Just when you thought it was safe to go back to the Fens.... It spreads.

[Digger]

Just to inform all, Sandwell MBC has decided to remove its commitment to Archaeology and make redundant both Borough Archaeologist and HER Officer. The Director of Planning has informed me that the council will no longer exercise any responsibility for any archaeology that may be unearthed during future development or by any other reason. Within the Equality Impact Assessment recommending the redundancies it states: "The functions are not core services to the planning service and could almost be considered luxury."

Regards,XXXXXXXXX

[BAJR]

RESCUE has learned that Sandwell Municipal Borough Council is planning to axe the posts of Borough Archaeologist and the HER Officer. This will leave the Borough without any provision for archaeological monitoring of planning applications and no Sites and Monuments Record. Archaeology is, it seems, considered a ‘luxury’.

http://docs.google.com/viewer?a=v&q=cach...grYwkBjQ5w

Please take time to e-mail the Council members responsible with your arguments for the retention of the two posts and if you have friends, colleagues or family in the West Midlands please encourage them to do the same. RESCUE’s letter will be published on their website in due course.


The document (link above) states

5. WHAT ACTIONS CAN BE TAKEN TO MITIGATE ANY ADVERSE IMPACTS?

There are no adverse impacts identified on service delivery.

The impact on the individual will sought to be mitigated by the actions identified below. (ie offering them vacant posts within the council - as if there will be ones for out of work archaeologists!)

[BAJR]

2. EVIDENCE USED/CONSIDERED

A ‘posts’ rather than ‘people’ approach was used to identify the future human
resource requirements needed to support those activities that will still be
required by the Regeneration and Economy Directorate to provide a frontline
service. This approach is in line with the Councils equality of opportunity
policies and follows the principles central to the Council’s single status and
recruitment and selection processes.

In identifying these posts the impact of not undertaking these functions was
considered against what is required to deliver a planning service for the
community of the Borough and the development industry. The impact of
stopping doing these parts of the service will have no impact on front line
service.

Before the decision was made any necessary regulations or guidance notes
relating to the Planning Service were reviewed to examine whether or not
any of the services that are subject to the action of this report or not are
required to be undertaken under statute they are not. The functions
identified are not core services to the planning service and could almost be
considered to be a luxury.

could almost? OR has been decided to be?

[Marcus Brody]

I'm not condoning or supporting this decision in any way, but in strictly technical terms, the statement that the Council has no statutory duty to deal with archaeology is probably correct. As has been pointed out in various threads, archaeology is covered by documents that are couched in terms of 'guidance' and 'policy', rather than being laws. In relation to this, however, it's worth noting that the Draft Policies for Consultation document, which was only issued by Sandwell MBC in March of this year, contains the following draft policy for dealing with archaeology and development proposals (apologies, it's quite long):

Draft Policy - Archaeology & Development Proposals
In Areas of Potential Archaeological Importance (APAI) and any other areas where the Council considers there to be archaeological potential, the local planning authority will require archaeological information (derived, if necessary, from an archaeological evaluation), prior to the determination of planning applications. This information will be needed to assess the archaeological implications of the development proposals and to identify requirements for archaeological preservation or investigation.

Referral of applications for development will also disclose sites or areas where archaeology or conservation is necessary before redevelopment or demolition is permitted to take place.

In considering proposals for development, the Council will seek to ensure that special heritage assets of national or possibly high regional importance are identified as being particularly worthy of preservation in situ. Other heritage assets will be preserved wherever possible, but where it would be unreasonable to withhold planning permission for the development of such sites, provision will be made through agreements and conditions of planning permissions for an appropriate level of archaeological evaluation and recording (preservation by record), prior to damage or destruction through development.

It is essential that heritage assets and their settings are preserved and enhanced so as to fully exploit their archaeological, recreational and educational value, and, where appropriate, made attractive to visitors.

Prospective developers are encouraged to consult the Council and the Historic Environment Record in advance of submitting planning applications whether they are in an Area of Potential Archaeological Importance or elsewhere.
Areas of Potential Archaeological Importance and specific sites and areas beyond the APAI have been identified within the Borough. Each area fulfils one or more of the following criteria:
- Ancient structures, either buildings or earth works, are visible or have been located by excavation, or objects have been found by chance or by deliberate search;
- Early settlement or other activity is indicated by written documents or maps;
- There has been little ground disturbance through earthmoving, mining or similar activities, so that archaeological features as yet unknown might be expected to be preserved.

The principal reasons for the rapid growth of the urban areas of the Borough were the mining and industrial activities of the 18th, 19th and 20th centuries. The area became one of national industrial importance. Although the legacy of dereliction, pollution and poor building should be removed where possible, it must be recognised that this also includes heritage assets of significance. Most of these are undesignated. Under existing criteria, much of this heritage is not recognised as being of sufficient national historic, archaeological or architectural importance to merit statutory protection; but Areas of Potential Archaeological Importance will be identified by continual local monitoring and assessment of relevant information sources, including the Sandwell Historic Environment Record, where information is consolidated and recorded.

