Dr. Ruth Johnson:

As spokesperson for the Local Authority Archaeologist Network, LAAN, I thank the Chairman and the committee for the opportunity to attend. Today's meeting is held in advance of the network's scheduled briefing on the Bill with the National Monuments Service. In light of this, and given the relatively short time that we have had to prepare, our response is going to be brief and high level. We would welcome the opportunity to provide the committee with more detailed comments, through correspondence, following the briefing next week.

In 2018, the establishment of the Local Authority Archaeologist Network was approved by the County and City Management Association, CCMA. Our members currently comprise 13 archaeologists working in seven local authorities, which are Cork city and county, Dublin city, and the counties of Kerry, Limerick, Mayo and Meath. The network enables local authority archaeologists to share their professional expertise and join together to engage in communications with other agencies. Local authorities deliver a broad range of services pertinent to that Bill, including planning and development management and care of the local heritage resource. The archaeological resource is largely managed in accordance with the Planning and Development Act 2000, as amended.

The county development plans, and local area plans, provide the strategic framework and policy context for local planning decisions. They provide the opportunity to protect, manage and promote archaeological heritage for public benefit at a local level. Many development plans afford safeguards to archaeological sites discovered since the publication of the Record of Monuments and Places. We ask that the new Bill will be designed in such a way as to interact effectively with the Planning and Development Acts, and support the role of local authorities in terms of our archaeological heritage protection.

The Monuments and Archaeological Heritage Bill is an important and very much anticipated piece of legislation. As stakeholders, many of the network members have participated in previous working groups towards the preparation of this scheme. We look forward to seeing a modern, consolidated and legal framework enacted that will meet the many challenges of today's operating environments.

A number of heads in the Bill directly concern local authorities. The network will need more time to consider their implications in this regard and consult. I refer, in particular, to where local authorities may be appointed as guardian by the Minister, in terms of enacted by-laws, and where the Bill refers to burial grounds under head 27.

The network will seek clarity and greater detail on a number of the heads in our forthcoming discussions with the National Monuments Service. In particular, the interpretation and definitions of registered and prescribed monuments, the term "relevant thing", and the levels and mechanisms for monument protection.

There are many practical considerations regarding the interface between architectural heritage and archaeology. We note that there are both overlaps and gaps between the relevant legislative instruments with which we work today that leave gaps for industrial heritage and vernacular architecture. We also have questions on the performance of functions, expenses, landowner consultations, dangerous buildings and environmental impact assessments.

The network welcomes specific aspects of the Bill, including Part 10, which concerns enforcement, and Part 4, which concerns objects. We welcome the heads that concern activities, licensing and inventories. We especially welcome the inclusion, and wish to emphasise their importance, of national guidelines and codes of practice to the committee as these are key to the Bill's successful implementation.

As an addendum to my statement, I wish to take this opportunity to draw the committee's attention, under Parts 8 and 9, to some personal considerations to resources, sustainability and managing the loss of archaeological heritage. This is particularly an issue that affects subsurface archaeologists or archaeology in urban regeneration areas. The principle of preservation in situis enshrined in the existing legislation. It is provided for in this Bill but it can be difficult to achieve, especially in urban settings. Will provision be made for the reporting and evaluation of things of interest that are discovered during, for instance, licensed rescue excavations?

Further, where preservation by record is the agreed option, the project design excavation and post-excavation dissemination strategies are currently variable in rescue excavations. We would like to see a levelling up to those standards currently implemented, perhaps, by Transport Infrastructure Ireland, TII. Finally, I wish to refer to excavation results in the loss of the archaeological resource and the creation of a paper record, collection of artefacts and interpretative grey literature. We ask that the committee considers whether the Bill can make provision for the dissemination of grey literature for public benefit as seen in initiatives such as the County Dublin Archaeology Government Information Service, GIS, and TII's web resource.