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. See part 1 of the series here, and part 2 here.

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C/ It is worth pointing out the extent of the archaeological work that has been undertaken. It has involved:

  • A desk based assessment in 2005 Overlooked for example the historic coal industry remains and the stone alignment which is apparently clearly visible on aerial photographs consulted as part of this exercise. Much has been made of the fact that the stone alignment has only been visible since a fire removed the “dense vegetation”. This is untrue as there are photographs of the feature in records held by the DAT. These photographs should have been consulted as part of the planning process and the feature therefore identified at an early stage in the process.

  • A field survey in 2005  Also overlooked the historic coal remains, hollow way and bank with ditch

  • Field visits by Trust and Cadw staff for a number of projects DAT officer claimed for a short time at our meeting that the stone alignment was in Neath Port Talbot and clearly demonstrated on several occasions that he had had no idea where he was.

  • An extensive augur survey to identify peats and/or prehistoric horizons, carried out to the Standard and Guidance of the Institute for Archaeologists (IfA), our national governing body.

  • 43 trial trenches (on the access roads and turbine bases), carried out to the Standard and Guidance of the Institute for Archaeologists (IfA). According to the Evaluation report “A total of 40 trenches was excavated across the development site”. Have DAT even read the report as they do not seem to know how many trenches were actually excavated?

  • an extensive archaeological watching brief, carried out to the Standard and Guidance of the Institute for Archaeologists (IfA). Areas shown in the Preliminary Statement as having benefited from a watching brief were being removed by machinery with no archaeological supervision on 16th January 2012.

  • Full excavation of the stone alignment where the new access road and spur to Turbine 16 impacted on it, carried out to the Standard and Guidance of the Institute for Archaeologists (IfA).

  • Preparation of a preliminary statement on the stone alignment, carried out to the Standard and Guidance of the Institute for Archaeologists (IfA). Is it normal practise not to include photographs of an excavation that is being reported upon within the format of a report that does include drawings and other photographs? Can’t think of any excavation reports that include photographs of the surrounding archaeology, but none of the excavation itself.

  • To be done-final reporting.

This is a comprehensive catalogue of the archaeological work that has been undertaken to date and in our estimation meets the planning requirements of Welsh Government and Carmarthenshire County Council.

If failing to carry out a search for earthworks within a development area in a landscape known to contain nationally important archaeological earthworks meets the planning requirements then perhaps these requirements should be re-visited.

D/ Finally, notwithstanding the above catalogue, it was this Trust’s view, and that of Cadw, that the application should have been refused on historic environment grounds. This Trust recommend refusal for this application on the basis that the area was not included in Tan 8, that no assessment had been carried out on the impact of the proposal on the historic landscape (even though we produced a brief to assist this work) and that the reporting as presented by the applicant’s contracting archaeologists (Cambrian Archaeological Projects) had consistently undervalued the scheduled and non-scheduled ancient monuments and their settings. It was therefore partly due to the inadequacy of the presented information that we raised our objections. Subsequently on-site recording and reporting have been carried out to our satisfaction.

In 1917 the Royal Commission published a report describing the Bancbryn coal workings as late C18 or early C19. In 2012 CAT produced a report stating that they were C20 indeed suggesting elsewhere that they were created in 1926. We are being asked to believe that the Royal Commission recorded the coal workings some nine years before they were created. It would be helpful if someone from the Dyfed Archaeological Trust could explain how this is possible and why they are satisfied with this explanation that is clearly wrong.

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