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Archeology and Planning Policy Guide 16

   The documents abbreviated as PPG16 was created in order to somehow reorganize and consolidate the actions of all the players in the archeological society. Such segments as land owners, planning agencies, contractors, developers and society in general have to come to a agreement in order for the archeological science to freely develop and improve. This document was created in England in 1990 and concerns the following problems: ‘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.’[4]

   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.’[5]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.’[6] 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 assessment[10] 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 area[12]. 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.

   The ethos behind PPG 16 can be seen as the ‘consolidation of best practice already in place in parts of England’[13] and the culmination of broader trends from the 1980s and before[14] with widespread application of the ‘polluter pays’ principle driven perhaps by the privatisation of services previously the preserve of public and governmental agencies. PPG 16 transferred planning influence from central to local government but moved the financial burden onto the private sector, creating what is in effect a ‘hidden’ tax. Although the relinquishing of central government’s role does restrict the nation having a nationwide view of its heritage and the archaeological projects within it, as previously mentioned, it can be argued that PPG 16 has created a new dynamism and increased employment in the field of urban archaeology at least. The switch from core to initiative-based funding has seen the number of investigations triple in the period between the introduction of PPG 16 in 1990 and English Heritage’s second review in 1999, which also claims that planning-prompted investigations accounted for 89% of all archaeological work in England, leaving the stark realisation that therefore only the remaining 11% is purely research orientated.[15] Whilst this reactive mitigation[16] has lead to advancement in archaeological expertise in ‘rescue’ archaeology, the lack of long-term planning has meant that the results are ‘uneven, both in geographical and chronological spread and in terms of the topics addressed.’[17]

   Addyman does however acknowledge that PPG 16 has allowed national agencies to direct funds towards the previously neglected areas of post-excavation processing and publication, but bemoans the continuing inaccessibility and paucity of provision for the material and artefacts after these excavations.

   Darvill and Russel’s research from 2002[18] does show that in the areas where PPG 16 does direct its focus, it has proved beneficial. The report states that there were three times as many investigations in 1999 than in 1990, and that the range of types of investigation also increased. Furthermore, there is little sign of any bias towards a particular type of local artefact or period of history requiring assessment by curators. In addition, what Addyman and others have deemed a disadvantage in being forced to follow development trends rather than being able to initiate areas for excavation, with the consequent ‘uneven results’ may in actual fact be a useful randomising factor, forcing digs and excavations into areas that would have been disregarded by those focused only on their pet projects. Darvill and Russel make mention of the ‘widespread criticism that the long tradition of fieldwork in Wessex and central southern England has provided inappropriate models for the rest of the British Isles.’[19]

   A more worrying implication of the effect of PPG 16’s transference in funding is that with a heavy reliance upon the developers, comes an equal vulnerability to the cyclical phases of ‘boom and bust’ for which the property industry is renowned. Such oscillations can see a reduction of up to 25% in activity[20], which will have a destabilising effect upon excavations. It must be pointed out, however, that interruptions in funding are par for the course in all areas of academic research, and that the increasing demand for affordable housing threatening first brown-field and now, potentially, green-field sites, would serve to suggest that the property industry is not in too precarious a state.

   PPG 16 has highlighted the importance of the management of archaeological resources for effective care of our heritage. The increased role of accurate contextual information at a strategic level, in order to balance ‘what can be achieved through the development planning versus what is desirable archaeologically’[21] is of vital importance if the strategy is to successfully respond to public interests and commercial concerns. It is a rather damning indictment that even thirteen years after the ‘release’ of archaeology’s core funds to concentrate on the neglected areas of archiving and record storage, Addyman can claim that ‘the products of urban excavations are to all intents and purposes inaccessible. Their potential for research, education, recreation and enjoyment is unrealisable.’[22] Associated criticism of PPG 16 causing the over-working of untrained county officials or local amateur archaeologists and historians leading to inaccurate research is compounded by this oversight. For curators to be able to safeguard our heritage in the most academically expedient way, they need detailed, comprehensive and most importantly, accessible archives of previous work. That the results of excavations can be kept under embargo is baffling although admittedly exceptional, but projects such as the Urban Archaeological Strategies and Urban Extensive Surveys are helping to address this. Also, the research undertaken by Darvill and Russel would serve to suggest that in actual fact a higher quality of pre-site research and analysis is now the norm along with more excavation.[23] Concern has also extended to the abilities of those responsible for the practical side of site management, with debate over PPG 16’s use of the term ‘nominated’ rather than ‘qualified’ archaeologist. The claim that this leaves a loophole for those unscrupulous groups bidding for projects outside their area of expertise implies that good archaeological techniques are not applied across the range of specialities, regardless of the specific features of a site. The German model of having two superintendents[24] to oversee the project appears to successfully address this issue, with one possessing cultural and historical knowledge appropriate to the period, and the other providing technical expertise for the best methods of excavation for the site.

