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English Heritage Policy Position Statement

Mineral extraction and the historic environment

A response by RESCUE – The British Archaeological Trust

15A Bull Plain

SG14 1DX

Tel. (01992) 553377


Mining and quarrying are widely perceived as highly intrusive impacts on the environment.
This is particularly true at the local and regional level where people may see landscapes that they
have known for many years and which have, in the popular perception, remained ‘largely
unchanged’ for generations being entirely or wholly dismantled, to be replaced with vast holes and
the mechanical paraphernalia of mineral extraction. Only after extraction ceases will such
landscapes be replaced with new and in some sense, artificial ones. In some cases such
developments may be welcomed (where, for example, reed beds and lakes replace intensive cereal
cultivation) but in many others the perception is one of destruction and the eradication of known
and loved landscapes. Local and wider protests are a regular feature of proposals for mining and
quarrying, particularly of an open cast nature. RESCUE has been involved (along with other
organisations) in supporting many such campaigns including that centred on the Thornborough
henge complex, the proposal for extensive quarrying on the Isle of Harris and on the fringes of the
Dartmoor National Park. It might be true to say that, along with road schemes, airport expansion
and wind farms, quarrying is seen as one of the most contentious of the many types of development
which have an impact on the historic environment.
In the light of this history, RESCUE welcomes the publication of the draft policy on mineral
extraction and the historic environment as a first step towards meeting the challenge posed by this
industry. It is particularly timely in view of the proposals for extensive urban expansion in south-
east England and the south Midlands which will undoubtedly increase demands for a wide range of
minerals and aggregates, with a corresponding impact on other areas of the country, where the
existing landscape will be, in a literal sense, consumed, in order to contribute to building elsewhere.
It is entirely possible that developments in the future, particularly related to rises in sea level will
also increase demands for aggregates and stone as attempts are made to mitigate the impact of sea
level rise on costal communities.
The document identifies three areas of particular concern (Section 1.2) which are
subsequently discussed in sections 4 to 7:

• the historic significance of mining and quarrying sites and landscapes

• the impacts on the historic environment that can be caused by mineral extraction together
with advice on appropriate mitigation measures

• the need for and supply of natural stone and other materials required to conserve the historic
environment and maintain local distinctiveness

RESCUE agrees that these three areas are of particular significance but we have some
reservations regarding the way that they are dealt with and, as outlined below, with the structure of
the document to the extent that it is based upon these three themes.
The historic significance of mining and quarrying sites and landscapes
RESCUE agrees with and supports the statement in section 5.6 that ‘further work is
required to raise general awareness of the extent, significance and cultural value of former mining
and quarrying remains if the legacy of the extractive industries is to be safeguarded’. The impact
of past mining and quarrying has contributed significantly to landscapes in many parts of the
country; lead mining and stone quarrying in Derbyshire, tin mining in the south-west, peat cutting
in Norfolk have all contributed to the unique landscapes that are amongst the most valued in
England. While some of these landscapes are pre-industrial in nature, many, perhaps the majority,
are associated with the growth of the British economy between the 17th and 20th centuries and form
a highly significant part of the transformation of British (and ultimately global) society that is,
somewhat unfortunately, still subsumed under the name of the ‘Industrial Revolution’. We see an
opportunity for contributing significantly to emerging areas of research within social and economic
history, economic sociology and archaeology through the specifically archaeological investigation
of these landscapes, the physical remains of structures and features linked with the extractive
industries and the nature of the social relationships embodied in the physical remains which
constitute much of the available data on these industries. We would advocate radical and
innovative programmes of research based on the investigation of landscapes and individual sites
resulting from and connected with mining and quarrying landscapes. Such investigations should
include both the physical remains of the mining/quarrying sites and the communities associated
with them as the one cannot be fully understood without the other. That the relationship between
mining and quarrying practice is understood within the framework of changing social structures and
practices is of particular significance when questions of interpretation and presentation are
considered in order to subvert the somewhat economistic and functionalistic interpretations that
have, until recently, tended to dominate discourses surrounding industrial practice. RESCUE would
actively support the kind of research framework proposed in section 5.8. This might, at an initial
level at any rate, usefully employ some of the data collected in connection with the abandoned
Monuments Protection Plan (MPP), parts of which dealt with the extractive industries and their