The Historic Environment Record or HER is a record of all known sites and monuments of archaeological and historical importance in the Borough of Sandwell. It links archaeological sites with studies, evidence, finds and includes buildings and structures, demolished and extant. The HER is a resource for students, Archaeological/Conservation Consultants or the interested public. In conjunction with this, the library accumulated for the compilation of data is also available as a source for further studies. The record is sometimes called the Sites and Monuments Record (SMR). It records the archaeology of the Borough from its earliest prehistoric remains through to recent time

The boundaries of these areas may be modified and further areas and sites may be identified, as more archaeological information becomes available. The Council will be able to give up-to-date advice on the extent of the areas of archaeological importance and the integration of the preservation of archaeological deposits with other land uses; achieved by means of management agreements.

This is defined in terms of Policy ENV2 of the Black Country Core Strategy, which protects Historic Character and Local Distinctiveness, and as you'll see, it makes several references to dealing with archaeology and the HER. It'd be worth asking the Council what's changed in the last six months to so radically alter their policy, given that they were so keen on archaeology six months ago. It'd also potentially be worth asking how their decision sits with Policy ENV2, and indeed National planning policies.

[BAJR]

Damn but you are good Marcus!

That is very useful reading.

And that said - YEs I am still pursuing Cllr Melton through a full complaints procedure...!

And perhaps we should get onto this as well. ask questions - require answers... exchange information and don't accept stock replies.

[Marcus Brody]

Have managed to track down policy ENV2 of the Black Country Core Strategy, which was adopted by Sandwell MDC on the 3rd of February this year. Again, it's a long and densely-written piece of work, but it makes all the right noises about protecting 'historic assets', including archaeological sites, and has a sizeable section justifying this policy in terms of the rich and diverse historic environment of the Black Country as a whole.

I realise that documents like this are not particularly exciting, and I wouldn't suggest that anyone would want to read them for fun, but I think it's always pretty embarrassing for a Council to have it pointed out to them exactly which of their own policies they're failing to adhere to, as it suggests that the people making the decisions don't actually know what the Council's policies are. In this instance, the Black Country Core Strategy covers four Councils, so it's potentially particularly embarrassing for Sandwell as it could be viewed as breaking its agreement with Dudley, Walsall and Wolverhampton Councils to have a common policy framework across the whole Black Country area.

Anyway, Policy ENV2 is below. Enjoy!

ENV2 Historic Character and Local Distinctiveness
Spatial Objectives
Environmental transformation is one of the underpinning themes of the Vision which requires a coordinated approach to the protection and enhancement of the built and natural environment (p18). The protection and promotion of the historic character and the areas local distinctiveness is a key element of transformation and in particular helps to deliver Spatial Objectives 3, 4, 5 and 6 (p19-20).

Policy
All development should aim to protect and promote the special qualities, historic character and local distinctiveness of the Black Country in order to help maintain its cultural identity and strong sense of place. Development proposals will be required to preserve and, where appropriate, enhance local character and those aspects of the historic environment together with their settings which are recognised as being of special historic, archaeological, architectural, landscape or townscape quality.

All proposals should aim to sustain and reinforce special character and conserve the historic aspects of the following locally distinctive elements of the Black Country:
a) The network of now coalesced but nevertheless distinct small industrial settlements of the former South Staffordshire Coalfield, such as Darlaston & Netherton;
b) The civic, religious and commercial cores of the principal settlements of medieval origin such as Wolverhampton, Dudley, Wednesbury & Walsall;
c) Surviving pre-industrial settlement centres of medieval origin such as Tettenhall, Aldridge, Oldbury and Kingswinford;
d) Areas of Victorian and Edwardian higher density development which survive with a high degree of integrity including terraced housing and its associated amenities;
e) Areas of extensive lower density suburban development of the mid 20 th century including public housing and private developments of semi-detached and detached housing;
f) Public open spaces, including Victorian and Edwardian municipal parks, often created upon and retaining elements of relict industrial landscape features;
g) The canal network and its associated infrastructure, surviving canal-side pre-1939 buildings and structures together with archaeological evidence of the development of canal-side industries and former canal routes (see also Policy ENV4);
h) Buildings, structures and archaeological remains of the traditional manufacturing and extractive industries of the Black Country including glass making, metal trades (such as lock making), manufacture of leather goods, brick making, coal mining and limestone quarrying;
i) The Beacons shown on the Environment Key Diagram and other largely undeveloped high prominences lying along: the Sedgley to Northfield Ridge, including Sedgley Beacon, Wrens Nest, Castle Hill and the Rowley Hills (Turner’s Hill);
the Queslett to Shire Oak Ridge (including Barr Beacon);
including views to and from these locations.

In addition to statutorily designated and protected historic assets particular attention should be paid to the preservation and enhancement of:
locally listed historic buildings and archaeological sites;
historic parks and gardens including their settings;
locally designated special landscape areas and other heritage based site allocations.

