BSAC response to draft Heritage Protection Bill
Response to the to the draft Heritage Protection Bill prepared by Jane Maddocks on behalf of the British Sub-Aqua Club
Part 1 Chapter 4 Clauses 50-54
We are very pleased to see the level of consultation that is necessary before a site is designated as a marine heritage site. The continuing provision for consultation and appeal as outlined in the Bill is also very welcome. As representatives of the recreational diving community we would wish to be included in all consultations regarding marine heritage assets, especially as access to these sites is likely to be altered or curtailed. We would request that recreational water users generally and the British Sub Aqua Club in particular should be specifically named as mandatory consultees in Part 1 of Schedule 1 for English waters, and Part 1 schedule 2 in Welsh waters.
The recreational diving community could be a great force for good in the protection of the marine heritage, and involving representatives of the governing body as mandatory consultees and stakeholders would be seen by divers as a positive step in the management of marine heritage sites.
Part 4 Marine Heritage Licences
We are pleased to see the clarity of conditions for the granting or refusing of a licence. However Clause 196 (5) gives us some cause for concern because the definition of competent is difficult, and liable to non-specific interpretation. We would suggest that the phrase ‘or under the supervision of a competent person’ be added to the clause. This does not make the definition of competent any more specific, but it would allow recreational divers to take part in survey or general guardianship activities on sites that are marine heritage sites. However we are pleased to see that Clauses 200-208 allow for appeals against decisions to be taken in England and Wales. At this stage we would wish to reiterate our request to be added to the schedule of mandatory consultees.
Clause 198 Designation of a site as suitable for unintrusive diving activities
The new designation of a site as ‘suitable for non-intrusive diving activities’ is particularly welcome. Divers are becoming much more conservation conscious and we are pleased to see the recognition of that in this Bill.
Jane Maddocks, BSAC Underwater Heritage Advisor.
Page last modified: 28th Oct 2008 - 11:13:27