RESCUE

The British Archaeological Trust
15a Bull Plain, Hertford, Hertfordshire SG14 1DX Telephone: 01992-553377

rescue@rescue-archaeology.freeserve.co.uk http://www.rescue-archaeology.org.uk

Realising the benefits of planning-led investigation in the historic environment: A framework for delivering the requirements of PPS5. A response by RESCUE, The British Archaeological Trust to the draft report by the Southport Group. Introduction to this response: RESCUE welcomes the publication of the Southport draft report, and the opportunity to comment on its contents. We are pleased to note that the report highlights a number of what we believe to be the fundamental issues affecting the current and future practice of archaeology and historic environment management, and that the report recognises there are both deficiencies within current practice and challenges in addressing change. We are pleased also to note that practical solutions have been presented to facilitate these changes. When commenting, it is difficult to avoid a sense of negativity as by definition, comments highlight a series of differences of opinion. However where we have not raised specific comments to the contrary, the Southport Group should be assured that RESCUE is in broad agreement with the visions or recommendations made. The Southport Group has specifically requested comments on four specific questions, although we believe that there is more within the report that requires discussion or comment. This response is therefore organised into an initial comment on the overarching four questions, with subsequent additional discussion based on a number of separate points from the issues raised in the report. Paragraph numbers referred to are as given in the report and there is an overall conclusion given lastly, to summarise RESCUE’s organisational opinion of the report overall. Following submission to the Southport Group, this response will be published on the RESCUE website. Question 1: Do you think that the Southport Group visions are the right ones? There is quite clearly much to commend in the Vision statements. However it is also the case that there are a number which are constructed upon a false or inadequate initial premise, or which are overly simplistic. Dealing with each in turn, 3.1.9, - the perfectly agreeable suggestion of; a … vision… that the management of the historic environment should be a partnership between local authorities and community groups - actually presents practices that more forward-looking authorities and societies have previously undertaken for a considerable period as if it were new thinking. Of greater use would’ve been a vision that drew on projects where this type of collaborative working had already been implemented, and produced a blueprint for a next stage. The initial premise – that partnership working is not the norm – fails the subsequent construction of a truly innovative vision statement. Similarly vision 3.1.10, where it suggests commercial investigation should be conducted in such a way as to facilitate more fully public participation, is built upon a premise that we (the archaeological profession) have significant control of development-led commercial archaeological investigation and can institute these recommendations. We do not. The ongoing fundamental problem for the archaeological profession regarding commercial development-led investigation, is and always has been, the dichotomy between sector aspirational ideals for practice, participation and outcome, and the hard business of commercial resourcing, timetabling, legal practice and safety legislation. RESCUE fully supports the vision stated here (and acknowledges that this dichotomy is outlined elsewhere within the report), but frankly doubts its viability unless the profession undertakes a far deeper review of working practices – including competitive tendering

