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Over the years the Heritage Journal has highlighted various issues regarding the protection of archaeology in Wales. It now seems that the Welsh Assembly Government agree with most of our concerns and have acknowledged problems with the existing system.
A Heritage Bill designed to tackle these problems is to be introduced in late Spring 2015 and amongst the proposed changes is the idea of making the designation process “more open and transparent by introducing formal consultation with owners and establishing mechanisms to review decisions”. Currently the process sometimes gives outsiders the impression that it is very secretive, inconsistent and often ill-informed. The move to a more transparent system should be welcomed by everyone with an interest in protecting Welsh heritage. Clearly as well as ensuring the creation of a designation system that works it is crucial that it is funded adequately. Providing that the Welsh Assembly can deliver on their promises to change the system and ensure that sufficient resources are made available Welsh heritage may have a better future.
Every year large numbers of scheduled ancient monuments are damaged. Cadw’s own figures (which are probably very conservative) indicate that between 2006 and 2012 there were 119 cases of unlawful damage to scheduled ancient monuments in Wales. Furthermore Cadw acknowledge that there has been only one successful prosecution under the Ancient Monuments and Archaeological Areas Act 1979 in the last 25 years. There is clearly a very large problem here and it is therefore somewhat disappointing that Cadw initially overlooked it. It is tempting to think that the recent case of damage to a length of Offa’s Dyke jolted them into making a late change to the proposed Heritage Bill. Hopefully their proposed remedy will work and ensure that the really important archaeological sites in Wales are finally offered some degree of protection.
A scheduled farmstead at Mynydd y Betws severely damaged in 2012 did not even appear on Cadw’s list of damaged sites. The site remains on the schedule but no remedial works have been carried out to protect the battered vestiges. Let’s hope the new proposed heritage protection system serves us better than the current one.
Having asked Cadw if they would keep us in touch with developments at Bancbryn there was no news. Instead the only snippets emanating from the organisation were a few tweets from a Cadw officer who had been copied into internal correspondence and who clearly despite having never visited the site felt confident enough to announce to the world:
The Mynydd Y Betws wind farm stone row ﬁasco – a ﬁeld boundary not neolithic but hey what do I Know? dlvrit/17rD8J
Mynydd y Betws stone row is conveniently placed next to a sheep track—- Mhmm those sheep must like neolithic archaeology!
These comments provide a window into Cadw’s “balanced” approach to heritage protection whilst at the same time illustrating a total failure to understand basic fundamentals of field archaeology. Cadw now accept that there is no evidence to support the field boundary interpretation and even after all this time there is actually no evidence to support the position that the alignment is not Neolithic. These tweets clearly indicate that even before the assessment process had started that some sort of uninformed biased consensus had enveloped Cadw’s mind set. The second tweet provides the clearest indication that the officer concerned has no field experience or they would have known that most stone rows are “conveniently placed next to” sheep tracks. This is because sheep respect ancient features in the landscape whilst Cadw…
The Ringmoor Down stone row on Dartmoor is conveniently placed next to a sheep track—- Mhmm those sheep must like neolithic archaeology!
An internal Cadw e-mail written three days after they were asked to consider the Bancbryn stone alignment for scheduling provides an insight into much of what followed.
“I think we know the answer to the questions raised – although if it does prove to be schedulable it might prove awkward. But we are under pressure to do something. At present the line is that DAT are keeping it safe and assessing the feature. Should we though bring it to a head by arranging an urgent inspection so that we can discount this for scheduling (or otherwise), as the pressure to do something will not go away in the meantime.” (Cadw official, 19 January 2012).
This item of correspondence written at a time before anyone from Cadw had visited the site acknowledges that it would be awkward for them if the site was of national importance. The suggested remedy would on the face of it seem somewhat prejudiced. The (or otherwise) reads very much as an afterthought and there is an implicit assumption that the site will be discounted for scheduling – and all of this before they have even seen it. Some might think this approach lacks balance.
An awkward feature that should be discounted for scheduling (or otherwise)
Three days after Cadw were asked to consider the Bancbryn stone alignment for scheduling the responsible Cadw officer informed her colleagues that she was starting to lose her temper. This outburst was attached to a proposed reply to a couple of emails sent to Cadw on 16th and 17th January 2012.
What can have been said to have triggered this outburst?
- asked to see the evidence that the area had been covered in dense vegetation.
- expressed concerns that it was now apparently acceptable practice to ignore areas covered with dense vegetation during an assessment on areas adjacent to scheduled archaeology that are to be destroyed.
- expressed surprise that no archaeological earthwork survey work has been conducted as part of this project.
- asked that a fresh survey be conducted as a matter of priority.
- informed Cadw that Dyfed Archaeological Trust had claimed that they did not have time to monitor this development in the field.
- expressed concern that an earlier response had suggested that mitigation would be limited to a watching brief.
- asked that a scheduling assessment be carried out as a matter of priority.
- asked to be kept up to date with progress.
- requested that the site be accorded sensitive handling.
Whatever the reason it was surely a somewhat inappropriate reaction to genuine concerns expressed in a constructive manner.
