APPENDIX 24
Memorandum submitted
by the Association of Local Government Archaeological Officers
(F36)
As Chairman of the Maritime Sub-Committee of
ALGAO I am writing in response to your press release which has
invited comments which might be useful in the current inquiry
by the Agriculture Committee into Flood and Coastal Defence.
The Association of Local Government Archaeological
Officers is a professional forum of specialists who are employed
by local authorities to protect or "curate" that part
of the national archaeological heritage which is concealed within
the landscape. The raison d'être of our members is to implement
Government's advice to county, unitary and district planning authorities
that "archaeological remains are valuable for their own
sake, for their roles in education, leisure and tourism and that
particular care must be taken to ensure that they are needlessly
or thoughtlessly destroyed" (Planning Policy Guidance
16; planning and archaeology 1990—paraphrase).
Since, the late 1980's many County authorities
have been increasingly involved with questions concerning archaeology
and the changing coastline. Information on the known distribution
of archaeological sites is usually held at County level in an
on-going data-base known as the Sites and Monuments Records, (SMR);
this can include significant coverage of an array of coastal archaeological
sites which due to a changing environment have become wholly or
partly submerged in marine waters.
Since the excellent initiative taken by MAFF
with its promulgation of Shoreline Management Plans it has become
evident that coastal archaeological sites recorded in County Sites
and Monuments Records can shed considerable light on the long-term
changes in England's coastline. Now that strategic options are
sought for future shoreline management it is apparent to archaeologists
that the testimony provided by coastal ancient monuments and submerged
archaeological landscapes is a vital key to future coastal planning
and protection. A little of this was recognised by Government
in 1992, in its Advisory Note on Coastal Planning (PPG 20).
Now that the first generation of Shoreline Management
Plans has started to appear in print a problem has emerged. Government's
advice on the value and significance of coastal archaeological
sites was addressed to Planning Authorities whose archaeological
advisors are generally placed within the Strategic Planning sections
of County Councils.
Where Shoreline Management Plans have been generated,
the initiative has rested with "Operating Authorities"
who are generally based within the engineering sections of District
Authorities. Here liaison with County Archaeologists and their
SMRs is still in need of direction. MAFF's general advice on the
formulation of Shoreline Management Plans was issued in 1996 and
it wisely identified the archaeological resource as an environmental
consideration. Unfortunately, this seems to have been a topic
which has been generally tacked on to a loose list of items given
to environmental consultants who have been engaged to produce
the Shoreline Management Plans.
Although a full analysis by English Heritage
of the archaeological content of Shoreline Management Plans is
still in preparation it is already emerging that current comprehension
of this issue by consultants and plan commissioners is regrettably
weak. Some strategic authorities maintaining SMRs have been approached
by consultants to provide simple lists of coastal ancient monuments
which might be reproduced uncritically in the commissioned Shoreline
Management Plans. It has been evident to our members that many
of the consultants have been able to offer qualified expertise
in the natural environment but have lacked expertise in the historic
environment and an understanding of the scientific potential of
coastal archaeological sites. In most cases the archaeological
significance of these sites in relation to the objectives of the
plan have been omitted. This means that the potential of inter-tidal
and submerged archaeological sites to determine the history of
shoreline change, flood events or sea-level rise has been commonly
overlooked.
Since 1996 very sound advice on the scientific
interpretation and the protection of coastal archaeological sites
have been issued on behalf of Government. This has been published
by English Heritage and the Royal Commission on Historic Monuments
in England. The two publications issued by these bodies have been
very well received by coastal planners and archaeological bodies
yet there remains an outstanding need to provide each Operating
Authority with clear and specific advice on the right archaeological
questions to ask and resolve in a Shoreline Management Plan. There
is also a need to name and quantify the particular archaeological
issues which should first be considered in the scoping document
and then carried into the specifications for the tendering brief
which will determine the tasks for which consultants will be engaged.
In the light of its experience, the Maritime
Sub-Committe of our Association feel that this difficulty may
be an issue which the Agriculture Committee may wish to know about
when considering the affectiveness of current Coastal Defence
measures. Perhaps it might be viewed when weighing the social,
economic and environmental implications of Shoreline Management
Plans. Although we have identified this issue as a problem it
seems that it might be readily resolved in the form of a MAFF
guidance note issued for the benefit of Operating Authorities.
Perhaps this could follow the excellent principles already set
out by Government in its advice issued through English Heritage
and RCHME.
We hope that the Committee will find these observations
constructive and useful and we should be pleased to provide further
information if required. I might, perhaps, add that some of our
members are in contact with archaeological specialists working
on other sections of the European coastline particularly in France
and Eire. Here there is a clear consensus that the Shoreline Management
Plans guided by MAFF are an exemplar in attaining a template for
the long term management of the coastal heritage.
14 April 1998
| 
