Planning for mineral extraction and archaeology

Practice guide

A response by RESCUE – The British Archaeological Trust

15A Bull Plain

Hertford
SG14 1DX

Tel. (01992) 553377

E-mail: rescue@rescue-archaeology.freeserve.co.uk
Website: www.rescue-archaeology.freeserve.co.uk

Chairman: Roy Friendship-Taylor M. Phil., MAAIS., AIFA

roy@friendship-taylor.freeserve.co.uk

Introduction
RESCUE welcomes the opportunity to comment on the guidance document produced by the
Minerals and Historic Environment Forum Planning for mineral extraction and archaeology.
Practice guide (generally referred to hereafter as ‘the document’). RESCUE supports the principle
behind the formation of the Forum in that the key to resolving issues arising from mineral extraction
in relationship to archaeology is effective communication between those involved in the process and
mutual understanding of the issues that are at stake.
In our comments on an earlier document Mineral extraction and the historic environment, we
noted that the unusual and distinctive feature of mineral extraction is its extreme impact on
archaeological assets and resources. Once quarried a landscape may be restored, recreated or created
anew in respect of its amenity value, ecological status or in terms of its agricultural potential, but the
archaeological value will be zero once mineral extraction has taken place. This fact underlies our
approach to mineral extraction and, we would argue, means that mineral extraction must be
accounted as an unusually destructive impact on the archaeological record.
In considering the document and the covering letter RESCUE is concerned at an apparent
disjunction between the two. While the document itself provides a range of useful (if limited)
definitions and descriptions covering the nature, scope and potential of various methods of data
acquisition but stops short of formulating specific policies or guidelines, the covering letter is
somewhat more prescriptive, particularly in terms of its identification of key issues. This response
will therefore consider firstly the document itself and secondly the contents of the covering letter.

Planning for mineral extraction and archaeology. Practice guide

In general terms, RESCUE acknowledges that the Introduction (paragraphs 1 – 13) provides a
useful overview of the issues surrounding mineral extraction and archaeology. The high level of
public interest surrounding the historic environment in all its many diverse aspects is clearly brought
out in paragraph 4. The need for ongoing mineral extraction is equally clearly set out in paragraph 5.
The final two sentences of this paragraph are central to the issue as a whole and to the success of the
document. RESCUE is not convinced that the issues inherent in this identification of the conflict
between the historic environment and mineral extraction are resolved in the document and suggests
that they are, to some extent, sidestepped in part because of the emphasis on description as opposed
to the identification of the central problem which is the cost (including the time cost) of adequate
archaeological responses to the extreme threat posed to archaeological assets by mineral extraction.
Introduction
The definition of ‘archaeology’ set out in paragraph 1 is an inclusive one and, while entirely
defensible in general terms, is not, in practice, followed throughout the rest of the document. The
inclusion of historic buildings for example, is not followed up by a discussion of historic building
legislation or of the methods of building survey used by either archaeologists or architectural
historians.
Paragraph 9 introduces the key policy basis for the document, Planning Policy Guidance
notes (PPG) 15 and 16. RESCUE questions the validity of equating these with the CBI
Archaeological Investigations Code of Practice and notes that the latter document has not been
updated to take account of developments in archaeological methodology since its publication in
1991. PPG 16, which dates from the same period, is a more flexible document and as such has stood
the test of time somewhat better (although as RESCUE has argued elsewhere, it is not without its
own problems). RESCUE is far from convinced that the CBI document is a sound basis upon which
to base current practice and would prefer to see a new and more robustly argued document replacing
it.
Mention of ‘marine settings’ in paragraph 11 draws attention to the very slight attention paid
to the issue of marine resources and submerged archaeological sites in the document. The marine
environment is increasingly being recognised as of great archaeological importance and has recently
become the responsibility of English Heritage. It is also a significant source of minerals and as such
requires specific attention if the particular archaeological issues raised by its exploitation are to be
addressed fully and properly.

Guiding principles (paragraphs 14 – 31)

