| Consultation
responses: Eco-towns: Living a greener future - consultation paper (DCLG 2008) |
|
|
Submission from ALGAO Planning & Legislation Committee Eco-towns Team
T he Association of Local Government Archaeological Officers for England (ALGAO:England) is the national body representing local government archaeology services at County, District, Metropolitan, Unitary and National Park level in England. ALGAO:England co-ordinates the views of its member authorities (93 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association (LGA) on archaeological matters. The range of interests of our members embraces all aspects of the historic environment including archaeology, buildings and the historic landscape. We welcome this opportunity to comment on the proposals for Eco-towns, which we recognise have a valuable part to play in providing a sustainable form of housing, that will minimise harm to the natural environment whilst delivering valuable housing capacity and new communities. The historic environment is ubiquitous throughout this country, as it is past peoples who have shaped our landscapes, occupied and managed the land. This is marked by earthworks, field boundaries and banks and ditches, as well as by specific settlement evidence, such as past farmsteads and special monuments, and historic parks and gardens, ranging through to industrial and military features. A number of the potential locations on the shortlist are on former RAF sites, redolent of our wartime and cold war histories. These are demonstrative of past communities, and how they previously used and changed the land, and can speak to the proposed new communities, to provide a very real sense of place. Within them may be sites and features of great intrinsic archaeological and historic interest. It is therefore with some disappointment that we do not see the term `historic environment' used in this document. There seems to be a narrow focus on the natural environment only that fails to recognise some of the broader implications of new town development. The varied character of the historic environment, and its variable survival, means that its' potential must be elucidated at the local level. However in general terms it has much to contribute in terms of town planning, and planning of the land uses for the surrounding countryside. Historic boundaries and routeways may be re-used, field systems and land-use areas, including woodland, may influence layout and design of communities that fits the historic grain of the landscape. The need to preserve particularly important archaeological remains or historic structures will need to be factored into planning, and consideration given to display and enhance aspects that may benefit the new communities. Interpretation to aid understanding and appreciation of both the historic and natural environment will maximise this potential. Given the considerable potential of the historic environment to make a contribution to place-making, we are very disappointed that the few historic elements identified in the brief descriptions of the 15 sites going forward for consideration are listed as `constraints'. We would like to propose that these become viewed as `opportunities' in community creation. We also note that neither the Government's advisors on the historic environment, English Heritage, nor the, mostly county-based, archaeology advisory services, were consulted on the strategic infrastructure impacts. Many of the measures to develop in a sustainable way for the natural environment, and to tackle climate change, have the potential to damage the archaeological resource and need to be planned with care. Such features as underground systems for recycling within the town, or the planting of bio-mass fuels in the landscape around the town, have the potential to impact. Clearly the management of water will be an important consideration, but extensive drainage systems, stormwater retention lakes, and the creation of wetlands, all have the potential for impact. We are therefore very concerned that the archaeological and historic character of the proposed eco-town sites is understood at an early stage in site selection and master-planning. We welcome the fact that the final eco-town proposals will be subject to the full planning process, and we would expect a full EIA to be submitted in support. Our members look forward to engaging with this and providing full advice to the relevant planning authorities and applicants. We note that before this Sustainability Appraisals will be prepared for each of the 15 locations on the shortlist, and our members would be happy to provide further information and advice to contribute to this, based on the county Historic Environment Records (or Sites and Monuments Records) available throughout the country. These provide a broad evidence base for the character and potential of the historic environment, that goes beyond limited Listed Building or Scheduled Monument designations. We feel that it is essential to assess the historic environment potential of these proposed eco-town sites, as it may well be a significant factor in site selection. Equally it is essential that we contribute to the working up of specific schemes with the scheme promoters. We will be happy to engage with the refinement and improvement of detailed proposals, as this is very much in line with planning guidance on the historic environment and archaeology (PPGs 15 & 16). It will be essential to understand the landscapes in which the eco-towns are proposed in adequate detail, and this will involve land survey, and field evaluation of specific sites, probably as a component of bid preparation. We would be very happy to discuss any of these points in more detail with you. R Whytehead, Convenor ALGAO:;England Planning & Legislation Committee |
|