The final irony is that the Cadw officer “forgot” to send the reply!
By Dr Sandy Gerrard.
As part of the planning conditions imposed by the Planning Inspector at Mynydd y Betws he stated: “No development shall take place within the site until a programme of archaeological work has been implemented in accordance with a written scheme of investigation approved by the Local Planning Authority in consultation with Cadw”
In August 2010 the necessary approval was obtained with a Cadw Officer stating:
“I have read through this WSI and can conﬁrm Cadw’s agreement to what is a comprehensive programme of work linked to the appropriate professional standards.”
Please can someone tell me how can a Written Scheme of Investigation (WSI) which does not include any earthwork recording in a landscape which Cadw described in 2006 as having a “density of visible upstanding archaeological sites and monuments of many periods” be described as comprehensive?
Furthermore the Planning Inspector had already stated in his report when mentioning archaeological sites that “it would appear from the site inspection that some are not specifically recorded.”
So why did Cadw and Dyfed Archaeological Trust not insist that at least these were recorded prior to destruction?
If they had perhaps a field system through which a road was driven would have at least been noticed before it was destroyed.
By Dr Sandy Gerrard.
On the 2nd January 2012 we were invited by friends to have a look at an area that was about to be destroyed by wind farm construction works. The wind farm was to occupy Mynydd y Betws and the part we chose to look at was around Bancbryn.
A few years earlier despite protestations from Cadw and Dyfed Archaeological Trust (DAT) permission had been granted by the Welsh Assembly Government for a wind farm to be erected subject to a whole raft of conditions. Amongst these were a couple of archaeological ones which sought to ensure that the archaeology was properly recorded prior to destruction. In 2011 a programme of work was carried out by Cotswold Archaeology who reported that very little had been found. With the green light in place construction work started towards the end of 2011 and it was then that we were approached by friends who were concerned that various planning conditions were being flouted.
The visit on 2nd January rapidly revealed that there were archaeological remains within the area that was scheduled for destruction. Traces of archaeological trenches were visible in places but these appeared to have missed the surviving remains. The local archaeological trust (DAT) were informed of our discoveries and eventually agreed to meet on the mountain on 16th January. The DAT officer agreed that the remains were of potential significance and asked the developers to stop work in their vicinity until they had been investigated.
In the meantime a request to schedule one of the sites was submitted to Cadw together with a question. Why had no attempt been made to look for and record the archaeology within the development footprint?
From this point onwards the archaeological organisations involved set about protecting their positions and in doing so exposed series flaws in the way that archaeology is conducted in Wales. Freedom of Information requests have revealed the highly questionable ways in which the various organisations sought to minimise the political fallout and the considerable lengths that they were willing to go to try and protect their vested interests.
Amongst the techniques used were: ignoring evidence; failing to substantiate claims; not publishing the excavation report, refusing to engage with many of the issues; conducting a biased scheduling assessment and attempting to withhold information. Perhaps most telling however was the role played by DAT who were simultaneously providing planning advice to the local authority whilst working on behalf of the developer. Where else within the planning system is a private company (DAT) able to act simultaneously on behalf of both the developer and the planning authority?
Running through the whole sorry saga however is a seam of complete incompetence. Fundamental mistakes were made at every turn – contradictions, inconsistencies, inaccuracies and contempt for public concerns are all apparent. During the coming months the evidence to support these and other claims will be presented.
Of course if any of the organisations involved would like to comment we would be happy to publish their responses in full (The Heritage Journal).
by Sandy Gerrard
Cadw’s refusal to designate the Bancbryn stone alignment allegedly hangs on a lack of compelling evidence to support a prehistoric date for the site. We have seen that this sort of nicety does not normally inconvenience them. The schedule is stuffed full of sites that lack any evidence (compelling or otherwise) to support their identification and a whole load more where the evidence strongly suggests that fundamental interpretative mistakes have been made. On an area of moorland not far from Mynydd y Betws at Carn Llechart (SN 69668 06275) stands a scheduled chambered tomb. Over the years doubts have been expressed regarding its identity but despite this and the lack of any evidence to support its identification as a chambered tomb it has remained firmly on the schedule. The surviving earthworks and slabs of rock can be most plausibly interpreted as a quarry. The dumps of waste are piled up into three neat banks, the slabs have been trenched around to expose their edges and one of the slabs has been split. There is no part of the evidence that does not fit a quarrying scenario whilst by contrast nobody seems to have been able to explain how the different components fit together to form a chambered tomb. Perhaps Cadw would like to explain what the compelling evidence is to justify the statutory designation of this feature.
Quarry pits visible at A with waste material dumps at B. Although scheduled as a chambered tomb the surviving features look like the result of quarrying. View from south east (28th December 2014).
A large split stone. The thin rock on the left has been split from the slab on the right. View from above and west.
Large slabs exposed by trenching along their edges. Material removed thrown up to form a bank along the western side. Classic quarrying remains. View from south east.