The five guiding principles, summarised in paragraph 14 are, to a large extent unarguable but
they are not without problems. The first two (dealt with in detail in paragraphs 15 and 16) contain a
fundamental inconsistency in that mineral resources are described as ‘finite and irreplaceable’ but
mineral extraction has to be ‘steady, adequate and sustainable’. If mineral resources are finite (as
they clearly are) then extraction is sustainable only so long as those resources exist. Once consumed
by the development industry, extraction must move elsewhere or alternatives to exhausted resources
must be sought. The minerals industry, part of a development sector that has to continue to expand
and grow if it is to survive and to continue to generate profits for its stakeholders, is a fundamentally
exploitative one. In saying this, we are not making a value judgement, merely making an
observation on the nature of extractive industry. A sustainable response to issues surrounding
development would seek to reduce the levels of consumption of mineral resources through a wide
variety of strategies designed from the start with sustainability in view, from the recycling and reuse
of waste to a presumption in favour of the reuse and refurbishment of buildings on a scale vastly
greater than that which is the case at present. Such considerations open up areas of debate far
beyond those tackled in the document under discussion. In view of this they will not be further
developed here, but we look for a broader consideration of such issues at a later stage and involving a
broader group of stakeholders and a revised basis for the drawing up of the real costs of specific
schemes of development and the further expansion of the development industry.
Paragraphs 17 to 31 provide a useful overview of the archaeological process although the
absence of the consultancy sector from the description is notable. The existence of the consultancy
sector and its self-appointed role in seeking to mediate between developers and archaeological
curators in the sole interest of the former introduces an adversarial element into the system which
acts against the interests of all parties. It does this by imposing increased costs on the developer,
over and above anything that will be required to carry out an investigation of the archaeological
assets on a particular site and by seeking to undermine and subvert the role of independent
archaeological curators whose task is to reconcile the requirements of mineral planning and mineral
extraction with the nature of the archaeological assets within a given area. It is in this discursive
arena that critical decisions regarding archaeological assets and mineral resources are debated and
ultimately resolved and the omission of a group of key players is unhelpful in this respect.
 RESCUE is surprised to note the omission of the Palaeolithic from the discussion in
paragraphs 17 to 19. This is a serious omission given the presence in gravel deposits of evidence of
the earliest occupation of Britain amongst which are some of the more vulnerable archaeological
sites in the country. The survival, on gravel terraces, of in situ Palaeolithic occupation sites, is of
national and, potentially, international importance and deserves far greater attention than it receives.
The omission is all the more surprising because of the investment made by English Heritage in this
aspect of the archaeological record over the past decade.
Paragraphs 22 to 24 address the complex issue of archaeological importance. This is a
question which involves a surprisingly large and diverse number of social constituencies.
Archaeology, strictly defined, pertains to the description and interpretation of past human society
through the study of the material traces left behind by former populations. As such it is susceptible
to study using a defined (and ever-expanding) range of technical responses and theoretical
perspectives. It is largely these that are defined in the body of the document under consideration
here.
In a somewhat wider perspective archaeological sites and monuments attract a range of
responses over and above what might be regarded as the ‘purely archaeological’ as defined above.
This is not the place for a comprehensive review of this subject but a number of examples may be
used to establish the point.
For a sector of the population, specifically those concerned with the amenity value of a
historic or otherwise valued landscape a range of leisure pursuits exist which are orientated
specifically towards the appreciation of the landscape for and in its own right. Thus while walking
as a physical activity may be practised in virtually any environment, ‘walking’ or ‘rambling’ may be
understood by a large number of people as involving this activity specifically within a rural
environment and preferentially within wooded, upland, moorland, coastal or other environments.
The place of historic landscapes and the presence of upstanding archaeological sites, monuments and
features as crucial components of the wider ‘walking’ experience should not be underplayed, even if
the value placed upon them may not be identical to those of the professional archaeologist.
The growth in popularity of archaeology as both a technical and social practice and as a way
of understanding local, regional, national and personal history has, in the years since the widespread
availability of television, been dramatic. With the spread of new media and easier access to the
production of knowledge (through the creation of self-published books, websites, on-line discussion
forums and related resources) it seems that this is a trend that is likely to increase in the future. The
government’s recent emphasis on issues of ‘identity’ and national self-consciousness (through
debates over the nature of community relations and citizenship amongst other factors) seem designed
to increase and deepen such concerns.
Recent years have seen the rise of vocal and committed religious and quasi-religious groups
who, while highly diverse in their ideologies and beliefs, often cohere around the investment of
particular localities and monuments with elements drawn from their own particular belief systems
and from particular understandings of the nature of archaeological sites and monuments. While
RESCUE has no particular affinity with any of these groups and regards many of the claims that they
make with considerable scepticism, they do nevertheless represent a constituency with concerns
which may be considered to be as legitimate as those of any other group of religious believers.
These issues cannot be addressed in full here but they are relevant to the question of the
definition of the importance of archaeological sites in that they extend the notion of ‘importance’
beyond the exclusive judgement of heritage professionals or the employees of mining and quarrying
companies. RESCUE’s experience over the last decade is that as awareness of the archaeological
potential of even superficially unprepossessing landscapes and localities has grown (encouraged by
the variety of information sources noted above), so there has been an increasing commitment to the
importance of preservation and presentation of all types of archaeological features and monuments
both upstanding and buried. Much of this interest is locally or regionally focussed and pertains to the
relationship between the individual or smaller social groups and particular historical and landscape
features. The result of such growing awareness is a concern for archaeological and historic
landscapes and archaeological monuments and features which exists in parallel with ‘orthodox’
archaeology. While RESCUE feels that the concerns of the professional sector are to some extent
addressed in this section of the document, it omits all consideration of popular perceptions of the
value of archaeological sites, landscapes and monuments and in this respect will do little to resolve
future conflicts that will inevitably arise as the requirements of the mineral extraction industry
expand. While we recognise that discussion of individual cases is perhaps not required here, we
would suggest that the Thornborough Henges case is an example of the type of complex dispute
involving numerous parties with overlapping concerns which we believe will become more common
in the future if the very real nature of such concerns are not taken into account in documents such as
this.
Paragraph 24 represents a controversial point of view in which the general is explicitly valued
over the specific. It is asserted that

In areas where remains are relatively abundant, an additional find of a similar nature to others may not add
significantly to overall knowledge (paragraph 24)

The implication of this would seem to be that archaeological sites fall into specific categories,
each with an undefined number of identical examples. From this perspective, one medieval church
in East Anglia is much the same as another and the features of one Cumbrian stone circle will be
replicated (or at least adequately represented) by another some miles away. Such statements are
demonstrably false. The line of argument implicit in this paragraph would seem to hark back to the
uniformitarian principles advocated by the processual school of archaeological thought which were
thoroughly discredited in the 1980s and early 1990s. It is of great concern that such intellectually
bankrupt approaches should remerge here where they have the capacity to cause untold damage to
archaeological resources. A full recapitulation of the extensive debates between the processual and
post-processual schools of thought is inappropriate here but RESCUE will be pleased to provide
further information on this point, should it be required.
The notion of ‘value’, also introduced in this paragraph is also one which requires discussion
rather than simply assertion when deployed in contexts such as this.

