You are currently browsing the category archive for the ‘Guest article’ category.

by Sandy Gerrard

In March last year 18 questions relating to the archaeological situation on Mynydd y Betws were asked. During May the answers provided by Cadw were published here. I also asked my local Assembly Member (Mr Rhodri Glyn Thomas) to ask the Dyfed Archaeological Trust (DAT) the same questions and he kindly did this on my behalf. Having had no response in October I asked Carmarthenshire County Council for a copy of the DAT response and this was passed to both Mr Thomas and myself shortly afterwards. A commentary on the DAT response was then produced and sent to Carmarthenshire County Council. This series of articles present DAT’s responses in black and my own comments upon them in green.

General Comments (my commentary in green)

At the outset we should explain that this Trust has had strong reservations about the interpretation of the stone alignment as given by Dr and Mrs Gerrard largely through the medium of the press.

Interesting use of the words “has had”. The Trust surely either has or had strong reservations but surely not both at the same time.

At the site meeting the Dyfed Archaeological Trust (DAT) officer first raised the possibility of the stone alignment being schedulable and offered to contact Cadw directly for an assessment to be conducted. We informed him that we would also contact Cadw. The DAT officer also said that he would get straight back to us. I only contacted the “press” after it became clear that both the DAT and Cadw were not going to engage with our concerns.

This has concerned us as the nature of this archaeological find makes it very difficult to provide immediate or clear-cut interpretations on date and function and it is regrettable that this was done in the context of a sensitive windfarm development that has clearly invoked much local opposition.

I totally agree that it is regrettable, but as the stone alignment was only identified at this very late stage in the process clearly some sensitivity was going to be needed. If the Trust had instead chosen to involve us, as they initially promised, we would have been happy to work with them. Instead they choose to first alienate and then exclude us from the process and by doing so created the regrettable situation.

The Cotswold Archaeological Trust were commissioned by the developer to provide a report on the newly discovered stone alignment, based on a recommendation made by this Trust to the planning authority. The contents of the report are self-explanatory. However, it concludes that whilst a prehistoric origin cannot wholly be dismissed, it is:More plausible that the current alignment is representative of a later boundary, perhaps demarcating grazing rights on the moorland, or marks a pathway, perhaps from Bryn Mawr to the twentieth century adit workings’. [p12].

This form of “later boundary” is unknown in Wales so if this interpretation is accepted it would make the feature unique and therefore arguably more important than a prehistoric stone alignment of which there are several examples.

The “twentieth century adit workings” are neither C20 in date or adits. This site is described as late C18 or early C19 by the Royal Commission and was described by them some 9 years before the date assigned by the Cotswold Archaeological Trust (CAT). Adits are never cut into the very top of hills and it is perhaps better to consider them as outcrop coal workings. This is important because it means the report is suggesting that an impossible explanation is more plausible than one that “cannot be wholly dismissed”.

This Trust agrees with this conclusion, though our preferred interpretation is that the stones have been taken from nearby prehistoric cairns and used as a way marker across an open and inhospitable moorland environment, where changes to weather can occur very quickly.

This explanation can and has been challenged on many grounds:

  • There is no logical need for a third route to the summit of Banc Bryn

  • None of the other paths or tracks on the moor are waymarked

  • The small size of the stones means that they are soon covered by snow

  • There is no man made path or track on the upslope side

  • There is no need to build a path to a small scale outcrop working whose focus would have been continually shifting

  • The outcrop workings are much earlier in date than suggested by the report and may therefore not even be contemporary with the farmstead

  • The route chosen is more uneven than the one currently being utilised a short distance upslope

  • There is no tradition of waymarking across moorland using large numbers of closely spaced small stones

Why is the Dyfed Archaeological Trust so eager to accept an interpretation that is completely contradicted by its own records?

However, Dr and Mrs Gerrard may not agree with these alternative interpretations and it will be for them to produce a detailed report on their find which can perhaps be published in an academic journal making their views open to professional archaeological scrutiny and judgement.

A report has been produced and copies sent to DAT and Cadw. An online version is also available at: http://heritageaction.wordpress.com/2012/06/06/mynydd-y-betws-stone-row-very-poor-scholarship-and-a-system-which-is-clearly-unfit-for-purpose/

This report and others are now hopefully being used as part of a consultation exercise being conducted by Cadw. However, no response to the contents of the report has been received from DAT or Cadw. Indeed the officers to whom the report was initially sent did not even bother to acknowledge receipt.

____________________________________

For previous and subsequent articles put Mynydd Y Betws in our Search Box.