The impacts on the historic environment that can be caused by mineral extraction together
with advice on appropriate mitigation measures
This part of the document (section 6) is perhaps the one that will be the most contentious
when the final version of the document is circulated. For the reasons outlined in sections 6.2 and
6.3, RESCUE has particular concerns over the impact of large scale mining and quarrying and we
would emphasise the highly destructive impact of such work on the historic environment both in
terms of the actual quantifiable impact and also in terms of the popular perception of these impacts
on the environment of individuals and communities. While we acknowledge the difficulty of
dealing with these issues and largely endorse the points made in sections 6.4 to 6.9 (dealing with the
mitigation of the impact of mining and quarrying), we would like to see the development of some
clearer and stronger guidelines for use by development control and curatorial archaeologists and to
inform the advice given by consultants to their clients. Key areas, we would suggest, include:

• Sampling strategies for excavation and survey;

• The contribution to be made by national and regional research frameworks in determining
responses to applications for mineral extraction consent;
• The nature and quality of areas in which preservation in situ is desirable and/or possible.

Investigation of these areas is of vital importance in the context of development control

protocols and procedures and there are areas in which decisions should be taken with the benefit of
specialist technical advice. Sampling strategy, which is poorly understood by the majority of
archaeologists, is of particular importance in this area. Sampling strategies have, traditionally, been
formulated and applied with a relatively limited understanding of statistical principles and, in some
cases, of the nature of the archaeology involved. The later prehistoric crop-mark landscapes of
southern Yorkshire are a case in point; sampling strategies which might be appropriate in the
context of the Thames Valley (for example) are inappropriate in the cases of the largely aceramic
societies of this area. The work of Hey and Lacey (2001) is a useful starting point in this regard but
should perhaps be pursued on a broader scale. The integration of such work into national and, more
particularly, regional research strategies is of considerable importance in providing archaeological
curators with the information and tools that they require to respond most effectively to the particular
challenges posed by large scale mining and quarrying within specific regions and locales.
With reference to the issue of preservation in situ, RESCUE is concerned that this can
become a token gesture by quarry companies towards the historic environment which involves little
real concession on their part while a high price is extracted elsewhere in return for such modest
concessions. We would like to see evidence that there is a willingness on the part of the aggregates
industry to make significant concessions to the historic (and natural) environment in the sense of
setting a side areas within which preservation would be of a sustainable nature; all too often small
areas are designated irrespective of issues such as dewatering and the integrity of historic
landscapes. Archaeology has, de facto, surrendered large areas of historic landscape in return for
relatively small scale investigations using sampling strategies of a questionable nature. There
seems to have been little acknowledgement by the aggregates industry of the massive loss of data
that this has involved, or of the finite nature of the unique assets that continue to be lost. These
issues require action as a priority if we are not to loose the opportunity to understand prehistoric and
early historic societies in detail.
RESCUE endorses the concerns expressed in sections 6.19 and 6.20 concerning land banks
and the renewal of old mineral planning consents. We have argued in the past (together with other
organisations, notably the Council for National Parks), that there is an urgent need for companies
holding existing planning permissions to submit themselves to contemporary scrutiny as to the
nature and scope of these permissions. To assert that there has been no effective change in society
or social attitudes between the later 1940s and the first decade of the 21st century is absurd and the
fact that the retention of old planning consents is predicated on such an assertion is entirely
indefensible. The use of the threat of actions for compensation by companies in order to maintain
such consents requires urgent attention. It may be that firm government action is required in order
to remove the possibility of compensation from those companies who would exploit this
undemocratic means of enacting rights that are as outdated as health and safety laws or rights to
pollute dating to the same period.

