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Pembrokeshire Coast National Park Authority 


Pembrokeshire County Council 


Pembrokeshire Coast National Park Local Development Plan 2 


Pembrokeshire County Council Local Development Plan 1 


HISTORIC ENVIRONMENT (ARCHAEOLOGY) 


Supplementary Planning Guidance 


This item is also available in Welsh/ Mae'r eitem hon ar gael yn Gymraeg hefyd 


Pembrokeshire Coast National Park Authority 


Consultation September 2020 


Adoption approval date 


Pembrokeshire County Council 


Consultation October 2020 


Adoption approval date 


Contents 


sedit —————————Á—————————————— 1 
INTRODUCTION e—————————M 2 
SECTION A - WHERE CAN I GET INFORMATION AND EARLY ADVICE? ...........................eeeeeeeeee eene eene e nennen nenne nn nnuue 4 

How are archaeological sites protected? ............... esses essen nh nnns ness thia sa nisse serta rada s asses easi ada asas nnn 4 
SECTION B WHAT HAPPENS BEFORE A PLANNING DECISION? .............................eeeeeeeeee eese e eene nenne ense sss sn nass s sss suu 6 


Preservation of Archaeological Remains in situ 






Preservation of Archaeological Remains by Record 


SECTION C WHAT HAPPENS FOLLOWING A PLANNING DECISION? ..........................e eee eere eene nennen nnne nnne nnnnn 10 
APPENDIX 1 RELEVANT LEGISLATION AND POLICY REQUIREMENTS ....................... ee ee eee eene ee eene nennen nennen nnno 12 
Scheduled Monuments and CadWw ............... sees siis seen siii tnn enini seen soia ia esses tasses tns ss sa esses an assets 12 
Human:Remains 5er enit eee ee RH deant e e Ae oer i ceu dés eed bes 13 
Hedgerow:Regülatiahs: 5 eiii ee terr nd aede eee A200 ced bon EY ENT Lo oh Fed EY asides o SE YR sy ed ae ea rea Na RET Q IE CEPR ge ET 13 
Historic Parks and Gardens Register ............... sss esee seen nnne nh nhan nsns ssa taa d asas essa sa ada asas sse sa sa daas iaasa 14 
Historic Landscapes Registers............... sessi esses eese nennen ener AE sse Aa aa sess ea Aaaa AE a sa aa dass assa easi aa daas EAEn 14 
Landscapes of Outstanding Historic Interest ..........ccceessssscececeseessassceseceseesscseceseceseeseasecesecsesesasesesecseeesesseasseeees 14 
Landscapes of Special Historic Interest................. eiiis sessi n nnns en na ra asas sess ALEEN assess ea sa ra daas assa 14 
Assessment of the Significance of the Impact of Development on Historic Landscapes Areas - ASIDOHL ..... 15 
Historic Landscapes of Regional or Local Importance ............... isses esee eene en nhrhan asses enti ra dans nnn 15 
Other Environmental Considerations ................ eese eee enn seinen nnns tenth siis sa esses thai itera nissan 16 
APPENDIX 2 CONSIDERATIONS FOR UNDERTAKING ARCHAEOLOGICAL WORK .......................... eene ee eene nnns 17 


Responsibility for Costs 







Quality Control sssrin AF EE RARE Goo 
How to find an Archaeological Contractor 


APPENDIX 3 ARCHAEOLOGICAL WORK ......................eeeeeeeeeeeesess sess ese sh sss husu sss assa sa sass sss ss asas sss sssa assa assa sss ss assa asas aun 19 


Historic Environment Appraisal... are e aha een a RENE Rx e steeds e PERR URN EMT IT CHR R RR na EET e Pe RRRAEE VE SY enda 
Desk:büsed'assessment «5:0 estt cc etre n e xa Hg LR Ego e eque E T ERN URL Re 
Eaürthwork SUkVeyui iis iitecsii eie A CERE ER AE FRE AER EE RENE TS EXER VER EAN VL UTER A a A A TR RATES UTER RYAN RA 
Remote sensing / Geophysical Survey .... 


Field: EvaluatiOnss:;.i ne c ete e E ERR ENTERO E a RR RIDERE nie eda 

BUIGING ateolgelis sam ————— — teiees 

Watching Brief... s i du e eds on e ee ad a reda Te ROBA a ERE ER EB E Ve CUTE e ed aaa coe SEA a abe 21 

IU) EX COV ORCI ON PE ie aariin AAE A A AAAA A E TAE E Aa A EAE AA a a a eia aa ei aiaa ii aaia 22 
APPENDIX 4 STANDARD PLANNING CONDITIONS AND ADVICE ON IMPLEMENTATION ........................ eee eee 23 
oda vb e-Xeo] Nie —————————————————Ü 24 
hiddsid [gl —————————————————— 26 

Local Development Plans... rtis ete d ea detenta eee ex un oes aee en epa bud ad vna dee y eua nan eda e da Voip ean deua 

PACES irit terr rp For E 

National Policy and Guidance 

CIfA' Regulations. etc... «xn od wo ente Cose a eai M reed ox Gee uo 39 eheu eee hae o AEEA oda d o edes PORE 





Introduction 


1. In (September 2020) the Pembrokeshire Coast National Park Local 
Development Plan 2 (end date 2031) was adopted by Pembrokeshire 
Coast National Park Authority. 


2. In (February 2013) the Pembrokeshire County Council's Local 
Development Plan 1 (end date 2021) was adopted by Pembrokeshire 
County Council. 














