In November 1990, archaeology in England saw a series of fundamental changes to the practice and application of the archaeology of planned development sites, with the Department of the Environment’s ‘Planning and Policy Guidance Note 16’. This document is directed at the planning authorities, property owners, developers, amenity societies and the general public, as well as the archaeological community.
Wales and Scotland have very similar guidance policies, and PPG 16 has become the basis of all rescue archaeology – and therefore the majority of excavations – in England. Imitation being the sincerest form of flattery, similar models are being implemented in other areas of the world such as Romania and Taiwan1 As a pre-excavation guidance strategy, PPG 16 ‘advocates the presumption of preserving important archaeological sites and their settings’.
It can therefore be seen as an official endorsement of the fact that ‘archaeological remains are a non-renewable and fragile source [for which] care must be taken to ensure they are not thoughtlessly destroyed [and that] they are part of our national identity.’3 Having set out the key factors to consider with regard to the effects of environmental planning on the archaeological record in section A, the document goes on to state in section B how developers and planners should investigate local archaeology, in order to best consider the potential impact of these factors on their planning applications:
‘Development plans should reconcile the need for development with the interests of conservation including archaeology… plans should include policies for the protection, enhancement and preservation of sites of archaeological interest.’ And furthermore: ‘Authorities should bear in mind that not all nationally important remains meriting preservation will necessarily be scheduled; such remains and… other unscheduled remains of more local importance may also be identified… as worthy of preservation.’
This last point is pertinent in light of the comments made by Peter Addyman, in a paper given at the Society of Antiquaries of London in February of this year, where he stated that one of the effects of PPG 16 was to allow national agencies to concentrate their efforts – and therefore their funds – ‘on the provision of the background data needed by planners and developers to manage and conserve the archaeological resource.’
The adage that the ‘polluter pays’7 is another new development in urban archaeology brought about by PPG 16. In supplying the mechanism for financing by the developer, the costs incurred in the process of assessment, evaluation, excavation and analysis are borne by those who – however benevolent their approach – threaten the aforementioned ‘precious resource’. Crucially, the responsibility for ‘rescue’ archaeology now lies with local planning authorities rather than central government. Although this may mean that a nationwide perspective is sacrificed to local concerns, with the national heritage of the country as a whole being lost sight of, this is potentially outweighed by the greater good in saving and minimising the damage done to those sites that will inevitably fall prey to the inexorable process of building development.
PPG 16 makes a clear distinction in the types of personnel involved in the newly localised assessment process, distinguishing between the ‘curators’ and the ‘contractors’8. The former are the archaeologists employed by the local authorities to advise planning departments as to the archaeological significance of the planning applications put before them. They are also responsible for maintaining the ‘Sites & Monuments Record’, a database of all (officially recorded) archaeological finds made, which is designed to offer a context and guide when determining the relative archaeological ‘value’ of the proposed development site.
The ‘contractors’ are the commercial archaeologists retained by the developers – the potential ‘polluters’ – to draw up and present their proposals to the ‘curators’. Their responsibility lies in carrying out the preliminary evaluation of the site and then to oversee and carry out any excavations needed.9 The preliminary evaluation follows four main stages, the first of which is the appraisal, which consists of a quick visual assessment10 of any archaeological aspects to the proposed development. Following this, the contractors research the site using sources such as the Sites ; Monuments Record, in order to assemble an archaeological background context for the site. This assessment is very clearly distinct from any site evaluation, being a ‘purely desk-based exercise’.11
The resulting assessment serves to determine the need for a subsequent field evaluation, with a far more detailed examination of the site. According to Geoffrey Wainwright, this should ‘include as many surveying techniques as possible… [most importantly] trial trenching a minimum of 1-2% of the site area12. The evaluation produces a factual report, divided up by methodology, to be combined with the assessment to ensure that the developers are complying with the specifications of PPG 16.
Upon receipt of the report proposal, the local authority has the option to refuse consent, to modify the proposal, to seek an exploratory excavation before development commences or to request a watching brief to observe the development. It is revealing to note that the local authority may only request a watching brief, and in all likelihood would have difficulty upholding opposition to the development on purely archaeological grounds indefinitely. Planning Policy Guide 16 is just that – a guide. It is not legislation, and relies upon the co-operation of the curators and contractors for its efficacy.