See also this website and Facebook Group

by Sandy Gerrard

It is more than a year since what Cadw call “that row of stones” on Mynydd y Betws was brought to the attention of those responsible for Welsh heritage.  In the intervening time two segments of the row have been “preserved by record” a brand new environmentally friendly road has been built and turbines have started popping up out of the heather.

Putting aside for the moment the controversy regarding the stone alignment and the archaeology that has (not) been preserved by record, this photograph illustrates rather well the threat facing archaeology in the “windy” uplands:

View from the south of the Banc Bryn prehistoric ceremonial landscape with the scheduled areas highlighted in red and the stone alignment in green.

View from the south of the Banc Bryn prehistoric ceremonial landscape with the scheduled areas highlighted in red and the stone alignment in green.

Despite complete agreement amongst archaeologists that this was a really important archaeological landscape the need for renewable energy was seen by planners as much more important than the setting of seven unproductive scheduled ancient monuments. Actually it goes further than setting – the so called “empty” spaces between the constituent parts of this ritual landscape are in some respects as significant as the features themselves and their loss means that this site will never be quite the same.  The proximity of the road and turbines to the scheduled areas highlights just what might happen to your favourite bit of moorland archaeology.

If you want to see for yourself the scale of the wind farm development on Mynydd y Betws click here for a recent aerial photograph. Enter SN 67711053 into the Grid Reference Box and explore the mountain for yourself.

from Sandy Gerrard.

holly

For fun I thought it might be interesting to utilise the powerful search engine at The National Heritage List for England to see if there is a Christmas theme to any of the schedulings. Alas the search revealed no scheduled Christmas sites, but as always seems to be the way a little further digging revealed 61 listed buildings with a Christmas mention. Yet more discrimination on the part of English Heritage I hear you cry.  Actually this is a salutary lesson in how even the biggest of anomalies can have the most innocent explanations unless of course English Heritage are willing to admit to deliberately depriving the schedule of festive cheer!

Seriously though it was really interesting to see the distribution of “Christmassy” listed buildings – with none in the north of England. On the basis of the evidence it would also appear that national important archaeology and Christmas place names are mutually exclusive – which is a shame. Perhaps next year English Heritage will try and rectify this sorry state of affairs or explain why there is no Christmas in the Schedule of Ancient Monuments?

__________________________________________

[For other articles  in the series put Scheduling in the search box]

by Sandy Gerrard

English Heritage have kindly responded to last week’s scheduling article which looked at yet another example of scheduling being described as listing. It is encouraging that EH have taken this concern seriously and their positive and forward looking attitude is to be commended.  In order to avoid misrepresentation it is repeated in full:

“Having looked into this case it was a simple clerical error and nothing more. It was made by a member of the IMT Resources Department, not Designation. The officer in question accidentally blended the letter templates for scheduled and listed sites. It was a genuine mistake, and the manager in question has reminded all officers in question to check carefully that they refer to the appropriate form of designation throughout any correspondence.
 
While English Heritage, like all organisations, strives to avoid such mistakes, unfortunately they do occasionally occur. We remain committed to protecting and managing sites where appropriate through scheduling, and are determined to do more work in this regard, both expanding and improving the scheduled element of the designation base. There is no deep seated problem with the archaeological element of our role as you appear to fear.”

 My reply to English Heritage stated:

“Thanks for looking into this.  I think the evidence and my own experience indicates that there is more of a problem than you currently wish to admit to.
I note your commitment to expanding and improving the archaeological designation base and this I obviously welcome. However 10 years have now passed since these promises were first aired by the newly formed Designation Department and still there is no evidence to demonstrate any progress – instead only promises of better days ahead and increasing numbers of mistakes.”

Looking at a couple of aspects of the English Heritage response in a little bit more detail it is perhaps worth emphasising that this is the second occasion in this single case that this very same mistake has been made. So perhaps these mistakes are not as occasional as EH would like us to believe. A detail perhaps confirmed by the inordinate number of mistakes in recent scheduling documentation.  Just how many mistakes will be notched up before the management at EH have to admit that there is a fundamental problem and seek to address it?

I love the idea of letter templates being blended. Surely the purpose of template letters is that there is one for every occasion. Perhaps the scheduling one is so rarely used that they had forgotten it existed!

__________________________________________

[For other articles  in the series put Scheduling in the search box]

by Sandy Gerrard

I recently received an e-mail from English Heritage asking me if they could reveal to someone that I had asked for Bosiliack prehistoric settlement to be scheduled. It’s no secret and I am happy to admit to anyone that it was indeed Bosiliack that launched this mini-series of scheduling articles. Bosiliack is an incredibly important monument and it would appear that English Heritage agree, as it has now been added to the Schedule of Ancient Monuments.

