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Marine Policy Statement (UK): A draft for consultation (Defra 2010)

Submission from ALGAO:Scotland

Amy Holmes
Marine Stewardship Team
Area 2C
Nobel House
17 Smith Square

15 Sept 2010

Dear Madam

UK Marine Policy Statement: A draft for 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.

General Comments

ALGAO Scotland welcomes the UK Marine Policy Statement, in particular section 2.9 Historic Environment.

Detailed Comments on the Draft Provisions of the Policy

Box 1 lists “The high level marine objectives”. In the section “living within environmental limits” there should be a bullet point which relates to the historic environment/heritage assets.

This is not only desirable, but also would be consistent with section 2.9

Section 2.9:
Footnote 42, this applies to Scotland as well as England and Wales.

Para1. It should be made clear that the need to consult is ongoing, on a case by case basis, since the marine record constantly evolves and changes as new data is added and sites are ground truthed. A single data gathering exercise to produce a definitive plan is neither desirable or possible.

It is recognised that the phrase “heritage regulators and advisors” is sufficiently loose in order to cover a range of bodies however it would be appropriate to make a direct reference to Local Authority Sites and Monuments Records Services.

A footnote could explain that Sites and Monuments Records are the most complete record available for any given area, and are held by the Local Authority Archaeologist or Archaeologist providing services on behalf of Local Authorities, for every authority in Scotland and Wales and almost all of England.
This is particularly important as the marine plan authority might be separate/outsourced from the land based planning system.

Para 3, reference to the “relevant statutory regulator or advisors” should include “and Local Authority Archaeologist”.

Yours faithfully

Val Turner

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