DBA, method statement, project design

[Unitof1]

In peepeeG the statement is particularly intended for work for diggers -excavation ....so why dont they just say so and why is it being applied to watching briefs or evaluations?

“30. In cases when planning authorities have decided that planning permission may be granted but wish to secure the provision of archaeological excavation and the subsequent recording of the remains, it is open to them to do so by the use of a negative condition i.e. a condition prohibiting the carrying out of development until such time as works or other action, e.g. an excavation, have been carried out by a third party.”

Not finding it in the section after the hole is dug

And warming up the Barker principle of EIA before development consent can a watching brief mitigation which might find significant archaeology be an assessment of the impact. I think that you cant have a watching brief until there has been an evaluation more work for diggers, or a dba -.

leading question: can public inquires be seen as a part of the “development consent” process

[1man1desk]

A watching brief cannot be an assessment of impact - which is why it is never put forward as such. It is put forward instead as a mitigation method, which follows both the assessment and the subsequent decision to grant consent.

Assessment of impact, however, does not necessarily depend on evaluation, and not all evaluation necessarily means trial excavation. If you have done a desk-top and walkover survey that concludes that there is very little chance of any archaeology being present, it can be hard to justify carrying out something as onerous as a trial excavation. Depending on circumstances, you might go for no further action, or for a watching brief as a sort of 'back stop'.

Of course, there is no clear dividing line, just a big grey area, and how you make the decision depends on all sorts of case-by-case factors. Also, there are other options (e.g. geophysics) that you might put in place before deciding on whether or not to go for trial excavation.

Having said that, if you do know there is archaeology there, you have to have a very good reason before choosing watching brief as the principal method of mitigation.

1man1desk

to let, fully furnished

[Unitof1]

“If you have done a desk-top and walkover survey that concludes that there is very little chance of any archaeology being present, it can be hard to justify carrying out something as onerous as a trial excavation.”

Onerous excavation -not to me mate, bread and butter for diggers.

I would suggest that if they went straight for evaluation without all the flaffing with desk-tops and “walkover survey” (not sure that there are any standards for that or for geephiz) it would be cheaper for the client and we would end up with an archive (and get rid of the consultants ish).

“it can be hard to “justify” carrying out” - peepgee has evaluation written all over it.

[geodan]

Walkover survey and geophysical survey are both methods of evaluation and as such there are standards, both general and specific, drawn up by the IFA and EH.

Plus, if these methods of evaluation are carried out post determination then a WSI stating the standards to which a contractor will adhere will have been agreed with the planning archaeologist. Some sensible companies may even discuss/consult with planning archaeologists before carrying out pre-determination evaluation.

If you were questioning the value of DBA's or walkover survey as standalone techniques for determining the presence/absence of subsurface archaeology, then I might agree.

You seem to suggest that archaeologists should roam across the countryside strapped to the back of 360s blindly digging holes wherever a large scale development is proposed without any knowledge of the setting or past land use of the area affected?

Also, the idea that progressing straight to widescale evaluation trenching would work out cheaper for a client than producing a DBA and conducting non-intrusive types of evaluation, which subsequently inform the need for trenching, their position and the total area investigated is questionable.

As to your final point - the thrust of PPG16 is preservation in situ or otherwise by record, not trenches, trenches, trenches.

Happiness depends on ourselves.

[1man1desk]

Posted by Unit of 1:

quote:I would suggest that if they went straight for evaluation without all the flaffing with desk-tops and “walkover survey” (not sure that there are any standards for that or for geephiz) it would be cheaper for the client and we would end up with an archive (and get rid of the consultants ish).

“it can be hard to “justify” carrying out” - peepgee has evaluation written all over it.

This is what PPG16 actually says about desk-based assessments:

quote:[the developer] may wish to commission their own archaeological assessment by a professionally qualified archaeological organisation or consultant. This need not involve fieldwork. Assessment normally involves desk-based evaluation of existing information: it can make effective use of records of previous discoveries, including any historic maps held by the County archive and local museums and record offices, or of geophysical survey techniques.