4. While only the policies in the adopted development plans have special 
status in deciding planning applications, (i.e. for the purpose of any 
determination under the Planning Acts, the determination must be made in 
accordance with the relevant Plan unless material considerations indicate 
otherwise), Supplementary Planning Guidance can be taken into account 
as a material planning consideration provided it is derived from and is 
consistent with the adopted development plan and has itself been the 
subject of consultation, which will carry more weight. 

decisions on matters that come before it, Welsh Government and 


























i of-policies-within-the 


relevant Development Plan and 
b. Weigh up-all the other planning considerations to see whether they 
outweigh the conclusion of the relevant Develooment Plan. 








6. This Supplementary Planning Guidance provides detailed information 
regarding how planning applications with the potential to impact upon 
archaeology within Pembrokeshire will be dealt with. It also provides 
information on the way in which Development Plan policies will be applied. 


. This Guidance is intended to assist all applicants seeking planning 
permission whether their proposed development is large or small in scale. 
As developers will be expected to meet the costs of archaeological work 
(see Appendix 2 Considerations for Undertaking Archaeological 
WorkApoendbcz-coensdemtencdorndenaldac-^rehaeologiea Wore), this 
document will assist in guiding non-specialists through the planning 
procedures and any archaeological work that may be involved. Information 
is provided on where to seek information and specialist advice and how to 
secure the services of professional archaeological contractors. 


. This Guidance document has been prepared in consultation with the Dyfed 
Archaeological Trust (Development Management section): the authorities’ 
professional advisors on matters relating to the historic environment. 


. This Supplementary Planning Guidance is divided into three parts: 


a. Section A provides information on getting early advice 

b. Section B advises on what happens before a planning decision is 
made 

c. Section C advises on what happens following a decision being 
made. 


10. The appendices provide more detailed advice on various technical issues 


involving archaeology in the planning process. They also include a list of 
useful contacts. 


Section A - Where can I get information and early 
advice? 


How are archaeological sites protected? 


11.In Pembrokeshire over 530 sites are currently given statutory protection as 
scheduled monuments under the Ancient Monuments and Archaeological 
Areas Act 1979, and more recently the Historic Environment (Wales) Act 
2016. It is an offence to carry out any work to them without written consent 
from the Welsh Government. If scheduled sites or their settings are 
affected by planning applications, Cadw must be contacted'. 


12.20,867 non scheduled archaeological sites and their settings are currently 
recorded in the regional Historic Environment Record maintained by Dyfed 
Archaeological Trust (DAT). These are protected by the planning process 
with a presumption in favour of preserving, in situ, nationally important 
archaeological sites. Welsh Government guidance is set out in Planning 
Policy Wales (Chapter 6, Edition 48 11) and Technical Advice Note 24: The 
Historic Environment (May 2017). 


13. This places an onus on developers to consider the impact of their 
proposals on archaeology. The key to the protection of archaeological sites 
lies with the Local Planning Authorities working closely with applicants and 
the regional Welsh Archaeological Trust; in the case of Pembrokeshire 
Coast National Park Authority and Pembrokeshire County Council this is 
Dyfed Archaeological Trust. 


14.Both Local Development Plans in Pembrokeshire provide for heritage 
protection. For Pembrokeshire Coast National Park, Strategy Policy 8 
‘Special Qualities’ of Local Development Plan 2 requires the safeguarding 
and enhancement of the special qualities of the Pembrokeshire Coast 
National Park. Among these recognised qualities is the historic 
environment. Policy requires that 'the historic environment is protected and 


! Cadw is the historic environment service of the Welsh Government. Cadw works to protect the 
historic buildings and structures, the landscapes and heritage sites of Wales, so that the public can 
visit them, enjoy them and understand their significance. 


where possible enhanced'. Further information on the historic environment 
is given in the 'Historic Environment' section. 


15.For Pembrokeshire County Council, Local Development Plan 1 recognises 
the importance of the historic environment in Policy GN.38 Protection and 
Enhancement of the Historic Environment: 'Development that affects sites 
and landscapes of architectural and/or historical merit or archaeological 
importance, or their setting, will only be permitted where it can be 
demonstrated that it would protect or enhance their character and integrity. 


16.A summary of relevant national legislation policy and guidance and their 
main implications can be found in Appendix 1 Relevant Legislation and 
Policy Requirements. 


17. Detailed data on the archaeology within Pembrokeshire is held within the 
regional Historic Environment Record and is available on request from 
Dyfed Archaeological Trust. Early consultation is advisable as the needs of 
development and archaeological preservation are best reconciled at an 
early stage. 


18.In their own interests applicants are encouraged to assess the impact of 
their proposals on archaeological sites by consulting with Dyfed 
Archaeological Trust Development Management (DAT-DM) during the pre- 
planning stages. Guided by information and advice, sympathetic designs 
can be prepared, which are intended to protect archaeological interests 
without incurring potentially high costs in carrying out archaeological work. 


19. Applicants should take into account archaeological considerations and 
should discuss preliminary plans with the relevant planning authority at an 
early stage prior to submitting a planning application. 


20. Once detailed designs have been prepared and finance arranged, flexibility 
and archaeological mitigation become more difficult to consider. 
Developers who do not consider historic environment issues at an early 
stage can be faced with unexpected discoveries, delay and expense during 
the course of development. Managing this risk through obtaining early 
advice is considered vital to all parties concerned in the planning process. 





