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Celebrating and Looking after Scotland's Historic Battlefields - Inventory of Historic Battlefields (Historic Scotland)

Submission from ALGAO:Scotland

Historic Scotland Inspectorate
Inspectorate Admin Team
Room 2.31
Longmore House
Salisbury Place

10 February 2011

Dear Sirs,

ALGAO:Scotland represents Local Authority and National Park archaeological services in Scotland and is part of the UK-wide organisation, ALGAO:UK. Local Authority and National Park archaeological services are responsible for the conservation of 95% of the historic environment that is not afforded statutory protection. This historic environment encompasses both buried and upstanding archaeology, the built environment and historic landscapes. Local Authority and National Park archaeological services provide both a strategic framework for the protection of historical and archaeological sites at local level, and the policy context for appraising, evaluating and managing change on a case-by-case basis through day-to-day advice and information.

The historic environment is an important cultural, environmental, social and economic asset that makes a major contribution to the quality of people’s lives and community identity. Archaeological resource management in local government plays a fundamental role in the management of the historic environment, working to deliver government objectives in protecting and sustaining the historic environment for the benefit of current and future generations, and in promoting awareness, understanding, appreciation and enjoyment of this unique resource.

We very much welcome the Battlefield Inventory. It comes at a time when many battlefields are being increasingly impinged on and impacted upon by development and the Inventory will help support Local Authorities striving to find ways to preserve their fragile remains. We welcome this opportunity to comment upon the Inventory of Historic Battlefields consultative draft (deadline February 11th 2011) and we acknowledge that comments have been invited specifically on:

a. The list of sites proposed for inclusion in the Inventory; b. The site descriptions and boundaries for the first 17 sites (Summary Reports); c. A booklet explaining the purpose of the Inventory, and; d. The additional information (Further information) which is to compliment the Summary Reports, which will be available online. e. Managing Change: Historic Battlefields leaflet

At this stage we would prefer to leave comment on the choice of the 17 proposed sites (a) and inclusion or not of other potential sites to representatives of the individual Local Authorities concerned. Detailed comments on the full descriptions and boundaries of the 17 sites (b and d) will also be left to individual Local Authorities, however, general comments on (b) and the guidance booklet (c) can be found below.

It should be noted that our comments on the draft version of the guidance note Managing Change in the Historic Environment: Historic Battlefields (e) in addition to Appendix One, Two and the SEA report will be commented upon in a separate consultation response (deadline March 9th 2011).

We note that the selection criteria have previously been determined and are set out in Annex 5 of the SHEP.

(b) Inventory Summaries and Further Information reports

1) We have major concerns about the mapping quality and the delineation of the inventory boundaries for each battlefield.

The mapping used to show the location and extent of each battle is out of date. To make the inventory more of a practical management tool, the maps for each battle site should ideally show:

  • Areas of new housing
  • Areas of future development sites contained in the adopted development plan.
  • Areas of archaeological work
  • Either on it, or be accompanied by another map, the places referred to in the Summary and Further information reports for each battlefield
  • New map titles explaining more clearly their function

In any case the maps should be the most up to date coverage available.

2) The battle site inventory boundaries are very disappointing and not helpful. Although we appreciate that there has been a move away from defining a battlefield in terms of an inner and outer battle core, we believe that the current depiction of the Inventory boundaries will be difficult to use within local development plans and development management.

If one of the compulsory criteria of a battle site to be included in the Inventory is that it can be mapped, then the extent of the battle site needs to be more defined. Although we appreciate that there has been a move away from a solid boundary line, a loose circle around the site of the battle is not particularly useful for local development plans nor development management purposes. We feel that the following alternatives should be considered:

A) Defining the ‘currently known’ extent of the battle site by using topographical features within the landscape and/or B) Adopting the early Burgh Survey Series method of blurring the edge of the defined area so that is clear that once you move into the blurred area (a buffer zone perhaps) you are moving into an area of uncertainty and further advice and information is required

Whatever method is adopted it needs to be clear, both in the text and on the map legend, what the line is supposed to represent. In addition, it needs to be clear whether land beyond the line is considered to be part of the peripheral battle landscape. A comparative example might be the way in which World Heritage Sites are mapped.

3) Finally, photographs or illustrations through the report would not only be useful in visualising some of the places/features/artefacts being described but would also help to make meatier sections easier to understand and digest.

4) The Inventory Summaries for each battle site are very useful and give a useful outline of the battle, however, we think it would greatly benefit from the following statements, which were present in the 2007 Statement of Significance Inventory overviews, but unfortunately now appear to be missing:

  • Historical and military significance, and;
  • Management issues (ownerships, different land uses, different stakeholders, present and future development impacts, current designations etc)

In addition to:

  • The Inventory map, or an accompanying map, showing the key places referred to in The Battle and Battlefield Landscape sections, and;
  • The Inventory map, or an accompanying map, showing the areas defined and described in bullet points under Inventory Boundary.

(c) Comments arising from the booklet “A Guide to the Inventory of Historic Battlefields”

The Guide clearly describes the importance of battlefields and how they contribute to our archaeological and historical knowledge; the wider public’s sense of identity and sense of place; how they have contributed to the arts, music and literature and how they are, and can have, an enormous potential to attract visitors and tourists.

The Guide also clearly describes the background to the Inventory; how battlefields have been selected; what research has been undertaken; which aspects of the battlefield landscape have been appraised and importantly, how battlefields are living, working landscapes and that any future development and/or impacts need to be sympathetically designed.

However, there are a number of weaknesses within the Guide and the proposed Inventory battle site reports and we would suggest the following changes in order to make this Guidance and Inventory a more useful and practical document.

Inventory of Historic Battlefields (page 2)

“The Inventory of Historic Battlefields is a list of nationally important battlefields in Scotland...” needs to be amended to make it clear that it is a list of nationally important sites that meet a list of selected criteria and not just the list of all nationally important sites. Although we appreciate that this is mentioned in the following section on the Principles for Selecting Battlefields, we feel it should be made very clear from the outset that there are other battlefields which are recognised as being of national importance but because they do not meet the Inventory’s criteria then they cannot be included at this stage (although it is always possible that they could be included at a later date if further information comes to light).

Researching sites (page 2-3)

While we are fully supportive of a properly maintained Inventory we feel that to assist with the protection of these sites more constructive information should be gathered, which would help to define areas better. We agree that ‘it must be possible to define the site on a modern map with a reasonable degree of accuracy.’, however we would argue that, although considerable background research has been undertaken, without further work it is not possible to be certain, particularly regarding medieval battles such as Harlaw and Pinkie, about their exact location and extent. Indeed the research itself into Harlaw admits that ‘no contemporary accounts of the battle survive ...and the secondary sources are largely poetic in nature, the topographic details of the action is extremely vague.’ Desk-based research can only go so far.

As has already been proven, at what were already considered to be well known battlefields such as Culloden and Prestonpans, battlefield archaeology can alter the original perception/ conception of where the battle was actually fought. We would therefore suggest that such a survey should be undertaken on each Battlefield in the Inventory, or at the very least provision made to grant support future projects which may be developed by other parties (Local Authorities, research organisations, local community groups etc). Battlefield archaeology would strengthen both Planning and Management decisions by having firmer evidence than that based on documentary evidence, which can be altered over time.

Understanding the battlefield landscape (page 3)

In the fourth paragraph where it says “While the landscape will usually have changed to some extent since the time of the battle, it often retains key characteristics of the terrain at the time...” we would also like to see included an acknowledgement that: a) Artefacts can also still be preserved in the ground and, b) Even if subsequent land use has removed much of the key characteristics of the terrain and/or artefacts pertaining to the battle, it has not removed the fact that a battle has still been fought in that location.

How information is presented in the Inventory (page 4)

See our comments above (B) 2) in respect of our concerns about the mapping of battlefield boundaries.

Conserving Battlefields (page 5)

In paras 4 and 5, the Guide states that

“The Inventory is non-statutory, which means that there are no new legal restrictions on the area identified by the Inventory maps. Instead, Inventory sites are given particular consideration in the planning process and planning authorities take the Inventory sites into account when preparing development plans and considering development proposals for their areas.

Planning authorities are encouraged to establish policies within their development plans and may give battlefields additional protection through conservation area status or other local landscape designation. They are advised to develop appropriate conditions and agreements to protect and enhance sites on the Inventory, and set out criteria to guide their decision making.”

  1. We feel that that this level of guidance is not clear enough. We would suggest that Historic Scotland should either provide model policies for local development plans, distinguishing between Inventory and non-Inventory sites, for Local Authorities to consider; or as an alternative, make good practice examples of such available. This would accord with para 2.73b of the Scottish Historic Environment Policy (SHEP). Otherwise, in view of the insufficient guidance so far provided by Historic Scotland, there is a danger of differing protective designations and policies being developed by different Local Authorities. Provision of draft Supplementary Planning Guidance, which could be adapted, and then adopted, by local authorities for inclusion in local development plans might be another way forward.

  2. There will be circumstances where Conservation Area designation may be appropriate for a battlefield site. However, this will clearly not always be appropriate, for example, if the battlefield contains built up areas whose built form does not merit Conservation Area designation. If there is to be an ‘other local landscape designation’, then it should be made clear in the guidance what this could be. It might be preferable for all such sites in Scotland to have similar designations rather than varying designations between local authority areas. Another alternative is to recommend that local authorities include the defined boundaries of battlefields within local development plans with appropriate policies and development management guidance attached to the defined areas.

  3. The Guide encourages local planning authorities to ensure battlefields are recognised and impacts upon them considered. This can only be done in the context of the statutory land use planning system and it must be recognised that some alterations to the landscape, farming, public utilities and forestry, for example, lie out with the land use planning system. We would like to see a clear steer in the Guidance for those in the Forestry and Agricultural sectors and public utilities to ensure that battlefields are protected and/or sympathetically managed and developed.

  4. In para 7 it says that “Many battlefields that have not been included in the Inventory will be of local significance...” is not quite correct. There will be examples of national important battlefields that are not in the Inventory either, because they do not fulfil the criteria, for example the battle of Largs.

  5. We are concerned at the statement in para 7 that says that “Planning authorities may consult Historic Scotland on development proposals considered to affect an Inventory battlefield”
    Not only does this wording not accord with SHEP (para 2.65), which refers to a requirement to consult Historic Scotland and take Historic Scotland's views into account as a material consideration, we consider there should be a requirement for Local Authorities to consult Historic Scotland in proposals affecting Inventory Battlefield sites (see also FAQ’s below and the Role of Historic Scotland) or at the very least, it should be consistence with their role in the Inventory of Gardens and Designed Landscapes. We note that an appendix to the draft Managing Change guidance for Historic Battlefields looks at this matter in more depth and we will be responding more fully on this matter in our response to that consultation.

  6. Additionally, in para 8 it says that “Other public bodies with responsibilities…should also develop policies and guidance...” The Guide needs to include suggested model policies. As above, “They may also wish to consult HS...” needs to be changed to “They should also consult HS...”

Management Plans (page 7):

We agree that for landscape designations such as battlefields-with different land owners, stakeholders, needs and impacts- management plans are crucial if we are to attempt to conserve important battle remains. It is, therefore, disappointing to see such an important part of this guidance described in only one paragraph. Much more information and guidance is required in terms of how to go about such a huge exercise, what should be the key considerations, examples of best practice etc. Although the Guidance suggests that “Anyone can take the lead...” the Guidance should state what should be considered as a minimum and where advice and financial support can be found.

Notwithstanding the comments on page 6 of the guidance leaflet (Living and Working within an Inventory battlefield) which refer to Scottish Ministers principles for simplifying designations and avoiding placing significant new burdens on local government or the private sector, without more central government direction there could be several differing protective designations, policies and management plan approaches to battlefields may not be welcomed by the private and public sectors.

The lack of mapping to identify the significance of key areas of battle activity within the Inventory boundary will in fact place a considerable burden on the local authority to prepare and consult on management plans and to develop polices and supplementary planning guidance in local development plans for the protection and enhancement of battle sites.

For example, the defined battle area for the Battle of Pinkie includes the majority of the built up area of Musselburgh. Without any indication of significance within this area there will be an immediate and onerous burden on the local authority to make sense of it and to develop policies, supplementary planning guidance and procedures to deal with development proposals in the area and in addition to prepare management plans for its protection and enhancement.

FAQs (page 8-10):

In the “What will happen to sites that do not qualify for inclusion in the Inventory?” paragraph (page 9), the sentence “make an important contribution to the local historic environment...” should read “make an important contribution to the local, regional and national historic environment...”. As this paragraph says, “...there are many sites across Scotland that do not meet the criteria set for national importance...” but that should not mean that they are now regarded as not nationally or regionally important, just that they do not meet the criteria for inclusion in this list. For example, the under representation of early medieval battlefields such as Athelstaneford (AD 832) Is due not to the lack of national/international importance but due to the simple fact that it is not possible to accurately map the site in today’s landscape . This does not mean it should be demoted to ‘local significance’.

In the “What is Historic Scotland’s Role?” we think it is confusing that in paragraph one it says Historic Scotland “...are responsible for protecting and providing advice on the management of the most important parts of Scotland's historic environment” but in the second paragraph “It is for other authorities to manage the impact on Inventory sites...” even though the battle sites included on the Inventory are classified as nationally important. This section could describe why there is this divergence and perhaps give examples of where else this sort of set up exists and how well it works i.e Joint Working Agreements, Gardens and Designed Landscapes etc. We will return to this matter in more detail in our response to the consultation on the Managing Change guidance for battlefields and the specific questions in Appendix 1 about the options for consultation with Historic Scotland by planning authorities.

Setting and Buffer Zones

While we are fully supportive of a properly maintained Inventory we consider there to be a need for further guidance on the issues of setting and buffer zones in relation to historic battlefields. Although we appreciate that there is a Managing Change: Settings leaflet, we feel that this Battlefield Inventory Guidance deserves a section on Setting and Buffer Zones.

Metal Detecting

In addition we are surprised and concerned that there is not a section and clear statement on the use of unauthorised metal detectors on battle sites. Metal detecting on battle sites is an increasing problem, with few of the artefacts being reported to Local Authority Archaeology Services or Treasure Trove. The Battle of Prestonpans has already been the site of one of the first organised mass rallies in Scotland but we are also aware of individuals and small groups undertaking metal detecting activity on all battle sites across the county. We feel very strongly that there should be a clear national steer on metal detecting on battlefields which are not part of a formal archaeological research project.

ALGAO: Scotland would be grateful if you could consider these points before the final documentation on the Inventory of Historic Battlefields is produced.

Yours sincerely,

Biddy Simpson
ALGAO:Scotland Acting Chair