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Scotland's National Marine Plan - Pre-consultation

Marine Planning
Marine Scotland
Area 1-A South
Victoria Quay
Edinburgh
EH6 6QQ

7th June 2011

Dear Sirs

Scotland’s National Marine Plan – Pre-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 pre-consultation draft and wish to offer the following responses to the consultation.

ALGAO:Scotland would like to broadly support the general aims and policy objectives outlined in this Scottish Government pre-consultation draft document, as it provides and important opportunity to bring together and integrate terrestrial archaeological and heritage conservation planning polices with the maritime world. Having stated our general broad support however we do have several specific concerns and comments to make as follows

Chapter 9 Cultural Heritage (p26-7)
On the whole the policy as outlined in these two chapter is acceptable, however as written we have a concern over the first sentence of Section 9.3 as it would appear from this that only ‘designated assets’ are worthy of preservation. As stated in Section 7.2 it is widely accepted that the vast majority of archaeological marine sites (as on land) are not designated, surveyed or in fact recorded. Therefore the true significance of as yet undesignated heritage assets, as is the case on land, is often only discovered after proper assessment has been undertaken as a result of planning/development led work as per the policy outlined in para 9.4.

It is therefore strongly recommended that the first sentence of para9.3 on page p26 is amended with the deletion of the term ‘designated’ in order to recognise clearly the importance of all archaeological assets from the outset of the process. This would not only bring it in line with current land based policy as contained in SPP but also avoid possible contradiction with later sections of this document (Chapter 7.2), which recommend that all archaeological/heritage assets have some value and that only once each asset’s value has been characterise can the appropriate mitigation measures be put in place for their preservation or recording.

Chapter 12: Section 7.2 Marine Historic Environment

Firstly we agree with and endorse both the overarching Key Challenge and also the Objectives as detailed on page 111. Secondly we support and agree with the outline mitigation strategy proposed on p115 for dealing with marine heritage assets in the development process namely: record and avoid where at all possible in order to preserve in situ with excavation as a ‘last resort’.

The section on Spatial Constraints (p115) however does lack clarity in how the proposed Historic Marine Planning Partnerships (HMPP) will undertake this function in particular the role of the Local Authority Archaeologists. This needs to be explored and clarified and we accept that different solutions may emerge through process regarding the involvement of ALGAO member Authorities across Scotland.

The possible integration of LA Archaeologists within new HMPP needs in order to provide professional curatorial consultancy advice to these partnerships in terms of the mitigation and management of the non-designated archaeological/heritage assets as happens on land could provide added benefits by providing a crossover between land based and marine planning. However it must be recognised that this would require both specialist training and significantly additional resourcing.

I would welcome the opportunity to work with Marine Scotland and others with the development of the National Marine Plan Policies and Integrated Coastal Zone Management as per the timetable on page116.

Please contact me if you require any further information.

Yours sincerely

John A Lawson
Chair ALGAO:Scotland

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