The planning process and following sections

Paragraphs 32 to 40 cover the early stages of a planning application with the emphasis on
aspects of this process which are of particular relevance to the minerals industry. As a summary it is
concise and useful but in places appears to assume that the status quo is somewhat more advanced
than it actually is. In particular the references to regional research frameworks (which also occur
elsewhere in the document) seem to imply that these documents exist for all areas of the country.
This is not, at present, the case and it is particularly ironic that a document that (unusually) draws
many of its examples from northern England fails to mention that the regional research framework
for Yorkshire remains incomplete and to an extent controversial in the limited extent of the
consultation that has taken place regarding it to date.
RESCUE endorses an approach in which the emphasis is placed upon a consultative approach
involving the planning authorities and archaeological curators (see also paragraph 28) but recognises
that in practice, the existing system is far more adversarial in nature than could be guessed from the
description in the document. RESCUE would look for an acknowledgement of this and for concrete
proposals for ways to mitigate the negative aspects of the adversarial approach. It may be that this is
what is intended here, but the point is not made explicit.
Following a brief introduction (paragraphs 43 and 44) the remainder of the document is
concerned with an outline of the various techniques that have been developed in archaeology to
evaluate and investigate archaeological sites, features and landscapes. RESCUE notes (and is
surprised at) the omission of approaches, notably Historic Landscape Characterisation, which move
beyond the traditional site-based approaches to consider archaeological landscapes more broadly. As
such approaches are highly applicable in the case of landscapes threatened by large scale mining and
quarrying, their omission from the document is puzzling.
 The relevance of the photograph of a restored gravel pit on page 17 is unclear. There is no
doubt that restoration can deliver ecological and recreational benefits to an area, but there are no
comparable archaeological benefits as under most circumstances large scale quarrying will remove
archaeological features and deposits in their entirety. Only pre-quarrying investigation will mitigate
such impacts and restoration is, archaeologically, largely irrelevant other perhaps in some
exceptional circumstances in which the setting of a particular monument might be marginally
enhanced.
In the case of each technique discussed a short qualitative summary of the cost implications is
provided. These will be reviewed together below rather than being commented on individually.

Desk-based assessment
RESCUE entirely endorses the importance of undertaking desk-based assessment as the
essential preliminary stage of any programme of archaeological investigation. While the scope and
nature of such assessments vary to some degree between different curatorial bodies, the basic process
has been established through practice since the introduction of PPG 16. It is curious to see place-
name evidence placed ahead of archaeological literature in the list of sources typically consulted as
part of a desk-based assessment (paragraph 47), but we are willing to accept that this is an editorial
oversight rather than an implicit assertion that this most difficult (and often misleading) of data
sources is superior in its nature to the results of formal archaeological investigation.
Paragraph 48 includes reference to site visits and to ‘walkover’ survey (which could perhaps
more accurately be described as an ‘inspection’ as the term survey implies the use of measurement
and accurate recording). It should be noted here that the guidelines issued by the Institute of Field
Archaeology are somewhat more prescriptive in this regard than is indicated in the document (IFA
2001; paragraph 3.3.9) and archaeological curators faced with a survey lacking this element may
well require additional work in order to rectify the omission.

Aerial photography
We have little to add to the section concerning aerial photography (paragraphs 49 – 52) other
than to note that coverage is most effective when an area has been investigated in successive years
under differing weather conditions. Thus a county such as South Yorkshire, the subject of many
years survey by a number of photographers, has better and more detailed coverage than an area of
comparable archaeological complexity which may have seen only one or two season’s
reconnaissance. Such considerations have to be taken into account when reviews of existing aerial
photographs are commissioned with reference to specific applications for mineral extraction either as
part of a desk-based assessment or as a ‘stand-alone’ evaluative project. It should also be noted that
the absence of archaeological features from aerial reconnaissance is not unequivocal evidence of the
absence of archaeological features as geological and pedological conditions might preclude the
formation of cropmarks even when archaeological sites exist in the area.

