Consultation responses: The Scottish Soil Framework (Scottish Government 2008)	Consultations index ALGAO:Scotland
Submission from ALGAO:Scotland Antje Branding Scottish Government Water, Air, Soils And Flooding Division Area 1G North Victoria Quay Edinburgh EH6 6QQ 22 September 2008 Dear Sirs, Scottish Government Soils 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 Scottish Government consultation and would like to offer the following comments and recommendations. ALGAO:Scotland welcomes and supports the Scottish Government's vision for its proposed Soil Framework which states that 'soils are recognised as a vital part of our economy, environment and heritage to be safeguarded for existing and future generations.' Further we are also encouraged that the document recognises the important roll that Scotland's Soils play in preserving our cultural and archaeological heritage. In relation to the specific questions asked we would like to like to make the following specific answers Question 1. The Government is proposing the Scottish Soils Framework in order to provide a policy overview and a coordinating vision for future actions on soil protection. Do you agree this is desirable? Yes Question 2. Do you agree that the distinct Scottish soil resource requires protection? Yes Question 3. Do you agree with the analysis of the main soil functions presented here? Yes Question 4. Do you agree with our analysis of soils in the context of climate change? The analysis is incomplete, in that it doesn't mention the impact of climate change on the buried or upstanding cultural heritage. The impacts of soil changes rooted in climate change will be felt in damage to the foundations of upstanding buildings, loss of organic matter from buried archaeological sites, and also microscopic loss of information (such as loss of preserved pollen and other palaeoenvironmental information) from the body of soil. There may also be significant direct loss of archaeological sites as a result of coastal, wind and rain erosion. Question 5. Do you agree with the analysis of the pressures and threats faced by Scottish soils? If not, which other threats need to be considered? Yes Question 6. Do you agree with our analysis of the current role of soils in existing policy framework? Yes Question 7. Where do significant gaps in soil protection policy exist? There is insufficient recognition of the importance of palaeoenvironmental sites and dispersed palaeoenvironmental evidence, and the need to protect these sites and evidence. Cultural Heritage policy at present sees soil as a 'neutral matrix' (para. B20), rather than an active resource of information. Question 8. What are your views on the impact of climate change on existing soil protection policy framework? Climate change-related loss of carbon/organic content in soil will endanger cultural heritage evidence and structures most acutely in precisely those areas where present policy is weakest (see answer Q7). Question 9. Views are invited on the vision and aim. The overall proposed vision and aim is acceptable. Question 10. Views are invited on the outcomes, to which specific activities contribute to. Should we be adding additional outcomes? ALGAO:Scotland have no specific comments to make. Question 11. Views are invited on the four work areas under which future activities will be carried out. The four work areas are acceptable and we have no specific comments to make. Question 12. Have the right activities been identified to contribute to achieving the outcomes? Yes Question 13. Are additional activities required? ALGAO:Scotland have no specific comments to make. Question 14. Which activities need to be prioritised? ALGAO:Scotland have no specific comments to make. Question 15. What are your views on future stakeholder engagement? ALGAO:Scotland would welcome the opportunity to engage in this process. 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 Scottish Government Consultation page