   The old scheduling criteria before PPG 16 looked at the rarity of potential finds, the vulnerability of the site if left unexcavated and the potential insight to be derived from intervention. The guidance offered in PPG 16 is not therefore radically different in its declaration to protect our heritage, but it does alter where the financial burden of this protection falls, whilst emphasising the importance attached to local consultation and research.

   More importantly, PPG 16 persists with the overriding ethos of its predecessors, that in rescue archaeology, it is better to intervene than to leave finds in site. Not everyone agrees with this, with a minority of the archaeological community expressing the opinion that posterity would be better served if uncovered remains were left unexcavated until technology has sufficiently advanced to use and exploit them in a far less invasive and potentially destructive fashion. The most obvious difficulties with this standpoint are that preservation is an unknown quantity, and failure to excavate risks the loss of public interest[25]. How can we confidently assert that the risk of damage from development without excavation will be less than that of initial investigation and extraction? Furthermore, it is a very risky path to predict that the fragile ‘diminishing resource’ will survive long enough for us to catch up with suitable technology. 

   Techniques for in situ preservation are potentially more damaging than the straightforward excavation they condemn, with systems such as piling causing highly destructive changes in the water level of sites, despite recent advances in the use of continuous flight-augured or CFA piles, cast in the bore holes of the site using concrete and metal sleeves to minimise the impact upon the site remains.[26] Guidelines that allow the 5% loss of the archaeological evidence in a site to allow for protective construction activities such as piling are predicated on the ‘assumption that economical foundation scheme [such as flight-augured piles] will ensure the preservation of archaeological deposits. Evidence is accumulating that this is not always so.’[27] Air as well as water can seep into holes and affect the remains, causing changes in the chemical environment. But Addyman does go on to cite the example of Hungate, York as a demonstration that with strategic planning, this ‘intensive brown field redevelopment… cam relatively easily be accommodated archaeologically…’ and that it had been possible to ‘design urban open spaces where important structures lay near the surface.’[28]

   The loss of public interest in failing to excavate may seem trivial in the cloistered academic community, but it has arguably proved crucial in lobbying for government and now industry to be seen to be protecting our heritage by funding vital excavations and research. It is also instrumental in keeping archaeology on the political agenda, and for the regeneration of the levels of both curator and contractor personnel entering university – essential to avoid a decline in the specialist caretakers of this diminishing resource.

   The perennial issue of funding appears to have been addressed to a certain extent by PPG 16, despite the early misgivings about the potentially unsympathetic role of the private sector. An omission about the responsibility for the storage of excavated finds is an increasing concern given that with the rise in excavations comes a correlated increase in the quantities of artefacts and remains requiring specialist preservation. Overall, PPG 16 has not changed the fact that archaeology will never be given unrestricted time, access or funding to pursue its investigations, but it has gone some way in alleviating the impact of these restrictions – particularly financial – in the area of urban archaeology.

