Have I missed something?
Consultation on draft PPS 15 ends 30th October, but there seems to have
been little discussion of what apopears to be a threatening weakening of the
protection offered by PPGs 15 & 16.
I have been trying to avoid getting involved, but I was browsing the
unconscionably long draft last night and noticed (inter alia) the apparent
assumption that assessment and evaluation are the same in terms of the lead-
up to an application being considered.
The specific reference that raised my eyebrows was HE7.2 "Where a
development site includes heritage assets with an archaeological interest,
local planning authorities should require developers to carry out appropriate
desk-based or field evaluations as part of any application for consent. They
should refer to the results of these evaluations when determining the design
of the proposed development. A copy of the outcomes of such evaluations
should be deposited in the relevant historic environment record."
Aside from the extremely unimaginative and worrying implicit assumption that
archaeology is only below ground, and does not continue upwards, there is
the real potential for planning authorities and developers to claim that a desk-
based 'evaluation' is the same as a 'field evaluation'. The former should either
lead to the need for the latter, or not, but it certainly does not replace it.
The weasel word is 'appropriate' which is lawyer-speak, and will mean different
things to different people. The principal beneficiaries will be the same lawyers,
busy trying to prove at enquiries that their own interpretation of 'appropriate'
is the correct one.
I am also disturbed by the use of 'should' rather than 'shall' throughout the
document. It was the appropriate (oops) form of the verb in a guidance note,
but in a statement the opt-in/opt-out potential ought really to be removed.
As somebody who fought hard in the 1970s and 1980s to bring archaeology
(which I don't consider ends at ground level) into the serious material
considerations of planning and decision-making, I sense a weakening of
protection rather than a strengthening. The 'grading' of importance of sites is
an area in which much of significance is going to be destroyed because people
will argue that local significance is not sufficient reason for preservation in
whatever form. I can think of examples in my own history that would have
been destroyed in this way.
Finally, there is an arrogance about the assumption that we today (whichever
today that may be) are always right in our assumptions about the importance
of a particular type or class or form of 'monument'. In my career I have been
told to 'ignore the medieval and get down to the Roman - that's the important
bit' when we had happily ploughed through any evidence for the important
ECW deposits let alone later ones. I have watched Crown Properties carrying
off the original decorated-tile floors of the castle in Gloucester, and I have
seen hundreds of acres of land disappear under housing with little or no
protection for the archaeology.
I have argued with colleagues who dared to say that all that is needed for a
battlefield is a monument saying that this is where it happened, and have
been vilified for daring to suggest that planting trees as 'community
woodlands' or the 'national forest' is potentially to the detriment of
archaeology. Those same people now shout support for the Battlefields
Register and the protection of battlefields or the need for archaeology to be a
consideration when tree planting.
It is not that I am all-knowing (far from it - I have my own failures), or that
they have been ignorant or stupid, but rather that we need to make reasoned
and sensible decisions about the security of our archaeological heritage which
recognises that we can not possibly retain it all, but most importantly allows
the destructive decisions to be taken wisely and from a position of knowledge -
or at least the best knowledge we can offer.