Archaeological Survey Planning Requirements

[Ferdinand]

Are archaeologists bidding for more archaeology on even modest projects?

I came across this requests (excerpted) from the Derby County Cuoncil archaeologist, which includes a request that that analysis, publication and dissemination be included as part of a "modest" "monitoring" process - presumably at the cost of the developer.

This is for a development of 2 dwellings and one building conversion in a former farmyard on the possible edge of a medieval village centre.

Quote

...There is consequently some potential for below-ground archaeology in the proposal area,
relating to the medieval village. Historic map evidence suggests that there were two buildings of
unknown date and function present within the proposal site, present in 1880, but demolished by 1900
when they were replaced by the building now proposed for conversion. It is likely that below-ground
remains of these buildings also survives within the proposal site.
I recommend that the modest archaeological potential outlined above is best addressed through
archaeological monitoring of the development groundworks (watching brief), secured by a planning
condition in line with NPPF para 141. The following condition should therefore be attached to any
planning consent:

* No development shall take place until a written scheme of investigation (WSI) for
archaeological monitoring has been submitted to and approved by the local planning authority
in writing. For land that is included within the WSI, no development shall take place other than
in accordance with the agreed WSI, which shall include the statement of significance and
research objectives; and:

* The programme and methodology of site investigation and recording and the
nomination of a competent person(s) or organisation to undertake the agreed works

* The programme for post-investigation assessment and subsequent analysis,
publication & dissemination and deposition of resulting material. This part of the condition shall
not be discharged until these elements have been fulfilled in accordance with the programme
set out in the WSI.

http://planning.bolsover.gov.uk/WAM/doc/Consultee Comment-2057383.pdf?

I have not seen this before. Is this unusual?

Leaving aside that the comment is a little ungrammatical, the Council appear to have ignored it as there is no Condition relating to Archaeology.

The Bat Men are engaged, however.

http://planning.bolsover.gov.uk/WAM/doc/Decision-2068853.pdf

Ferdinand

 

[Ferdinand]

As a rider, can one erquest an estimate of the cost of carrying out a condition from the person proposing the imposition?

Has it been tried?

Does that meet the 6 tests required of a Planning Condition:

Quote

“Planning conditions should only be imposed where they are:

1. necessary;
2. relevant to planning and;
3. to the development to be permitted;
4. enforceable;
5. precise and;
6. reasonable in all other respects.”

The policy requirement above is referred to in this guidance as the six tests.

http://planningguidance.communities.gov.uk/blog/guidance/use-of-planning-conditions/application-of-the-six-tests-in-nppf-policy/

Ferdinand

 

[Jeremy Harris]

The "reasonable in all other respects" point seems to be ignored by planners with monotonous regularity. 

I'm a reasonable person, who probably regards sensible protection to archaeologically significant items, nature conservation etc as being a higher priority than many, but if I were faced with a site where something like this was likely to be included as a planning condition (and here in Wiltshire you can hardly stick a spade in the ground anywhere without finding a bit of worked flint),  then I'd be inclined to just get an excavator in and level the site down to foundation base level before submitting a planning application.

We've been seeing people do this with trees, to avoid getting hit with TPOs and expensive tree protection measures at the instigation of objectors, and I'm sure that some try to avoid getting hit with ecological survey costs by removing potential habitats before making an application.

If the "reasonable in all other respects" bit was applied then we'd probably have better real protection to archaeology and ecology, IMHO.

[curlewhouse]

Glad I saw this because I'm in a similar position with having to subsidise that level of detail - unfortunately though our planners seem to love anything that adds cost to the householder so they have adopted this, and the quotes I've received from archaeologists so far make me believe they all think they are Howard Carter! (or possibly Indiana Jones in their dreams - certainly from the level of quotes I may well be subsidising a major motion picture). 