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and the use of standards and guidance - to reposition the profession within the development sector more satisfactorily. Without such a repositioning and reassessment exercise, the Group should also be fully aware of the dangers in these recommendations, whereby public participation in commercial projects is seized upon by the development sector as an even cheaper alternative to professional involvement. The objectives of 3.2.15 are again laudable and to be commended, but appear shaky when compared to the realities of many practices. Particularly recently, a number of higher education establishments and local authorities have shown scant regard for the quality or reputation of their archaeological field units, in the face of short-term budget considerations. The role of these bodies in fully participating in development-led research must be called into question. The role of research agendas is problematic also, as these have not been completed for the country as a whole, have few mechanisms for continued updating where they do exist, and do not have a satisfactory umbrella structure tying them together. There is little indication that such issues are soon to be addressed. The current drain of resources away from English Heritage by successive Governments, and EH’s own policy shift away from practical involvement in heritage protection, does not inspire confidence that research or research agendas will be a priority in future years. An example of the impracticalities of this vision can also be seen in the bullet points regarding leadership competence and project team skills, which reflect closely proscribed practices set out in MAP II (1991), but which were never implemented appropriately in practice. In addition to the points raised above, RESCUE is particularly concerned by the suggestion that … development-led research… should be focussed on interpretation, understanding and significance, not record. We strongly are of the opinion that the compilation of a comprehensive record of an archaeological site whilst it is under investigation, is the fundamental basis from which interpretation and understanding and all else flows. The record is also the basis from which reinterpretation and reinvestigation can be conducted years after the investigations have been completed. We accept that PPS5 has removed the principle of preservation by record, and sadly acknowledge that recording practices under PPG16 deteriorated significantly, but we reject the assertion that in some way, recording is now a secondary concern. This particular vision is therefore highly objectionable and at the very least, should be reconsidered if not removed. Vision 3.3.15 broadly states a series of recommendations that are in line with RESCUE’s own aspirations in this area. We are pleased to note this section, and are in agreement with the points outlined (see response to question 3 below also). The vision for a collaborative sector (3.4.15) is to be encouraged to a certain extent, although some caution should be exercised here. We who take part in the historic environment discipline should not underestimate or devalue the diversity of opinions, approaches and values that make our profession such a vibrant community. To a certain extent this is reflected in the first point, but is undermined by subsequent points made within the vision statement. For example, collaborative working within the planning process without being adversarial is often not difficult, due to the higher overriding policy positions of the non-archaeological bodies such as developers and local authorities, that some heritage professionals represent. The often unsatisfactory and deliberately adversarial role of the archaeological consultant needs to be explored more fully here and in the discussion in section 4, and ultimately there must be a professional commitment that the best interests of the archaeological resource should be the overriding principle that underpins collaborative working. Much conflict within the planning process stems plainly from the developmental need to expedite excavations and therefore reduce sampling levels, budgets and available timescales. The lack of recognition of this within this particular section is worrying. The idea of “adding value” in vision 3.5.8 is probably one of the few areas addressed in this report where the heritage profession exercises a serious degree of control – yet this is simply because the vision deals with the products and services that we offer, and even then these services are subject to external market forces set out above over which we as a profession have no current control.

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RESCUE fully endorses the principle of the profession providing a higher quality product to our clients – whether they be developers or the wider public. However, the concept of “value” is in itself nebulous and subjective. Archaeology to many (most?) developers is seen as a simple site contamination management issue. The question of how a developer can be persuaded that archaeological material on a site is a different and altogether more advantageous prospect than the presence of Heavy Metals or Japanese Knotweed is one that in 20 years of PPG16 the profession failed to adequately communicate, and whilst PPS5 is littered with statements on the “value” of heritage assets, many developers will place a far higher “value” on poor archaeology done quickly and cheaply, over the high quality projects suggested here. See response to question 3. Vision 3.7.10 aims to improve professional standards – a principle with which RESCUE agrees. However, see question 3 below. We are not convinced by the recommendations presented for achieving this aim. The premise that this improvement is geared towards better delivery of PPS5 is also of concern, given the deficiencies that document presents. Question 2: If you do, do you think we have made the right recommendations to achieve them? The large number of recommendations precludes discussion on all. However, there are broad issues that warrant comment, and where specific recommendations require discussion, these are referenced. The recommendations for visions 3.1.9 and 3.1.10 regarding partnership and public participation are very narrowly focussed towards the profession, giving the impression of a condescending “top down” approach. One of the weaknesses of the heritage profession in this area has been an inability to both adequately listen to, and communicate with, the wider public and our partnership organisations. The recommendations within this section refer heavily to organisations such as the IfA, ALGAO, IHBC and English Heritage – bodies which by and large have a poor visibility with the wider public (beyond obviously EH’s role as a manager of historic sites open to the public for tourism). An enforcement of complex professionalism on the wider public by these bodies is not likely to be successful – particularly when it is focussed on Government policy (recommendation 3), standards documents (recommendation 4), or formal training programmes (recommendation 5). This sort of approach would be better suited to members of the profession and whilst it is recognised that these specific recommendations largely deal with the profession, such an approach can surely only alienate the wider public. At the very least within these recommendations, RESCUE would have hoped to see a commitment to the creation of a proper focus or discussion group, comprising a number of members of alternative professions that have had considerably more success in attracting and involving the wider public. The green lobby has for example, succeeded in galvanising public support and participation in a way that the heritage lobby cannot begin to match, as have the performing arts. Neither of these sectors appear to see the need to provide training for the public on Government policy documents. The heritage profession should be looking for parallels with these areas, and look to take serious note of the practices, principles and projects where they have succeeded – and where we have demonstrably failed. The recommendations for section 3.2.15 (development-led research) rely heavily on the university sector participating – our concerns on this matter have been set out above. In particular, the role of SCFA should be scrutinised, as this body has been virtually invisible prior to the production of this document. It is disappointing that all the recommendations focus on disparate existing bodies that have a poor track record thus far when it comes to collaborative working and innovation of ideas. In particular recommendation 11 should certainly have a commitment to the establishment of an independent cross-organisational group, funded by the main heritage bodies (IfA, CBA, SCFA, EH, ALGAO etc.) which would have a specific remit to advise and direct better intra-sector communications. As it stands at the moment, the recommendation is basically for more discussions between existing bodies – an approach that hasn’t yielded satisfactory results thus far.

