Pilot Pentland Firth and Orkney Waters Marine Spatial Plan. Consultation Analysis and Modifications Report.
The Pentland Firth and Orkney Waters Marine Spatial Plan is a pilot process undertaken by a working group consisting of Marine Scotland, Orkney Islands Council and Highland Council in advance of statutory regional marine planning. This report presents an
20. General Policy 6: Historic environment
20.1 Summary of responses received
| Stakeholder | Count |
|---|---|
| Commercial | 3 |
| Fisheries and aquaculture | 1 |
| Individual | 1 |
| Non-governmental organisation | 0 |
| Public sector | 3 |
| Recreation | 1 |
| TOTAL | 9 |
20.2 Main themes
20.2.1 Some respondents noted that the policy was much longer and different in style to the other polices. Two respondents, both representing the renewable energy industry, suggested it would be better to have the information in this policy as supporting information or guidance.
20.2.2 One respondent noted that the setting of the Heart of Neolithic Orkney World Heritage Site is a key part of its special quality the designation is largely cultural/historical. They suggest the text from General Policy 4D relating to the site would be better placed in this policy (General Policy 6).
20.2.3 A recreational stakeholder noted that an explanation of conflicting polices needs to be contained within the Plan e.g. flood defences to protect an eroding historic site could cause environmental damage or impact on leisure use.
20.2.4 A renewable energy representative queried why the wave and tidal industry had been singled out in paragraph 260 as it was not clear what effects were being considered. Another renewable energy representative did not feel this policy added anything to the equivalent policy in the National Marine Plan.
20.2.5 A fisheries representative noted that fishermen will have knowledge of the location of wrecks that may not be mapped.
20.2.6 Historic Environment Scotland provided several comments, the suggested text changes are provided in the table below. The remaining points were:
- They note the reference to the UK Marine Policy Statement but suggest using the Scottish Historic Environment Policy (Annexes 1.3 and 4.2) to provide a more comprehensive indication of factors that contribute towards the significance of historic sites and monuments
- They suggest presenting the policy in a format similar to the rest of the Plan
- They note the map is difficult to interpret and suggest indicative mapping of selected areas may be appropriate for coastal archaeology and other data sets that do not display easily on the map.
Table 20.1 General Policy 6 Historic environment - Table of suggested modifications
| No. | Suggested modification | Action taken | Reason |
|---|---|---|---|
| 196 | Note that corrosion of the Scapa Flow wrecks will occur over time. Suggestion that digital mapping could take place and then the removable items could be placed in the museum at Lyness. | None. | Historic Environment Scotland have undertaken survey work on the High Sea Fleet in Scapa Flow including the Scapa Map project and the more recent Scapa Flow 2013 Marine Archaeology Survey Project commissioned by Historic Scotland. |
| 197 | Suggestion that text relating to the Heart of Neolithic Orkney World Heritage Site should be taken from General policy 4D and put in general policy 6. | Reference to the World Heritage Site has been removed from policy text of General Policy 4D to the background supporting information. | Although the landscape setting of the Heart of Neolithic Orkney World Heritage Site is a key part of its special quality, the designation is largely cultural/historical. |
| 198 | Format policy in the same style as the other policies in the Plan. | None. | Different policy styles have been developed for the range of policy areas. |
| 199 | Clarify why the wave and tidal industry is mentioned in paragraph 260 and what effects are being referred to. | PARAGRAPH 260: Deleted. | To reduce the overall length of the supporting text for General Policy 6 by removing this non-essential paragraph. |
| 200 | The Scottish Historic Environment Policy ( SHEP) (Annexes 1.3 and 4.2) could provide additional context for this policy. The aspects of significance from SHEP should be included in this policy. | INFORMATION BOX 14: Second paragraph amended to 'Significance is the importance of the site in archaeological, architectural, artistic, historic, traditional, aesthetic, scientific or social terms. Understanding the type of significance a site has is crucial to its good management'. | To provide a more comprehensive definition of significance. |
| 201 | General Policy 6: Historic Environment - statement of policy It was suggested that the policy statement could be compressed so as to make the key considerations more explicit ( e.g. removal of legislative references already contained in supporting text). In doing so, this policy could be re-presented in a similar format to other general policies within the plan - with key points expressed in bullet form. |
POLICY TEXT: Deleted from third paragraph: 'all protected sites under the following Acts: Protection of Military Remains Act 1986 (as amended); Planning (Listed Buildings and Conservation Areas) (Scotland) Act 1997 (as amended); Ancient Monuments and archaeological Areas Act 1979 (as amended); Marine (Scotland) Act 2010' and replaced with 'protected sites identified in Table 3'. |
To reduce the length of General Policy 6. |
| 202 | Query on the wording of the final paragraph of General Policy 6 which states that "requirements of navigation and safety take precedence over the conservation of the historic environment". Whilst the rationale is understood where a vessel is in grave and imminent danger and impacts are unavoidable, the policy as drafted could be interpreted much more widely to include planned developments such as capital dredging for the purposes of navigation. In such instances, avoidance of policy commitments would not be merited, particularly for designated heritage assets, except where, in accordance with stated policy, the development can be demonstrated to deliver social, economic or environmental benefits which outweigh the impact on the heritage asset, and then only if appropriate mitigation is put in place. We would advise, therefore, that this part of the policy be redrafted to take account of these issues and better reflect the other policy documents that form its source material. | POLICY TEXT: Final paragraph deleted and replace first paragraph with 'Development which has the potential to have an adverse effect on the archaeological, architectural, artistic or historic significance of heritage assets, including their settings, will be expected to demonstrate that all reasonable measures will be taken to mitigate any loss of significance, and that any lost significance which cannot be mitigated is outweighed by the social, economic, environmental, navigation or safety benefits of the development'. | To provide clarity regarding the relationship between the conservation of the historic environment and navigational safety considerations. |
| 203 | Consider displaying the spatial data in a different format so it is easier to interpret. | MAP 10: Has been updated as follows, TITLE changed to 'Coastal Historic Environment' and caption has additional sentence added at the end of the paragraph 'This map does not show listed buildings with the Conservation Areas, the location of these listed buildings can be viewed on National Marine Plan interactive'. | To improve its legibility particularly the data relating to the World Heritage Site. |
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