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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.

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Dr Gerrard’s specific points

(It should be noted that Dr Gerrard’s questions are based on the premise that he has discovered a rare prehistoric stone row of national importance – an assertion that could not and has not been verified) How can DAT know what premise my questions are based on? If they had asked I would have told them. They are based on the premise that the archaeological response to the development on Mynydd y Betws has been inadequate. Most of the issues flow from the single fact that the area being developed was not at any time properly looked at or surveyed. No attempt was made to look for archaeological remains and no consideration was given to the possibility of removing vegetation to make sure that nothing important had been overlooked. Whilst my assertion that this feature is a prehistoric stone row has indeed not been verified on the basis of available evidence it still seems a more likely explanation than the alternatives offered by CAT and DAT which incidentally have also not yet been verified.

 1. Why was no earthwork survey ever conducted?
In terms of this development a considerable amount of pre-determination work was undertaken, including a walk-over survey by Cambrian Archaeological Projects in 2005. This work concentrated on the proposed development area and was no doubt hampered by vegetation. The work concluded that no major archaeological asset would be disturbed along the line of the proposed development. As no archaeological asset would be disturbed by the development an earthwork survey was not necessary.
An interesting shift in emphasis in this response. To start with DAT points out that “the work concluded that no major archaeological asset would be disturbed”. But by the next sentence the word major has been dropped and now no archaeological asset was going to be disturbed. This is untrue unless of course DAT now believe that early coal mining remains described by the Royal Commission are no longer to be considered as archaeological assets.
Furthermore and perhaps most significantly the Planning Inspector observed that there was unrecorded archaeology within the development area and despite this no measures were taken to rectify the situation. Why was the Planning Inspector’s guidance not heeded?

2. Why was no watching brief carried out when a fence was erected on the very edge of a scheduled monument?
The posts were sited, following Cadw’s advice, 10m beyond the limit of the Scheduled Monument in order to protect the monument from unauthorised or accidental encroachment. It is not normal practice for archaeological watching briefs to be carried out when fence posts are being driven into the ground as there is no opportunity for observation.
Would this explain why posts have been driven into the centre of the feature identified adjacent to Turbine 5? I think in the circumstances it would be very easy to argue that the statement “there is no opportunity for observation” is clearly wrong. In this instance there were clearly considerable opportunities for observation.

3. No archaeological watching brief was being conducted on 16th January 2012.
It was agreed that watching briefs would be carried out in sensitive areas as part of Stage 4 of the mitigation strategy and where the previous stages (augering and evaluation) had determined possible archaeological presence. The previous stages had proved entirely negative as did the subsequent watching brief work during geotechnical operations. With the developers cooperation a more extensive watching brief has been maintained throughout a large proportion of the subsequent development works but has not identified any archaeological features nor recovered any artefacts. The Trust is confident that the development has not needlessly destroyed significant archaeology without record. Indeed, Dr Gerrard provides no evidence that this happened.
The area in question is now depicted in the Preliminary Statement as having benefitted from a watching brief. The DAT officer who asked the developers to stop machining this area is also aware that no watching brief was being carried out and yet DAT are satisfied that this work was carried out. Why?
The use of the term “significant archaeology” is clearly intended to confuse the issue but also helpfully implies an appreciation that archaeology has indeed been needlessly destroyed without record. It’s simply that the DAT do not see historic coal mining remains, hollow ways and ditches with banks as significant.
Evidence of damage to archaeological assets is provided at several locations in the on-line “Heritage Journal” a resource that DAT were helpfully pointed towards early in February by the Gwynedd Archaeological Planning Service.

This area is recorded as having had a watching brief.

This area is recorded as having had a watching brief.

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