And this is what it says about evaluations:

quote:Where early discussions with local planning authorities or the developer's own research indicate that important archaeological remains may exist, it is reasonable for the planning authority to request the prospective developer to arrange for an archaeological field evaluation to be carried out before any decision on the planning application is taken. This sort of evaluation is quite distinct from full archaeological excavation. It is normally a rapid and inexpensive operation, involving ground survey and small-scale trial trenching

In other words, PPG16 explicitly advises both DBA and geophysical survey as preliminary steps before deciding on evaluation, and does not limit evaluation to trial trenching - it includes surveys. It also says that evaluation should be 'rapid and inexpensive', and limits its application to circumstances where other information already suggests that important archaeological remains are present.

In practice, trial trenching is often applied on a 'scatter-gun' approach, where there is no real information suggesting that anything is there. Also, it can be very far from 'rapid and inexpensive' - I know of evaluation programmes that have taken months and cost well over £100,000, causing great disruption to local farmers who stood to gain nothing from the development. Thats what I meant by 'onerous' in my previous post.

A few years ago I arranged the evaluations for a road scheme that crossed a county boundary. On one side, the curator wanted a fixed-size sample arranged randomly, ignoring geophysics results. On the other side, by agreement with the curator, we used previous information (including geophysics) to target our trial trenches. With a sample about half the size in % terms, we found more than twice as much archaeology.

Looks to me like using more than one source of information improves your archaeological results as well as helping your client, and is specifically mandated by PPG16.

In terms of standards - the IFA publishes a Standard and Guidance for Desk-Based Assessments, and one for Evaluations that covers things like geophysics as well as trial trenching.

All of this information is really very easily available - you really ought to go and read the documents before you quote them.

1man1desk

to let, fully furnished

[beamo]

1m1d's post has demonstrated some of the 'issues' that are thrown up by PPG16, and why a reformed PPS is now required (roll on thr Heritage White Paper).

Yes - PPG16 does say 'Where early discussions with local planning authorities or the developer's own research indicate that important archaeological remains may exist, it is reasonable for the planning authority to request the prospective developer to arrange for an archaeological field evaluation to be carried out before any decision on the planning application is taken.'

However, for many local authorities the requirement for evaluation is not that research has demonstrated the potential for important archaeological remains to exist, it is actually that the research (DBA / geofizz / whatever) has not been able to demonstrate that important archaeological remains do not exist within the proosed development area, especially for larger development sites.

I.e. the onus is on the applicant to prove that significant remains are not present or that impacts can be mitigated adequately, rather than on the curator to demonstate that significant remains are present. This is a logical response and in many cases is the only way to ensure real progress towards identifying the presence of remains, but is not in line with PPG16.

Developers with keen legal advisers can use this to their advantage. I recently completed a DBA for a large development in the open countryside that concluded that there were no known significant archaeological remains present. the curator then requested an evcaluation, pointing out quite rightly that there had actuially noit been any development in this area (or even any ploughing as it was all pasture) that would have resulted in the discovery of artefacts or archaeological remains. The developer claimed that this was not in line with PPG16 as the DBA had not identified any potential for the presence of significant remains and therefore evaluation could not be justified. Fortunately PPG16 does allow for further non-intursive research beyond DBA (such as geofizz) and therefore this can be justified. However, if the geofizz is negaitive then it may be harder for the curator to insist on evaluation.

The principal issue is whether or not the applicants have provided sufficient information on the potential presence (and nature, date, extent, etc) of archaeological remains for the plaqnning authorities to make an informed decision on determination and mitigation, but the PPG does not give this adequate emphasis.

I have also been involved in developments where the applicants have tried to resist extensive evaluations on the grounds that PPG16 refers to evaluation as being 'normally a rapid and inexpensive operation'. The get-out word here is 'normally' but this leaves the curator in the position of having to justify why they feel that the proposed development site is abnormal to the extent that it requires expensive and time-consuming evaluation. Again this is a problem within PPG16, not (well, not often) an issue of curators being over-zealous.


Beamo

[Unitof1]

I have found fieldwalking/geephiz named in ifa evaluation standards in an appendix- hardly a standard for fieldwalking and I suspect the term “walkover” of being consultant speak for a site visit by a consultant who will do an impression of “field scanning”. I would suspect that very little archive is produced. (fieldwaking on pipelines now theres a standard...)

