key Stakeholders in formulating such guidance. In particular we feel that any such guidance should cover the following topics: define what is meant by the terms sustainable use and sustainable management? provide a framework that establishes general principles that could equally apply to the identification and management of non-Inventory battlefield sites. specify what management plans should include - such as the identification of the key interests of each site and individual management objectives, considering issues such as the nature conservation interests of the site, potential for access and recreation as part of a green network, and through interpretation for education and tourism. establish standards for fieldwork including the use of metal detectors encourage community involvement consider offering financial assistance with the development of management plans c.f. that in place for Gardens and designed Landscapes. advice on what might constitute the setting of a battlefield Question 11: Do you agree with the roles identified here? If not, what changes would you propose, and why? Are there other key stakeholders who have significant roles to play? In principle we agree broadly with the roles that have been identified in section 6. However, We feel that Historic Scotland should adopt a promotional role for Battlefields at a national level, to complement that expected from Local Authorities. In addition 6.4 importantly misses out a key stakeholder - the local community. The key role to be played by local communities, particularly in respect of the future management of Inventory sites, must be mentioned in this section. In addition the vital role of the Scottish Rural Development Programme and its associated Rural Development Contracts needs to be identified in this section. We hope that our comments and recommendations are incorporated within the final document. Yours faithfully, John A Lawson Chair ALGAO:Scotland Consultations index ALGAO:Scotland