Select Committee on Agriculture Sixth Report

APPENDIX 33

Memorandum submitted by English Heritage (F51)

INTRODUCTION

  1.  This Memorandum of Evidence, submitted by English Heritage, relates to the implications of, and sustainability of, existing flood and coastal defence policy for the historic environment.

BACKGROUND

  2.  English Heritage is a Non Departmental Public Body established by the National Heritage Act 1983. It is the Government's principal advisor on the historic environment and its statutory duties are:

(a)  to secure the preservation of ancient monuments and historic buildings situated in England,

(b)  to promote the preservation and enhancement of the character and appearance of conservation areas situated in England, and

(c)  to promote the public's enjoyment of, and advance their knowledge of, ancient monuments and historic buildings situated in England and their preservation.

  3.  The interests of English Heritage intersect with flood and coastal defence policy in two ways.

—  First, because of the large numbers of important archaeological sites and historic buildings situated within the coastal zone, whose continued preservation is dependant, at least in part, on flood and coastal defence policy. In this context, it should be noted that, in carrying out their function under The Coast Protection Act 1949 and The Environment Act 1995, operating authorities and ministers are, amongst other things, required to have regard to the desirability of protecting and conserving buildings, sites and objects of archaeological, architectural or historic interest.

—  Secondly, because English Heritage directly manage a number of nationally important historic sites situated in coastal locations (for example Hurst Castle, in Hampshire, Reculver Towers and Roman Fort in Kent, and Lindisfarne Priory in Northumberland). The continued survival of, and public enjoyment of, these sites will also be influenced by flood and coastal defence policy.

PROTECTING THE HISTORIC ENVIRONMENT

  4.  It is fundamental to the Government's policies for environmental stewardship that there should be effective protection for all aspects of the historic environment. The physical survivals of our past are to be valued and protected for their own sake, as a central part of our cultural heritage and our sense of national identity. They are an irreplaceable record which contributes to our understanding of both the present and the past and which adds to the quality of our lives by enhancing the familiar and cherished local scene and sustaining our sense of local distinctiveness. The historic environment is also of immense importance for leisure and recreation.

  5.  Our coastal zone contains a particularly distinctive and fragile array of historic assets vital to the understanding of Britain's emergence as an island, her developing relationship with the sea, and those maritime influences which have contributed to our identity as a major mercantile, industrial and imperial nation. Of particular importance at the coast are the remains of submerged prehistoric landscapes, inundated by the sea-level rise which accompanied the close of the last ice age. These landscapes preserve evidence for early prehistoric settlements and their contemporary environments, seldom available on dry land. They also offer important information on past coastal evolution, which provides important background data on current changes. A policy statement by English Heritage and the Royal Commission on the Historical Monuments of England, setting out in more detail the importance of our coastal heritage, is appended to this memorandum.

  6.  A small proportion of the most significant historic buildings and archaeological sites are protected by means of designation as listed buildings or scheduled monuments or contained within conservation areas, but most sites and structures are not protected by any form of designation. The key to the future of the great majority or archaeological sites and historic landscapes therefore lies with local authorities acting in their capacities as planning, education and recreational authorities, and as landowners, and the nationwide network of local authority Sites and Monuments Records, Archaeological Officers and Conservation Officers is central in providing advice to those taking decisions which may affect the historic environment (including those taking decisions on coastal and flood defence).

FLOOD AND COASTAL DEFENCE AND THE HISTORIC ENVIRONMENT

  7.  Historic remains and structures can be affected in a number of ways by flood and coastal defence works. The construction and maintenance of sea-defences can have a beneficial effect on historic assets by arresting erosive forces, and therefore decisions not to defend a coast or to manage its set-back may lead to the destruction of important remains or structures. Equally, where "hard" engineering works are carried out, they may impact directly on fragile archaeological remains, cause hydrological or erosive pressures on more distant remains, or cause a vital impact detrimental to the setting and visual amenity of historic buildings. The winning of aggregate for "soft" engineering works may also damage archaeological remains.