The alarming thing about the English Heritage letter was that it stated:

“English Heritage has received a request for the release of the identity of the listing applicant for Bosiliack prehistoric settlement.  I am writing to you because I understand from our Local Office that you requested that we consider the property for listing.”

So English Heritage who are the heritage designation experts still seem incapable of telling the difference between listing and scheduling. I asked for the site to be scheduled and this is what has happened, so why call me the listing applicant and the monument as “the property for listing”? Why is it that England’s leading heritage organisation seems unable to tell the difference? Does it matter that EH can’t tell the difference between scheduling and listing? Do these constant failings on the part of the organisation imply some form of deep seated problem with the archaeological element of their role?

The evidence is certainly piling up to indicate that all is not well within Designation Department at EH.  We are all capable of making the odd mistake, but EH appears to have taken this to a new level where mistakes are becoming the norm.

__________________________________________

[For other articles  in the series put Scheduling in the search box]

by Sandy Gerrard

In Scheduling – Part 5 English Heritage kindly provided a response to a number of points raised in previous articles.  This week I would like to focus on one particularly important issue raised by their response.

Previously English Heritage wrote:

While scheduling is, was and will remain an important way of protecting archaeological sites, there are other ways of protecting archaeology beyond designation. The partnership of local authorities and communities is crucial to the protection of sites through local schemes of designation and recognition of importance. Such local schemes are often the only viable solution to the protection of archaeological sites discovered as a consequence of the development / planning system, of which only a small number of such sites have ever been suitable for inclusion on the schedule.

There have always been other mechanisms to ensure the protection of archaeological sites and indeed conversely there is some anecdotal evidence to suggest that the demise of some sites may have been hastened by their scheduling. Many sites have been successfully safeguarded using the types of measures referred to and in particular one thinks of organisations such as the National Trust, Forest Enterprise and National Parks who have certainly contributed to the protection and enhancement of many important sites. However, national recognition and legal protection are very important markers to decision makers whose archaeological expertise is often minimal. How many times have we heard local authority planners dismiss sites as unimportant simply because they are not scheduled? When Joe Flatman was County Archaeologist in Surrey did he ever wish that certain assets on his patch were scheduled? Scheduling is a clear steer to local and national planners that either an individual or collection of sites are particularly important and as such deserve full consideration and respect.Conversely undesignated assets   may be regarded as being of less importance and therefore more expendable. In the complex world of ever evolving policy guidelines, notes and directives it is easy to overlook or underestimate the importance of even the most remarkable undesignated assets. The significance of heritage and the levels of protection it is offered within the real world is something that is becoming increasingly clear and relevant.  The presence of ‘heritage’ is being used to influence all sorts of planning decisions.

Recently EH were asked to enhance the National List for Upton Cressett, Shropshire.  A request to update the designation regimes within the area was precipitated by a proposed wind farm and as a result three listings and three schedulings were rapidly generated. This type of response was one that I advocated in a letter to “British Archaeology” and I was delighted to learn of it. Furthermore, by taking this action EH is making a stance and saying these heritage assets are nationally important and should be given full consideration in any forthcoming planning application.  In similar situations inadequate national protection regimes or local schemes of designation and recognition are hardly likely to carry any weight when considered alongside conflicting key strategic national policies without the further intervention of the National body responsible for their ultimate protection. The suggestion that nationally important archaeology which benefits from only local recognition and safeguards is going to be positively recognised and afforded protection by a decision making process that involves key national policies – which by their nature might bring about its damage or destruction – when the body which exists to provide such protection has failed to do so is optimistic to say the least. EH’s actions at Upton Cresset suggest they recognise that national importance needs to be expressed by designation.  The inhabitants certainly believe that formal recognition of national importance means that their heritage is more likely to be taken seriously in the future planning debates.  Surely it is time that EH accepts that they have a key role to play in safeguarding the most important sites and stop hiding behind the idea that most of them can be looked after by other organisations?

__________________________________________

[For other articles  in the series put Scheduling in the search box]

by Sandy Gerrard

Recently I voiced my concern that English Heritage may have accidentally scheduled the wrong field.  English Heritage has kindly responded, confirming that a mistake has been made:

“in this particular circumstance it does appear that English Heritage made an error regarding the extent of the scheduled area. We accidentally made this a larger area than intended, and thus also covered the area that was subjected to excavation in 2011 within the larger scheduled area. We are now in the process of revising this schedule.”