ARCHAEOLOGY AND YOUR PLANNING APPLICATION 


Developer 


Welsh Archaeological Trust 
(Curatorial Division) 


Planning Authority 


Z 
Ss 
3 
E 






CONSIDERATION OF APPLICATION 


2VELOPMENT 


DE 





* additional information — for example 
desk-based assessment 
field evaluation 


geophysical survey ‘The Welsh Archacological Trusts 


monitor archacological work 
throughout on behalf of the Local 
Planning Authority to ensure 
compliance with planning and 
maintenance of best practice 


This simplified flow-chart is designed 
to show key stages in the planning 
process and should be used with the 
accompanying leaflet 





Section B What happens before a planning 
decision? 


21.Acting as the professional archaeological advisors to the planning 
authorities in Pembrokeshire, Dyfed Archaeological Trust - Development 
Management is notified of all planning applications lodged in 
Pembrokeshire and makes appropriate recommendations accordingly. 


22. Planning authorities expect proposals to take account of archaeology and 
may require additional information to be provided in support of a planning 
application. Without this further information they may recommend deferral 
or refusal of a planning application. 


23. This additional information can be provided in the form of desk-based 
assessment and/or archaeological field evaluation which may also involve 
geophysical survey. This work will determine the nature of the archaeology 
and its significance, and could include proposals designed to protect 
archaeological interests while enabling development. In all cases, 
archaeological projects must be carried out in accordance with an agreed 
specification / Written Scheme of Investigation (WSI) prior to the 
undertaking of any work. Assessment methodologies are fully described in 
Appendix 3 Archaeological WorkApperdix 3 Archaeological Work. 


24.Early consultations, as described above, will give prospective applicants 
advance information about the archaeological sensitivity of their site. The 
submission of archaeological information is not a validation requirement 
from the standard application form. Therefore determination regarding 
whether archaeological information is adequate would need to be assessed 
post-registration as part of the consideration of the application (unless 
made as a local validation requirement for major applications). Therefore 
pre-application engagement is even more important. 


25.Where insufficient information has been provided, the planning authority 
can decide to refuse to grant planning permission. 


26. Developments which seriously affect nationally important archaeological 
remains are unlikely to obtain planning permission. For archaeological 
features of lesser importance, permission may be given providing 
strategies are put in place to investigate and record in advance of 
development. 


27.At this stage two main options are open to the planning authority; these are 
‘preservation in situ’and ‘preservation by record’. 


28.Where remains are not known but suspected, the relevant planning 
authority may require that archaeological mitigation, such as a watching 
brief, be carried out as part of development. Occasionally unexpected 
remains can be found during development. To meet these unforeseen 
circumstances developers should make contingency arrangements and 
consider insuring themselves. 


Preservation of Archaeological Remains /n situ 


29.Where nationally important archaeological remains, whether scheduled or 
not, and their settings are affected by proposed development there will be a 
presumption in favour of their physical preservation in situ, i.e. a 
presumption against proposals which would involve significant alteration or 
cause damage, or which would have a significant impact on the setting of 
visible remains. In these instances it may be appropriate for the planning 
authority to refuse planning applications that would have a significant 
adverse impact on the historic environment. 


30. The policy of the planning authority is to ensure the protection of 
archaeological remains through engineering solutions and designs. For 
example, raising ground levels or constructing foundations that avoid 
disturbing archaeological remains altogether will be actively encouraged. In 
other circumstances, sensitive archaeological remains can be physically 
preserved through the careful positioning of landscaped or public open 
areas. Such techniques can seal archaeological remains beneath buildings 
or through careful landscape design within development areas. Although 
these remains may remain inaccessible for the time being, they are 
effectively preserved for the future, when archaeological techniques of 
excavation and scientific analysis will undoubtedly be improved. In these 
instances, the planning authority may seek assurances that buried 
archaeological material will remain secure after development through on- 
going monitoring procedures, or, in certain circumstances, the removal of 
permitted development rights. 


Preservation of Archaeological Remains by Record 


31.Where remains of less than national importance are known to exist, the 
planning authority may decide that when weighed against all other material 
considerations, including the need for development, the significance of the 
archaeological remains is not sufficient to justify their physical preservation 
in situ. 


32.In such cases the planning authority, through the attachment of appropriate 


planning conditions (see Appendix 4 Standard Planning Conditions and 
advice on implementationAppendbc4-Standard-Planning-Conditions-and 
advice-onimplementation) may require the developer to make satisfactory 


arrangements for the excavation, recording, archiving and publication of the 
archaeological resource. This detailed excavation and recording work, 
which may often be time-consuming and expensive, is generally a second- 
best option and must be carried out prior to the commencement of 
development. 


33. Other planning conditions may require the applicant to carry out building 
recording in the form of a photographic record prior to and during the 
course of development or arrange for an archaeological watching brief to 
be carried out by a professional archaeologist during development. 


34. On behalf of the planning authority, Dyfed Archaeological Trust - 
Development Management will consider the applicant's submitted 
archaeological scheme and, if satisfactory, the relevant Local Planning 
Authority will approve the document in writing, allowing the archaeological 
work to commence. Only when the work is satisfactorily completed will the 
planning authority be able to discharge the relevant condition. 


Section C What happens following a planning 


decision? 


35. On behalf of the planning authority, Dyfed Archaeological Trust - 
Development Management will normally monitor archaeological work to 
ensure compliance with planning requirements and the maintenance of 
high archaeological standards in the county. All archaeological work will be 
subject to monitoring from inception and project design, through fieldwork 
and the post-excavation processes, to the deposition of the resulting 
archive in an agreed repository and final publication. 


36. The planning authority will be advised by Dyfed Archaeological Trust - 
Development Management on whether conditions can be discharged either 
in full or partially as the successive stages of the agreed archaeological 
programme of work are satisfactorily completed. 