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Recommendation 12 of 3.2.15 doesn’t appear to offer much more than was outlined in MAP II in 1991, which is disappointing, although we await the “standard” for consultants with some interest. The IfA in particular should recognise that its continued adherence to “minimum requirements”, rather than “best practice” within its standards documents has stunted professional growth in favour of developer-driven concerns, and precluded the very developments in participation, innovation and collaborative research, that this report suggests we need to adopt. Without this change in emphasis, a revision of the existing standards documents is unlikely to present the opportunities for research or public benefit from development projects that the vision sets out. RESCUE supports the recommendations for the vision of accessible archives (3.3.15). We would query the lack of mention within these recommendations of the Museums Association or other museums organisations, as it would seem obvious that these institutions would have significant expertise to contribute. Once again, the recommendations are focussed around a small number of organisations, when it seems clear that wider cross-sectoral participation is required. In recommendation 15 English Heritage are suggested to approach the HLF to discuss revenue for resource centres, but as the national heritage body, they should be addressing this serious and long-term issue by conducting a thorough review of the state of the problem, and approaching the Government with proposals for centrally-funded regional storage and educational archive depositories. A substantial root and branch reassessment of how archaeological material is curated in the UK is required to address this vision. The recommendations for 3.4.15 (collaborative working) do not seem unreasonable – although as noted previously, there is a heavy emphasis on the same organisations to carry the ideas through, rather than an identification of where greater external organisational liaison is obviously required. The continued reliance on IfA standards as addressing the visions in these recommendations is of ongoing concern: there is a danger of these being viewed as a panacea for the profession’s problems, whilst the fact that these standards have been in existence for some time now and have failed to be successful suggests a different approach is needed (see comments above). There is a lack of mention of SCFA in this section, which reaffirms our concerns regarding the participation of the university sector in this process. RESCUE would also like to have seen a commitment by ALGAO to open its own membership up fully. At the moment, ALGAO admits only one member per local authority, meaning that the majority of local government Archaeological Officers are not represented. It frankly does not inspire confidence in a vision of a shared collaborative sector implementing PPS5 when one of the key organisations driving that process steadfastly refuses to become fully inclusive of the group it purports to represent. Also, any attempt to ensure the planning process becomes less adversarial, that then fails (as these recommendations do) to address the practices and market position of the Archaeological Consultancy industry, is likely to be unsuccessful in our opinion – as indeed is a process that relies on “professional self regulation” (recommendation 18). Both of these issues need to be addressed if there is to be any real progress in this area. Our comments regarding the recommendations for 3.5.8 (“adding value”) are largely dealt with under questions 1 and 3, although we would add here that we are surprised that there is no recommendation to ask the customers (developers and local authority planners in this case) what they consider to be of “value” in this regard. The recommendations for 3.7.10 (management of development) are more problematic however. Once again, they rely on the same organisations pursuing the same courses they have done for years, and once again, there is an over-reliance on IfA standards. The suggestion that these standards “…provide the bulk of what the sector needs.” (paragraph 3.7.7) is indicative of the staid thinking, when it is clear that these standards have failed to significantly increase either the quality or the professionalism of archaeological practice. The spectre of a whole raft of yet more guidance papers, “toolkits” and “frameworks”, as suggested in recommendation 22 is one that will likely fill most local authority archaeologists with horror – and is presumably the kind of guidance proliferation that the current Government is aiming to curtail with the creation of the National Planning Policy Framework. Such a series of technical implementation papers are hardly likely to inspire the wider public to engage with the profession either, as we have