BIBLIOGRAPHY

Peter Carrington (Editor) ‘Evaluations in Rescue Archaeology: PPG 16 Three Years on - Papers from a Seminar Held at Mold, Clwyd, December 1992’
Published by Chester Archaeological Service Occasional Papers (1993)

R. Lee Lyman ‘Prehistory of the Oregon Coast: The Effects of Excavation Strategies and Assemblage Size on Archaeological Inquiry (New World Archaeological Record Series)’
Published by Academic Press (1991)

M. O. H. Carver: 'Arguments in Stone: archaeological research and the European
town in the first millennium AD'

Published by University of Glasgow/Oxbow: Oxford (1993)

English Heritage: ‘Urban archaeological strategies’
Published by English Heritage Review (1995-6 edition)

Department of the Environment: Circular 8/87: Historic Buildings and Conservation Areas — Policy and Procedures
Published Her Majesty’s Stationery Office (1987)

Department of the Environment: Planning Policy Guidance Note 16: Archaeology and Planning
Published by Her Majesty’s Stationery Office (1990)

Department of the Environment & Department of National Heritage: Planning Policy Guidance Note 15: Planning and the Historic Environment
Published by Her Majesty’s Stationery Office (1994)

• Geoffrey Wainwright, quoted by Andrew & Robert Selkirk (eds.) ‘Current Archaeology’
www.archaeology.co.uk/gateway/wainwright.htm

T. C. Darvill & B. Russel: ‘Archaeology after PPG16: archaeological investigations in England 1990 – 1999.’ Research Report 10.
Published by Bournemouth University in association with English Heritage (2002)

English Heritage: ‘Planning for the Past: a review of assessment procedures in England 1982-91.’
Published by English Heritage (1995)

David Baker: ‘Review & Combination of PPG15 & PPG16 – Preliminary Comments to the Office of the Deputy Prime Minister’
Council for British Archaeology

http://www.britarch.ac.uk/conserve/ppg15&16.html

Peter Addyman: ‘Urban Archaeology – Where Now?’

http://www.sal.org.uk/lectures/read/addyman.php

Transcript of paper given at the Society of Antiquaries of London (2003)

Jim Williams & Mike Corfield ‘Construction impacts on in situ preservation of archaeological sites and artefacts’ www.heritage.xtd.pl/pdf/full_williams.pdf

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[4] Ibid, paragraph 15

[5] Ibid, paragraph 16

[6] Peter Addyman: ‘Urban Archaeology – Where Now?’ Transcript of paper given at the Society of Antiquaries of London (2003): http://www.sal.org.uk/lectures/read/addyman.php  page 6

[7] Lecture notes, Methods & practice in Archaeology H0001 (2002-3)

[8] T. C. Darvill & B. Russel: ‘Archaeology after PPG16: archaeological investigations in England 1990 – 1999.’ Research Report 10. Published by Bournemouth University in association with English Heritage (2002) & Geoffrey Wainwright, ‘Current Archaeology’ as before;

[9] Geoffrey Wainwright, ‘Current Archaeology’ as before

[10] Ibid ‘Determining whether there is an archaeological dimension… even if only by going and looking over the hedge.’

[11] Ibid

[12] Ibid

[13] T. C. Darvill & B. Russel: ‘Archaeology after PPG16: archaeological investigations in England 1990 – 1999.’ (as before) p.3

[14] Ibid Darvill & Russel cite Darvill & Fulton 1998, pp 58-64, p.3

[15] Ibid p.

[16] Peter Addyman: ‘Urban Archaeology – Where Now?’ as before

[17] Ibid

[18] Darvill & B. Russel: ‘Archaeology after PPG16: archaeological investigations in England 1990 – 1999.’ as before

[19] Ibid p.53

[20] Ibid

[21] Ibid

[22] Peter Addyman: ‘Urban Archaeology – Where Now?’ as before

[23] Darvill & B. Russel: ‘Archaeology after PPG16: archaeological investigations in England 1990 – 1999.’ as before

[24] Lecture notes, Methods & practice in Archaeology H0001 (2002-3)

[25] Lecture notes, Methods & practice in Archaeology H0001 (2002-3)

[26] Jim Williams & Mike Corfield ‘Construction impacts on in situ preservation of archaeological sites and artefacts’

www.heritage.xtd.pl/pdf/full_williams.pdf  p.2

[27] Peter Addyman: ‘Urban Archaeology – Where Now?’ as before

[28] Ibid