August 2005 - After more than a year of waiting, Tarmac finally announces what it's going to do with the archaeology at Ladybridge Farm. The Issues at a Glance How Tarmac say they'll “mitigate” the damage: First, they say there's nothing of national importance at Ladybridge Farm that needs to be preserved, and that when English Heritage, the Council for British Archaeology and Expert Archaeologists say there is they are simply wrong! Second, they say they've searched the site thoroughly enough to have found exactly what's there. English Heritage say they haven't! Third, By not accepting the site is of national importance, they have failed to provide a mitigation strategy that is fit for purpose - it assumes all archaeology is of lesser importance and treats in accordingly. Important According to Tarmac, recent press statements, the current published mitigation strategy is no longer relevant. This is because a large number of the mitigation measures it contains should no longer be included. However, there is currently a council consultation process (deadline 9th September 2005) based on the out of date mitigation strategy, and no revised strategy has been provided. This document is based on that provided for the current consultation, which is to be reviewed when the planning committee meet of September 20th. Currently there are NO PLANS TO SUBMIT A NEW MITIGATION STRATEGY. Whilst we will attempt to show which elements of the strategy are no longer valid, in the absence of new document the exact details of what is on offer are unclear. Mitigation Any major development that is going to have an impact on archaeology must draw up a mitigation strategy. This tells how this impact will be addressed. In the county of North Yorkshire, nationally important archaeology must be preserved in situ. This is determined by the Minerals Local Plan, which is an interpretation of the national guidelines set out in PPG16. Archaeology of local or regional importance should be preserved in situ but can (with the approval of the planning authority) be preserved "by record" - a percentage excavated and any features/finds recorded and photographed. Importance of Archaeology The Deputy Prime Minister of Britain takes advice on all archaeological matters from English Heritage. Click here to view their response to the Ladybridge planning application. It is clear that English Heritage regard the archaeology on Ladybridge as nationally important - "English Heritage believes that, on the basis of the information available, the southern part of the Ladybridge Farm site contains nationally important archaeological features." English Heritage, July 2005. It is also evident that they do not believe all of the archaeology on site has been Located - "It is clear from the evaluation report that this combination of techniques has not characterised the archaeological deposits of the Ladybridge site." On this basis, English Heritage have asked that more work be done in order to categorise the archaeology on site before any mitigation strategy can be addressed. TimeWatch support this position and would like to add that the Ladybridge evaluation failed to report the results of the investigations to the west of Ladybridge Farm. This area included a potential ring ditch identified from air photographs, it is therefore intriguing that this area has been "forgotten". Mitigation Strategy. Regardless of the advice given by English Heritage, Tarmac Northern Ltd have chosen to produce a mitigation strategy for Ladybridge, apparently in ignorance of the total extent of the archaeology . What do we know? The above map illustrates the archaeological features and artifacts found so far at Ladybridge. (n.b. size of feature is not indicated by the markers). What are the planners looking for? Whilst there are many that feel this site should not be quarried at all, the fact is, unless a site is scheduled, the only protection for archaeology is via the local planning authority who take input from council officers, the developer, English Heritage and other concerned bodies as well as the public. The relevant section of the Minerals Local Plan is as follows: Policy 4/8 “Proposals for mining operations and the associated depositing of mineral waste which would have an unacceptable effect on nationally important archaeological remains, whether scheduled or not, and their settings, will not be permitted. The Mineral Planning Authority will seek to preserve, in-situ or by record, other sites of regional, county or local importance, as appropriate to their archaeological interest, in making decisions on planning applications.” An appropriate mitigation strategy for the archaeology present at Ladybridge would therefore be preservation in situ for nationally important remains and a reasoned debate as to what level of preservation is suitable for regional important archaeology. In order to have this reasoned debate it is important that a clear understanding of the extent and nature of the archaeology on site is known. At Ladybridge this information is not available, so the only option is to assess the likely extent using expert knowledge of the archaeology in the surrounding area. One such expert is Dr