Fieldwalking
The section on fieldwalking (paragraphs 53 to 56) gives a useful brief account of the
technique and its potential for contributing to a programme of archaeological survey. There are,
however, some worrying aspects to this section.
RESCUE questions the suggestion that an area might be ploughed specifically to facilitate
fieldwalking (paragraph 53). This would involve deliberate damage to archaeological features and
deposits in order to remove artefacts from their archaeological context for no other purpose than to
facilitate the identification of sites. RESCUE deplores this notion as one which elevates the surface
mapping of site location above the process of excavation by context. This, we suggest, is
incompatible with accepted archaeological methodology within which considerations of context and
association are paramount.
It is noted in paragraph 55 that ‘the most common finds are stone tools and pottery’. While
this may be true in a general sense, it does rather give the impression that such finds are universally
present. This is not the case in areas where, for a variety of historical and socio-cultural reasons,
certain classes of material culture were not present or were only present in certain archaeological
contexts. The manufacture of pottery, for example is a particular cultural choice which was not
exercised in a number of areas of the country at different times. South and West Yorkshire, for
example, are notorious for being virtually aceramic during the pre-Roman Iron Age and in the post-
Roman period in spite of being intensively settled and having complex organised landscapes. Parts
of Wales were likewise aceramic for much of prehistory and the earlier part of the medieval period.
The pre-Roman Iron Age is omitted from the list of periods deemed susceptible to fieldwalking for
reasons that are unexplained.
From a methodological point of view, it would have been useful to see mention here of the
potential role that can be played by the use of metal detector survey (when undertaken in conjunction
with a formal programme of fieldwalking or geophysical survey under archaeological supervision).
This is particularly the case for the early Anglo-Saxon period in eastern England, when settlements
and cemeteries are rarely identifiable by remote sensing techniques, the pottery is friable and often
not identifiable to period but there are a range of distinctive metal objects associated with both
domestic and cemetery sites. Metal detecting survey standards are included in Standards for Field
Archaeology in the East of England (Gurney 2003), a publication that should perhaps have been
consulted since it provides the consensus view of archaeological curators in one region on standards
for many of the techniques discussed.
The final paragraph focuses again on cost and it should be noted that while the process of
fieldwalking itself may be rapid, cost effective and relatively inexpensive, this is not necessarily the
case when it comes to analysing and interpreting the results. Pottery from fieldwalking is
notoriously time consuming to record and analyse as the quantities involved can be large and the
condition of individual sherds is typically very poor. Different methods of pottery manufacture
result in the differential survival of sherds in the topsoil which can bias results between and within
specific time periods. Patterns of manuring (a common explanation for the presence of pottery on
fields) and the methods of acquiring manure of various types may confuse and obscure the situation
with regard to local settlement. Slaughterhouse and domestic waste from 19th century Sheffield, for
example, was sold to farmers in Lincolnshire and transported thence in the same barges which
brought agricultural produce back to the city so patterns of pottery consumption evident from
fieldwalking data in Lincolnshire actually pertain to conditions in a major industrial city and not to
nearby rural communities. Such factors as this have to be taken into consideration when interpreting
fieldwalking data.
While it may be said that these examples are matters of detail, to be dealt with at the local
level, we would suggest that they are examples of the kinds of local idiosyncrasies which can
fundamentally affect the outcomes of individual schemes of investigation and which should be
acknowledged as contributing to the complexity of the archaeological process. To omit mention of
them risks presenting an oversimplified account of the archaeological process and misleading a
potential audience who may lack a background in archaeological methodology.

Test pits
Test pitting (paragraphs 57 – 59) suffers from some of the same problems as fieldwalking and
evaluative trenching (paragraphs 64 to 67) in terms of geographically or chronologically related
variability in the observable presence of archaeological deposits and features. Variation in the use of
pottery in time and space is again a problem and in areas with acid soils, bone may not survive.
Local conditions and the details of local history and social practice can have a profound effect on the
survival of archaeologically significant finds and features. Such factors have to be fully understood
when surveys are commissioned and when the results are analysed and interpreted. More generally
the technique suffers from the disadvantage of revealing extremely small and possibly
unrepresentative areas of a much more complex site or group of sites and can lead to serious errors of
interpretation. RESCUE would look for more caution to be expressed in relation to the use of this
technique and some emphasis on its limitations.
Geophysical survey and remote sensing
The section on geophysical survey and remote sensing (paragraphs 60 – 63) focuses on two
specific techniques (Ground Penetrating Radar and Lidar) which are, in practice, amongst the least
common and most expensive of geophysical techniques. It would have been useful to have a
paragraph describing resistivity and magnetometry while techniques such as phosphate analysis
would surely have been worth mentioning, at least in passing. No mention is made of the value of
combining geophysics with other techniques such as fieldwalking and aerial photography in order to
obtain a more fully rounded understanding of the archaeology of a particular area.
While paragraphs 62 and 63 are useful in outlining the problems posed by particular ground
conditions, pedology and geology, this section fails to deliver a rounded appreciation of the
contribution to archaeology which can be made by geophysical techniques.

