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Submission
from ALGAO:UK Maritime Committee
The Association
of Local Government Archaeological Officers; UK (ALGAO:UK) represents
the senior Local Authority Archaeological Officers throughout England,
Scotland and Wales. The association operates through national and
UK wide subject committees. The Maritime Committee provides a lead
to the organisation in Maritime matters.
The ALGAO:UK
Maritime Committee welcomes the white paper, 'Heritage Protection
for the 21st Century' as a much needed attempt to draw together
and simplify the operation of heritage protection in England and
Wales. In general we are concerned about the resource implications
of implementing the measures set out in the white paper, however
the comments below focus on Chapter 3 of the white paper 'Protecting
the marine historic environment in the UK'.
The response
below is based on the paragraphs of Chapter 3 of the White Paper.
A More Comprehensive
Regime
Para 4. ·
- We would
endorse the need expand protection of marine historic assets to
ensure that archaeological sites and artefacts are properly protected
as well as vessels and aircraft. This will work towards the development
of a 'seamless' approach between the protection of terrestrial
and marine historic assets although we note that the importance
of this approach is not emphasised in the white paper.
Paras 7 - 10,
·
- We would
endorse the decisions not to apply an age limit for marine historic
assets, but that statutory criteria alone should apply.
- We would
also endorse the decision not to apply a grading system. Such
a system would require a much greater knowledge of marine historic
assets than is currently available.
- As a UK
wide organisation we would agree with the maintenance of a UK
wide system of designation which would allow a baseline commonality
of approach as far as our members are concerned.
A Clearer
System
Paras 15-16
·
- Local Authorities
should be included in the consultation for designation and should
equally be made aware when licences are granted for works on designated
sites. Local Authorities throughout the UK have a variety of duties
and responsibilities in regard to the coastal zone and activities
within it and it is our position that activity within 6 miles
of the coastline are of major interest to a local authority and
activities up to the 12 mile limit are a valid concern where they
impact on a local authority.
Para 17 ·
- We would
concur with the need for interim protection whilst protection
is being considered.
Para 19 ·
- While there
is much to endorse in this section of the white paper, the absence
of any serious consideration of the role of Local Authorities
is a serious weakness. Local Authorities have responsibilities
and duties in the coastal zone which are not reflected in the
white paper and there is no consideration of the positive contribution
that local authority archaeologists could make to the development
and operation of the new system of marine designation.
- Local Authority
Archaeologists alongside their Museum colleagues could have an
important role as an initial contact for local finds of marine
historic assets and in monitoring their management. They could
further provide invaluable assistance to those, usually local
groups, who wish to visit and investigate such assets.
- One of the
major issues in relation to the marine environment is the absence
of detailed information. Local Authority Historic Environment
Records (HERs) have a proven track record in the acquisition and
documentation such information. At the moment there is no formal
involvement of HERs below the low water mark. This severely restricts
the capacity of the Heritage sector to acquire information about
the Marine environment, particularly in the case of locally generated
information.
- Both English
Heritage (in a draft position paper) and DCMS in this white paper
have indicated a desire to encourage local authorities to extend
their HERs into the marine environment. There is however a critical
failure to acknowledge the huge benefits that the development
of a marine component to a HER could bring to the sector and a
failure to provide a concrete mechanism to expand HERs in this
way.
- It is the
position of ALGAO:UK that Local Authorities have a valid interest
in their coastal areas and that HERs should extend into these
areas. Unfortunately this white paper has squandered this historic
opportunity to involve the largest component of the heritage sector
in the development of our understanding of the marine historic
environment.
- This situation
may be re-dressed if DCMS and English Heritage agree that a marine
component extending to the six mile limit is an essential component
of a coastal HER and coverage upto the 12mile limit is desirable.
This could then be incorporated and resourced through the guidance
that English Heritage have been tasked to provide to HERs in Chapter
1.4 para 24 of the White Paper.
Para 20-21
·
- We would
support the continuation of the ACHWS and the expansion of their
role to provide a wide range of advice.
Increased
protection for Marine Historic Assets
Paras 27-31
- This is
a missed opportunity and the title of the section seems misleading
as this offers no further protection to marine historic assets.
Rather it points to the continuation of the current contradictory
and unsatisfactory regime, where salvage claims can over ride
heritage interest. There is a clear need to resolve the tension
between salvage and heritage protection and the complete failure
of the white paper to even begin to address this is a grave disappointment.
Not the least disappointing is the acknowledgement of the problem.
·
- The reference
to the Marine Bill is misleading as the DEFRA white paper 'Sea
of Change' contains nothing which will affect or any better protect
marine historic assets from salvage operations.
Para 32 ·
- The continued
support of the Receiver of Wreck in providing information about
heritage material is acknowledged. However it is not clear to
which agencies information will be provided and in order for effective
follow up to any finds of significance to occur it is essential
to include local authority HERs in the dissemination of information.
·
- It is also
not clear how the remit of the Receiver will be changed given
that the current remit only covers wreck material and not the
full range of marine historic assets. In order to be effective
the new system must ensure the reporting of all marine historic
assets and not just wreck material.
General
Comments
This white
paper misses the opportunity to integrate the local authority sector
into the process for caring for the marine historic environment
. It also does not address the major issue of the competing claims
of salvage and heritage in relation to marine heritage assets. Both
of these issues must be addressed as part of any legislation arising
from he white paper.
In addition
to the above there is no discussion of the creation of area wide
designations of heritage interest to match the proposed marine conservation
zones of the DEFRA white paper. Presumably proposals of this nature
will be brought forward now that the marine white paper has been
published.
R Daniels
Chair ALGAO:UK Maritime Committee 29.05.07
Consultations
index
ALGAO
:England Heritage White Paper response
ALGAO:Cymru
Heritage White Paper response
Maritime
Committee
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