Archaeological Archives Forum

The Policy Team,

English Heritage,
1 Waterhouse Square,
138-142 Holborn,
London EC1N 2ST,

22 October 2009

Dear sir/madam

PPS Planning for the Historic Environment: Historic Environment Planning Practice Guide

I have been asked to respond to the consultation on PPS Planning for the Historic Environment:
Historic Environment Planning Practice Guide on behalf of the Archaeological Archives Forum
(AAF).

The AAF was established by English Heritage in 2002: to link together in partnership all major
parties with an interest in archaeological archives in order that common policies and practice can
be developed and applied and to identify the courses of action necessary to further best practice in
the field of archaeological archives and to effect the means to achieve this action.

The Forum currently comprises representatives of: the Archaeology Data Service, the Association
of Local Government Archaeological Officers, the Council for British Archaeology, the Department
of the Environment Northern Ireland. English Heritage, Federation of Archaeological Managers and
Employers, the Institute for Archaeology, the IFA Finds Group, the IFA Maritime Affairs Group, the
Institute of Conservation Archaeology Group, the Museums Libraries and Archives Council, the
Royal Commission on Ancient and Historical Monuments Scotland, the Royal Commission on
Ancient and Historical Monuments Wales, the Society of Antiquaries of London and the Society of
Museum Archaeologists.

The AAF welcomes the inclusion of a statement relating to the archiving of the results of work on
the historic environment in the new guidance. The earlier Planning Policy Guidance Note 16 of
course makes no reference whatsoever to archaeological archives. However we are extremely
disappointed by the limited and unsatisfactory nature of the wording of the guidance given in the
section dealing with Reporting, Publication and Archiving: ‘The archive can be offered to a
suitable repository, such as a museum, county archive service, or an expert institution who may be
very willing to take it. It is best practice to consult the repository at the earliest stage’ (paragraph
63). We urge that the following text be substituted:

<It is established good practice that information gathered as a result of recording in

mitigation of damage to an historic asset (e.g. archaeological excavation, building
recording etc) is preserved and made publicly accessible. The preparation of a report, and
the compilation and deposition of the material, digital and documentary archive prepared
and conserved to agreed standards in an appropriate museum or repository will form an
integral part of any recording project. In order to maximise the public benefit, it is important
that a copy of the report and appropriate data be transferred to the local authority historic
environment record.>
It is also appropriate to place in a footnote at the end of this paragraph a reference to the AAF
Guide to Best Practice. The following text is proposed:

<For more information and guidance on standards see Archaeological Archives: A guide to
best practice in creation, compilation, transfer and curation, Archaeological archives
Forum (July 2007).>

In addition we would argue under the section dealing with Conditions and Planning Agreements
that an additional statement should be included as a separate bullet point within paragraph 65 as
follows:

<It is established good practice that planning authorities satisfy themselves that the
developer has made appropriate arrangements for the investigation of the archaeological
remains, the analysis and publication of the results and the long term preservation and
curation of any archive.>

Our comments are informed by our fundamental belief that the public must benefit from research
carried out on the historic environment as part of the planning process. This public benefit can best
be served by the preservation of the archaeological archive in a museum or similar repository.

Yours sincerely

Philip J Wise
MA (Cantab) AMA MIFA

Chairman: Archaeological Archives Forum

Archaeological Archives Forum

℅ Colchester and Ipswich Museum Service,
Museum Resource Centre
14 Ryegate Road
Colchester
CO1 1YG