Association of Local Government Archaeological Officers UK

Consultation responses:
Guidance for the assessment of cumulative impact on the historic environment from offshore renewable energy
(COWRIE 2007)

Submission from ALGAO:UK Maritime Committee

The Association of Local Government Archaeological Officers (ALGAO) represents the senior archaeologists within local authorities within the UK. The Association operates through a series of committees and the Maritime Committee deals with marine issues on behalf of the Association.

The following comments are based on the questions asked in the Questionnaire

Q1. Extent of the Historic Environment Resource - The only major omission from the consideration of the resource is aircraft. There have been many losses of aircraft at sea and finds in this medeia may be better preserved than aircraft lost on land. English Heritage have produced a policy document on aircraft losses in the past and this type of site falls under the current remit of the 'Protection of Wreck Act' although no aircraft has as yet been designated.

Q2. Sources of Impact - The range of activities is reasonably wide. It is very difficult to prescribe time scales and geographic areas in a marine context because it is so dynamic and because impacts can stretch over very long distances. This is better considered on a case by case basis with a justification based on the prevailing conditions in a given locality.

Q3. Cumulative Impacts - These definitions are necesary but difficult to grasp, this may need some refinement if it has to be presented to a public audience.

Q4. Assessment of Impacts - The checklists and pro-formas seem useful.

Q5. Mitigation & Monitoring
a) In reference to Table 12, I think that 'Offsetting through Record' can be used to enhance the perceptual value by increasing public awareness of the HE in the location, including them in the process and presenting information to them. I would add a category of 'Dissemination of Information' within 'Offsetting through Record' . I would disagree that perceptual impact could not be monitored this can be done through a consultative process with the stakeholders, this is particularly the case with development within sight of the shore.
b) Developers should have a continuing and full responsibility for the impact of their development, unless central government wishes to mitigate this as a matter of national policy.

The only general comment I would have is that the role of English Heritage in relation to the Protection of Wrecks Act is not quite correct. EH do not designate. The Secretary of State designates on advice from the the 'Advisory Committee on Historic Wreck Sites' (p 5).

Yours sincerely
Robin Daniels, Chair ALGAO Maritime Committee

Consultations index
Maritime Committee
Link to COWRIE consultation document