Memorandum submitted by the British Sub
Aqua Club
EXECUTIVE SUMMARY
— This response concentrates mainly
on the maritime cultural heritage, with a special emphasis on
underwater remains.
— We would wish to be fully involved
with all consultations concerning the maritime environment and
issues of protection as we are the people who actually see the
sea-bed, and are fully aware of some of the abuses of the natural
habitat that are current.
— An holistic vision of the maritime
environment must also include the underwater cultural heritage.
— Funding should be sufficient.
— Multi-agency control can reduce the
ability to see the overall picture.
— Protection mechanisms in place should
be enforced, there should be sufficient funds for such enforcement.
Note
We would wish to express our serious concern
at being omitted from the list of consultees for the consultation
paper "Seas of Change". We would like to affirm clearly
that divers, as major users of the underwater maritime environment,
are important stakeholders in any vision for the maritime environment.
Our unique ability to monitor what is happening underwater, with
at least half a million person dives per year from members of
the major diving associations is unrivalled by any of your other
consultees.
1. Special areas of conservation and special
protection areas.
1.1 The issues of conservation and special
protection areas need to be wider in scope than that generally
associated with terrestrial/bird life. There are serious issues
with shipwrecks which are important but for whom no protection
is offered. Shipwrecks are part of the cultural heritage per se
but what is not fully appreciated is the value that wreck has
as a marine life habitat. The wreck of the Royal Adelaide off
Chesil Beach attracts trigger fish every summer. These fish are
infrequent visitors to British waters. The wreck can stabilise
the seabed in the locality and most wrecks harbour a diverse range
of marine life.
1.2 Wrecks are also important because they
are often the only examples of their type of technology. An example
of this is the triple expansion steam engine. Access to such vessels
is important from a cultural heritage viewpoint. It is also important
that such a vessel is not threatened by any fishing, dredging
or pipelaying operations in the future.
1.3 It is noted with concern that Special
Areas of Conservation are subject to scallop dredging and fish-farming
in some areas of Scotland. Wrecks which have very special life,
and are themselves important artefacts, are in danger of pollution
from fish farms.
2. Barriers that might hinder implementation
of policy. There is a substantial case for revisiting legislation
concerning wrecks. There are inconsistencies between the Merchant
Shipping Act 1995, the Protection of Military Maritime Remains
Act 1986 and The Protection of Wrecks Act 1973. If we are to manage
our maritime environment actively then the move to rationalise
the legislation to allow non-intrusive access by divers, with
the concomitant "Look but don't damage the site" is
important. There is a special tension around the issue of salvage
awards which really does need addressing at Government level.
The investigation of greater use of the Ancient Monuments and
Archaeological Areas Act 1979 could be a positive way forward
in a few areas where the landscape and group value above water
is echoed by important material below water. An example of this
might be an historically important wharf with remains of walls,
slips and shipbuilding debris below the waterline perhaps as at
certain points along Portsmouth harbour.
2.1 The diverse agencies who have responsibilities
for underwater cultural heritage and other maritime environments
result in a less effective management of the issues, because there
is no single vision. Centralisation of the management of the maritime
environment under one body may well speed up the work. It will
certainly encourage effective communication, and may well strengthen
the enforcing of legislation. However, while we would applaud
the principle underpinning such a centralising move there must
remain a serious fear that the underwater cultural heritage may
well be sacrificed to other more visible areas.
2.2 We applaud the intention to protect
the underwater cultural heritage demonstrated by the recent assumption
of responsibility in this field by English Heritage. We have some
serious concerns about funding. There is a massive backlog of
work, with no extra apparent injection of financial support. An
holistic strategy demands adequate funding and adequate legislation.
3. STRATEGIC
ENVIRONMENTAL ASSESSMENTS
AND IDENTIFYING
MARINE ENVIRONMENT
HIGH RISK
AREAS
3.1 Divers have a vested interest in such
assessments. Divers are often the first to see the effects of
dredging, scalloping and sewage disposal schemes at first hand.
We are fully aware of the need to balance green tourism with other
economic demands—we are often the consumers of the green
tourism. We also contribute substantially to the economies of
businesses exploiting the marine environment.
3.2 If Strategic Environmental Assessments
are introduced then those tasked with undertaking such assessments
need to be formally required to consult the recreational diving
community. Such Assessments must deal with both ecological and
cultural aspects of the environment.
3.3 Marine Environment High Risk Areas should
be identified as soon as possible. Again we would stress that
such identification should be preceded by some consultation with
the relevant recreational diving communities. We are jealous guardians
of much that happens on the sea-bed within the 0-50 metre depth
range, some considerably deeper, and we are likely to have substantial
local knowledge in specific areas.
3.4 We must be mindful of our responsibilities
under international conventions such as Valletta to protect our
underwater cultural heritage, and to promote public access and
education. We would like to reinforce the obligations under Valletta
Articles 2, 3, 4, 5, 6, 7, 8 and 9 which range from the creation
of inventories to the promotion of public access and awareness.
CONCLUSION
Divers have a diverse range of interests and
skills. Photography, wreck diving, marine life identification,
avocational archaeology and membership of voluntary bodies such
as the Marine Conservation Society and Subsearch, as well as those
who have "Adopted a Wreck" have a substantial body of
knowledge of the marine environment. Diving access and involvement
should be seen as a positive contribution to the protection of
the maritime environment.
Jane Maddocks
Wreck Advisor to the British Sub Squa Club (BSAC)
12 September 2003
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