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PPS15 Draft Consultation - ex-archaeologist - 31st August 2009
I was going through the draft PPS yesterday when I noticed this, which no one seems to have commented on on the previous forum.
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.
Does the first sentence imply that DBA's and Evals should only be required if archaeological remains are already known on the application site? Surely something like 'risk', 'possibilty', 'probability', 'clear potential' or 'likelyhood' of remains being present should be inserted into this somewhere, otherwise it will represent a considerable watering down on present practice.
PPS15 Draft Consultation - kevin wooldridge - 31st August 2009
I think the inference is that the archaeological potential of any given area should already have been picked up in the local development plan and through the HER. This potential might be unproved, but at least recognised.
I can't see that this is a watering down of the current system because that is precisely the process that the current system uses (unless there is a local authority somewhere that relies on more 'spiritual means' of identifying archaeological potential).
PPS15 Draft Consultation - ex-archaeologist - 31st August 2009
I wasn't suggesting that the proposed system of DBA, Eval, Mitigation and Deposition, waters down the present system, indeed as you rightly point out Kevin, that is current practice. My concern is the wording seems to imply that it is only required when archaeological remains already known on the proposed development site, rather than that the local HER records 'archaeological potential' for the site.
I hope that you are right Kevin and that potential is inferred, I would gladly be proved wrong. Ultimately this will be interpreted by planners, developers and lawyers.
PPS15 Draft Consultation - BAJR Host - 31st August 2009
This is a point which I would like to explore.. What is the concept about 'potential' ? where is the definition... we wander down the wooly road again.. and there lies dispute and wriggle space!:face-confused:
PPS15 Draft Consultation - kevin wooldridge - 1st September 2009
The problem is: look at the alternative. If archaeological remains are definetly known on a site without further testing it suggest that such remains have been excavated or uncovered at some past date and therefore have probably been afforded some form of protection. Short of excavating every site of archaeological 'potential' to prove or disprove the surmise, I dont see how we can ever have a situation other than one of uncertainty. And therefore the evaluation sceanrio through DBA and test-excavation remains the primary tool of initial planning guidance.
PPS15 Draft Consultation - BAJR Host - 1st September 2009
Kevin Wrote:short of excavating every site of archaeological 'potential' to prove or disprove the surmise, I dont see how we can ever have a situation other than one of uncertainty
There fore the concept remains that arguing what is potential lies at the heart of this. Potential is therefore an area where there is no known archaeology, but based on a best guess it may be there... was there somewhere that looked at teh percentage of developments with conditions including archaeology, and the number that went to full archaeological mitigation?
:face-huh:
PPS15 Draft Consultation - Weegie - 1st September 2009
The PPS is intended to be a series of statements of principle, so inevitably it will be a bit woolly in places. The key here is whether the supporting guidance document explains adequately what this will mean in practice. The guidance document is out for consultation as well, and I imagine that our curator chums having been going through it with a fine toothcomb.
Brian
PPS15 Draft Consultation - BAJR Host - 1st September 2009
I indeed hope that too!
For reference
PPS
http://www.communities.gov.uk/publications/planningandbuilding/consultationhistoricpps
PPS Practice Guide
http://www.english-heritage.org.uk/server/show/nav.21136
As they say
Quote:Though the PPS itself will have primacy, the Practice Guide will carry governmental weight and be enforced as such. This is no different to the situation with PPGs15 and 16, except that policy and guidance are clearly separated, making the documents easier to use and understand.
PPS15 Draft Consultation - BAJR Host - 1st September 2009
david Wrote:Policy HE6: Monitoring indicators
25. Ensuring effective delivery is fundamental to the process of producing plans. Authorities will find that plans with clear historic environment objectives, targets and performance indicators will deliver more effective outcomes. Local authorities might usefully seek ways of measuring how changes, positive and negative, to the historic environment compare to economic and social changes, particularly in those settlements and/or areas undergoing change either through regeneration or growth.
Here is an example of trying to quantify the unquantifiable... do performance indicators work on a relative resource.. is recovery or 8 sherds of pottery more or less important than 16 coins? is a bronze age round house worth 2 iron age round houses? having a clear historic environment objectives, targets and performance indicators would be lovely IF people actually had that. I have yet to see a coherent and nationally accepted set of criteria for this. correct me if i am wrong.
:face-huh:
PPS15 Draft Consultation - vulpes - 4th September 2009
With respect David you're wrong - or rather you've got the wrong end of the stick here. Performance indicators are already used with respect to the Historic Enviornment in terms of e.g. the 'assets' referred to in the annual heritage at risk surveys published by our EH chums. These provide a breakdown of listed buildings; Conservation Areas and Secheduled Monuments at risk by local authority area. The PPS is suggesting that Local Authorieties should in future seek toi further engage with this process by (as far as possible) giving and indication of the condition (and sometimes loss) of non-nationally designated heriatge assets i.e. locally listed buildings and non-scheduled archaeological sites. It is not an invitation to measure the unmeasurable.