 

One even quoted me for him taking transport from his house back and forth to the county archives to research the village before he even comes to do the "work", carbon dating is included , also  paying for "publication and dissemination" of their work!   This all supposedly under the heading of a "watching brief" on the one day we dig. A "watching brief" would be fine with me, but the potential in what they actually specify is without exaggerating tens of thousands of pounds.  I think we'd have a damn good argument that this would not be "reasonable", but experience so far has told me that our planning dept are not open to negotiation or discussion - there's a real power trip going on in there.

 

I am confident there is nothing to dig up though because to make it all even sillier, my site has actually even had a proper archeological dig done on it about 5 years ago, which found nothing apart from a couple of shards of medieval pottery, which you will find absolutely anywhere you dig at all....... and that proper dig was part of an entire village survey, (so our plot was just a random bit of ground as we offered to let them dig there if they wanted, not because of any significance or likely significance)  paid for by the very same National Park who now specify almost £2k of "work" for an archaeologist to look in on 1 days worth of digging! (sloping site will take 1 day to level so my founds will actually be below archeological depth, confirmed by the planners archeologist himself, so it's only the site clearance these people are needed for thank God).  But this:  

5. precise and;

6. reasonable in all other respects.”

Gives me hope because clearly it is not reasonable to expect people to pay for research into the whole village (yep, that's included in some of the quotes as the brief sort of indicates it) - to add to the lunacy, this research has actually already been done.... by the National Park themselves at the time of the dig and they produced a rather excellent file where they interrogated the county archives fully and produced a fascinating 100+ page document with masses of the archives and old maps etc (all of which show nothing on our bit of field) and an entire history of the village. So it's actually already done (though expecting a self builder to pay for an entire history of a village to be researched would not "reasonable" anyway by any sensible standard I would say) but they want me to pay for it to be done again! Madness.

 

I felt it was obvious from the similarities in some of the quotes that the archeological practises are familiar with our National Parks attitude towards self builders and these parties very clearly know they are in a position of power by proxy and can financially exploit it. 

 

Like JH, I'm all for a sensible overwatch and care, in fact having grown up in the village and planning come back and to see my days out there now, I would say I care for the history of the place far more genuinely than any office wallah frantically looking for ways to exercise power.

 

The charges for "written scheme of investigation (WSI) for archaeological monitoring has been submitted to and approved by the local planning authority
in writing. For land that is included within the WSI, no development shall take place other than in accordance with the agreed WSI, which shall include the statement of significance and research objectives..." should in fact be very low (they are not -  quotes £100+ on top of the £250 per day) because in reality, that will be a cut-and-paste exercise for the archaeologist as very little will vary from building site to building site in that respect. It is interesting also that "watching brief" has somehow morphed into  an entire research project with "research objectives".  It's a hell of a leap.  

 

It looks very like archaeologists providing work for other archaeologists rather than a sensible watching brief.  I would suggest for a genuine "watching brief" the "written scheme of investigation" In reality only needs to say "stand with hands in pockets whilst watching the digger, shout STOP and look in the hole if something interesting appears." ! 

 

How I wish I had just levelled the site before we put in the planning application - there was absolutely nothing stopping us doing so, but we did not forsee we'd be told we had to fund a "research project" - I mean it's so insane and wasteful that it just wouldn't occur to you..

 

 

[Ferdinand]

Perhaps you could remind them what happened to George Edward Stanhope Molyneux Herbert, 5th Earl of Carnarvon .

 

[PeterW]

11 minutes ago, curlewhouse said:

In reality only needs to say "stand with hands in pockets whilst watching the digger, shout STOP and look in the hole if something interesting appears."

 

I know of a local site where the archeologist was marched off site after he refused to wear high vis and PPE - site manager eventually got the local HSE guy to come over as he was concerned the guy was putting his team at risk ..! 

 

Apparently at one point he jumped into a trench with a 13T excavator boom a foot away from his head ...

 

And I thought dealing with bats was hard enough ..!

[curlewhouse]