FAME response to Fenland District Council
Newly-installed Fenland District Council Leader Alan Melton has shocked the archaeological world with an announcement that conservation rules in the district are to be relaxed and pre-application archaeological evaluations no longer required. The full text of his speech can be viewed here. FAME has written to Councillor Melton, pills emphasising the importance of pre-application assessment, cough and the potential risk of costly delays and disruption should archaeological deposits be revealed once development is underway.
“Dear Councillor Melton
Fenland District Council and Archaeology
I am writing to you on behalf of the Federation of Archaeological Managers and Employers, which represents around 50 archaeological businesses providing advice and specialist services to commercial clients and developers throughout the UK.
We were concerned to read your comments last week on proposed changes in policy on archaeology and development in Fenland District.
Fenland contains some of the most significant and exceptionally-preserved archaeological deposits in the country and our members have been actively engaged in archaeological excavation, recording and publication within the district for many years.
The changes you suggest would of course have serious consequences for the archaeology of Fenland, those businesses who record and interpret it and those local residents and communities who benefit from it.
However, my reason for writing is to raise our particular concerns about its potential implications for our clients in both the public and private sector.
For the past two decades, central and local government planning policy has provided a clear and effective framework in which archaeological issues can be dealt with through the planning and development management process. This remains true of both current and proposed national planning guidance, and is reflected in Fenland District Council’s own development plan policies.
The fundamental principle underlying all this guidance is the necessity for the earliest possible assessment of archaeological significance – to provide greater certainty for applicants and developers before planning applications are determined, and to reduce the risk to them of costly delays and disruption once planning consent has been granted and development is underway.
This strategy of pre-determination survey is precisely the same as that which has proved so effective in assessing other environmental constraints, such as flood risk and hydrology, ground stability, land quality, ecology, access and transport.
In our extensive experience of advising commercial clients and developers throughout the UK, the greatest risk they face in relation to archaeology is not the cost of potentially unnecessary pre-application works, but the uncertainty of proceeding with development without first having assessed its likely archaeological impact. Whilst many business clients might well begrudge the cost of pre-application works, most will accept them as an essential risk-management measure.
We do not disagree with you that archaeological requirements must be reasonable and, as government planning guidance makes clear, proportionate to the significance of the archaeological remains. However our fear is that, far from promoting economic growth, a return to an era of eleventh-hour post-consent archaeological works could have potentially very costly and disruptive consequences for the development sector.”
cc Sandra Claxton, Chief Executive, Fenland District Council
Derek McKenzie, Head of Development Services, Fenland District Council