The stone alignment at Saith Maen stands on moorland above Craig-y-nos in Powys at SN83311540. The row includes a line of seven slabs (two of which are recumbent) extending for a total length of 13.7m. There is nothing else quite like it in Wales. Compared with all of the others the stones are set very close together and indeed for the closest parallels one must look west to Ireland where several well-known examples exist.This alignment also lacks a prehistoric context as there are no cairns or similar features in the immediate vicinity. Finally the stones are relatively unweathered compared with others in the area.
These warning signs could be seen as an indication that all is not as it appears. No conclusive evidence exists to support a prehistoric date but it is accepted as prehistoric because well it looks right and no alternative explanations have been forthcoming. Interestingly when Cadw were asked for alternative explanations for the Bancbryn alignment they responded “I am not minded to express an opinion on the most likely interpretation given the limited nature of the evidence.” A curious response given that there is plenty of evidence to support a prehistoric date for Bancbryn whilst none exists for Saith Maen and its documented use as a sheepfold should perhaps sound warning bells!
by Sandy Gerrard
Situated near the base of a steep sided shake hole at SN 82898 15123 near Craig-y-nos and the Welsh National Showcaves is a small circular stone built structure. The building is a Scheduled Ancient Monument, (BR256 Hut Circle west of Saith Maen) although it is actually situated to the south-west. The structure is very small with an internal diameter of 3.1m surrounded by drystone walling up to 0.6m high. A clearly defined slab-lined entrance faces west. The Royal Commission record it as a hut-circle, although David Leighton in his Western Brecon Beacons book notes only that “The building is probably of prehistoric date” (Leighton, 2012, 69) but the Clwyd Powys Archaeological Trust go rather further stating that “There is something about the site which feels more akin to a shelter of a more recent date than any kind of prehistoric dwelling”. So definitely no consensus and despite the considerable uncertainties Cadw scheduled the site as a prehistoric hut circle.
This is important because when an application to schedule the Bancbryn stone alignment was submitted to Cadw they concluded that “because the evidence base is inconclusive, and there is an alternative theory of post medieval origin that would not meet the criteria for scheduling, it is not possible to schedule the site.” So why was this structure near Saith Maen scheduled? After all alternative very plausible post-medieval theories have been offered but with typical Cadw inconsistency and total disregard for their own professed procedures they pressed on regardless. The final irony is that the post-medieval explanations offered for this scheduled site remain whilst Cadw have now accepted that no specific evidence to support the post-medieval explanations for the Bancbryn stone alignment exist. A fine old mess indeed.
Despite being at the foot of a very steep slope no hillwash deposits have accumulated within the upper part of the building. This strongly suggests that the structure is relatively recent as does its fresh almost pristine appearance. Furthermore its very small size is unusual as is its position in the bottom of a shake hole. A couple of post-medieval interpretations which Cadw appear to have overlooked include a gunpowder magazine or shelter and both would seem, given the anomalies highlighted above, much more plausible than the prehistoric one favoured by Cadw. The structure stands in the midst of an industrial landscape and this context complete with the character of the remains makes a post-medieval date much more likely. The sides of the shake hole would have provided an excellent blast wall and the gunpowder could have been transferred throughout the area using the adjacent tramway. The form of the structure however suggests that it is most likely to be a shelter. Identical structures are known in the archaeological record.
by Sandy Gerrard
David Leighton in his excellent “The Western Brecon Beacons – The Archaeology of Mynydd Du and Fforest Fawr” book published by the Royal Commission on the Ancient and Historical Monuments of Wales deals head on with the issue of standing stones. He notes that they are “an enigmatic group of monuments” and may have been raised for a wide variety of purposes. Most significantly he goes on to say “Those of prehistoric date, which may subsequently have served any of these purposes, can only be described confidently as such after excavation, and few have been investigated in this way” (Leighton, D., 2012, 87).
Most of the scheduled standing stones in Wales have not been excavated and therefore varying degrees of doubt must exist regarding their identification. This however does not prevent Cadw confidently scheduling them as prehistoric without a shred of evidence. This is important because it clearly illustrates that definite proof is not seen as a requisite for a site to be added to the schedule. So why is a lack of evidence seen as a justifiable reason for not scheduling the stone alignment at Bancbryn? Cadw now accept that the various alternative explanations are spurious and in public have stated that it is not being scheduled because of “insufficient evidence”. To be more specific Cadw have stated to me that they “did not feel able to recommend the structure for scheduling since the action would require Cadw to state with confidence that it is a prehistoric structure and as you yourself have noted ….. – this has not yet been proven.”
So there we have it, on the one hand Cadw can state with confidence that the scheduled standing stones are all prehistoric despite the lack of any supporting evidence for most of them whilst at the same time refuse to schedule a stone alignment despite an abundance of evidence and all of it pointing one way. The duplicity of this position highlights a fundamental problem with the way in which Cadw selects monuments for protection. It would not be an exaggeration to describe it as an utter shambles, lacking any rigour or consistency resulting in a system where contradictory and unsubstantiated decisions have become the norm.
Prehistoric standing stones inconveniently do not come complete with their original dates inscribed on them. Despite this Cadw can confidently tell without any evidence which ones are prehistoric or not. Perhaps they have a time-machine parked up outside their offices!