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noted above. We note the recommendation for higher requirements for effective quality management by Registered Organisations – but would suggest that higher quality management of Registered Organisations would be more advantageous in achieving the aims of this vision. It should be considered that Registration is actually not a defining characteristic of quality – just that they have met the organisational criteria set out by the IfA: these criteria deal very little with the quality or the practice of the practical archaeological discipline (digging, recording and publication) itself. Certainly the archaeological unit working in and around London that provides the highest quality archaeological product is not Registered for example. This concern is mirrored by the recommendation for Royal Charter status by the IfA, which ultimately suggests an imposition of IfA values on practitioners wish to continue to work, when the majority of practitioners and members of that heritage profession are not currently members of the IfA, and have not subscribed to those standards. RESCUE is very much in favour of improved archaeological practice, but sincerely doubts that the imposition of a Chartered Institute on the profession will achieve this. Question 3: If you don’t, what alternative visions would you like to see included? The majority of this report has been focussed upon reaction to PPS5. It is disappointing that there is no recognition within the text that PPS5 is an imperfect document, and nor is there a recognition that these imperfections are already causing real problems as the policy is put into practice. The archaeological profession was (for example) assured by English Heritage that the reliance on the word “should” throughout the text of PPS5, rather than the more proscriptive “must” or “will” was not an issue of concern, as the terms were interchangeable and this was an issue of legal terminology, whilst the IfA was apparently happy that the new policy gave much improved protection for local authority advice services – almost as good as statutory protection it was suggested. There were warnings at the time that this was not the case, and the recent loss of the Liverpool advice service and closure of the HER to the public has sadly demonstrated this very clearly. It is consequently also disappointing that there is not recognition within this report of the two-way process required to implement PPS5, with reference to the role of the local and national Government in supporting it. Alternative Visions to include therefore should call upon the Government itself and its agencies to better support the practical implementation of PPS5 by the wider heritage profession. Section 3.1.9 should include a “vision” where English Heritage is once again an active participant in heritage protection, rather than simply acting to catalogue the problem of where there is damage and deterioration in the resource, and most certainly a vision that statutory HER’s and local authority advice services will become a reality. The vision for research (3.2.15) should include reference to a fully “respected” profession supported by national policy, where practitioners are (for example) able to continue reasonable project research without threat of legal action from Druid groups due to chaotic Government licensing arrangements, or where it is nationally recognised that expert archaeological research is of significantly greater value than metal detecting. The profession should also be seeking a commitment from the Government that research into, and protection of, the Historic Environment will be their number one national policy provision, and that the Government will henceforth actively avoid repeat situations such as that of the HMS Sussex. We believe that it is the role of the central Government to actively participate in the protection and future well being of the country’s heritage resources, so to that end we would also advocate a “vision” whereby the Government provides an adequate financial and policy framework for doing this. As stated above, we are in agreement with the statements regarding archiving in paragraph 3.3.15. We would also like to see a sectoral “vision” within this section whereby it is deemed unacceptable for archaeological archives to be disposed of by receiving bodies. Although no overall policy has been officially adopted to support the practice of disposal as yet, there has been considerable discussion on this subject for some time, and it seems to be only a matter of time before such practices are implemented. We do not believe that this is an acceptable “solution” to the current problems regarding archival storage space. A further commitment to retaining material where it can

