Society response to a consultation on Battlefields: Planning Best Practice
The Society response submitted to a consultation by Historic Environment Scotland on “Battlefields: Planning Best Practice – feedback on a report by Lichfields UK”. Submitted on 2022-11-03 online – these are the online responses: Introduction and executive summary About you 1 What is your name? Name: Dr Simon Gilmour 2 What is your email address? Email address: director@socantscot.org 3 If …
The Society response submitted to a consultation by Historic Environment Scotland on “Battlefields: Planning Best Practice – feedback on a report by Lichfields UK”.
Submitted on 2022-11-03 online – these are the online responses:
Introduction and executive summary
About you
1 What is your name?
Name:
Dr Simon Gilmour
2 What is your email address?
Email address:
director@socantscot.org
3 If you give your permission, we may contact you by email to discuss your response in more detail. Are you content for Historic Environment
Scotland to contact you again in relation to this consultation exercise?
Yes
4 Do you use the Inventory of Historic Battlefields? (Select all that apply)
Yes – for my work
5 Are you responding as an individual or an organisation?
Organisation
If you’re responding as an organisation, please enter the organisation’s name here:
Society of Antiquaries of Scotland
6 Historic Environment Scotland would like your permission to publish your consultation response. Please indicate your publishing
preference:
Publish response with name
7 Our privacy notice explains your rights and our role in protecting the information you share with us. Please confirm that you have read the
privacy policy and consent to the data you provide being used as set out in the policy
I have read and agree to the privacy policy
Conclusions by Lichfields
8 How do you view this conclusion?
Strongly agree
Do you have any comments?:
Any work that improves clarity and transparency is welcomed.
Recommendations about the inventory
9 How do you view the following: ‘Boundaries of Inventory areas should be redrawn to exclude areas (particular redeveloped areas) which no
longer “exhibit some level of preservation and/or significance in terms of its special qualities and landscape characteristics through which it
can contribute to our understanding”?
Slightly disagree
Do you have any comments? In particular, do you have any views on setting boundaries and how to define when a battlefield, or part of it ‘no longer
exhibits some level of preservation and/or significance in terms of its special qualities etc…’?:
Redrawing boundaries to exclude areas would negate one clear purpose of the inventory as recognised through the review to aid understanding outside
of the planning process. Perhaps it would be better to have two boundaries, one of which is, as per the current situation, relevant to the history of the
battle and its understanding, and another which delineates areas which have the potential to retain remains of the battle and its aftermath itself (i.e.
excluding those areas as per the statement)? Clarity and transparency is required to ensure that users understand the difference and also understand the
processes that were used to define the different boundaries. This would ensure that the inventory retains its broader purpose, beyond that of
management.
10 To what extent do you agree or disagree that ‘HES should provide further clarification in its Selection Guidance regarding how it defines the
boundary of Inventory sites’?
Strongly agree
Do you have any comments on this recommendation:
Clarification and transparency on the processes used to define these boundaries is essential. This also includes the setting and other wider landscape
attributes (such as views) where they contribute to the key landscape characteristics and special qualities of site.
11 How do you view the following: ‘The documentation which was prepared to support the designation decisions (particularly the Summary
and the Deployments maps) should be separated from the Inventory entry itself. While these should remain easily available from the Inventory
entry, it should be clear that these were prepared for the purpose of designation’ ?
Strongly disagree
Do you have any comments on this recommendation:
The purpose of the inventory, even as stated by HES themselves, is not solely for management through the planning system. The information contained
in these documents is crucial to an understanding of the sites, and therefore goes beyond their use simply for designation. The Act does not specify what
the inventory is to be used for, simply specifying that sites so included must be of “national importance”. Any understanding of why a site is of national
importance will require the information in these documents. As noted in the review, it is policy (separate from the Act which created the inventory) which
provides specific aims.
However, this inventory information must be updatable as understanding changes. If the aim of this proposal is to provide clearer guidance for
management of sites, then this can be provided in separate documentation, in addition to that available for the understanding of the sites. There is
nothing in the Act which would preclude different information being provided for the same site (“in such form as they think fit”) to address different aims.
