Mynydd Y Betws: Cadw’s responses [Part 1]

Dr Sandy Gerrard, joint discoverer of the Mynydd Y Betws stone row, has written scheduling recommendations for over 50 stone rows. He has posed “18 vital questions” on how a windfarm has come to be being constructed on the Mynydd Y Betws archaeological landscape, first without the discovery of and subsequently despite the discovery of what gives every appearance of being an extensive prehistoric stone row of major regional and national significance. [For previous and subsequent articles put Mynydd Y Betws in our Search Box].

He has now received responses to some of his questions from Cadw.  Today we publish the first half of them (preceded in each case by Sandy’s original question and followed by his comments on their response).

The remainder will be published next week. EDIT: late on Wednesday – see here: Mynydd Y Betws: Cadw’s responses [Part 2].

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Original Background Statement:
On the slopes of Bancbryn (forming part of Mynydd Y Betws) there is an incredibly rich multi-period archaeological landscape the importance of which has in part been recognised by Cadw’s designation regime. To all intents and purposes this looks like an important ceremonial/ritual landscape with a stone row forming its focus. The hillside is further enhanced by the survival of a range of historic features highlighting the importance of the area in more recent years. This impressive landscape now has a large road cutting right through its heart and shortly will have two substantial wind turbines towering 110m above it. The setting of this significant landscape will be compromised for years to come and even after the turbines have been dismantled the archaeology lost in their construction will be gone for ever. It is just not possible to replace archaeology once it has been destroyed and for this reason and quite rightly so there are legal constraints in place to ensure that archaeology is recorded before it is destroyed. This has not happened at Mynydd Y Betws and it is therefore surely appropriate that an explanation of this lamentable situation is forthcoming. To provide a focus I would suggest that answers to the following questions are needed:

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Question 1. Why was no earthwork survey ever conducted?
If this work had been carried out the archaeological remains of many periods would not have been destroyed before they could be recorded. The Planning Inspector observed that there was unrecorded archaeology within the development area and despite this no measures were taken to remedy the situation. The plan below is an unofficial survey of the archaeology and evaluation trenches. It took 2 days to produce and on many levels is more informative than the evaluation work carried out as part of the planning conditions. A survey of this type would have provided a context for the archaeology within the development area and allowed a properly targeted and effective mitigation exercise.

Cadw’s Response: “As you say no archaeological fieldwork was undertaken for the Environmental Statement submitted in support of the planning application and Cadw’s evidence at the public inquiry stated that the Archaeological Assessment underrated the detrimental impact that the development would have on the historic environment. However, although the windfarm had the potential to have an visual impact on the landscape as a whole the direct impacts were relatively limited and specific and the archaeological response had accordingly to be proportionate to the potential direct impacts. The Written Scheme of Investigation prepared by Dyfed Archaeological Trust, and agreed with Cadw, sought to respond to this by a staged approach to seek to identify potential archaeological feature and then to investigate and record them in line with established good practice guidance. Earthwork survey was also limited by the reported vegetation conditions.”

Sandy Gerrard’s Comment – To describe the destruction of at least one square kilometre of moorland within a landscape known to contain an array of nationally, regionally and locally important archaeological sites as “relatively limited” is an interesting stance and the failure to recognise that these areas could be understood better by looking even briefly at the adjacent areas still continues to amaze me. I do hope that lessons will be learnt and in future the experience at Mynydd Y Betws will be used to ensure that in the first place all the archaeology within a proposed development is presented to the planners and secondly every opportunity is taken to look for any archaeology that may be impacted upon using the full array of tools including eyes.

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Question 2. Why was no watching brief carried out when a fence was erected on the very edge of a scheduled monument (see image below)?

Cadw’s Response : “Best answered by Dyfed Archaeological Trust“

Comment – Are Cadw no longer responsible for the management of scheduled monuments in Wales? The fence is so close to the edge of the mapped depiction of the monument I am surprised to learn that Cadw were happy to allow this to happen with no input from yourselves. Is it normal practise to allow fences or other boundaries to be erected unsupervised on scheduled monument edges?