However, they note that:

“1. The excavations of 2011 strongly suggest that the archaeology present on the (excavated) southern half of the site continues to the north, possibly associated to one or more features visible on air photos. There is a strong presumption of in situ archaeology of national significance remaining to the north, and at real threat – thus worthy of scheduling;

2. In relation to point 1, I would convey the fundamental importance of our ability to respond effectively in cases where real or potential development pressure dictates the use of designation as an effective management tool, para. 139 of the NPPF notwithstanding. Any error in defining the constraint area in the case of Storrey’s Meadow should not be allowed to obscure those initial assessments of archaeological interest and significance which prompted the application for scheduling;

3. The consultation responses for this case did not highlight any concerns about the necessity to exclude this area of the site.

While these points do not excuse our error, and while we are setting up an amendment case to remove the excavated area from the scheduled area, English Heritage stands by the good intent and expertise underlying this schedule.”

It might be worth briefly considering some of these answers. Firstly, however it is should be emphasised that there is no explanation for this fundamental error. It has happened, it has been pointed out to them and now they are going to put it right.  This is important stuff – the scheduling description and mapping forms part of a legal document and mistakes will lower or some cases are likely to invalidate protection.

Moving onto the numbered points.
1. The evidence for nationally important archaeology within the northern half of the site is not proven beyond reasonable doubt. The Secretary of State is being asked to schedule an area on the basis of a presumption only – albeit a strong one. The available evidence does not support EH’s stance and more importantly the scheduling documentation is rather vague on what survives within this area. For the scheduling of this area to be effective a clear indication of what is being protected and why it is nationally important needs to be provided or else in the future the decision will almost certainly be challenged.
2. EH have correctly identified that it is fundamentally important to be able to “respond effectively”. Demonstrating national importance and clearly defining the extent of surviving remains are crucial elements of an effective response. Neither appears to have happened here.
3. Essentially this point is saying that nobody else involved with the case spotted the serious error.  This suggests that nobody involved in the process checked the details.

The final sentence in the EH response is baffling in the circumstances:
“English Heritage stands by the good intent and expertise underlying this schedule.”

Perhaps someone can explain what this means?

None of the other issues raised in the original article have been addressed by English Heritage and I am still awaiting a response to the scheduling of the C19 gravel pit raised in Scheduling – Part 6.

__________________________________________

[For other articles  in the series put Scheduling in the search box]

By Sandy Gerrard

Industrial archaeology is an often overlooked heritage resource. In some quarters in Wales it is not even seen as archaeology. In England, however this is clearly not the case as English Heritage have just scheduled a large C19 gravel pit!

Whilst this might appear to be good news and a long overdue appreciation of the importance of this much maligned industry, sadly this is not the case. No mention of the pit appears in the documentation and instead English Heritage seems to be under the impression that the area where the pit once stood is the site of a small Roman town worth protecting.  The scheduling documentation gives no clues to why EH believe that the shallow remains of the town have survived large-scale quarrying. Perhaps EH would be kind enough to explain why they have asked the Secretary of State to place this backfilled gravel pit onto the Schedule of Ancient Monuments?

EH’s own online PastScape describes the area as the “Site of a possible Roman settlement at Billingford represented by coins, pottery, a bronze brooch and a silver ring.” But apart from the finds mentioned above and a few “ephemeral cropmarks” there really does not appear to be anything in the scheduling documentation to strengthen EH’s own published tentative identification. Settlement remains are known to have existed in the area to the south, but there appears to be no definitive evidence that nationally important Roman remains actually survive within the scheduled area and the chances of them surviving within an area that has been quarried are surely non-existent.

There are many other peculiar aspects about this scheduling which I may return to in the future, but in the meantime EH might wish to consider why:

  • the descriptive details all relate to the parts of the site that are not scheduled.
  • the details imply that the focus of the settlement is elsewhere
  • no building materials have been found and there is no mention of post holes
  • the monument is described as “A Roman small town or roadside settlement occupied between the C1AD and c.750AD.”
  • they have scheduled an area that may have been severely disturbed. The large number of finds might be an indication that much of the remains have been disturbed. Can EH be sure that nationally important remains survive in any part of the site?
  • the continuity of settlement into the early Anglo-Saxon period and its association with the early see at North Elmham is also significant. Does proximity always mean association?
  • aerial photographs indicate pre-Roman settlement in the form of a clearly defined co-axial field system.
  • the site is described as “immediately connected to Roman roads” but what does immediately connected actually mean? Surely it is either connected or it is not?
  • the new bank adjacent to the road is not excluded from the scheduling.
  • the selected source details are incomplete

If they can come up with answers it would great if they could share them.