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be demonstrated to have a viable future scientific use (for example skeletal material or ceramic assemblages) would be appropriate also. Vision 3.5.8 should have an aspiration that there is actually no low quality archaeology for developers to turn to, and a commitment to better advocacy of the benefits of our work as well as doing the work better. There ought also to be reference to better valuing ourselves as a profession: A vision whereby professional archaeologists are remunerated to commensurate levels in line with their skills and knowledge base would also be highly appropriate Perhaps most important of all, RESCUE believes there should be an industry-wide commitment/vision where “Best Practice” is the norm for archaeological practice. The current emphasis on minimum acceptable standards cannot continue if the profession is to grow appropriately in a competitive market-driven environment. Certainly section 3.7.10 would improve markedly if this ethos were adopted. Question 4: What other recommendations would you make to achieve these visions? In order to achieve the additional visions set out, it is clear that the profession, through either the Heritage Alliance, or The Archaeology Forum, has to become better at informing the Government Departments of our requirements, philosophies and practices. Lobbying must be used more effectively, and the profession should make a commitment to defend professional practice much more robustly in the face of potential opposition. In recent years, professional archaeological and historic environment practice has come under threat from fringe religious groups, terrestrial and maritime treasure hunters and ill-informed civil servants to name but three – and has failed to satisfactorily defend itself in all cases. We would strongly recommend that the campaigning and lobbying should be used more actively by the profession to achieve its aims, and that the profession should support its philosophical viewpoints more forcefully. Given the problems with the wording and quality of PPS5 we have raised, there should also be a recommendation to undertake a thorough review of the document’s implementation (or the implementation of its principles if it is subsumed into the NPPF in a different guise) after a five year period, and that this review should be used to inform the Government of how improvements can be made. As various recommendations mention IfA standards on a number of occasions, the commitment to best practice we have highlighted should be set out with those documents fully. Best practice should be defined and practitioners should be made to explain themselves when they dip below this standard. The concept of doing less better is highly questionable and should not be countenanced. It is RESCUE’s view that we broadly already don’t excavate sufficient of our sites and have excused this as an exercise in scientific “sampling” – a practice which is poorly founded in empirical research data. Usually in archaeology the more you investigate the more information you find and the better understanding of the site you have. With PPS5’s emphasis on enhanced understanding, we should be looking to excavate more – not less. Doing less better means that we just do less archaeology and so know less. It is not only a clumsy approach to the concept that needs to be avoided but a clumsy approach to articulating the concept, so as to avoid misunderstanding, too Additional Points: There are a number of issues raised within the text of the report that require further comment, whilst some possible avenues for discussion have been apparently omitted entirely. The historiography offered in section 2, which informs and underpins much of the subsequent analysis of current practice is overly simplistic and thus flawed. This detracts from the value of the conclusions and recommendations. It also disregards much of the modern history of the