Evaluation trenching
Evaluative excavation (paragraphs 64 to 67), more commonly known as ‘evaluation’ or
colloquially as ‘eval’ has become a mainstay of commercial archaeological practice but in spite of
this has attracted surprisingly little in the way of a critical literature. In part this may be because it
harks back to a rather cavalier, ‘freewheeling’ style of archaeology that certain practitioners find
appealing together with the fact that it appears to offer a cheap method of undertaking archaeological
investigations. In fact both test pitting and evaluation as commonly practised in Britain have many
of the disadvantages of the Wheelerian style of excavation that preceded the development of open
area techniques in the 1970s and it is unfortunate that this is not more widely appreciated within the
profession.
RESCUE feels that there are a number of flaws with this section which might, with
advantage, be addressed at greater length and in greater detail in subsequent versions of the
document.
The underlying assumption is that a series of trenches placed across an area of land will, by
effectively conforming to a probabilistic sampling strategy, reveal a representative sample of the
archaeological deposits in the area. The logical flaw in this assumption is rarely acknowledged but
lies at the root of numerous failures of the technique which tend never to be acknowledged. The
simple fact is that if a series of evaluation trenches reveals the existence of archaeological features or
deposits then it is clear that such features exist on the site. The converse is not true. If no
archaeological features are revealed then the only logical conclusion that can be drawn is that there
were no features existing in those areas where the evaluation trenches were placed. An abundance of
features may exist a matter of inches from the edge of the evaluation trench but will not be detected
by it. Although this methodological flaw is not acknowledged in the text, the photograph on page 6
clearly demonstrates the point. RESCUE would have expected to see some discussion of the value
of combining evaluative excavation with other techniques, notably aerial photography, fieldwalking
and geophysical survey.
Other problems with evaluative trenching are discussed in paragraph 66 and issues of sample
size and the use of probabilistic sampling are alluded to in paragraph 65. It is deeply unfortunate that
more space is not devoted to a discussion of these matters as it is at the level of detail and individual
practice that evaluative trenching stands or falls as a valid technique. Issues of sampling strategy and
the assumptions which underlie different strategies were debated at length in the days when
processual archaeology was the dominant intellectual paradigm within the profession but none of this
is referred to here. While processualism has, thankfully, ceased to be an intellectually respectable
position within archaeology, it is noticeable that some of its more questionable practices are re-
emerging in the guise of ‘common sense’ and establishing themselves in day-to-day practice without
acknowledgement of the problems inherent in them. It would be particularly valuable to have seen
more discussion of the contribution of Hey and Lacey (2001) in this regard, particularly given the
comments made in the covering letter (discussed separately below). Hey and Lacey are clear that
samples of between 3% and 4% yield ‘moderate to good results’ (2001: page 54-5, paragraph 5.1.6)
while higher percentages yield more reliable archaeological results (albeit at a higher financial cost).
The lack of any serious discussion of the results of Hey and Lacey’s work is a striking omission from
the document, particularly given the emphasis on the earlier and less robust CBI Archaeological
Investigations Code of Practice throughout the document.

Geomorphological mapping
RESCUE would suggest that some of what is dealt with as ‘geomorphological mapping’
(paragraphs 68 – 70) ought to form part of the desk-based assessment while the more detailed
techniques should form part of any comprehensive landscape survey undertaken on land threatened
by quarrying. Reference to the principles and practice of Historic Landscape Characterisation might
also have strengthened this section by relating it to other compatible survey techniques. The
important point, which is not perhaps sufficiently emphasised, is that all archaeological survey
involves the combination of techniques drawn from a range of related disciplines in addition to
specifically archaeological techniques. Some methods will be more appropriate in certain areas
(dyke survey in the Fens for example) than in others and it is not possible to specify a range of
techniques that will be universally applicable. Detailed local knowledge is essential if techniques
appropriate to the area under consideration are to be employed and this reinforces the importance of
the role of local archaeological curators in the process of assessment.

Sediment analysis
RESCUE has few specific comments on sediment analysis (paragraphs 71 – 73) but again
notes the importance of understanding local conditions in the design of investigative strategies. The
omission of any reference to the scientific study of sediments is curious as this is implied in the
reference to ‘specialist equipment and staff’ in paragraph 73.

Post-permission mitigation measures

The introduction to the section dealing with post-permission mitigation measures
(paragraphs 76 to 78) includes a series of criteria for archaeological conditions on mining and
quarrying. These are not referenced to any other source and there is no discussion of the value
judgements contained within them. RESCUE would query the inclusion of the ‘catch-all’ criterion
‘reasonable in all other respects’ (paragraph 76; number 6). We would look for a great deal more
precision here and discussion of the term ‘reasonable’ with reference to the different constituencies
affected by mining and quarrying operations.

Watching brief
In many ways watching briefs (paragraphs 79 – 82) hark back to an earlier, more chaotic
stage of archaeological investigation and still, for many practitioners, conjure up visions of
archaeologists risking life and limb to record features as they vanish beneath earthmoving machinery
or plucking pots and other artefacts from the buckets of mechanical excavators. Such a technique
was, notoriously, advocated during the 1990s by a leading archaeological consultant as a valid
method of obtaining a representative sample of human remains from a medieval cemetery, a
suggestion that was rightly scorned by all who were aware of it. In spite of this highly questionable
history, the technique persists, although (in all cases we would hope) mitigated by the sensible
provisions of health and safety law.
RESCUE is not an enthusiastic advocate of watching briefs although we acknowledge that
the technique is one which is likely to continue to be used, particularly where cost is a major factor.
The difficulties of ensuring sufficient numbers of experienced individuals on a site (particularly an
extensive site such as a quarry) and a consistent level of monitoring of machinery under difficult
conditions means that there is always the danger that important sites will be missed or severely
damaged before appropriate measures can be taken to investigate them. Even if adequate monitoring
arrangements can be put in place, there is the additional problem of ensuring a rapid response by a
dedicated and appropriately experienced team should archaeological features or deposits be
identified while at the same time maintaining monitoring elsewhere on the site. These aspects of the
process are omitted from the discussion, to the detriment of the document as a whole.
While watching briefs will probably remain a fact of life for the foreseeable future, we
welcome the note of caution in paragraph 82 with regard to the possible expense and inconvenience
that they may cause and would add to this the possibility that the archaeological outcomes may also
be highly unsatisfactory.