The need for and supply of natural stone and other materials required to conserve the historic
environment and maintain local distinctiveness
RESCUE considers section 7 to be relatively uncontroversial, given the need to maintain the
fabric and appearance of historic buildings using appropriate types of stone and stone products. We
would tend to support moves to maintain small quarries as the source of such resources and would
argue for liaison with natural environment bodies and community and amenity groups as a way of
ensuring that such exploitation is both sustainable and sympathetic to local concerns.
We are not convinced by paragraph 7.8 in which it seems that an effort is being made to
elide the distinction between the large scale exploitation of aggregates, coal, minerals and other
resources which are undertaken on a large scale and the much smaller scale exploitation discussed
generally in section 7. The greatest threat to archaeology comes from open cast aggregate and clay
extraction, open cast coal mining and large scale open cast mineral extraction (such as the titanium
mine proposed for Crownhill Down). The inclusion of this paragraph would seem to serve no
useful purpose other than to offer an opportunity for the open cast mining industries to cloak their
activities under the façade of maintaining the historic environment. Greater clarity would be of
value here, perhaps through the quantification and explanation of the different types and scales of
mineral extraction.
English Heritage policy on minerals extraction and use
RESCUE has a number of specific comments on this section;

P1. The statement ‘Nevertheless, mineral extraction, particularly on an extensive scale, can have
an adverse effect on the landscape and on historic assets situated on land and at sea’ seems
strangely ambiguous; surely it is undeniable that mineral extraction has a demonstrable and proven
effect on the historic environment and on archaeology specifically through the wholesale removal
of archaeological strata as a preliminary to mineral extraction. Even if topsoil is restored to an open
cast mining site after extraction, this will be 100% archaeologically sterile apart from a few
archaeologically worthless items fortuitously preserved in the replaced topsoil. This is the central
concern with mining and particularly with open cast mining and must be acknowledged if
archaeology is not to surrender wholesale to the demands of the mineral extraction industry.

P2 – P4. RESCUE supports these principles

P5. RESCUE would hope that English Heritage would take into account local and regional
concerns regarding specific sites and specific areas of valued landscape rather than being wholly
driven by national policies which might be inappropriate in certain local circumstances. We look to
a greater degree of regional responsiveness than is implied in this paragraph.

P6 – P9. RESCUE broadly supports the principles set out in these sections but would look for the
inclusion of research alongside understanding and public enjoyment in paragraph P9. Both of these
outcomes are predicated upon robust historical and archaeological research and we would expect to
see this acknowledged in the text.

P10 & P11. There is some potential conflict between these paragraphs and while we acknowledge
that this is perhaps inevitable, we would like to see a clear and unambiguous statement that English
Heritage will press for the full and complete investigation and recording of sites and landscapes
threatened by mineral extraction with this work being monitored independently of any consultants
employed by mining and quarrying companies. As noted above, the development and testing of
sampling strategies and the relationship between sampling and the local and regional idiosyncrasies
of the archaeological record needs to be set out in detail.

P12. RESCUE broadly supports this point.

P13 & P14. As with paragraphs P10 and P11 and following from the discussion above, RESCUE
would like to see a great deal more detail here on the responsibilities of mineral extraction
companies towards the historic environment. Issues of sampling, survey methodologies and the
opportunity to undertake large scale survey and excavation need to be referenced here or,
preferably, set out in detail. We note that reference is made to arrangements for reinstatement, but
there is no way in which archaeological deposits can be reinstated after open cast quarrying, even if
it is possible to produce a reasonable simulacrum of the previously existing landscape. Archaeology
loses 100% when a landscape is quarried and the only possible mitigating response to this is full
and complete excavation, archive creation and publication. This is what we should be arguing for,
irrespective of the concerns of those for whom the destruction of the archaeological assets is an
acceptable price for the acquisition of minerals and of profits for company shareholders.

P15. RESCUE has no specific comments on issues connected with the marine environment, other
than to note that there is no significant difference between the value of archaeological assets
whether on land or within the marine environment. The extension of the principles of PPG 16 to
marine assets is thus welcome and many of the points made elsewhere in this document regarding
the terrestrial environment are equally applicable to the marine environment.

