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Item 7 Appendix 2

West Dunbartonshire Council · 16 November 2022
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ITEM 7 Appendix 2
Frontiers of the Roman Empire (Antonine Wall) World Heritage Site – comments received on draft version and Council’s
proposed response
Respondent Comment WDC response
Historic Environment Scotland
The comments submitted by HES
reflect comments already
submitted when the Antonine
Wall Supplementary Guidance
was consulted on by other
partner authorities. As the
document had been reformatted
for publication by West
Dunbartonshire Council, the
section references in the HES
response do not reflect the
paragraph numbers in the WDC
version. Most of the changes
requested had already been
made in the version published by
WDC
The comments in the attached annex reflect
comments that we have already given in
response to consultation on the draft
Supplementary Guidance from other partner
authorities (e.g. East Dunbartonshire). We have
also included some notes where the wording of
the document should be altered to use
appropriate and up to date terminology.
Annex
Section 1.6 
The wording could be improved in this
paragraph. It suggests initially that the Wall only
survives where it is visible above ground.
Potential alternative wording: ‘Today, around one
third of the Antonine Wall is visible above ground,
at places such as... open spaces within urban
areas and, though not visible above ground,
survives below ground’ 
Section 1.8 
The last sentence needs amended from should
read ‘not only identifies the reasons for the Wall’s
inscription as a World Heritage Site, but provides
the basis for its effective protection and
management. 
The HES comments mostly relate to an
earlier version of the SG, published by
other partner authorities, and have
largely already been incorporated into the
version of the document published by the
Council. As a result, the section
references used by HES do not always
match up with the current version. Any
outstanding changes are considered
below.
Accepted, change made at section 1.3.4.
Changes already incorporated at
paragraph 1.4.2.

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Section 1.9 
The end of this sentence should read
‘authenticity and integrity’. 
Section 1.10
The revised wording here no longer specifically
refers to the protection of the World Heritage
Site. This revised wording may imply a
weakening of the protections for the WHS. If the
original wording has not caused problems it
would be better to revert to the original wording
here. 
Section 1.11 
A page number for boundaries of the WHS and
Buffer Zone (singular) will need to be inserted
here. Furthermore, the list of relevant local
plans/local development plans is listed in
Appendix 4 not 3. 
Section 1.12 
This section incorrectly refers to Historic
Environment Scotland Policy (HESP). This
should be amended to the Historic Environment
Policy for Scotland (HEPS). As we noted in the
earlier, SPP will be replaced by the policies
within the Fourth National Planning Framework
(NPF4) in the relatively near future it may be
worth considering how this change can be
accommodated both for this note and for the
others. 
Changes already incorporated at
paragraph 1.4.3. 
Changes already incorporated at
paragraph 1.5.1. 
Changes already incorporated at
paragraph 1.5.2. 
Changes already incorporated at
paragraph 1.6.2.
The document needs to reflect the policy
documents in place at the time of
preparation so reference to the draft
Fourth National Planning Framework is
not appropriate.

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Section 1.14 
The first sentence of this section refers the ‘the
following specific planning policies’ whereas the
policies are presented on the page before this. 
Key Points (Page 5) As a point of detail, the
second bullet point has a typographic error (hich
instead of which). 
Site Audit (Page 6) The list of key questions for
Site Characteristics and Setting should include
'will the proposal have a direct impact on the
remains of the Antonine Wall and associated
archaeological features?' 
Section 2.9 
The last sentence of this section states that
‘further information is provided at Section 3.8.2’.
As there is no Section 3.8.2 it may be that the
appropriate reference is Section 3.19 and 3.20. 
Section 2.12 
As with Section 1.12 the correct reference here is
HEPS not HESP. 
Section 3.2 
The last line of the first paragraph of this section
should read ‘Examples of what could be
considered adverse include development that:’
The second of the following bullet points should
read ‘interrupts views to, from, or within’. 
Accepted, minor revision made at
paragraph 1.6.4. 
Changes already incorporated in Key
Points below paragraph 1.6.5. 
Changes already incorporated in Table 1. 
Noted – section reference has been
corrected in paragraph 2.4.1 
Changes already incorporated at
paragraph 2.5.3. 
Changes already incorporated at
paragraph 3.1.2.

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Section 3.5 
The fourth sentence of this section should read
‘The vertical buffer zone may include complex
archaeological deposits, with features...' 
Section 3.6 
The below text would be more appropriate
terminology to use in this section. 'should avoid
areas of surviving archaeological remains.'
'Avoiding the World Heritage Site and, in
particular areas which are scheduled will be the
best approach' '... the presence, location, depth
and sensitivity of deposits cannot...' 'This may
help to design proposals that avoid...' '...impacts
upon archaeological deposits from other
periods...' 
Section 3.8 
The first sentence of this section should read
‘any new development site overlying the
boundaries of the WHS’. 
Section 3.9 
This section is not clear on what happens if
new/unknown elements are discovered during
site works. We would therefore offer the following
revisions to address this ambiguity. 
• Revise first sentence to read: 'There may
be sub-surface archaeological deposits...' 
Changes already incorporated at
paragraph 3.2.2. 
Changes already incorporated at
paragraph 3.2.3. 
Changes already incorporated at
paragraph 3.2.5. 
Changes already incorporated at
paragraph 3.2.6.