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development of archaeological practice and fails to provide any critique of the effects of commercialisation on archaeology - which is a pity as discussion along these lines could have facilitated meaningful recommendations for future management practices. There is no mention of the fact that most Local Authority Conservation Officers virtually ignored PPG15 and 16 for years and worked primarily through using the Planning (Listed Buildings and Conservation Areas) Act 1990 – principally because that Act has judicial teeth by which to enforce conservation protection, whilst the planning policy guidances (and now the statements) demonstrably did not. A lack of “teeth” for local authority archaeologists in particular has been a mainstay of the problematical relationship between archaeologists and developers, and discussion along the lines of addressing this problem should’ve been included too. The PPG “benefits” highlighted in paragraph 2.2.8 are broadly correct, but it is debatable whether this has led to a “highly skilled sector”, and nowhere subsequently is it adequately highlighted how transient the PPG-created system actually is. None of the improvements and innovations outlined will be continuing in Merseyside for example – as the whole edifice collapses once the local authority historic environment service is removed. Implementation of PPS5 is entirely dependant upon these services – yet the paramount interest to the profession in maintaining them for its continued livelihood is largely unrecognised within this report. There are arguments that such services should be removed from local authority control altogether and based in regional research archives and centres. Whilst the argument for regional archives is made in this report, the next step of redefining operational structures to better serve the resource is shied away from, apparently deliberately. The emphasis in the report to research is welcomed, and RESCUE supports the ambition to refocus archaeology back onto research, but the discussion fails to address the issue that local units situated in communities with local workforces will better address local priorities - but that they may not do that at the lowest cost. The document also does not address the mechanism by which clients’ select successful tenders, which could have formed a useful sub-discussion in the section regarding value. The issue of how exactly to accommodate research in a commercially-driven environment has always been difficult, and whilst PPS5 permits the return of research to the development agenda, there is little debate to suggest practically how this might be achieved. To suggest that “understanding has explicitly superseded recording” (paragraph 3.2.3) ignores the fact that the former is entirely dependant upon the latter and is a highly worrying statement for the future. There is also a critique of the principle of “offsetting” to be had here – at what point does an ongoing or piecemeal development-led micro investigation of a site for “enhanced understanding” become detrimental to the overall “significance” of that site? Yet as elsewhere in the report, such comment on the deficiencies in the underlying principles of PPS5 is absent. There is a similar lack of critique demonstrated elsewhere in the research discussion also. Paragraph 3.2.8 for example reads as if a subsequent five or six sentences discussing the role of consultants have been excised. In many places, the report appears to approach or identify problems that exist in the profession, but falls short of entering into a meaningful analysis, which is a great shame. Helpfully, this lack of critique does not extend to issues outside of commercial archaeology with paragraphs 3.2.11 - 14 regarding the university sector being a useful summary of the current position, although the position is restored again in the vision and recommendations, which entirely omits the valuable contribution and important continuing role of specialists and specialist study groups. Conclusions: As stated above, RESCUE supports many of the principles that underpin this draft report, and therefore is in agreement with many of the conclusions and recommendations it contains. However, there seems to be an underlying confusion apparent within the document – is it a commercial industry document about the implementation of PPS5, or is it wider reassessment of the discipline of historic environment practice for the 21st Century? This doesn’t appear to have been resolved satisfactorily. If the latter, then there are numerous issues that warrant further detailed discussion as we have highlighted – particularly in the need for wider consultation and association with nonheritage related interest groups that have faced similar problems to our own industry in the past. If it

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is the former, then there are areas such as personal accreditation and chartership where the discussion unnecessarily reaches beyond planning concerns. The fundamental problems with PPS5 undermine the report and its conclusions – it is a pity that these are not recognised, as the policy’s continuing implementation will bring these into sharper focus as time passes. PPS15 was the subject of an initial consultation process with the profession, but was initially drafted without the involvement of front-line heritage staff. Comments on the principles were extensive, but PPS5 was rushed out without a suitable pre-assessment period, reconsultation, or input from the wider profession, just prior to the 2010 General Election. It is not without flaws. Given the current Government review of the planning system, and the imminent creation of the National Planning Policy Framework, an opportunity exists to iron out many of the deficiencies in PPS5, which this report has failed to take. As the introduction states – such opportunities are few and far between so it would be of lasting detriment to the profession if this imbalance in the report’s discursive framework was not addressed before a final version appears. We hope that the Southport Group finds these comments of use.

RESCUE: June 2011

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