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Question 3. Why was no archaeological watching brief  being conducted on 16 th January 2012 when a large digging machine was removing topsoil adjacent to a scheduled monument (see image below)?

Cadw’s Response: “Best answered by Dyfed Archaeological Trust”

Comment – So even archaeology adjacent to scheduled monuments is beyond the brief of Cadw. The organisation would on the face of it appear to have a very narrow brief and should perhaps be thought of as having involvement in only a tiny percentage of Welsh heritage. Not really a national organisation then.

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Question 4. Why despite the fact that Evaluation Trench 36 (see below) was cut straight across the stone row  was the stone row not identified?

Cadw’s Response: “Best answered by Dyfed Archaeological Trust”

Comment – Agreed and we await their response with interest.

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Question 5. Was the possibility of protecting the row below the new road even considered?
At Rotherwas, near Hereford, English Heritage insisted that the Rotherwas Ribbon,  a linear feature (see below) of unknown significance be protected in this manner when a road was built, thus preserving it in situ…..

Cadw’s Response: “best answered by Dyfed Archaeological Trust“

Comment: Surprised by this response as you had already provided an answer in your e-mail of 27th March 2012. In this you stated that “Preservation in situ was explored but the diversion of the road was not practical or feasible, given the agreed layout of the development and the advanced stage of construction. Evaluation excavation seemed to us, and to the planning authority, to be a reasonable thing to ask the developer to fund and a way of trying to establish the nature and character of the feature.”

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Question 6. Why was no evaluation trench placed across the obvious linear hollow labelled on the map as a hollow way (see below)?
Given that a length of this earthwork was going to be destroyed by the new access road why was no trench actually placed across this very obvious earthwork and instead positioned on apparently level ground next to it? Why was this very obvious archaeological feature within the permitted development area ignored by the evaluation report? Does not this oversight confirms that the evaluation was not carried out to adequate standards, as graphically illustrated by the fact that most of the feature within this photograph was subsequently destroyed?

Cadw’s Response: “best answered by Dyfed Archaeological Trust“

Comment: Agreed

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Question 7. Why was no evaluation trench placed across the three cairn-like features between Evaluation Trenches 38 and 39?
The photograph below shows a probable cairn partly within the permitted development area below the bucket of the digger. This feature was not located during the archaeological mitigation works.

Cadw’s Response: “best answered by Dyfed Archaeological Trust“

Comment: Agreed

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Question 8. Why was the bank with associated ditch near to Evaluation Trench 40 not examined and why was the trench not excavated on the site of the earthworks? The feature has now been cut through by the road and is clearly visible in the section formed by the newly constructed road ditch – see below.

…… whereas the surviving ditch and associated bank can still be seen beyond the permitted development area (see below):

Cadw’s Response: “best answered by Dyfed Archaeological Trust“

Comment: Agreed

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Question 9. Why after the discovery of the stone row and a request for a full survey to be conducted was this not carried out?
Further archaeological remains are known to have been damaged and others may have been destroyed. It seems inconsistent that on the one hand the Trust appear to be saying that the archaeology was invisible because it was covered in dense vegetation but now that this vegetation had been removed and it had been demonstrated that there was unrecorded archaeology in the area that they did not ask for this important work to be conducted. Cadw were also asked to explore this option and did not respond.

Detailed observations at the site entrance indicate that Cotswold Archaeology (90% of the time comprising a single member of staff) spent a maximum of 10 full days and five part days on the mountain between 17th January and 10th February. Most of their time was spent carrying out very limited watching brief work leaving no time for survey.

Cadw’s Response: “Following the discovery of the stone row feature, Cadw and the DAT discussed what further work was possible, within the scope of the agreed Written Scheme of Investigation. The developers funded additional walkover surveys carried out by their archaeological contractors, Cotswold Archaeology and as mentioned above have also carried out further desktop research with the aim of establishing the age and nature of the row”.

Comment: We await with interest the results of these walk over surveys, but are somewhat surprised that despite this work further archaeological remains which could have been easily avoided were damaged in the course of subsequent operations.

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