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• • Potential Alternative wording - '...Where
known archaeological remains are present,
investigation will be required in conjunction with
new development. Where previously unknown
archaeological deposits are identified during site
works the Council should be informed
immediately and further archaeological
investigations may be required' 
Section 3.10 
The quote marks around setting should be
removed as they are unnecessary, potentially
confusing for readers and have been used
elsewhere in the guidance. 
Section 3.11 
The second sentence of this section should read
‘does not seek to prevent all change’. 
Key Points (Page 10) The first bullet point does
not make it clear whether this is referring to
scheduled sections of the WHS or unscheduled
ones although the text is similar to the scheduled
monument policy in SPP. The current wording
would allow for impacts in exceptional
circumstances which doesn't reflect policy
wording for the WHS in the Proposed LDP or
SPP which presumes against development with
an adverse impact. Also suggests a potential
weakening of protections. It is  recommended
that this is changed back to previous wording or
otherwise clarified. Furthermore, it would be 
Changes already incorporated 
Accepted- wording will be revised at
paragraph 3.3.2. 
Changes already incorporated at
paragraph 3.2.6.

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useful to include a further key point that where
the extent or presence of archaeological remains
is unclear, pre-determination evaluation will be
required 
Section 3.12 
The last two bullet points in this section are not
examples of significance of setting but separate
points. This may be a result of reformatting of the
original guidance which separated these out. It is
recommended that the formatting is adjusted to
make this clear. 
Section 3.16 
As a point of detail, the second bullet point of this
section should read ‘and the integrity of its
setting’. 
Section 3.19 
The link provided here for the EIA regulations is
still to the 2011 regulations rather than the 2017
regulations and should be updated. The updated
link would be The Town and Country Planning
(Environmental Impact Assessment) (Scotland)
Regulations 2017 (legislation.gov.uk). 
Section 4.3 
Bullet point 1 of this section should read 'Site
selection should avoid the WHS...'. Similarly,
bullet point 2 should read ‘Site selection with the
Buffer Zone should avoid the most sensitive
areas and avoid obstructing views. 
Changes already incorporated at
paragraph 3.3.3. 
Changes already incorporated at
paragraph 3.4.1. 
Changes already incorporated at
paragraph 3.7.2 
Changes already incorporated at
paragraph 4.2.1

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Section 4.3 (High Quality Landscape Design) 
The last sentence of this section should read ‘It is
therefore important that the location and
specification of new landscaping is considered in
relation to impact on the WHS and its setting’. 
Section 4.4 
The reference to the Buffer Zone in the first
sentence of this section should be singular. 
Section 4.7 
The final sentence of this section should read
‘Examples of suitable conditions might include
landscaping and/or protective buffer zones
around key in-situ sections of the wall. 
Section 4.9 
The second sentence of this section should read
‘Loss or damage to upstanding archaeological
remains and…’ 
Section 4.10 
As a point of detail these is a space missing in
the first sentence between or and in. The second
sentence should read ‘In all cases it will be
required that ongoing…’. 
Section 4.8 
(This follows 4.10 and should be amended to
4.11) 
Changes mostly already incorporated at
paragraph 4.2.1; minor correction to
wording made. 
Changes already incorporated at
paragraph 4.3.1 
Changes already incorporated at
paragraph 4.3.4. 
Changes already incorporated at
paragrpah 4.4.2. 
Changes already incorporated at
paragraph 4.4.3. 
Changes already incorporated at
paragraph 4.4.4.

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If useful a link to HES web pages on enforcement
could be added here:
https://www.historicenvironment.scot/advice-and-
support/applying-for-consents/scheduled-
monument-consent/compliance/ 
Appendix 4: General Information,
Development Plans and Useful Contacts 
It is welcomed the contact information here for
Historic Environment Scotland. However,
Heritage Management has now been changed to
the Planning, Consents and Advice Service. It
would be beneficial to update this contact
information. 
Noted; minor revision to wording made. 
NatureScot Broadly support the content of this Guidance
which consider provides clear, useful information
for those involved in development proposals
affecting the wall and its setting.
It is noted that landscape effects are one of the
criteria for the acceptability of development in the
context of the Antonine Wall. While consideration
of these effects is focused on the World Heritage
Site and the protection and setting of the site, we
note that the design criteria of reinforcing existing
landscape features and character is likely to lead
to outcomes that are generally positive.
Comments are noted. No changes to the
document are considered necessary.
The Coal Authority Our records indicate that within the West
Dunbartonshire area there are recorded coal
mining features present at surface and shallow
depth including; mine entries, shallow coal
workings and reported surface hazards.  These
Comments are noted. No changes to the
document are considered necessary.

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features may pose a potential risk to surface
stability and public safety.   
The Coal Authority’s records indicate that surface
coal resource is present in the area, although this
should not be taken to imply that mineral
extraction would be economically viable,
technically feasible or environmentally
acceptable. As you will be aware those authorities
with responsibility for minerals planning and
safeguarding will have identified where they
consider minerals of national importance are
present in your area and related policy
considerations.  As part of the planning process
consideration should be given to such advice in
respect of the indicated surface coal resource. 
It is noted however that this current consultation
relates to Supplementary Guidance on the
Frontiers of the Roman Empire (Antonine Wall)
World Heritage Site.  The Planning team at the
Coal Authority have no specific comments to
make on this guidance document.