Managing Change Underwater Heritage
Feedback updated 21 Aug 2025
We asked
From 9 January to 5 March 2024, Historic Environment Scotland (HES) asked for your views on draft guidance on underwater heritage.
The draft Underwater Heritage guidance outlines how to conserve underwater heritage around the coasts of Scotland and in freshwater environments such as lochs and rivers. It explains:
- the cultural significance of underwater heritage
- current management practices
- impacts on conservation
- safe exploration and investigation
We asked for your feedback on the proposed content of this guidance. This included your views on the key messages, scope and approach of the guidance and considerations to guide decision-making. We also asked for case study suggestions.
You said
We recieved 11 survey responses on Citizen Space from a range of stakeholders, including local authorities, academics, and heritage consultants.
Stakeholders generally agreed with key messages, but we received feedback to refine specific key messages to improve clarity.
This includes:
- Reframing the original key message 6 to include an imperative to increase knowledge about underwater heritage and to clarify our messaging on the inaccessibility of underwater heritage sites.
- Adding that the impacts of climate and nature crises are affecting underwater heritage and that underwater heritage itself can be dynamic and changing, not just the environment it’s in for key message 7.
- Adding messaging on the international significance of underwater heritage.
- Highlighting that underwater heritage is a finite resource.
There was a range of suggestions from stakeholders on how to improve the scope and approach. Some of the key points from comments were:
- The scope should expand to include more references to freshwater heritage and heritage partly / sometimes underwater.
- There should be more clarity when using the terms ‘underwater cultural heritage’ and ‘underwater heritage’.
- The guidance should have more information about relevant policies, local marine plans, marine planning partnerships, regional differences and the role of local authorities should be included.
- We should strengthen references to the climate and nature crises in the guidance, including further detail on climate impacts and how underwater heritage can support marine biodiversity.
- The guidance should provide more information on how to reduce and mitigate the impacts of change on underwater heritage. This includes highlighting the importance of monitoring change, explaining the mitigation hierarchy and clarifying how impacts can be managed through strategies like Archaeological Exclusion Zones.
- The guidance should recognise the added value underwater heritage can bring to activities.
- Stakeholders noted sector skills shortages were important to the context of this guidance.
- Stakeholders suggested case studies focused on the unlawful removal or artefacts, monitoring natural and human impacts, impacts of the climate and nature crises, and local stewardship.
We did
You can review the final version of Managing Change in the Historic Environment: Conserving Underwater Heritage on our website.
We updated the guidance based on your feedback. We provided more clarity to the document by splitting it into 4 parts instead of 3.
We refined the key messages to provide more clarity including:
- Reframing how we referred to accessibility, emphasising in what is now key message 7 that managing change in underwater heritage provides opportunities to increase our knowledge of it, and access to it.
- Highlighting that underwater heritage is part of a dynamic environment that is changing due to the climate and nature crises in what is now key message 8.
- Creating a new key message about the international significance of underwater heritage (key message 4).
- Integrating the idea that underwater heritage is a finite resource into an existing key message, now key message 6.
Other key changes include:
- Provided more clarity on the scope of the guidance by including more references to freshwater heritage and heritage partly / sometimes underwater. This included information on canals and the need to apply for scheduled monument consent for a range of activities.
- Added information in Part 1 of the document to explain how we are using the terms ‘underwater cultural heritage’ and ‘underwater heritage’. We also outlined how the term ‘underwater cultural heritage' is linked with the 2001 UNESCO Convention on the Protection of the Underwater Cultural Heritage.
- Added further relevant policies and frameworks that outline the key considerations for decision making including more information on regional marine planning in Part 2 of the guidance.
- Included references to the climate and nature crises throughout the guidance, including on climate impacts and biodiversity restoration.
- Increased information on mitigation, including sections on how to avoid, reduce and offset impacts of change on underwater heritage and reordered Part 3 for clarity.
- Referenced the added value of protecting underwater heritage throughout the guidance, including the positive contributions it can make to the economy, biodiversity and activities.
- Decided that heritage skills, although important to the context, did not fit the scope of this guidance note. We have noted it for other HES work and resources, such as the Skills Investment Plan.
- Integrated some case study information into the guidance in the form of photo captions. HES will release more case study information through blogs and other communications material.
Overview
The Managing Change guidance series supports good decision-making and explains how to apply the policies in the Historic Environment Policy for Scotland (HEPS) and the National Planning Framework 4 (NPF4). It will also help anyone interested in a decision on a specific topic to understand the decision-making process.
Historic Environment Scotland (HES) is seeking your views on the draft Managing Change guidance on Underwater Heritage. This guidance outlines conserving underwater heritage around the coasts of Scotland and in freshwater environments such as lochs and rivers.
It includes information about the cultural significance of underwater heritage, current management practices, natural and human impacts on conservation, and safe exploration and investigation.
Why your views matter
We want to hear your thoughts and ideas about the proposed content of this guidance.
We welcome your feedback on any part, but particularly on whether you think we have identified the right key messages and considerations to guide decision-making. This includes considerations on the climate and nature crises and relevant plans and policies such as the National Planning Framework 4, UK Marine Policy Statement and the Scottish National Marine Plan.
We would like to hear your views on accompanying this guidance with case studies that demonstrate its practical application and if you have any suggestions for possible case studies.
You can provide feedback by completing this short online survey.
If you prefer, you can download the full set of consultation questions [PDF, 284KB] in advance. You can also download a copy of the draft guidance [PDF, 554KB].
Providing Feedback in Other Ways
If you would like a copy of the draft guidance and associated consultation questions in a different format, please let us know.
If you would like to provide feedback differently, such as over the phone, by email or via online meeting (on Microsoft Teams, Zoom or similar), please let us know and we would be happy to arrange this.
Please contact the Heritage Policy Service via email at heritagepolicy@hes.scot or via phone on 0131 668 8657.
Background
This proposed guidance has two key audiences:
- Practitioners and decision-makers who encounter underwater heritage in the course of their duties. This includes individual or organisations involved in:
- Heritage management
- Terrestrial and marine planning
- Water-body management
- Archaeological and environmental consulting or development
- Those who interact with underwater heritage for recreation, including scuba diving, or in the course of their work, such as commercial fishers.
The guidance aims to increase understanding of underwater heritage. It also aims to be a practical guide on identifying and managing the impacts of change in underwater heritage while protecting the cultural significance of these sites.
Contents
The draft guidance is split into three parts:
- Getting Started:
- Key messages
- Relevant policies
- Understanding underwater heritage
- Cultural significance
- Protecting underwater heritage
- Impacts on Underwater Heritage:
- Identifying impacts
- Managing impacts
- Exploration, Investigation and Discoveries
- Principles of preservation in situ
- Excavation and recovery
- Recreational activity including scuba diving
- Commercial fisheries
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