P16. RESCUE is wholly in favour of the review of old mineral planning consents, for the reasons
set out above. To compensate companies for changes in social attitudes to the historic environment
since the late 1940s is as absurd as suggesting that they should be compensated for those changes in
attitudes to death and injury in the work place which have led to the creation of modern health and
safety standards in place of those which were considered adequate in the late 1940s.

P17 & P18. RESCUE supports these two points.

P19. RESCUE would suggest that it would be worth emphasising the importance of comprehensive
regional research agendas and strategies in connection with this point. The issue of local, regional
and national importance would seem to be critical here and it would be advantageous if English
Heritage would commit itself to supporting the notion of significance as existing at all three levels,
rather then simply at the national level.

P20 – 23. RESCUE supports the need for local distinctiveness to be retained through the use of
appropriate materials and building techniques. We look to English Heritage continuing to engage in
dialogue with other national agencies with a view to reaching mutually acceptable agreements on
the exploitation and use of appropriate materials.

The structure of the document

While RESCUE welcomes this document and sees it as an indication that the issues of
mining and quarrying are being tackled by English Heritage, we are concerned that, as it is
structured at present, the document may not be in a form that is of the greatest value to those who
will be using it, particularly archaeological curators and those concerned with development control
and monitoring. We would suggest that a more useful format might involve the preparation of two
documents or a single document with a much clearer and more formal distinction between the three
principal issues discussed in the text.
The first section (or the first of two complementary documents) should be aimed at the
curatorial and conservation professional but should also be accessible and relevant to those in other
areas who need to understand the rationale behind the concerns of the archaeological community
over their activities. This section or document should deal specifically with the archaeological and
historical significance of mining and quarrying sites and landscapes. The issues addressed should
include the following:

• The structural, landscape and archaeological elements that constitute such landscapes, sites
and monuments;
• The nature of possible threats to their survival and ways to deal with this that recognise the
many demands on the English landscape as a whole;
• The significance of mining and quarrying landscapes, sites and monuments as heritage
assets today;
• The specific difficulties of the protection, enhancement and conservation of these and
associated structures, landscapes and buried archaeological assets;
• The role and significance of the maintenance and continued exploitation of existing quarries
which are needed to supply raw materials for use in maintaining and enhancing the wider
historic environment.

The second part of the document, or (preferably) a second document should address the
specific issues surrounding modern mineral extraction. This should consider the effects of mining
and quarrying on buried archaeological assets, on historic landscapes and on the wider historic
environment holistically and should include a consideration of appropriate mitigation procedures. It
should emphasise the importance of Environmental Impact Assessments and of pre-application
discussion with local archaeological curators and should address practical issues, including the
nature and role of sampling strategies and of archaeological evaluation and assessment. Such
matters inevitably entail a consideration of technical issues, notably the statistical status of different
sampling strategies which might not be otherwise available to archaeological curators but which are
of central importance in devising adequate responses to the unique challenges posed by mining and
quarrying, particularly when these are of an extensive or open cast nature. Such a paper should be
addressed to archaeological curators, archaeological consultants, the mining and quarrying industry
and government, but it will also be of relevance to the archaeological contractors who will have to
work closely with the industry in putting the principles into practice.
Discussion should include the full range of issues, including the adjustment of site working
practices by the industry to accommodate the variety of archaeological responses to mining and
quarrying including

• The extensive excavation, recording and sampling of archaeological and landscape features;
• The character and scope of the various types of monitoring (including watching briefs);
• The use of statistically based sampling strategies and the nature of preservation in situ.

While some of the issues raised might be unwelcome to the mining and quarrying industry,
the long term value of such a clear and explicit statement of principles and practice will surely be to
the benefit of all in minimising the extent of archaeological objections to particular projects and of
permitting the resolution of potential conflicts without recourse to expensive and time consuming
official enquiries or of mass protests in the face of plans for mining and quarrying projects.

Hey, G. and Lacey, M. 2001 Evaluation of archaeological decision-making processes and
sampling strategies Kent County Council.