Jan Harding of Newcastle University, his comments regarding the application include:"The planning application to quarry at Ladybridge proposes the destruction of a significant part of Thornborough's "sacred landscape". The archaeological evaluation of Ladybridge Farm.... appears to confirm Ladybridge's cultural significance." "The present quarry site (Nosterfield Quarry, next door to Ladybridge) has indeed produced a remarkable chronological range of evidence. Especially worthy of note is the "later Mesolithic pit alignment" from Area 15, the 83 Neolithic features from Investigation 3, the Neolithic ditch and pit alignment from Investigation 13, and the later prehistoric ring-ditches, burials and pit alignments from Investigations 15 and 16. This is truly a landscape of national, if not international, importance. Hence, it should be assumed that the same is true of the immediately adjacent Ladybridge Farm Extension." In addition, the Council for British Archaeology recently said "We believe the proposed quarrying (at Ladybridge Farm) would affect significant remains of international importance". CBA August 2005. What Tarmac have offered In August 2005, more than a month after the public consultation period had closed, Tarmac announced the proposed mitigation strategy for the archaeology at Ladybridge. These measures comprised two types - Those that are pertinent to the application and those whose relevance is doubtful, and therefore ineligible for consideration by the planning committee (in the same way as those objecting to the application on spiritual grounds may be ineligible, for example). Relevant Mitigation Measures Offer of Land It should first be noted that within the Mitigation Strategy for Ladybridge, Tarmac have rejected English Heritage and Dr Jan Harding's view that the archaeology on Ladybridge is of national importance and furthermore, the only strategy presented is preservation by record. This means that Tarmac are in technical breach of the Council Planning rules. The land offered by Tarmac as "set-aside" is in the most part the boundary for Ladybridge - and only the north and west sides. Much of this would not normally be quarried as it is used as the foundation for the"bund" - the mound of earth that prevents excessive noise and visual impacts from escaping the quarry. The important concern is to understand how much archaeology, and of what importance is to be preserved within this area of set-aside. The above image shows the areas (in green) that will not be quarried under Tarmac's mitigation strategy. Comparison with the known features and find spots (top map) shows that this land has not been chosen in order to ensure maximum preservation of the known features - it misses the majority of what is known. Instead it hugs the boundary, an area which for the most part (1) would not be quarried anyway, or (2) provides minimum impact to the quarry. (n.b. map not to scale, green likely to exaggerate the size of the set-aside area). This set-aside area fails to take the opportunity to address the problem of preserving the remains of this nationally important site in situ and it is therefore an unacceptable mitigation strategy. Preservation by Record From current evidence it is likely that most archaeology found on Ladybridge will be nationally important as defined by English Heritage, and this should be the advice passed council planning committee. Tarmac have failed to produce a suitable discovery strategy - the assumption should be that new archaeology is likely to be nationally important, and that only minimal sampling should take place until its status is confirmed by English Heritage. This may sound like an onerous specification to place on a developer, but it should be remembered that Thornborough is not just a nationally important monument. It is considered by English Heritage to be the "most important ancient monument between Stonehenge and The Orkneys". On the basis of this, it should be clear that the mitigation strategy is seriously flawed. These failures, also mean that the strategy for preservation "by record" is also seriously flawed since it is written on the assumption that the archaeology is of lesser importance and as a result only offers to perform archaeological investigations that are inadequate for the importance of the site and its remains. Non Relevant (Probably withdrawn) Mitigation Offers Important note: It is likely that all of the mitigation measures detailed below have now been withdrawn from the mitigation strategy, this is based on media announcements by Tarmac Northern Ltd saying that the mitigation strategy has been overtaken by a company decision taken at national level relating to the donation of the land and other measures outlined below. The media statements do not go into sufficient detail however, for this to be 100% certain. As mentioned previously, the mitigation strategy includes a large number of measures that are considered to be dubious since they lack relevance to the development being proposed. It is not just those objecting to proposals that must keep to the point as dictated by planning policy - it is also the developer that must follow the rules. The ruling regarding