Excavation
The brevity of the section on excavation, while to a degree understandable given the nature of
the document, fails to do justice to the range of techniques necessary to fully investigate, understand
and interpret a site. It is disappointing to see excavation described as ‘destructive’ (paragraph 84)
when it is actually a highly creative process through which we bring to light new information
regarding past human lives, activities and forms of social practice and social structure. The casual
and intellectually dishonest characterisation of excavation as a destructive process (of which this is
but one example) appears to be part of an implicit programme to discredit what is in fact the most
rigorous and effective archaeological technique in order to support a ‘preservation in situ’ ethos
which would, if carried to its logical conclusion, support a preservationist approach to archaeology
that would prevent us moving beyond bland, common sensical accounts of past human lives and
social structure.
The account of the process of excavation given in the bullet pointed notes in paragraph 84 is
so brief as to be misleading, particularly in terms of the balance between fieldwork and post-
excavation analysis and reporting. It is surprising and perhaps revealing that crucial documents
pertaining to excavation are not cited, notably MAP II (English Heritage 1991) and there is no
mention of the type of integrated work involving specialists in a variety of disciplines which is
essential if the work on-site is to be carried through to a successful conclusion. It is hard to avoid the
suspicion, when reading this section that English Heritage is retreating from the principles set out in
MAP II and is failing to replace them with an equally intellectually rigorous alternative. This has, de
facto, already happened in much of commercial archaeology (in spite of the ritual invocation of the
document at the beginning of many written schemes of investigation) and a restatement of the
policies and practices set out in MAP II would have been most welcome here. We can only take its
absence as indicative of a retreat from the rigorous standards that ought to exist within field
archaeology in the face of hostility from the development industry.
Paragraph 85 focuses on the intensive nature of excavation and its cost rather than on the
quality of the results and the enormous contribution that archaeological excavation has made to our
understanding of human life and human society in the past. Nor is mention made of the excitement
that is generated by excavation amongst the general public and of the enduring popularity of
excavation as both a spectator event and as a means of engaging directly with the past. While
RESCUE is fully aware of the problems inherent in involving voluntary and amateur groups in
commercial excavation (insurance, site access, health and safety concerns etc), it is perhaps true that
certain (although by no means all) excavations undertaken in advance of quarrying operations are
more suitable for such participation (given the availability of experienced supervisors and mentors)
than are most brown field and urban sites. Given that quarrying operations are instrumental in the
wholesale transformation of the environment of local communities, it would seem appropriate that
such communities should gain some cultural and educational advantage from the process, in parallel
to the extraction of financial value from their environment for the benefit of shareholders and others
located many miles away and often in entirely different countries.

Strip and record

Some of the same reservations expressed in relation to excavation also apply to ‘strip and
record’ although it is good to see that some of the positive results achieved through the use of the
technique are mentioned (paragraph 88). While the description of the technique is adequate, many of
the critical issues are sidestepped or are mentioned only in passing. This includes the all important
question of sample size which is mentioned in paragraph 86 but is not developed. RESCUE would
expect that in all but exceptional cases, excavation would aim for 100% investigation of features
revealed during a strip and record exercise. The technique is, after all, a relatively new one and
given that there is still much that we do not understand or cannot yet explain about prehistoric and
early historic societies, the opportunity to investigate sites on a spatially extensive scale, ought to be
taken wherever it occurs. This is particularly the case where mineral extraction will result in the total
destruction of the sites revealed by the stripping process.
As with other sections, the emphasis in paragraphs 86 – 89 is on fieldwork; post-excavation
analysis and interpretation, the creation of site archives and publication are all omitted from the
summary.

Archaeological survey
As with the descriptions of other techniques, the section on survey is brief and gives a broad
outline of the merits of the technique. The caption to the photograph on page 30 makes the point that
survey is non-intrusive, but the converse point, that survey is often unable to contribute significantly
to questions of sequence, timescale and date is omitted, apparently better to support the rhetorical
point (noted above) that excavation is a Bad Thing. RESCUE profoundly disagrees with this view,
seeing survey and excavation as equally essential and equally valid in the appropriate circumstances.

Palaeoenvironmental analysis
The brief section covering palaeoenvironmental analysis (paragraphs 94 – 97) provides a
brief acknowledgement that a considerable part of archaeological work takes place off-site, in this
case in laboratories. It scarcely does justice to the profound impact of such work on the
reconstruction of ancient environments, not only in contributing to our understanding of the character
of the world in which people in the past lived, but in contributing to an understanding of our modern
climate and wider environment which grows more important by the day.

Conclusion
Two paragraphs (98 and 99) conclude the document, the first of which consists largely of
statements culled from Force for our Future and a statement from the Quarry Producers Association,
both of which are so bland as to be largely meaningless. RESCUE looks to both the government and
the minerals industry to take radical steps in order that such statements are translated from mere
rhetoric into practical action and concrete commitments to ensure that all archaeological sites
threatened with destruction by mining and quarrying are fully and adequately investigated prior to
quarrying operations using appropriate techniques and with fully resourced programmes of post-
excavation analysis, interpretation and publication.