37.ln general the purposes of monitoring by the regional development 
management archaeologist on behalf of the relevant Local Planning 
Authority may be summarised as follows: 


a. 


To ensure the maintenance of high archaeological standards and 
best practice based on the Standards and Guidance issued by the 
Chartered Institute for Archaeologists. 

To ensure compliance with planning regulations and requirements. 
To ensure compliance with any Specifications / Written Schemes of 
Investigation submitted by the applicant for the approval of the Local 
Planning Authority. 

To ensure the relevance of the further information gained by the 
work to the ongoing planning process. 

To ensure that any suggestions made by the archaeological 
contractor are reasonable in planning terms. 

To ensure that any further recommendations resulting from the work, 
are founded on detailed knowledge and are reasonable in planning 
terms. 

To help formulate, where required, an archaeological mitigation 
strategy, which could protect the archaeological resource whilst 
enabling the permitted development. 

To ensure compliance with planning conditions and their satisfactory 
discharging. 


38. Where a pre-determination archaeological field evaluation is required, 
Dyfed Archaeological Trust - Development Management will visit the site to 
ensure that the work being carried out is in accordance with the agreed 


10 


specification and relevant to the on-going planning process. Dyfed 
Archaeological Trust - Development Management will therefore require 
notice of the start date, a projected timetable and a copy of the Health and 
Safety Risk Assessment to be submitted to them no less than 5 working 
days prior to the commencement of the work. 


11 


Appendix 1 Relevant Legislation and Policy 
Requirements 


Scheduled Monuments and Cadw 


39. Over 530 monuments and archaeological sites in Pembrokeshire are given 
statutory protection as Scheduled Monuments under the terms of the 
Ancient Monuments and Archaeological Areas Act, 1979. These 
monuments have met certain criteria, which are used for assessing their 
national importance. Any works that would affect these monuments will 
require scheduled monument consent from Welsh Government and in such 
cases the setting of a monument, as well as its physical preservation, are 
material considerations. Any work carried out to a Scheduled 
Monument without consent is a criminal offence and is liable 
to prosecution under the 1979 Act. Scheduled monument 
consent is separate from planning permission. The granting of 
planning permission does not confer scheduled monument consent nor 
vice versa. For a site, which is both scheduled and listed, scheduled 
monument legislation takes precedence over listed building requirements. 
Planning authorities would encourage the submission of any necessary 
scheduled monument consent from Cadw alongside a planning application. 


40. The planning authority is required to consult with Cadw (acting on behalf of 
Welsh Government) on any application likely to affect a scheduled 
monument or its setting. A planning application which would involve 
significant alteration or cause damage, or would have a significant adverse 


impact causing harm within the setting of the remains adversely-affects-a 
scheduled menumentwill normally be refused. 


41.Further information on these protected sites can be obtained from Cadw 
(please see contact details in Appendix 5 Contacts). 


42. For certain types of development (listed in Schedules 1 and 2 to The Town 
and Country Planning (Environmental Impact Assessment) (Wales) 
Regulations 2016), formal environmental impact assessment (EIA) may be 
necessary. Where EIA is required the developer must provide an 
environmental assessment setting out the information specified in Schedule 
3 to the Regulations regarding the site, and the likely significant effects of 
the proposed development on the environment. This should include 
information relating to any major effects on material assets and the cultural 
heritage, such as archaeological features and other human artefacts. This 


12 


should also include the measures envisaged to avoid, reduce or remedy 
such adverse effects. 


43. Supporting the Historic Environment (Wales) Act (2016) both Planning 
Policy Wales, Chapter 6: The Historic Environment and Technical 
Advice Note 24: The Historic Environment, provide the main guidance 
on conserving the historic environment in Wales. 


44. Technical Advice Note 24: The Historic Environment has been 
in place since May 2017 and supersedes Welsh Office Circular 60/96 
Planning and the Historic Environment: Archaeology and 61/96 Planning 
and the Historic Environment: Historic Buildings and Conservation Areas. 
This is a key policy document providing detailed guidance on the handling 
of archaeology in the legal land-use planning system in Wales. 


Planning Policy Wales and Technical Advice Note 24 - Registered 
Historic Landscapes and Parks and Gardens 


45. Both these documents also provide advice with regard to the appropriate 
consideration of both Registered Historic Landscapes and Registered 
Parks and Gardens. 


Human Remains 


46. Where human remains are considered likely to be found, the appropriate 
licence must be obtained from the Ministry of Justice in advance. When 
unexpected human remains are encountered as the result of 
archaeological work developers must adhere to legislation and best- 
practice procedures for handling this sensitive material. When discovered, 
human remains must always be left in situ, covered and protected 
sensitively. No further investigation should be permitted and the local 
Coroner and Dyfed Archaeological Trust - Development Management must 
be informed immediately. Advice should be sought from the ministry of 
Justice and if appropriate, a licence obtained. 


Hedgerow Regulations 


47.Developments that require the removal of hedgerow may come under the 
terms of the Hedgerow Regulations 1997. These Regulations require 
applications to be made to the Authority for permission to remove 
hedgerow. Certain criteria apply in the decision making process which 
involve consideration of archaeological and historical interests. For 
instance hedgerows may be important archaeological features in their own 
right or form part of an ancient monument. Accordingly, the planning 


13 


authority consults with Dyfed Archaeological Trust - Development 
Management for information from the Historic Environment Record. 