It would also be interesting to know why the site was rescheduled less than two years after it was first scheduled in 2010. This site was scheduled on 08-Jul-2010 and again on 27-Jun-2012 as “A Roman roadside settlement 150m south-west of Billingford Hall”. The List Entry Number is 1021458 and for those who wish to dig a bit further the PastScape No. is 130984.

__________________________________________

[For other articles  in the series put Scheduling in the search box]

We have received a response from English Heritage to Dr Sandy Gerrard’s first three articles on scheduling (Part 1, Part 2 and Part 3). We reproduce it below in full.  We understand Dr Gerrard may wish to respond to some of the points. In addition, any other constructive comments will be welcome.

___________________________________

The Scheduling of Archaeological Sites: A Response from English Heritage

These posts raise a number of important points as regards the scheduling regime which we respond to below. A longer response to Sandy Gerrard’s comments elsewhere can also be read in British Archaeology 122 (Jan/Feb 2012) (http://www.archaeologyuk.org/ba/ba122/feat2.shtml). English Heritage is committed to an increase in scheduling, in order that it continues to identify and protect sites that are truly of national importance.

  1. Many of the specific points stem from the introduction of the Unified Designation System and the National Heritage List for England. These are extremely complicated systems managing large data-sets, and they are still undergoing fine-tuning. Such inconsistencies and glitches within these systems are in the process of being rectified. These systems are leading to major improvements in the efficiency of the designation process, which in turn frees up time for more sites to be assessed.   
  2. There remain great strengths in archaeological expertise within the Designation Department and areas of upskilling in terms of expertise, for example, in its knowledge of maritime and coastal archaeology. Most recently, a new Head of Central Casework and Programmes was appointed to the Department’s senior management team, and that post-holder, Joe Flatman, has extensive experience of archaeology, having formerly been the County Archaeologist of Surrey.
  3. How English Heritage chooses sites for scheduling is determined by the National Heritage Protection Plan. As of the 1st October 2012, the total number of scheduling recommendations (including additions, amendments, and deletions) submitted to DCMS in the first seven months of the 2012-13 financial year was 48, of which 19 were new sites. If the same rate of submissions is maintained for the remaining five months of this financial year, then in 2012-13 we will submit approximately 100 recommendations. The intention is to continue to increase this number. Revision of older scheduling entries will add considerably to the numbers of new designations as well.
  4. While scheduling is, was and will remain an important way of protecting archaeological sites, there are other ways of protecting archaeology beyond designation. The partnership of local authorities and communities is crucial to the protection of sites through local schemes of designation and recognition of importance. Such local schemes are often the only viable solution to the protection of archaeological sites discovered as a consequence of the development / planning system, of which only a small number of such sites have ever been suitable for inclusion on the schedule.
  5. Sandy has raised a number of individual cases with us. We shall be responding to him directly on these.

__________________________________________

[For other articles  in the series put Scheduling in the search box]

by Sandy Gerrard

Much has been made over the years about the discretionary powers linked to scheduling, but looking ahead several major threats to our archaeological heritage have recently appeared on the horizon.  These are linked to the need to escape this recession and our ever increasing desires for more and more “green” energy. The threat to our nationally important archaeology is greater than it has been for decades. Does EH think that the scheduling of a handful of sites each year is going to safeguard this finite resource for future generations? Protecting archaeology involves several stages. The first is identifying the site, recording and interpreting it. Until this happens the site is essentially unprotected unless it happens by default to lie in an area where there are already sympathetic management controls. Once recognised, its importance needs to be assessed which hopefully allows informed decisions to be taken about its future including possible legal protection. In England assessment of potentially nationally important archaeology inevitably involves the EH Designation Department and to be effective this needs to be carried out before planning permission is granted. Does the Designation Department have the capability to efficiently and effectively assess the thousands of undesignated monuments that are likely to be impacted upon in the next few years? Are steps being taken to engage with the increasing threat to ensure that the very best of our archaeology is safeguarded?

[For other articles  in the series put Scheduling in the search box]

 

 

 

Archives

April 2014
S M T W T F S
« Mar    
 12345
6789101112
13141516171819
20212223242526
27282930  

Follow Us

Follow us on Twitter

Follow us on Facebook

Twitter Feed

Follow

Get every new post delivered to your Inbox.

Join 5,874 other followers

%d bloggers like this: