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Historic Environment Guidance for Wave and Tidal Energy

Anthony Firth
Fjordr Limited.
Post Office House,
High Street,
Tisbury,
SP3 6LD

cc. Philip Robertson, Head of Marine Team
Historic Scotland
Longmore House
Salisbury Place
Edinburgh
EH9 1SH

15/3/13

Dear Anthony

Historic Environment Guidance for Wave and Tidal Energy 15/3/13

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 on this consultation and would like to offer the following comments.

The document contains a lot of useful information and we welcome the attempt to bring some of this together, however we have identified a number of issues which need to be addressed within it, including a strongly English bias. I trust that our comments will help you to address this.

Presentation
The document would benefit from being more clearly divided into sections which specify for whom each is intended. The danger is that an audience will give up at the point at which they are being told what they already know, whether they are developers, contractors or curators. An index and subheadings would also assist in this.

The document would be more manageable with the greater use of tables, bullet points and a glossary. As it is, all the information presented is muddled up together in one long essay.

The document is too chatty in style, which makes it a difficult read. There are also numerous grammatical errors and typos: the whole requires a good copy edit, to tighten it up. This would immediately improve the usability of the document.

Specific points
In several places good practice is presented in terms of a wish or hope rather than what should be done. Examples include:
Bottom of p4 “is usually” remove “usually”
p38 1st full para: Developers should seek… (remove “are encouraged to”) etc.

Top of p5 Insert the word “level” ie : “a service level agreement”

Mention of SMR/HERs should be included in this paragraph

p5, 2nd & 3rd paragraphs The meaning of the term “array” remains unclear

p9 2nd col, parar 2, “just because it is inconvenient” add “to acknowledge the possibility”

p10 Last paragraph: in Scotland, brochs represent pretty important coastal activity

p15-16 No discussion of links to Marine Spatial Planning which is fairly fundamental in Scotland

p29 1st para – two references to “Plan authorities” – this has no currency in Scotland where we have “Planning Authorities”

p32 remove “locals” (derogatory overtones) and replace with “residents”

p34 Canmore is not an appropriate tool for development control, and although it contains much useful information it should not be relied on for such purposes. No mention is made of the Scottish SMRs/HERs which, whether they are on line or not, should be the first port of call.

p36 second para. Would a statutory designation really be added once work is underway? This is against current practice in Scotland regarding land based archaeology, where scheduling does not occur once planning permission has been applied for (regrettably).

p38 omit from “Adding archaeologists…” to the bottom of the page. That there is a cost is self evident ! initial investigations should include an archaeological assessment as standard, as without it the requirement for further work is impossible to determine. As written it offers developers the choice from an uninformed basis.

p39 middle of first column – Again, archaeologists need to be involved in the decision making process (regarding scale of data collection etc) rather than as an adjunct to work already being undertaken.

p43 Assessment. In Scotland this is undertaken through the production of a DSR (Data Structure Report)

Yours

Dr Val Turner
ALGAO member with responsibility for marine matters

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