Is there a North-South divide?

[Steven]

Hi
All good points, a lack of artefacts does make it difficult to impress groundworkers, particularly if the archaeologists find it dull.

This trend (I'm assuming its "true" rather than a perception) to downgrade the mitigation to watching briefs is very worrying and it may well be that the curators should be specifying that archaeological contractors/consultants must NOT include recommendations in their DBAs. I frequently do this and only accept DBAs with recommendations if I have agreed their inclusion prior to submission of the DBA. This way means the decision about further work is decided either in conjunction, or by somebody with local knowledge (i.e. me!). Hopefully, this means that decisions are based on local significance as well as regional and national, and reflect research priorities/gaps in the area rather than simply a value judgement.


Steven

[RedEarth]

quote:Originally posted by Steven


Hi
All good points, a lack of artefacts does make it difficult to impress groundworkers, particularly if the archaeologists find it dull.

This trend (I'm assuming its "true" rather than a perception) to downgrade the mitigation to watching briefs is very worrying and it may well be that the curators should be specifying that archaeological contractors/consultants must NOT include recommendations in their DBAs. I frequently do this and only accept DBAs with recommendations if I have agreed their inclusion prior to submission of the DBA. This way means the decision about further work is decided either in conjunction, or by somebody with local knowledge (i.e. me!). Hopefully, this means that decisions are based on local significance as well as regional and national, and reflect research priorities/gaps in the area rather than simply a value judgement.


Steven

I'm not sure anyone is in a position to determine whether the situation is true or just perceived, and I would have thought nothing short of a PhD's worth of investigation would be able to answer that one.

The curators I regularly deal with often do ask for recommendations to be excluded from the reports but at the end of the day they are still reliant on the interpretation of the archaeologist(s) on site to provide them with the information they need to make an informed decision. Otherwise they'd have to go out and do all the work themselves. It is probable that the 'problem' isn't as bad as it might be perceived but it's difficult to tell without some nation-wide comparison.

All I know is that the north-west never seems to shout loadly enough about its archaeology, and as a result it largely lays silent in response. Big up yourself, is, I believe, the correct modern vernacular?

[1man1desk]

Not 100% on-topic I know, but a particular section of Curator Kid's original post caught my eye, as follows:

quote:I'm quite happy to recommend an evaluation on a one-house development, although it doesn't happen very often. I did this morning, on an undesignated site, based on information from the local society that medieval artefacts have been coming from the area. I'm quite happy to justify it to the planners (but rarely have to in any depth beyond a letter), and the question of whether or not it is going to cost the developers a prohibitive anount of money is not one I'm bothered about.

I don't disagree with this in principle, but I am under the impression that curators, as local authority officers, are required to act in line with policy and on the principle of 'reasonableness'. Both policy and reasonableness in this case are defined by PPG16, which has this to say about evaluations and their costs:

quote:...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...

On that basis, a local authority (acting on the curator's advice) that had no regard for the cost when imposing evaluation requirements could be deemed to be acting unreasonably, and would lose any legal challenge by the developer against the requirement.

The same comments about cost probably don't apply to recording works carried out under a planning condition (as opposed to pre-determination evaluation), but even there the authority is required to be reasonable.

In that context, I have had discussions with one curator who told me explicitly that he saw it as his job to extract the maximum possible amount of archaeological investigation out of each development project, and he did not care whether the scale of work he asked for was warranted by the potential significance of archaeological impact. In my view, that was clearly unreasonable.

Another curator pushed to have a proposed development relocated into an area of higher archaeological potential, because that would give him the opportunity to make the developer investigate a site the curator was interested in. In other words, he saw the development as simply an opportunity to extract funding for archaeological investigation for research purposes. Again, manifestly unreasonable.

To bring it back on topic - both of these curators were located in the north of England, and neither of them is still in post.

1man1desk

to let, fully furnished

[historic building]

I have always taken the test of reasonableness to represent a balance between the impact of the development and likely resource on site. The balance, and recommendations, are a result of weighting these two up. The extreme costs tend to arise for small, urban developments where, frequently, there is not the space for stepped trenching and some method of trench support must be employed.

Considering the many financial obligations on development imposed through legal agreeements even a detailed, lengthy urban excavation represents a very small outlay.

[1man1desk]

Posted by Historic Building:

quote:Considering the many financial obligations on development imposed through legal agreeements even a detailed, lengthy urban excavation represents a very small outlay.

I am afraid that is not realistic at all.

It may be true if you are dealing with a very large, very high-cost/high profit development, such as a city centre office block. However, for the 'one-house develoment' originally mentioned by Curator Kid such an excavation would cost more than the whole of the rest of the development costs, and usually more than the capital value of the finished development. For many other developers, including small to medium-sized commercial developments, the archaeological work might be one of the largest single items on their cost sheet. Going to the other end of the scale of development size, I once saw statistics showing that on Irish road schemes, archaeological work cost an average of 4% of the total construction budget. That is a very substantial proportion.