Discussion
Having reviewed the contents of the document on a paragraph by paragraph basis, a number
of general points must be addressed.
The question of cost is stressed throughout the document (in relation to each archaeological
technique described and in paragraph 29) and it is clear that this issue is one that has concerned the
authors, possibly above all others. RESCUE would argue that the archaeological investigation of
threatened sites and landscapes should not be an option which can be set aside subject to cost, but
should be reckoned as a fundamental cost to be borne by the industry and its clients just as the costs
of machinery, labour, Health and Safety and so on are borne. As a powerful and successful economy
it is scarcely possible to argue that Britain should be in a position of having to discard archaeological
assets in pursuit of economic security. Archaeological investigations may cause the costs of mineral
extraction may rise slightly and shareholder dividends and individual profits may decline slightly,
but these are factors that have to be accepted as part of living in a modern, advanced and socially and
intellectually inclusive society. Arguments from economic necessity are unconvincing when set
against the nature of contemporary British society in which necessity has long since been overtaken
by desire and gratification as the principal impulses behind social and economic practice. Quarry
companies have been persuaded to adopt principles (and costs) of the reinstatement of landscapes
and ecosystems and now need to be persuaded with equal vigour that they cannot, with impunity be
allowed to destroy the nations shared cultural heritage. Ownership of mineral rights does not confer
ownership of the social and cultural heritage of millions of people and archaeologists and
government should be working together to bring this to the attention of the minerals industry. The
provisions of PPG 16 are, to some extent, an acknowledgement of this, but the point appears to need
constant restatement. It is unfortunate that the opportunity offered by the publication of this
document has not been taken as an occasion which to do this.
A more specific general point has been alluded to at several points above but can be briefly
restated here. The examination of the different archaeological techniques focuses exclusively on
fieldwork. Virtually no mention is made, other than in relation to palaeoenvironmental analysis, of
the costs and timescale involved in post-excavation analysis and reporting. This is a serious
omission in that post-excavation work has time and cost implications which form a large part of any
budget for archaeological investigation. This is true both directly in terms of individual projects and
more generally in terms of resource allocation in terms of access to museum collections, local and
regional ceramic type series, the training and support of specialists and so on. It is far from clear
why, given that a large number of individuals and organisations are credited as being involved with
the writing of the document, no one with a background in finds work or other post-excavation work
was consulted during its compilation.

The covering letter

Two versions of the covering letter have been seen by RESCUE, one of them from English
Heritage and one from the Association of Local Government Officers (ALGAO). This response
refers specifically to the latter although it is understood that the content of both is substantially
similar.
The letter outlines the breadth of consultation that has preceded the production of the
document and provides some background to the content. In doing this the covering letter goes
beyond the document itself in offering comments on questions of sample size and offers a direct
criticism of those curators who have asked for a 5% sample size during the evaluation of certain
unspecified sites. Such criticism is inappropriate in a covering letter and the point needs to be argued
properly if it is to be made at all. The use of the casually dismissive phrase ‘a rash of requests for
sample sizes of 5%’ implies a frivolous attitude on the part of the curators concerned and the reader
is left unsure whether these unnamed individuals simply woke up one morning and decided that it
was a nice day to demand 5% samples of threatened archaeological assets or, something that is far
more likely, whether they had good reasons to seek samples of this size, perhaps because the 1-2%
sample norm has long been recognised as having no basis in empirical study and was, in fact,
plucked out of the air by one archaeological unit manager in the early 1990s.
It is noted that although the work of Hey and Lacey (2001) is referred to on several occasions
in the document, no attempt is made to discuss the content or implications of their work in detail.
Given this it is unclear why the covering letter should be chosen as a suitable vehicle for an attack on
their work given that such a context does not allow space for reasoned argument and discussion.
A list of key issues are emphasised by bullet points at the end of the letter. The purpose of
this list is not clear as it includes issues which are not addressed in the document and in some cases
which need arguing on a detailed, case-by-case basis. The fact that these points are not numbered
while specific references to numbered paragraphs in the document itself are required in responses to
it (as stated in the ‘timetable’ section) seems to imply that these points are considered to be beyond
discussion when in fact they provide more grounds for discussion than much of what is contained
within the document itself.
RESCUE finds a number of the key issues to be disturbing in their implications.
 • A strong desire from industry to resuscitate the CBI Code of Practice for Mineral Operators,
with its suggestion that sampling should be no greater than 1-2%, to combat what it sees as
excessive requests for large sample sizes without adequate justification;
The attempt to ‘resuscitate’ (not RESCUE’s choice of word) the CBI Code of Practice for
Mineral Operators with its attempt to impose a blanket limit of 2% on sample sizes is unsatisfactory.
The original document lacked any empirical justification or support and has long been superseded by
more detailed studies, including that carried out by Hey and Lacey (2001).

• The industry’s concern that the approach by mineral planning authorities’ archaeological
advisors varies significantly within and particularly across regions, without any apparent
defendable justification;
Some effort to understand the nature of archaeology and the survival of archaeological assets
and resources is required from the industry. While the details of archaeological interpretation and
reasoning may on occasions appear arcane for the lay person, the basic point that human being react
to and in accordance with their immediate environment and cultural traditions is scarcely a difficult
or problematic one. Nor is the fact that the survival of archaeological assets differs across the
country as a result of differing environmental and anthropogenic conditions one that is particularly
difficult to grasp. RESCUE would advocate much closer interaction between the minerals industry
and local archaeological curators with a view to resolving such issues at an early stage. This is
preferable to the feigned deafness of the industry to issues of regional variation and demands for a
standardisation of response. Frankly, RESCUE is surprised that an industry which is surely well
used to dealing with geological and pedological variation at the local, regional and national scale can
claim to lack an understanding of comparable variation in human responses to the environment.