  8.  Whilst it is clearly not practicable to defend all historic sites, it is important that decisions on defensive priorities to be informed by the best available knowledge of the existence of historic remains and an assessment of their importance. Where historic sites or buildings cannot be protected, decisions should be taken on their selective archaeological recording prior to destruction.

  9.  English Heritage commends MAFF's initiative to put its flood and coastal defence operations on a strategic basis by encouraging the development of coastal defence groups and by the production of Shoreline Management Plans. These plans provide, for the first time, a means by which heritage and other conservation interests can be effectively integrated with coastal defence forward planning and, by providing a long-term framework for shoreline management, will also provide a framework which will allow English Heritage and other organisations to identify areas of greatest need and prioritise their own programmes of archaeological survey.

  10.  In the opinion of English Heritage, however, there are two areas of weakness with the current generation of plans, now approaching completion.

—  First, there is a lack of articulation between SMPs and other statutory plans (primarily structure and local plans) and non-statutory plans (particularly Estuary Management Plans, Local Environment Action Plans, and Coastal Zone Management Plans), and there is no clear mechanism for the transfer of or integration of policies set out in SMPs to statutory development plans.

—  Secondly, the initial results of a survey of the heritage content of SMPs currently being carried out on behalf of English Heritage has indicated that the quality (and therefore value-for-money) of the heritage input into SMPs is extremely variable. This appears to have been caused by several factors, including a lack of guidelines for consultants carrying out the work, the use of consultants with no archaeological or conservation expertise, and uncertainty on the part of local authority archaeological officers about MAFF's requirements. In our view, these are all problems which could be rectified by the issuing of a technical guidance note by MAFF.

RESEARCH AND DEVELOPMENT

  11.  Due to the often hostile nature of the coast and its complex geomorphology, the record of coastal archaeological sites contained within local authority Sites and Monuments Records is partial, and tends to be less comprehensive than its inland equivalent. Consequently, there is a need to improve this record by means of rapid survey, if strategic and operational decisions on flood and coastal defence are to be based on adequate information.

  12.  While English Heritage proposes to direct its own archaeological survey resources towards this task in the immediate future, we do not have adequate resources to complete this work rapdily. To do so effectively will require partnership with MAFF and with the Environment Agency in the procurement of selected archaeological survey projects. The completion of the first stage of SMPs will permit identification of those areas where survey should be prioritised in order to adequately inform flood and coastal defence policy formulation.

  13.  In addition, it is to be hoped that English Heritage, MAFF and the Environment Agency can fruitfully collaborate in relevant areas of Research and Development, evaluating, for example, the value of coastal archaeological depostis for studying and modelling coastal change, and the detailed implications of managed set back on historic remains.

CONCLUSION AND RECOMMENDATIONS

  14.  In conclusion, it is the veiw of English Heritage that, over recent years, MAFF has made important advances in ensuring that concerns relating to the historic environment are integrated within its flood and coastal defence policy—an area which we fully recognise must be primarily directed towards the protection of life and property. There are, however, areas where further improvements can be made and better value-for-money secured.

  15.  Accordingly, English Heritage offer the following recommendations for the Committee's consideration:

a.  The Committee commend advances by MAFF in the incorporation of concern for the historic environment in their flood and coastal defence activities, and recommend that MAFF continue to have regard for the protection and enhancement of the historic environment, in all its strategic and operational activities pertaining to flood and coastal defence, and in its R&D policy.

b.  The Committee recommend that the detailed relationship between SMPs and other statutory and non-statutory plans is clarified, and that an appropriate mechanism is established for the integration of SMP policy into statutory plans.

c.  The Committee recommend that, as SMPs are reviewed and as related Flood and Coastal Defence Strategies are drafted, MAFF strengthen their content pertaining to the historic environment, by means of issuing an appropriate technical guidance note.

d.  The Committee encourage MAFF and the Environment Agency to participate as partners in coastal archaeological survey work, where the results of that work will have a direct relevance to the formulation of MAFF/EA flood and coastal defence policy or operations.

19 May 1998

---

---

Prepared 5 August 1998