My point, however, is not to say that developers should not pay for 'preservation by record' operations. Under the 'polluter pays' principle, if you can't afford to protect the environment then you can't afford to do the development, so prohibitive costs are not an issue.

My point really relates to evaluations, since that is what Curator Kid was talking about in the original post. These are not archaeological investigations in their own right - they are supposed to be a quick look to see if there is anything there that might need investigating (or preservation). I don't believe it is reasonable to impose costs so high at that stage, when you don't even know whether there would be an archaeological impact, that the developer has to abandon the proposal because they can't afford the pre-planning investigation. Bear in mind that not everyone is making a profit here - sometimes these are houses being built as the 'developers' own home.

1man1desk

to let, fully furnished

[monitor lizard]

And how would you then propose reducing evaluation costs to whatever you consider to be reasonable?

It seems to me that there are only two ways to do this. Either under-cut tendering to such low levels that work is undertaken at a negative, or reduce the amount of evaluation area, if you are talking trenching. This quite obviously reduces the level of understanding across any site, and would increase the risk of remains of unidentified significance/volume/value being taken as a direct hit. Not good for developer or the archaeology.

See the Hey and Lacey PLANARCH volume for a very helpful discussion of evaluation percentages and strategies, which concludes that around 5% of a rural site gives maximium understanding for greatest efficicency.

ML

[drpeterwardle]

The purpose of an evaluation is not to characterise a site it is to provide enough infomation so that an informed planning decision can be made ie preserve in situ or an archaeological planning condition will be imposed. As soon as either of these thresholds is reached no more work can be demanded by the planning system.

Risk is a matter for the developers.

This is not to say that futher post determination evaluation may be neccessary to say define what the scope of the excavation is going to be. The Hey and lacey review is flawed in many respects - it calculates the percentage needed to find every site.

Peter Wardle

[vulpes]

That is not my reading of Hey and Lacey - the key quote from that publication is 'there can be no blanket solution' to evaluation. T'would be very easy and tempting to say 'oh just do 5% trenching' on all rural sites. When dealing with large sites a suite of techniques is often more appropriate. More a point of departure than a manual, I would suggest reading Appendix 2.

Edited for being gibberish.

[Steven]

Hi Chaps
An archaeological evaluation (in terms of PPG16) is only carried out to provide sufficient information to make a reasoned judgement concerning the likely impacts a proposal will have on any remains present. It is meant to be (and 1man1desk is right) rapid and inexpensive and is intended to supply information on the character, extent and significance of archaeological remains on a site. Of course inexpensive is a relative judgement so a £30,000 evaluation on a massive infrastructure project is (extremely) inexpensive but would be prohibative on a single 1 bed house.

It is unreasonable to make a applicant carry out work that is prohibative to the proposal, however, it is not unreasonable to require a small evaluation on a single or two house development, even if the evaluation comes to say £3,000-£4,000.

If the applicant considers it unreasonable they can appeal against non-determination (or if refused due to lack of eval). However, as I've won appeals with these circumstances Inspectors clearly agree that the cost is reasonable. So I cannot agree with 1man1desk that this

"developer has to abandon the proposal because they can't afford the pre-planning investigation"

is a "real" scenerio. If somebody owns a piece of (lets even say allocated) land and wants to get permission and then sell it on they should be in the position to outlay appropriate costs to get that permission. If they are not then they will have to sell the land at a much reduced rate to somebody who has got the funds. That's life, get used to it! Its the same in most economic situations, people normally need to invest to get a return.

It more realistic that people who can't afford a couple of grand for a small scale evaluation couldn't have afforded the huge sums of money required to buy a piece of allocated land!




Steven

[Curator Kid]

This all came about from a discussion of watching briefs on a different thread as I rather fuzzily remember. It was suggested that watching briefs were being used in certain (northern) areas, without evaluations being conducted beforehand to inform their purpose, as there was pressure to get developments underway. The original point, related to whether or not it was reasonable to request an evaluation on a site, if it was a small development proposal (for example, for one house). My own response was basically to say yes, I considered that it was indeed reasonable. I would want an evaluation to investigate whether or not any archaeological remains were present in an impact area, and if so, whether or not the development proposals were placing said remains under threat of destruction and therefore in need of mitigation. My original posting contains a quote from another post, so it's slightly out of context, and as mentioned, it's abbreviated too!

Generally, I wouldn't consider it all that reasonable to ask for a potentially cost-prohibitive pre-determination evaluation on an small undesignated site, and if I remember rightly, the example I gave also related to a post-determination evaluation, whereby the developer was able to calculate his costs and potential margins once he had a viable permission, with all the other conditions attached. Similarly however, National, County and District policies would support pre-determination investigations - particularly in an already designated area of known archaeological potential, and if this was cost-prohibitive then, as 1 man 1 desk suggests, the polluter pays principle applies and that's tough - exactly the same as if the cost of removing Great-Crested Newts or Slow-Worms or squatters from the site was prohibitive to development.