• The desire of the sector to stress that there is no ‘one-size fits all’ approach, that
requirements and expectations should be based on a well-founded knowledge and
understanding of the archaeology of any given area which should result in clearly
articulated, objective-driven strategies based on the five agreed principles contained within
the Practice Guide;
Once again, better liaison between the industry and archaeological curators at an early stage
is surely the key here. With the aid of regional research frameworks (where these are available) and
local environmental plans it should be possible to devise mitigation strategies based upon well tried
and tested archaeological methods as well as new innovations which will allow proper investigation
of unique and irreplaceable archaeological resources.

• That the Practice Guide should demonstrate what evaluation practices are currently
available, the kinds of situations where they are generally most appropriate and an
indication of the scale of costs likely to be involved in applying them;
As the foregoing critique should make clear, while RESCUE agrees that the provision of
information is essential to clarity of discussion, we do not feel that this aim has been achieved in this
document, for the reasons set out in this response.

• The industry’s desire to stress the need for good strategic planning for minerals provision
that draws properly on HER data and advice;
RESCUE is in full agreement with the principle that planning is essential both to ensure an
adequate supply of essential minerals and also the full investigation of archaeological resources
threatened by mining and quarrying operations. In view of this we agree that clear and explicit
documents be provided that will facilitate such planning. We are not, unfortunately, convinced that
this document fulfils those aspirations.

• That nothing in the Guide goes beyond the requirements of PPG16 (and PPG15) and other
planning policy, guidance and practice e.g. EIA Regs;
PPG16 was promulgated in 1991 and has been the subject of detailed comment and critique
in the years that have passed since then. A number of archaeological bodies, including RESCUE,
have sought to make a case for the replacement of PPG15 and PPG16 with a statutory instrument that
will better ensure the protection and investigation of the history of human occupation in Britain
through archaeological techniques. In view of this, PPG16, while remaining the cornerstone of the
present system of heritage protection, cannot be considered to be beyond criticism. RESCUE would
suggest that if better practices can be encouraged through the formulation of agreed strategies
between specific industries and archaeological curators, then this represents a step forward and as
such should not be discouraged.

• That everyone is aware that the Guide is not policy it is guidance, but that it is an important
document that is likely to be cited at appeal;
This is absurdly disingenuous; it is inevitable that the document will carry significant weight
once published given that it has been compiled by the Forum and is published by English Heritage.
To try to assert that it will not simply adds confusion to issues that are already controversial and
around which discussion often lacks clarity.

• That the Guide is a Forum-driven document. It attempts to reconcile range of competing

views and, while it is never going to satisfy everyone, its present form and content is
considered to cause least offence to everyone involved.
While no one, least of all RESCUE, wishes to give gratuitous offence to anyone, there is a
need for guidance on the matters covered by the document that is both clear and robust. As it stands,
the document fails to deliver this, in part, perhaps, because of the desire to avoid controversy
revealed by this comment.

Overview and conclusions

Planning for mineral extraction and archaeology is a curiously conservative publication.
While the intention seems to have been to present a comprehensible and cogent account of the
archaeological process as it exists in Britain today it omits too much for it to be entirely successful in
this regard. A number of points can be highlighted:

• The concentration on fieldwork techniques at the expense of virtually all other stages of the
archaeological process betrays the limited range of consultation within archaeology;

• The failure to address the objectives of archaeological research or the interpretative nature of
the discipline leaves the reader unclear as to the reasons for the emphasis on data recovery;

• The choice of survey techniques to highlight is eccentric at best; Lidar and ground
penetrating radar are highlighted but the commoner techniques are omitted entirely or are
mentioned only in passing;

• The emphasis on preservation in situ devalues the potential offered by excavation and survey
to contribute to the wider and deeper social and historical narratives which are the outcomes
of archaeological investigations.

The document is also highly defensive in tone as if the authors feel it necessary to apologise
for the existence of archaeology and to pass it off as a regrettable necessity to be imposed on the
minerals industry. We looked in vain for any sense that the search for understandings and
interpretations of past human lives and societies is one that is commonplace throughout humanity or
that the results of archaeological investigations are of consuming interest to many millions of people
in the UK (as recently acknowledged even by government ministers).
The curiously anachronistic tone of the publication is enhanced by the elimination of the
voluntary / amateur sector from the document and there is only the barest acknowledgement that
archaeology and history are not only matters for professional archaeologists but are of concern and
interest to millions of people throughout the UK and, indeed, beyond. The minerals industry has
demonstrated that it can address wider social concerns through its attention to matters of
reinstatement of landscapes and the creation of nature reserves and public amenities as well as by
retuning quarried land to agriculture. We need to see an extension of this concern to the pre-
extraction stage as well as the post-extraction stage of the mining and quarrying process and we need
to ensure that the minerals extraction industry recognises both the uniquely destructive nature of its
activities and the value that can be added to these activities through proper attention to
archaeological and historical matters. It is to be regretted that this document will do little to advance
such a cause.

Bibliography
English Heritage 1991 Management of archaeological projects 2nd edition (MAP II) English
Heritage.

Gurney, D. 2003 Standards for field archaeology in the East of England East Anglian
Archaeology Occasional Paper 14.

Hey, G. and Lacey M. 2001 Evaluation of archaeological decision-making processes and

sampling strategies. Oxford Archaeological Unit

IFA 2001 Standard and guidance for archaeological desk-based assessment

http://www.archaeologists.net/modules/icontent/inPages/docs/codes/dba2.pdf