Historic Parks and Gardens Register 


48. Pembrokeshire contains important historic gardens and parklands, many of 
which are contained within the Register of Landscapes, Parks and Gardens 
of Special Historic Interest in Wales, published by Cadw in 2002. The 
purpose of the statutory Register is to provide information and procedures 
on these sites and their settings, in order to aid their protection and 
conservation. For planning applications that may affect sites of Grades | 
and II* and their essential settings, the relevant Local Planning Authority 
will seek the advice of Cadw when assessing the suitability of proposals. 
For Grade ll sites and other non-registered sites of local interest, the views 
of Dyfed Archaeological Trust - Development Management, the Gardens 
Trust and the Welsh Historic Gardens Trust will be fully considered. Further 
guidance can be obtained from Cadw's Managing Change to Registered 
Historic Parks and Gardens In Wales (2017). 


Historic Landscapes Registers 


49. Parts 2.1 and 2.2 of the non-statutory Register of Landscapes of Historic 
Interest in Wales contain information on historic landscapes of outstanding 
or special historic interest. These landscapes have been recognised as 
areas of "the nation's most valuable cultural assets, and as special, often 
fragile and irreplaceable parts of our heritage". 


Landscapes of Outstanding Historic Interest 


50. These are large areas which retain physical evidence of the past, from the 
agricultural and ritual landscapes of prehistory to 19th century industrial 
landscapes. Eight of these Registered Landscapes lie within 
Pembrokeshire. 


Landscapes of Special Historic Interest 


51.As well as the areas above, Registered Landscapes in Wales include some 
that are designated as being of Special Historic Interest. They are generally 
smaller in area and the difference "is one of degree, and not quality of 
historic interests." Eight of these areas lie within Pembrokeshire. Further 
information can be found on the Dyfed Archaeological Trust website. 


14 


Assessment of the Significance of the Impact of Development on 
Historic Landscapes Areas - ASIDOHL 


52. Planning Policy Wales requires that planning authorities need to take the 
Register into account, for development which is considered to be "of a 
sufficient scale to have more than local impact on the historic landscape". 
In these circumstances the planning authority will expect applicants to have 
assessed the impact of their developments on registered historic 
landscape, which the planning authority will weigh against other material 
considerations. To assist applicants for planning permission please see the 
Guide to Good Practice on Using the Register of Landscapes of 
Historic Interest in Wales in the Planning and Development Process 
(Revised 2007). This document includes a Technical Annex — Assessment 
of the Significance of the Impact of Development on Historic Landscapes 
Areas, otherwise known as the ASIDOHL methodology. 


53. ASIDOHL provides guidance on assessment process and on the technical 
steps involved in assessing the impact of development on the historic 
landscapes. In the first instance it is recommended that applicants should 
seek the advice of the Trust on whether their development is of such a 
scale to warrant an ASIDOHL assessment and on what steps they should 
take in preparing their documentation for the purposes of the planning 
process. 


Historic Landscapes of Regional or Local Importance 


54. Not all historic landscapes in Wales are considered to be of national 
importance or are currently contained within the Register of Landscapes of 
Historic Interest in Wales. Many other, discrete landscapes of regional or 
local importance exist and are significant for the historical, archaeological, 
cultural or intrinsic value they bring to their communities. Where such 
historic landscapes are recognised and an Environmental Impact 
Assessment (EIA) is necessary, the planning authority requires an 
assessment of the impact of the proposed development on the historic 
landscape. This requirement is addressed in guidance on national EIA 
Regulations 1999 SI 1999 No 293 (EIA Regulations) in Wales, and is given 
in Welsh Office Circular 11/99 Environmental Impact Assessment. 
Paragraph 46 Criterion 2 (c) (viii) refers to the necessity for Environmental 


Impact Assessment in respect of “landscapes of historical, cultural or 


archaeological significance”. In the first instance applicants are 
recommended to consult with Dyfed Archaeological Trust — Development 
Management on whether their development is likely to impact on a non- 


15 


registered historic landscape and what course of action may be required to 
assess and mitigate this impact. 


Other Environmental Considerations 


55. Archaeological site work, which has been commissioned by an applicant 
prior to the determination of an application or as part of a consented 
development, may impact on other environmental interests, such as 
habitat, hedgerow, ground water, fauna and flora, etc. It is the responsibility 
of both those commissioning intrusive archaeological work and those 
carrying out the work that they consider whether there may be other 
environmental impacts resulting from their activities. Further advice on 
these issues can be sought from the relevant planning authority or Dyfed 
Archaeological Trust - Heritage Management. 


16 


Appendix 2 Considerations for Undertaking 
Archaeological Work 


Responsibility for Costs 


56. It is important to understand that archaeological work, particularly intensive 
excavation, can be time-consuming and expensive. Meeting these costs is 
solely the responsibility of the applicant / developer. As part of a planning 
requirement, this work can involve not just fieldwork but also post- 
excavation analysis, archiving and publication. There may also be costs 
relating to the conservation of artefacts, archiving and the storage of 
excavated archaeological finds. 


57.Because of these potential costs to developers, the planning authorities 
recommend that applicants for planning permission should seek early 
archaeological advice by discussing their proposals with the relevant 
planning authority and Dyfed Archaeological Trust - Development 
Management. With good information on historic environment issues and 
understanding constraints at an early stage in the formation of development 
proposals, applicants may be able to lessen the likely financial impact of 
their development through mitigating options, which avoid impact on 
sensitive archaeological material. 


Quality Control 


58. It is the responsibility of applicants / developers, or their agents, to 
commission archaeological contractors to carry out work on their behalf 
and they will need to satisfy themselves of the ability of their chosen 
archaeological contractor to undertake this work. 


59. The archaeological work must be undertaken by the staff of a competent 
and professional body, which is formally acknowledged by Dyfed 
Archaeological Trust - Development Management, advisors to the two 
planning authorities. The planning authorities and Dyfed Archaeological 
Trust - Development Management recommend to those requiring 
archaeological work that they consider the benefits of commissioning 
organisations that are Registered Archaeological Organisations (RAOs) 
with the Chartered Institute for Archaeologists (CIfA). This approach will 
provide confidence that the archaeologists undertaking the commission 
subscribe to codes of professional conduct and practice that are subject to 
strict professional sanctions should they transgress. Further information on 


17 


the Institute's RAO scheme can be found on their website (please see List 
of Useful Contacts). 


60.In any event it is recommended that the archaeological contractor has 
appropriate experience and is managed by a Member of the Chartered 
Institute for Archaeologists (MCIfA), who is appropriately validated. The 
archaeological contractor must adhere to the Chartered Institute for 
Archaeologists' Code of Conduct and the Code of Approved Practice for 
the Regulation of Contractual Arrangements in Field Archaeology and to 
the relevant Standards and Guidance. 


61.It is also recommended that, in the best interest of those commissioning 
archaeological work, that they ensure that contractors have appropriate 
professional indemnity or other insurances. 


How to find an Archaeological Contractor 


62.Information and advice regarding the commissioning of an archaeologist 
can be found on the CIfA website, including CIfA's client guide which has 
been designed to assist anyone with archaeological requirements to meet. 


63.A list of archaeological contractors undertaking work within Wales is also 
available via the British Archaeological Jobs Resource website. 


18 


Appendix 3 Archaeological Work 


64. Listed below are the main types of archaeological work required as part of 
the planning process. 


Historic Envi EA isal 





65. Anhistoric-environment-appraisaHHEAHs-Hesserformof 




















Desk-based assessment 


66. Where there is good reason to believe that an application site may have an 
adverse impact on the historic environment has-significant-archaeological 
potential and information is currently inadequate, the planning authority 
may direct the applicant to provide a desk-based assessment prior to the 
determination of an application. Depending on circumstances, this relatively 
rapid archaeological study may form part of an Environmental Impact 
Assessment or it may be submitted as a standalone document. The 
definition of a desk-based assessment is a programme of assessment of 
the known or potential archaeological resource within a specified area or 
site on land, inter-tidal zone or underwater. It consists of a collation of 
existing written, graphic, photographic and electronic information in order to 
identify the likely character, extent, quality, and worth of the known or 
potential archaeological resource in a local, regional, national or 
international context as appropriate. The desk-based assessment should 
lead to one or more of the following options: 





a. The formulation of a strategy to ensure the recording, preservation 
or management of the resource. 

b. The formulation of a strategy for further investigation, whether or not 
intrusive, where the character and value of the resource is not 


19 


sufficiently defined to permit a mitigation strategy or other response 
to be devised. 

c. The formulation of a proposal for further archaeological investigation 
within a programme of research. 

d. No further work required. 


Earthwork Survey 


67.In areas of agricultural land that have not been subject to intensive 
ploughing, archaeological remains may survive as earthworks. Surveying 
these sites, which may often only have shallow surface features surviving, 
will normally involve qualified archaeologists using electronic survey 
equipment to record the earthworks. From the resulting information detailed 
plans will be produced, which will be considered by the relevant planning 
authority when determining applications. 


Remote sensing / Geophysical Survey 


68.Indications of buried human activity can be detected by a variety of non- 
intrusive scientific methodologies and equipment. The main types of 
geophysical survey currently being used are magnetometer survey. and 
ground penetrating radar and resistivity survey. Site-specific geological 
conditions can have a major bearing on the quality of the results from such 
surveys and the type of survey that is appropriate in each circumstance can 
often only be determined after initial testing of methodologies. This work 
can often precede a field evaluation as the results of remote sensing can 
assist in determining the rationale for the number and location of trial 
trenches that might be required. It is unlikely that remote sensing on its own 
will provide the required information on an archaeological resource. 
Invariably, the results of these non-intrusive surveys will need to be tested 
through the physical process of trial excavation. 


Field Evaluation 


69.A field evaluation is required where the relevant planning authority has 
good reason to consider that a significant archaeological resource is 
present, perhaps as a buried feature, on an application site. An evaluation 
is normally a limited programme of intrusive fieldwork, which quickly 
determines the presence or absence of archaeological features and 
enables an assessment of their relative worth in a local, regional, national 
or international context as appropriate. The programme of work will result in 
the preparation of a report and ordered archive. 


20 


70. This type of physical or intrusive evaluation may, in certain circumstances, 
be preceded by a programme of non-intrusive work such a field walking, 
earthwork survey or geophysics. 


71.The intrusive element of the work normally involves trial trenching by 
means of archaeologically supervised mechanical excavation using 
machinery with a toothless bucket. The number, location and rationale for 
these trenches must be agreed with the relevant planning authority and 
Dyfed Archaeological Trust - Development Management prior to the 
commencement of the work. The evaluation areas must be cleaned to an 
appropriate standard to prove the presence or absence of archaeological 
features and to determine their relative significance. In each area the 
excavation of the minimum number of archaeological features, to elucidate 
the character, distribution, extent, date and importance of the 
eee remains is undertaken. In-each-area sufficient excavation 





een An slab will excavate ius to the in ol the 


archaeological horizon or the top of natural horizons — whichever is 
reached first. If safety reasons preclude manual excavation to natural 


subsoil, hand auguring may be used to try to assess the total depth of 
stratified deposits within each area. The resulting report should be 
presented to the relevant planning authority as further information to inform 
the planning process. 


