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By Sandy Gerrard

A recent response regarding the stone alignment on Mynydd Y Betws dated 17/2/2012 by Dyfed Archaeological Trust has come to my attention.  It is worth repeating it in full here (in blue) with my own commentary added at intervals (in italics).

“Recent paper articles are giving information from one side of the argument only.”
The reason that “one side of the argument only” has been heard to date is because “the other side” has hitherto been unwilling or unable to engage in debate.  A reasoned debate is what I have been seeking from the outset and the very first article in the Heritage Journal invited a response. When we met on Monday 16th January the Dyfed Archaeological Trust Officer promised to keep us up to date with developments, a promise re-iterated by Cadw.  Neither party has seen fit to keep their promises in this matter. Dyfed Archaeological Trust have not contacted us and Cadw have failed to respond to two e-mails.  I only went public after it became clear that both parties were not going to involve us in the matter.

“The facts are these:
1.  This Trust and Cadw recommended refusal of the application both to the Planning Authority and at the subsequent Planning Inquiry. We were concerned about the impact of the development on the scheduled ancient monuments and the wider historic landscape.”
Neither party was apparently concerned enough however to carry out a robust defence of the archaeological case and this omission was compounded by the fact that, as The Planning Inspector’s Report notes, “The archaeological assessment seriously underestimated the impact as a result of the lack of appreciation of the function and settings of the Monuments. There were serious errors in the measurements and archaeological assessment.” Elsewhere he notes that “There are a large number of monuments within the overall application site.  Some are Scheduled Ancient Monuments, some are of more local significance and it would appear from the site inspection that some are not specifically recorded.”

“ 2.  The Inspector however granted consent, putting in place a condition to ensure archaeological work is carried out by the applicant.”
I am sure that the Inspector had in mind that the unrecorded sites mentioned in his report should be identified and recorded whilst the serious errors were remedied. The Written Scheme of Investigation instead focused entirely on what might survive below the ground and no attempt was made to look for the unrecorded archaeological remains noted by the planning inspector. This approach almost certainly explains why: the stone alignment, three stony mounds, a hollow way, a ditch with associated bank and the northern mining pits all obvious on the surface and within the development area were not examined during the archaeological work carried out by the applicant.

“ 3. We at the Dyfed Archaeological Trust and Cadw have been acting as advisors to the planning authority to ensure compliance with this condition.”
No watching brief was being carried out on deposits adjacent to a Scheduled Ancient Monument when I visited the site on 16th January. Clearly there must have been no archaeological input into the positioning and erection of the fence on the edge of the same monument or else the row would have been identified. Cadw have made it clear in earlier correspondence that Dyfed Archaeological Trust are acting as their archaeological curators, and are, in part, acting on their behalf. They are responsible for overseeing and monitoring archaeological works. There is nothing to suggest that any monitoring of the fence erection or other works immediately adjacent to a scheduled ancient monument was conducted prior to the discovery of the row and other archaeological features.  

“ 4.  The stone alignment is a new discovery as a result of grass fires on the mountain. It is over 700m long and the development access roads have taken out about 10m. Here archaeological excavation has taken place, which could provide important information on the stone alignment and this can be used by Cadw in due course to judge whether or not the site merits statutory protection. We await the report on the excavations.”
The figure of 10m is twice that previously quoted by Dyfed Archaeological Trust and the use of the words “taken out” is clearly a euphemism for destroyed. None of it needed to have been “taken out” and indeed in England at Rotherwas near Hereford a linear archaeological monument of uncertain character and date was protected from damage during road building works.  Despite reference to the stone alignment as a “new discovery” and a result of grass fires on the mountain” it is clearly visible on Bing aerial photographs taken in around 2001. The hollow way, ditch with associated bank and northern mining pits are similarly apparent on all satellite photographs and these too were overlooked by the archaeological work carried out by the applicant.

“ 5. The vast majority of the stone alignment is not affected by the development at all.”
True, the vast majority of the stone alignment has not been physically damaged by the development, but its setting has been substantially altered.  I think it is somewhat disingenuous to suggest that it has not been affected “at all”. Surely in law the impact of a development upon the setting of nearby monuments and the wider historic landscape is as valid a matter for putting forward for consideration by the Inspector as any physical impacts? Certainly the non-physical impact was seen as important by the Trust in it’s first statement of “the facts” above: ” We were concerned about the impact of the development on the scheduled ancient monuments and the wider historic landscape”

“ 6.  We, and other professional archaeologists, have reservations about the prehistoric date and function suggested for this feature as other interpretations can been suggested. However, we have dealt with the stone alignment as if it is a major prehistoric find.”
This point is very difficult to contest as no other interpretations have been offered.  It is usual practise when challenging another party’s interpretation to offer a plausible alternative.  On the basis of field inspection alone it looks like a 700m long alignment of stones terminating at a cairn.  Furthermore it is associated with a large number of cairns some of which Cadw have already scheduled and considered without excavation to be prehistoric.  Alternative interpretations are awaited with interest.  

“ 7.  To date the developer has done everything required of them under planning requirements.”
Agreed.

“ 8.  Irrespective of our views on this windfarm, or indeed others, it is permitted development and it is in this context and the attached planning condition that this Trust is using its good offices to protect historic environment interests.”
It is indeed a permitted development.  Some might say that permission might not have been granted if a thorough survey had been carried out before the planning decision was taken. This said, it is surprising that most of the previously visible archaeology within the development corridor has not been recorded prior to destruction and perhaps it was not too helpful to allow the diversion of surface water from the new road into a channel leading across the stone alignment which is hardly a good example of the Trust using its good offices to protect historic environment interests.  An explanation of how these situations have come about would very much be appreciated.

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