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Consultation on Coastal Change Policy (Defra 2009)

Submission from ALGAO Maritime Committee

coastal [dot] change [at] defra [dot] gsi [dot] gov [dot] uk

22.09.09

DEFRA ‘Consultation on Coastal Change Policy’

Thank you for the consultation on this paper. The Association of Local Government Archaeological Officers (ALGAO:UK) represents the senior archaeological officers within local authorities throughout the UK. The association operates through a number of national, regional and subject committees and the Maritime Committee deals with marine and coastal based issues on behalf of ALGAO:UK.

ALGAO:UK welcomes this consultation paper and is particularly pleased to see the emphasis given to local decision making and community involvement. We also welcome the discussion of the Historic Environment as an integral part of the whole issue.

How we fund coastal defence works
Paragraph 2.17 refers to the funding mechanisms in place to assist with coastal defence. While we acknowledge the need to defend property it is disappointing that this there is so heavy an emphasis on this as the first call for national money. It might be appropriate to define areas of outstanding national importance due to their landscape, natural or historic environment which might also be regarded as being of national importance to protect.

The proposed DEFRA work on appraisal of flood and coastal erosion risk management measures (para 2.22) might provide some guidance here.

Coastal erosion assistance package
We would support the principle of support for homeowners in this area. As a number of the case studies bear out some of these structures are important Historic Environment assets, both designated and undesignated and careful consideration need to be given to the best way to ensure that the historic importance of any such buildings is properly preserved by record should the local authority seek to demolish a property. This can best be achieved by ensuring the Local Authority Archaeologist and Conservation Officer are consulted before any such work takes place.

Community adaptation planning and engagement
Para 4.4 We would endorse the emphasis on community involvement, but feel that there is a need to develop a fully rounded picture of a local community, rather than just assessing the potential loss before prioritising action. We are sure that the pathfinder councils will explore this further but it would seem sensible to assist a community in defining its character in terms of buildings, landscape, economy and institutions in order to define those which are most important and which every effort should be made to be saved, rather than working on the basis of those things most at risk. The approaches which have already been developed to create Conservation Area appraisals and Village Design Statements might usefully be deployed.

Para 4.7 The employment of coastal engagement officers by the Environment Agency is an interesting development, and we would hope that these officers will be liaising closely with their colleagues in English Heritage and the relevant local authorities. The way in which these partnerships are developed will be key to the success of the whole approach.

The Historic Environment
English Heritage’s Rapid Coastal Zone Assessment (RCZA) programme will provide a valuable source of information about the Historic Environment Assets along the coastline, however the number of these assets which currently enjoy any designation is very limited and the RCZA of north-east England has identified that Heritage Assets along the coast are under-represented in terms of designations, with a far smaller proportion enjoying protection then those inland. This suggests that there is a need for English Heritage to prioritise the assessments of the results of the RCZAs and to look to the increased designation of coastal heritage assets.

In addition to this measure, local communities will need to have access - through the local Historic Environment Record (HER) – to information about non-designated sites in their area in order to draw up character statements and help identify sites and areas of perceived importance. This will not however cover the full range of archaeological sites, some of which are not found until they begin to erode out of cliffs and sand dunes. There will therefore need to be a commitment to a programme of archaeological assessment and evaluation of threatened areas in order to ensure that the full range and importance of archaeological sites in a given area has been identified. There are currently no mechanisms in place to resource such a programme either through local authorities or English Heritage.

Given the range and numbers of elements of the historic environment which will be threatened by coastal erosion there will be a need to prioritise resources and this may best be done through providing specific funds to English Heritage, perhaps through their regional offices. These funds will allow work to take place with local communities and the relevant local authorities to identify specific threats to sites of national importance and to sites of more local importance where the local community regards some form of mitigation, whether by record or physical removal, as being an essential part of the preservation of the character of that community.

In addition it might also be hoped that the Heritage Lottery would continue to feel able to assist, particularly in relation to enabling community involvement. We would expect that the Pathfinder councils might explore some of these ideas further, particularly in relation to the characterisation of settlements and the means of identifying the full range of historic environment assets which might be threatened by coastal erosion. In addition the development ofcost-benefit analysis schemes which are more sophisticated than those based purely on properties should be deployed to assist in identifying the value of the local historic environment to communities.

Robin Daniels
Chair, ALGAO:UK Maritime Committee