Building recording 


72.Prior to the commencement of alterations to standing buildings of 
architectural and/or historical interest, including listed buildings, the 
relevant planning authority will require appropriate building recording to be 
carried out prior to the commencement of development work. This 
recording is usually required through the attachment of suitable planning 
conditions. As there are many forms and levels of building recording work, 
ranging from detailed and precise building survey through to digital 
photography, advice should be sought from the Dyfed Archaeological 
Trust-Development Management Section, who can recommend a form of 
recording appropriate to circumstances and national standards. 


Watching Brief 
73.An archaeological watching brief is normally carried out during the course 
of approved development for the purposes of observing, excavating and 


recording archaeological remains that come to light during operations such 
as topsoil stripping, cutting foundation trenches or landscaping. The work 


21 


requires a professional archaeologist to be present on site to carry out 
either an intensive or intermittent watching brief, which will have been 
described in detailed specifications. Developers should consider the 
implications of watching brief work which results in the discovery of 
significant archaeological remains. Contingency measures should be put in 
place to meet such unforeseen circumstances, which can have delay and 
cost implications. Where such remains come to light unexpectedly, the 
watching archaeologist will be required to contact Dyfed Archaeological 
Trust - Development Management for further advice. Whilst this 
consultation takes place the development work directly impacting on the 
archaeological resource will normally be required to cease until 
arrangements have been put in place for appropriate archaeological 
recording. A report on the watching brief work, whether it has had positive 
or negative results, will be required by the relevant planning authority. 


Full Excavation 


74.Full archaeological excavation or ‘preservation by record’ is normally 
required where no other form of mitigation has proved practicable. It entails 
detailed and careful stratigraphic excavation and recording of 
archaeological deposits by professional archaeologists within a specified 
area. The work is carried out with defined research objectives and in a 
controlled manner normally and beneficially ahead of the commencement 
of the development programme. The excavation will examine, record and 
interpret archaeological deposits, features and structures and, as 
appropriate, retrieve artefacts, ecofacts and other remains. The records 
made and objects gathered during fieldwork are studied and the results of 
that study are published in detail appropriate to the project design, which 
has been agreed with the relevant planning authority. 


22 


Appendix 4 Standard Planning Conditions and 
advice on implementation 


75.When required, the relevant planning authority will protect archaeological 
interests through the attachment of appropriate planning conditions to 
permitted applications. In line with national policy these conditions should 
meet the criteria of being necessary, relevant to planning and to the 
permitted development, enforceable, precise and reasonable. 


76.Only when it is demonstrated that these conditions have been properly and 
fully met will the relevant planning authority consider discharging planning 
conditions. In cases where it is clear that applicants have not implemented 
the requirements of planning conditions, the planning authority will consider 
the need for enforcement action. 


77.Pembrokeshire contains many buildings of national, regional and local 
significance and Local Development Plans contain policies for their 
protection. Many of these buildings are listed under the Planning (Listed 
Buildings and Conservation Areas) Act 1990 and therefore come under 
statutory protection. However, very many more are unlisted yet have 
regional or local importance having historical, architectural, traditional or 
intrinsic values within their communities. For these buildings, whether 
urban or rural, it is appropriate that they are recorded prior to the 
commencement of any development that will substantially alter their form or 
character. There may also be requirements for an archaeologist or other 
specialist to be present during development to record significant 
discoveries. The level of recording required will vary with particular 
circumstances and, in the first instance it is recommended that applicants 
contact Dyfed Archaeological Trust - Development Management to obtain 
advice on what level of recording is appropriate to their circumstances. 


23 


Appendix 5 Contacts 


























Organisation Address Telephone | Website 
Dyfed Archaeological Trust Ltd. Corner House, Tel: General | www.dyfedarc 
. : Carmarthen Enquiries haeology.org. 
Zoe Bevans-Rice — Archaeological Street. Llandeilo. | 01558 uk 
Planning Officer Carmarthenshire | 823121 id 
z.bevansrice@dyfedarchaeology.org. SA19 6AE 
uk 5 
Mike Ings — Archaeological Planning 
Manager 
m.ings@dyfedarchaeology.org.uk 
Pembrokeshire Coast National Park Llanion Park Tel: 0845 www.pcnpa.or 
Authority Pembroke Dock | 345 7275 g.uk 
Pembrokeshire 
Matthew Griffiths — Development SA72 6DY i 
Management Team Leader 
DC@pembrokeshirecoast.org.uk 
Pembrokeshire County Council Planning Tel: 01437 www.pembrok 
, i Department, 764551 eshire.gov.uk 
planningenquiries@pembrokeshire.go | Pembrokeshire 
v.uk l .. | County Council, Fax: 01437 
planning.support.team@pembrokeshir County Hall 776496 
e.gov.uk Freemans Way, 
Haverfordwest, 
SA61 1TP. 
Cadw email Cadw@Wales.gsi.gov.uk | Welsh Tel: 01443 
Government 33 6000 
Plas Carew 
Unit 5/7 Cefn Fax: 01443 
Coed 33 6001 
Parc Nantgarw 
Cardiff 
CF15 7QQ 
Natural Resources Wales (NRW) S.W. office 0300 065 www.naturalr 
Llys Afon 3000 esources.wal 
(Hawthorn Rise) es 
Haverfordwest 
Pembrokeshire 
SA61 2BQ 
Royal Commission on the Ancient and | Ffordd Penglais | 01970 www.rcahmw. 














