Archaeology: Just Another Planning Consideration Box to be Ticked? By James Archer, Senior Archaeological Consultant at CgMs Heritage, part of RPS

by Johnny Clayton on Wednesday, 27 March 2019

There is so much work that goes into a modern planning application and so many wide ranging and varied disciplines that need to be considered. Archaeology is just one of these disciplines and I can fully appreciate that with so much information to collate for an application, Archaeology could seem like a fairly minor part of an overall bigger picture!

This may be true on a lot of development schemes, however as with any discipline, it is always best to check with a qualified Archaeologist (Chartered Institute for Archaeologists approved) early on whether they think that archaeology could be a material consideration in the planning process.

Early Signs Requiring Archaeological Involvement

Some of the early warning signs that could indicate that archaeological works may be required to support a planning application include:

  • Is the site within or nearby to any nationally designated archaeological assets? Relevant designated archaeological assets include World Heritage Sites, Scheduled Monuments, Registered Battlefields and Protected Wreck sites – and of course there are other designated heritage assets such as Listed Buildings, Conservation Areas and Registered Parks/Gardens which may require Built Heritage input. If so, consultation may be required with Historic England (statutory consultee) per any direct impacts to the asset or indirect impacts to its setting and the way that the asset can be appreciated;
  • Is the site within a locally designated Archaeological Priority Area (or similarly named Area of Archaeological Potential, Notification Area, Alert Area, Priority Zone etc)? Most Districts/Boroughs/Counties have such areas, which are intended to draw attention to a particular known archaeological potential in that area. You will not necessarily have to undertake archaeological work for a development located within a Priority Area, however if you are undertaking below ground works there is a good chance that archaeology will be a material consideration. Many local planning policies reference these areas, and some even require as standard, archaeological fieldwork within these areas for pre-determination of a planning application;
  • What does Local Planning Policy require? For example, some Local Plans contain an arbitrary site size at which an archaeological assessment is required to support a planning application, whilst others will always require pre-determination archaeological fieldwork within locally designated Archaeological Priority Areas;
  • Is there any previous consultation advice from the Local Planning Authority or their archaeological advisor which requests archaeological work? Perhaps as part of a previous application at the site which didn’t go forward? Or perhaps as part of pre-application consultation?
  • Once planning consent is achieved and a planning condition is issued, archaeological works may contain an element of pre-commencement requirements, which will need to be satisfied before a material start can be made on site. Check the wording carefully – there is often a requirement for an archaeological methodology document (known as a Written Scheme of Investigation) to be approved by the Local Authority prior to construction (or demolition) commencing.

These early warning signs provide a good indication that archaeological works will be required as part of a planning application, although remember that they are not definitive and other sites may also require works.

Scope of Archaeological Works

Archaeological works would generally comprise three phases which would begin with non-intrusive works, before intrusive below ground works may be required to assess the archaeological potential of a site and the potential significance of any remains which may be present. The three phases of works are as follows:

  • Desk Based Evaluation;
  • Field Based Evaluation (Geophysical Survey, Boreholes, Evaluation Trenches etc);
  • Mitigation Works (Excavation, Watching Brief etc).

This may include some fairly substantial groundworks, particularly on brownfield sites, which may have large depths of made ground requiring deep stepped archaeological trenches. Such works take time and if this is going to be required as part of archaeological evaluation, then it is best to determine that early in the planning process to enable a realistic site programme to be produced that includes adequate time (and budget!) for both evaluation works and any subsequent mitigation works.

Just Another Planning Consideration – but an Important one!

To summarise, whilst just one of many considerations when collecting information for a planning application, Archaeology can involve substantial site works and therefore, if not tackled early in the process, can impact upon other disciplines and/or construction programmes and project budgets. If you think archaeological work could be required at a site to support a planning application, then get an expert involved early. It will avoid unforeseen knock-on effects to both project budget/site programme later on and avoid any associated headaches!

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