relevance is ordinarily particularly strongly adhered to by planning committees and this means that off-site mitigation measures are only allowed if they mitigate a problem actually caused by the development - for example a stand of trees to hide the view. A summary of Tarmac’s off-site mitigation proposals with comment: As the landowner use their good offices to promote a coherent and positive management agreement for the Southern and Central Henge. This cannot be considered as relevant to the development. It is our understanding that both the central and southern henge are already subject to an agreed management strategy that has stopped them from being ploughed. Provide parking and visitor facilities at the entrance to Nosterfield Quarry with a view to providing safe access from there to the scheduled monuments. This is a resource that is already being provided as part of the mitigation for Nosterfield Quarry and should not be accepted as further mitigation for Ladybridge. Again, it is unclear what makes this aspect relevant. The applicant proposes to work with the current landowner to produce a comprehensive management agreement for the Northern Henge. Again, work at the Northern Henge cannot be used to mitigate a plan to quarry at Ladybridge, and since this too involves third parties it cannot be guaranteed and therefore cannot be accepted as a mitigation measure. Partake in a wider research programme studying the landscape history of the Thornborough area. This should be a core part of any attempt to study the archaeology at Ladybridge and the fact that Tarmac seem to regard it as optional shows the severe limitations of developer archaeology in such an important landscape. Donate an area of land off Flask Lane between Nosterfield Quarry and Nosterfield Village (8 acres) to the nation to be managed as pasture by a charitable trust in perpetuity. If this happens, it will be the only known archaeology to be preserved in situ on the current quarry. It was planned to be one of the last areas to be quarried, but Tarmac have now been asked not to destroy it, the decision should not hinge on the planning application and is not relevant to it. Work with the current landowner to promote a coherent and positive management regime for the Northern Henge. This has no relevance to the planning application. Since it involved third parties is not something Tarmac can promise to deliver. It cannot therefore be accepted as mitigation. Donate an area of land adjacent to the Northern Henge (48acres) to the nation to be managed as pasture by a charitable trust in perpetuity . Whilst this sounds like an interesting offer, it is not relevant to the application since it is an area that will not be affected by the development. Most of this area has been offered to Nosterfield Village in the past and rejected. This area is very close to both Nosterfield Village and the Northern Henge and it extremely unlikely that planning permission would be granted here, especially since it is known to hold a possible second cursus for Thornborough. Donate an area of land between Nosterfield Quarry and Ladybridge Farm (5 acres) to the nation to be managed as pasture by a charitable trust in perpetuity. Again it is unclear that this can be regarded as relevant. It is certainly the closest, but will not be affected by the development and is the verge between the old quarry and the road. It is the area next to the 83 Neolithic features mentioned by Dr Jan Harding and is likely to contain settlement remains. However, this was once a quarry site and it is unclear how much archaeology remains here. In any case, it forms part of the mitigation for Nosderfield Quarry and is not relevant to the application for Ladybridge Farm. Clearly, none of these measures will actually help preserve the archaeology of Ladybridge, or any other environmental factors for which the quarry will cause disturbance. They are therefore not relevant to the application and should not be considered by the planning committee when it meets in September. The Verdict? Within the planning application and the mitigation strategy, the developer has disregarded any possibility that archaeology of national importance will be discovered on site. This goes against the best advice of English Heritage, Dr Jan Harding as well as many more archaeologists and heritage professionals that have offered an opinion. As a result, the mitigation strategy utterly fails to ensure that archaeology on site and yet to be discovered will be appropriately treated. By this measure, it is clear this planning application should not be granted. What about you? Are you convinced that Ladybridge is a key part of a highly important archaeological landscape? Are you concerned that Tarmac's commitment to quarrying in the Thornborough landscape? If you are, you can help us. Until the 9th of September 2005 you can send a letter to North Yorkshire County Council voicing you concerns (sample letter here). Until this planning application is decided, you can write a letter to our Prime Minister asking for the landscape of Thornborough to be better protected (sample letter here). There's lots more you can do, just look around the TimeWatch website.