Most of the proposed changes appear non-controversial, but certain of the proposals that require permits to metal detect, that create a new offense for purchases of undeclared artifacts, and declare archaeological finds Crown Property, are potentially very problematic.
A permit requirement could be used to preclude detecting from “archaeologically sensitive areas,” which could mean everything.
The proposed new criminal sanction could catch unwary buyers of objects that did not realize they were buying "treasure." Moreover, collectors should oppose the proposal's efforts to shift the burden of proof in a criminal matter.
Declaring all finds crown property may be a way to avoid paying fair market value for finds the State retains.
If you are a metal detectorist, an ancient coin collector, or just think the UK's current PAS and Treasure Act do a great job of bringing the public, museums and archaeologists together in a joint effort to record and preserve the past, please consider commenting.