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responses: Scottish Historic Environment Policy:The Marine Historic Environment (Scottish Government 2008) |
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Submission from ALGAO:Scotland/ALGAO:UK Maritime Committee SHEP on the
Marine Historic Environment 14th May 2008 Dear Sirs, SHEP Consultation: The Marine Historic Environment This is a joint response on behalf of the Maritime Committee of the Association of Local Government Archaeological Officers:UK (ALGAO:UK) and ALGAO:Scotland. ALGAO:UK represents local government archaeological services in the UK on behalf of County, District, Unitary and National Park authorities. It operates through three national associations and through a number of UK wide themed committees of which Maritime Committee is one. We welcome this document and the consultation and we are pleased with the intention to develop a simpler, more transparent system. Nevertheless we have a number of concerns and suggestions and these are set out below in relation to the Chapters and questions set out in the consultation document. 4. Proposals
for Scottish Ministers policy on the marine historic environment. Q2: Our knowledge of the marine historic environment is still very limited and based on the 'ad hoc' identification and location of individual sites. There is a clear need for a systematic approach to be taken to the acquisition, collation of information about the marine historic environment and an opportunity should be taken in this section to make a commitment to this undertaking. A similar undertaking should be made that adequate resources will be made available to ensure the successful implementation of these proposals. Qs 3 & 4: The marine historic environment will contain vessels and aircraft which do not originate from the country in whose waters they now lie. Their immediate significance to that country may be limited, however their importance to their home country and internationally may be great. Respecting this importance is a responsibility on the current host country. It is therefore important that the policies and any legislation allow for the recognition of these factors and the criteria in Annexe A of the SHEP would appear to do so. The use of the phrase 'national importance' is an appropriate one in this context and in designating assets with a more local origin. 5. Proposals
for new legislation to protect the marine historic environment in
Scotland. It is our view that such data in Scottish national waters could be best be held as a component of the Historic Environment Record hosted by the appropriate local authorities. Qs6 & 7: There is a clear need for an overhaul of the consents regimes in UK waters and the introduction of the concept of marine spatial planning would seem a sensible mechanism by which this could be achieved. The implementation of marine spatial planning should be carried out by a dedicated Marine Management Organisation (MMO) which has access to specialist advice in specific areas. Historic Scotland would be the appropriate body to provide advice to the MMO in respect of designated marine historic assets. It should however be recognised that the vast majority of marine historic assets will not be designated and that it is therefore important that they are properly considered in determining development proposals. In this circumstance it is important that there is both an adequate record of these sites (compiled on the local authority HER) and that appropriate advice is provided about their significance and any mitigatory strategies. As the holder of the record of undesignated marine historic assets the local authority historic environment service would be the appropriate body to provide this level of advice to the MMO. 6. Implementation
The implementation of these measures will require additional resources and expertise to be made available to the appropriate organisations, but this should result in a sound, well informed system of management of the marine historic environment. This should also provide an ability to disseminate local information to local people and would provide a ready contact point for local people wishing to provide information about new discoveries. We hope that our comments and recommendations are incorporated within the final document. We also look forward to engaging with yourselves and other Scottish Government Departments and agencies during the forthcoming consultation process surrounding the anticipated Scottish Marine Bill. Yours faithfully
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