“the idea that progressing straight to wide scale evaluation trenching would work out cheaper for a client than producing a DBA and conducting non-intrusive types of evaluation, which subsequently inform the need for trenching, their position and the total area investigated is questionable.”

The clients will always get cheap archaeology because of the competitive market-we dont have to worry about that! The problem is that the standards of all conditions are set are so low that we get crap archaeologist confused with pointless and inadequate conditions (and none at all) masquerading as archaeology set by the authorities.

As 1mans peepeeG says. “This sort of evaluation is quite distinct from full archaeological excavation. It is normally a rapid and “inexpensive operation”, involving ground survey and small-scale “trial trenching”

Somewhere along the line everybody has decided that “inexpensive” is “expensive”

“DBA and conducting non-intrusive types of evaluation” are absences of evidence methods of assessments and I from an earning a living from digging point of view dont see them as “archaeology”. I see bagging contexts with a trowel in a trench as archaeology and am willing to accept that as mitigation if needs be.....not another DBA document in the HER

As 1man has pointed out desktops in peepeeG is a product devised for the developer to use (for assessment of potential cost liabilities and they should have got it done before they bought the land and used it to haggle the price) rather than a request from a curator, as a form of mitigation, who is trying to get out of placing a full and juicy condition on the consent after having had a full and juicy evaluation. All the flaffing is about second guessing what the curators might put on which is where we work out the cost of the archaeology for the client.

Does a curator need a desktop? peepeeG intends them for the developer I feel a Standard coming on -something like an absence of evidence is a requirement for evaluation trenches -Beamo

Say NO to post determination watching briefs without a full evaluation

Preservation in situ- I have been on one too many sites where the preserved area was used to put all the services and soakaways through

"A few years ago I arranged the evaluations for a road scheme that crossed a county boundary. On one side, the curator wanted a fixed-size sample arranged randomly, ignoring geophysics results. On the other side, by agreement with the curator, we used previous information (including geophysics) to target our trial trenches. With a sample about half the size in % terms, we found more than twice as much archaeology."

there is no hope

[1man1desk]

So, as far as I can tell from the logic of your argument:

- no planning permission for any development anywhere should be given without an intrusive trial excavation;

- no existing information on the presence/absence of archaeology, its nature or its layout should be taken into account in deciding whether to trial trench or in designing the trench layout;

- no archaeological information that comes from sources other than digging a hole is worth considering.

Have I got it right?

If so, to quote your own comment - there is no hope.

1man1desk

to let, fully furnished

[troll]

I think its fair to say that the dialogue here is an excellent example of just why "modern, professional UK" archaeology is in such a state.Thankyou to all who contributed on this thread-its been superbly informative.My motivation for placing this thread has been the many commercial units I have worked for who are essentially a paperwork-free enterprise,i.e, reports cost money so to be competative and win the contract-they don`t do any.At all.I think both the main contributors on this thread are right-there is no hope.Archaeology as a discipline has been hijacked by pseudo-legal language that allows everyone to do as they please in order to make a profit.So....whats the next step? Do we give up and allow the finite resource to be bent over on a daily basis claiming that optional standards are adequate and policed or....do we do something pro-active?:face-huh:

..knowledge without action is insanity and action without knowledge is vanity..(imam ghazali,ayyuhal-walad)

[Unitof1]

On the grounds that Rescue still applies more than ever before you keep digging and fight to your last breath the parasites that don’t think that there is anything there worth looking for.

So, as far as I can tell from the logic of your argument:

- no planning permission for any development anywhere should be given without an intrusive trial excavation; Yes- unless its scheduled

- no existing information on the presence/absence of archaeology, its nature or its layout should be taken into account in deciding whether to trial trench or in designing the trench layout; Any white space on the map has to be systematically at an adequate sample evaluated by trench-anything “known” should be excavated.

- no archaeological information that comes from sources other than digging a hole is worth considering. It is not worth considering if it in any way it reduces the requirement to evaluate by trench

putting the field back into field archaeologist