Development proposals that would potentially have an impact on any of the above distinctive elements should be supported by evidence included in Design and Access Statements which demonstrates that all aspects of the historic character and distinctiveness of the locality have been fully assessed and used to inform proposals. In some instances local authorities may require developers to undertake detailed Historic Landscape Characterisation studies to support their proposals.

Justification
6.6 The Black Country has a rich and diverse historic environment which is evident in the survival of individual historic assets and in the local character and distinctiveness of the broader landscape. The geodiversity of the Black Country underpins much of the subsequent development of the area. The exploitation of abundant natural mineral resources, particularly those of the South Staffordshire coalfield, together with the early development of the canal network, gave rise to rapid industrialisation and the distinctive settlement patterns which characterise the area.

6.7 Towns and villages with medieval origins survive throughout the area and remain distinct in character from the later 19 th century industrial settlements which typify the coalfield and gave rise to the description of the area as an ‘endless village’ of communities each boasting a particular manufacturing skill for which many were internationally renowned.

6.8 Beyond its industrial heartland, the character of the Black Country can be quite different and varied. The green borderland, most prominent in parts of Dudley, Walsall and the Sandwell Valley, is a largely rural landscape containing fragile remnants of the ancient past. Undeveloped ridges of high ground punctuate the urban landscape providing important views and points of reference which define the character of the many communities. Other parts of the Black Country are characterised by attractive well treed suburbs with large houses in substantial gardens and extensive mid 20th century housing estates designed on garden city principles.

6.9 This diverse character is under constant threat of erosion from modern development;, some small scale and incremental and some large scale and fundamental, and as a result some of the distinctiveness of historic settlements has already been lost to development of a “homogenising” character. In many ways the Black Country is characterised by its ability to embrace change, but future changes will be greater and more intense than any sustained in the past. Whilst a legislative framework supported by national guidance exists to provide for the protection of statutorily designated historic assets the key challenge for the future is to manage change in a way that realizes the regeneration potential of the proud local heritage and distinctive character of the Black Country.

6.10 To ensure that historic assets make a positive contribution towards the wider economic, social and environmental regeneration of the Black Country it is important that they are not considered in isolation but are conserved and enhanced within their wider context. An holistic approach to the built and natural environment maximises opportunities to improve the overall image and quality of life in the Black Country by ensuring that historic context informs planning decisions and provides opportunities to link with other environmental infrastructure initiatives.

6.11 Considerable progress has been made towards achieving a fuller analysis and understanding of the local character and distinctiveness of the area using historic landscape characterization (HLC) principles. Much data is already available at sub-regional level, in the context of the Black Country Historic Landscape Characterization and from other local and more detailed HLC studies. Locally distinctive elements of the Black Country have been defined, including Beacon sites – characteristic, elevated landmarks which divide and help define individual communities.

Primary Evidence
The Black Country: An Historic Landscape Characterisation – First Report (2009)
A Landscape Character Framework for the Black Country Regeneration Corridors (2009)

Delivery
Development Management process including Design and Access Statements
Area Action Plans, Site Allocation Documents and Supplementary Planning Documents

[Unitof1]

Development proposals that would potentially have an impact on any of the above distinctive elements should be supported by evidence included in Design and Access Statements which demonstrates that all aspects of the historic character and distinctiveness of the locality have been fully assessed and used to inform proposals. In some instances local authorities may require developers to undertake detailed Historic Landscape Characterisation studies to support their proposals.


all it it requires is a statement with the planning application and then "other" archaeologists" to make comments on the application.

What ARCHAEOLOGISTS should do in this area is make comments on the planning applications to the authorities, ify, cba, anybody, why not make up a standard letter and post it to all the applications.

[Kel]

Unit, you're quoting from the policy that they're not planning to follow any more. Try and keep up dear.

[Marcus Brody]

Unit, you're quoting from the policy that they're not planning to follow any more. Try and keep up dear.

To be fair to Unit, he was only re-quoting a section of the policy that I quoted in the message above, and I'm aware that this is the policy that the Council no longer proposes to follow. But the point is that this is part of a core strategy that covers four Councils, which Sandwell only signed up to in February of this year. Local plans and strategy documents like this take several years to prepare and go through numerous consultation phases, so it's worth asking why they signed up to it so recently if they were unsure that they would be able to fulfil the obligations it imposes on them, or that they considered archaeology to be a luxury that they couldn't afford. If this is a policy that the Council didn't support or didn't think was affordable, there would have been plenty of opportunities for them to drop it.

I often get the impression that Councils make this sort of decision without actually considering whether it'll conflict with things they're committed to doing - i.e., the person who makes the decision to drop archaeology is looking only at the bottom line, and may not be aware of the other policies that require the Council to keep the post.

[BAJR]

I often get the impression that Councils make this sort of decision without actually considering whether it'll conflict with things they're committed to doing - i.e., the person who makes the decision to drop archaeology is looking only at the bottom line, and may not be aware of the other policies that require the Council to keep the post.

And we should all ALL point this out to said Council.

Am onto it next week for my part.! And thanks to all teh useful details