The Waun Mawn dig -- consents and conditions

I have been in touch (I'm probably not the only one) with Natural Resources Wales about the 2018 dig on Waun Mawn, conducted by Prof MPP and his colleagues, and have a detailed reply from the Senior Conservation Officer for Pembrokeshire.

I'm reasonably happy with the reply.  There is an admission that the consent was too loose, and that the monitoring of the work in progress was not as effective as it might have been.  So I'm reassured that there will be tighter controls in the future, should there be future digs in highly protected and vulnerable landscapes.

Some of the main points arising:

1.  The conditions laid out in the consent were not fully adhered to.

2.  NRW accepts that the breaches of the conditions were "not intentional".   Hmmmmmm..... my own view is that the diggers were so desperate to find stone sockets that they just kept on digging....

3.  No sanctions will be taken, and so NRW is sticking, at this stage, to "the provision of advice and guidance".  I think that's fair enough.

4.  There is no requirement that the diggers should return to the site, clear up all the stones that they have left lying around, and re-turf those areas left bare.  Quote: Some of the turves have also been cut too thickly to allow them to sit easily on the ground surface when re-laid. The visual impact of the excavation is exacerbated by the fact that the excavated material was placed directly on the ground surface and some soil and stones have been left behind after the trenches were refilled.  On balance, I accept the NRW point that a return to the site to undertake remedial work might well do more harm than good.

5.  I asked NRW whether, prior to giving consent (in just 7 days from receipt of application) for the dig, they consulted with other bodies (eg Cadw, National Park, RCAHMW, Dyfed Archaeology, Wildlife Trust, Biodiversity Partnership etc) in order to check on whether the dig was necessary rather than frivolous, and whether ecological impacts were properly assessed. This was the response: "It is not the responsibility of NRW to ensure a consent application is compliant with all or any other legislation - that is the responsibility of the applicant. Given that the work was undertaken by a professor at the UCL Institute of Archaeology NRW had no reason to question the validity of the proposed work nor to oversee it."  That lack of coordination and input from expert bodies is, I think, more than a little worrying, since there should be some way of heading off or discouraging digs in which the costs are likely to be far higher than any possible benefits.

6.  There appears to have been no effective oversight or monitoring in this dig, although the local National Park ranger was on site for part of the time during the dig.   Quote: "NRW feels that our Enforcement and Prosecution Policy is usually adequate but recognises that in this case there was insufficient oversight of the works to avoid what we accept was an accidental breach of the consent conditions."

7.  So will things be a little less cavalier and more tightly monitored in any future digs?  Let us hope so.  This is from the letter:

NRW has stated that, prior to any further consents being issued, a site meeting would be required where locations and sizes of excavations would need to be agreed and marked out. A number of conditions regarding reinstatement would need to be adhered to:

1. All trenches to be excavated should be marked out to an agreed size.
2. All turves should be cut around 10cm thick.
3. A turf cutting machine should be used where ground conditions allow.
4. Turves should be kept as large as possible (around 20 x 20 cm as a minimum).
5. Turves should be stored on plastic sheets to avoid damage the vegetation in the storage area.
6. Stored turves should be covered to avoid them drying out.