24 























Organisation Address Telephone | Website 
Historic Monuments in Wales Aberystwyth 621200 gov.uk 
SY23 3BU 
(RCAHMW) 
Pembrokeshire Archives Prendergast 01437 www.culture4 
Haverfordwest 775456 pembrokeshir 
SA61 2PE e.co.uk 
The Chartered Institute for Power Steele 0118 966 www.archaeol 
Archaeologists (CIfA) Building 2841 ogists.net 
Wessex Hall 
Whiteknights 
Road 
Earley 
Reading 
RG6 6DE 
British Archaeological Jobs Resource | Thornton Mill 01368 840 www.bajr.org 
(BAJR) Cottage 847 
Innerwick 
Dunbar 
East Lothian 
EH42 1QT 














Links checked May 2020 


25 





References 


Local Development Plans 


Pembrokeshire Coast National Park Local Development Plan 2 


https://www.pembrokeshirecoast.wales/planning/planning-policy/local- 
development-plan-2/ 


Pembrokeshire County Council Local Development Plan 1 
https://www.pembrokeshire.gov.uk/adopted-local-development-plan 


Acts 
Historic Environment (Wales) Act 2016 


Ancient Monuments and Archaeological Areas Act 1979 


https://www.legislation.gov.uk/ukpga/1979/46/contents 


National Policy and Guidance 


Planning Policy Wales - Edition 11 (gov.wales 
Technical Advice Note 24: Historic Environment May 2017 


https://gov.wales/technical-advice-note-tan-24-historic-environment 


The National Standard & Guidance to Best Practice for Collecting & Depositing 
Archaeological Archives in Wales (2017) 


http://www.heritage-standards.org.uk/new-welsh-archaeological-archives- 
standard-2017/ 


Guidance for the submission of data to the Welsh Historic Environment Record - 
available as a pdf. Via the Dyfed Archaeological Trust website 


http://www.dyfedarchaeology.org.uk/ 


Register of Landscapes, Parks and Gardens of Special Historic Interest in Wales. 
Part 1: Parks and Gardens: Carmarthenshire, Ceredigion and Pembrokeshire. 
Cadw 2002 


Guide to Good Practice on Using the Register of Landscapes of Historic Interest 
in Wales in the Planning and Development Process. Cadw 2006 


26 


https://cadw.gov.wales/advice-support/cof-cymru 
Cadw provides guidance documents on the following: 
Heritage Impact Assessment 


https://cadw.gov.wales/advice-support/placemaking/heritage-impact- 
assessment/heritage-impact-assessment 


Historic Environment Records In Wales — Compilation and Use 


https://cadw.gov.wales/advice-support/placemaking/historic-environment-records 
Managing Change in World Heritage Sites — Wales 


https://cadw.gov.wales/advice-support/historic-assets/other-historic-assets/world- 
heritage-sites/managing-world-heritage 


Managing Change in Historic Places of Worship 


https://cadw.gov.wales/advice-support/historic-assets/listed-buildings/historic- 
places-worship#section-ecclesiastical-exemption 


Managing Change in Listed Buildings in Wales 


https://cadw.gov.wales/advice-support/historic-assets/listed-buildings/managing- 
change-to-listed-buildings 


Managing Change to Registered Historic Parks and Gardens in Wales 


https://cadw.gov.wales/advice-support/historic-assets/registered-historic-parks- 
and-gardens/managing-registered-historic 


Managing Conservation Areas in Wales 


https://cadw.gov.wales/advice-support/historic-assets/conservation- 
areas/managing-conservation-areas 


Managing Historic Character in Wales 


https://cadw.gov.wales/advice-support/placemaking/historic-character/managing- 
historic-character 


Managing Listed Buildings at Risk in Wales 


https://cadw.gov.wales/advice-support/historic-assets/listed-buildings/listed- 
buildings-risk#section-managing-listed-buildings-at-risk 


Managing Lists of Historic Assets of Special Local Interest in Wales 


https://cadw.gov.wales/advice-support/historic-assets/other-historic- 
assets/historic-assets-special-local-interest 


27 


Managing Scheduled Monuments in Wales 


https://cadw.gov.wales/advice-support/historic-assets/scheduled- 


monuments/best-practice-quidance#section-managing-scheduled-monuments-in- 
wales 


Setting of Historic Assets in Wales 


https://cadw.gov.wales/advice-support/placemaking/heritage-impact- 
assessment/setting-historic-assets 


Understanding Listing in Wales 


https://cadw.gov.wales/advice-support/historic-assets/listed- 
buildings/understanding-listing#section-introduction 


The following are relevant documents published by the Institute of Field 
Archaeologists: 


CIfA Regulations etc. 


CIfA regulations, standards and guidelines | The Institute for Archaeologists 
Standard and Guidance for Archaeological Desk-based Assessment. 
Standard and Guidance for Archaeological Field Evaluation. 

Standard and Guidance for Archaeological Excavation. 


Standard and Guidance for Archaeological Watching Brief. 


Standard and Guidance for the Archaeological Investigation and Recording of 
Standing Buildings and Structures. 


Standard and Guidance for the Collection, Documentation, Conservation and 
Research of Archaeological Materials. 


Standard and Guidance for Archaeological Artefact and Environmental Collection, 
Documentation, Conservation and Research. 


The Chartered Institute for Archaeologists also has By-laws which include: 
Code of Conduct. 


Code of Approved Practice for the Regulation of Contractual Arrangements in 
Field Archaeology. 


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