Such separate documents might for example directly support the separate boundary maps produced to aid management.
There is an interesting discussion in the review which compares the level of information in the inventory for individual sites with other designations,
suggesting that there is more and that the inventory record is acting like a HER record. However, why shouldn’t it? Perhaps the HER records should simply
refer and link directly to the inventory record for a site? These places have after all been chosen to be designated by an Act due to their importance.
Recommendations about management of inventory battlefields in the planning process
12 How do you view the following: ‘Building on HES’ “Managing Change” guidance, detailed guidance should be developed for the assessment
of cultural significance of battlefields and the impact of proposals and the identification of effective mitigation and enhancement (potentially
generating examples or templates). This should aim to establish accepted standards for assessment by any of those working with battlefields’?
Strongly agree
Do you have any comments?:
Anchored in a need to ensure greater clarity and transparency for decision-making, such guidance and indeed the development of standards would be
welcomed.
13 To what extent do you agree or disagree that ‘Planning authorities should be encouraged to develop management guidance (preferably
inline with accepted standards) for their Inventory battlefields’?
Neutral – no opinion or undecided
Do you have any comments on this recommendation?:
If national guidance is produced there would be no need for such local authority guidance. However, given that individual sites can be very different in
their current preservation, landscape setting, scale and sensitivity to change, it would be useful to have specific management guidance for each site – this
could be produced at national scale or through individual planning authorities, but should be held by the inventory.
14 How do you view the following: ‘Planning Authorities should, where appropriate, require applications which have the potential to affect a
battlefield to be supported by a suitable assessment of impact(preferably in line with accepted standards) either individually or, preferably,
through amendment of HOPS Validation and Determination Guidance for Planning Applications’?
Neutral – no opinion or undecided
Do you have any comments on this recommendation?:
This is a question for those handling planning applications.
15 To what extent do you agree or disagree that ‘HES, as the lead public body set up to investigate, care for and promote Scotland’s historic
environment, should request the amendment of the wording of NPF4 to allow for the assessment of setting impact where appropriate.
Suggested wording is provided here: Development proposals affecting battlefields within the Inventory of Historic Battlefields should protect
and, where appropriate, enhance a battlefield’s cultural significance, key landscape characteristics, physical remains and special qualities’?
Neutral – no opinion or undecided
Do you have any comments on this recommendation? :
The para in the NPF4 draft already states: “Development proposals affecting sites within the Inventory of Historic Battlefields should protect and, where
appropriate, enhance a battlefield’s cultural significance, key landscape characteristics, physical remains and special qualities.”
Recommendations about archaeology
16 To what extent do you agree or disagree that ‘Archaeological evaluation, impact and mitigation should be closely incorporated into
the relevant strands of site assessment required to inform planning decisions’ ?
Strongly agree
Do you have any comments on this recommendation?:
17 How do you view the following ‘Archaeologists (both as curators and contractors) working in this area (or their professional groups) should
be encouraged to prepare best practice guidance on the investigation and recording of historic battlefields’?
Strongly agree
Do you have any comments on this recommendation?:
The Society may be able to help bring both archaeologists and historians together to discuss and prepare such guidance.
18 To what extent do you agree or disagree that ‘Opportunities should be explored for highlighting what is lost through irresponsible metal
detecting and promoting its responsible pursuit’?
Neutral – no opinion or undecided
Do you have any comments on this recommendation?:
There are opportunities but also risks in highlighting metal detecting on battlefields specifically and trying to define a responsible pursuit. There are views
on both sides of this discussion which are very far apart and unless sensitively handled this could drive them further apart. The core issue for battlefields
is that it is not illegal to prospect on them under the current legislation – the simplest answer here would be to make it illegal within one or both of the
boundaries (see above) for a battlefield site.
General recommendations
19 How do you view this recommendation?
Slightly disagree
Do you have any comments ?:
HES should certainly support such activity, but given its role in both designation and as a consultee in the matter, it might be more profitable to have a
third party organise such event(s). The Society may be able to help in this matter as the independent developer and host of the Scottish Archaeological
Research Framework and Dig It!.
20 Do you have any other comments on the recommendations ?
Give us your comments on the Lichfields recommendations: None