When I saw the sheer extent of the 2018 Waun Mawn dig, I was immediately concerned about its impact on a specially protected area -- inside a National Park, inside an SSSI and inside a Special Area of Conservation too. That all represents -- in theory -- the highest level of protection possible under British law. I wondered what the consent process was for archaeological digs of this type -- who does the applying, to whom, and how are consents issued? Are there any inputs into the process from other interested parties like Wildlife Trusts or CPRW? What judgments are made on costs versus benefits? (In other words, does somebody make a judgment on whether the environmental damage is acceptable when set against the potential scientific or cultural value likely to come out of the dig?) Further, what conditions are attached to consents, what monitoring is there, and what sanctions are there if the terms of the consent are breached?
and published a few photos of the open pits.
First, I asked the National Park whether they had issued a consent. No, they said, the whole process is handled by Natural Resources Wales (NRW). There is no input at all from Cadw, RCAHMW or the Dyfed Archaeological Trust -- and that's interesting in itself. It doesn't appear that other bodies are even asked for their opinions. Nobody apparently asked what the purpose of the dig was, or what the chances were of making significant finds. I checked on the NRW web site for any trace of a consent, but there is no searchable database. That means there is no role in the process for interested parties or the general public -- unlike the situation with regard to planning applications. There is no public record that can be searched. The only way to get information is to write in with a specific request. So I banged in a letter. After 20 days or so I got a reply, and it was very interesting indeed..............
It appears that the application to NRW was made on 30th July via the Barony of Cemais -- the landowner of the Preseli commons. That means that the Barony received the request from Prof MPP
and his team, approved it, and passed it on to NRW on his behalf. The application was in the form of a simple letter, asking for consent for "archaeological excavations" involving six trenches, each one no larger than 90 sq m, with a maximum area excavated totalling 540 sq m. The work was due to start on 2nd September, lasting for 3 weeks. There was no mention of the proposed depth of the trenches. The applicant stated: "Trenches will be excavated by hand. On restoration, they will be backfilled by hand with their soil, stones and turf so as to leave them in the condition in which they were found." Prof MPP also said on the application: "Vehicle use will be restricted to an ATV (all-terrain vehicle) provided by the National Park authority and driven by one of its staff, warden Richard Vaughan. The archaeological team will carry all equipment to and from the excavations on foot. They will park at recognised parking spaces and walk to the sites each day."
Consent for the operations was given on 8th August. (Consent Ref No: 2278324) No conditions or monitoring requirements were added at the consent stage, and so it was a straightforward "rubber stamping operation" taking just a week and involving minimal scrutiny.
So to the dig itself. It appears that the vehicle use restrictions were adhered to, and the dig was indeed completed without the use of mechanical diggers. A lot of human labour went into it! But this is what happened.......
Since NRW is clearly not very interested in checking that the terms of its consent have been adhered to, I offer it some assistance. In some cases it is quite difficult to determine where the boundaries are between the 2017 and 2018 excavations ("trenches" is the wrong word, because they are actually all quite shallow), and some parts of the 2017 digs have been re-opened. But as far as I can see there are 15 new excavations (not 6), ranged around the circumference of the putative giant stone circle. The total surface area involved in actual digs seems to be about 500 sq m, with approx the same area disturbed by soil and turf dumps, working traffic and vegetation clearance. Most of the work has been done in the NE and NW quadrants, and the biggest areas stripped of turf are in the south, where one excavation covered 60 sq m, and in the SW, where one covered 198 sq m. In the report sent to me by NRW, this is what their field officer said:
** Following completion of the works the applicant contacted me to state that they had accidentally gone over the consented 540m sq. He calculated that they had in fact excavated 700m sq. The applicant apologised for this accidental event.
** Unexpectedly dry weather this year will have undoubtedly hampered the reestablishment of the turves. I have not visited the site yet but will do so to assess if anything further needs to be done in terms of restoration.
** A letter will be sent to the applicant informing them that, should any consents be issued in the future for similar work, they must ensure that the works adhere strictly to the terms of that consent.
MPP has been quite honest in admitting that the area excavated in Sept 2018 (probably including the reopening of some 2017 pits) is about 700 sq m. I wouldn't argue with that, although one does wonder about how an area of 160 sq m could have been excavated "accidentally." But what worries me more is that one of the pits -- at c 198 sq m -- is far in excess of the maximum size allowed under the consent; that the replacing of turves has been for the most part pretty slapdash; and that some excavated areas (including one area of about 8 sq m near the eastern limit of the investigated area) have not been reinstated at all. All pegs, markers etc have been taken away, and the site was left clear of any litter -- so that's something to be thankful for.
I shall also ask NRW whether they are satisfied that their "due process" has provided an adequate level of protection to this sensitive area, given the requirements placed upon them in law.