5. Archaeology and Environmental Impact Assessments

Transcription

1 5. Archaeology and Environmental Impact Assessments Background Environmental Impact Assessment is a multi-disciplinary, and to some extent inter-disciplinary, audit of the environmental resources and attributes within a specified area, the results of which are then related to the anticipated impacts on the environment of a proposed development and variations of it. The result is an Environmental Statement that forms the basis of discussions between interested parties and informs the decision-making process within the planning system. The idea of Environmental Impact Assessment has a long history in the United States of America (Wathern 1988; and cf. Cleere and Fowler 1976), 17 and was formally introduced to Europe as a selectively applied requirement by the European Commission in June 1985 through Council Directive 85/337/EEC on The Assessment of the Effects of Certain Public and Private Projects on the Environment (EU 1985). In April 1986 the UK Government published a preliminary consultation paper on the implementation of the Directive and in July 1988 Regulations were introduced as the Town and Country Planning (Assessment of Environmental Effects) Regulations 1988 (SI 1988 No. 1199). Full details of procedures were set out in a circular (DoE 1988) and an accompanying advisory booklet (DoE 1989a). Procedures were monitored during the first five years of operating the regulations (e.g. Wood and Jones 1991) and consultations were carried out during the period covered by this study on possible changes to arrangements in the UK (DoE 1992; 1994b). Guidance and reviews of procedures relating to many of the subjects covered under the regulations have also appeared, including archaeology (Ralston and Thomas 1993), road traffic (IEA no date), and landscape issues (Stiles et al. 1991). The essential features of the scope and implementation of Environmental Impact Assessment in England are twofold. First, the procedures apply to two groups of projects: major projects listed in Schedule 1 to the regulations for which assessment is mandatory; and other projects as listed in Schedule 2 for which assessment is discretionary and within the powers of LPAs or the Secretary of State for the Environment to request where the project in question is judged likely to give rise to Illustration 21. The number of Environmental Impact Assessments recorded in relation to the number recorded with archaeological components for the period [Data: overall numbers from DoE/DETR; archaeological components from AIP.] 37

2 significant environmental effects. In general, Environmental Impact Assessments are carried out prior to the submission of a planning application, the resulting Environmental Statement forming part of the application documentation. Arrangements are therefore in place for the determination by an LPA as to whether an Environmental Impact Assessment is required in a particular case. Special regulations have also to be issued for types of project that fall outside the planning system. 18 Environmental Impact Assessments may also be undertaken voluntarily. Second, the regulations specify the information that has to be included in an Environmental Statement, and lists those aspects of the environment that must be considered. Ten dimensions of the environment were listed in the 1988 regulations (SI 1988 No. 1199, Schedule 3, 2.(c)). Archaeological remains were not explicitly listed in the regulations, although they are considered as part of the cultural heritage by crossreference to the original Directive which did explicitly include archaeology as a matter that should be considered under the heading material assets (EC 1985, Annex III.3; and cf. DoE 1989, 38 9). The principles behind Environmental Impact Assessment have far wider implications than the implementation of the regulations themselves. Key amongst these is the idea that in order to make informed decisions it is necessary to carry out appropriate verifiable tests and studies; this is also one of the principles that underlie the guidance offered in PPG16. In one sense the imposition of a common set of assessment principles across all European states provides the benchmark against which local procedures at all scales should be measured. In March 1997 the European Union issued a revised Directive amending the existing regulations covering Environmental Assessment (EC 1997). This has been implemented in the UK by the issuing in April 1999 of Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (SI 1999 No. 293). Revised regulations detailing projects outside the planning system have also been issued, together with general guidance (DETR 1999a). Although these new regulations post-date most of the work documented and discussed in the following sections of this report, it is worth noting that a number of wideranging changes were introduced, and have been outlined and discussed by Grant (1999b; and see DETR 1997b). Ironically, archaeology is not explicitly cited in the revised European Directive (although it is assumed to be subsumed with cultural heritage ), but is now itemized in the revised UK legislation where the list of aspects of the environment to be considered includes material assets, including the architectural and archaeological heritage (SI 1999 No. 293, Schedule 4, I.3). 19 One major problem with gathering information about the role of archaeology in Environmental Impact Assessment is the widely recognized difficulty of identifying Environmental Statements, and in particular the archaeological components of Environmental Statements. There are two aspects to the problem. The first is a general one and relates to the fact that there is no consolidated national index to statements submitted to LPAs or DoE/DETR. Attempts to publish consolidated lists (e.g. IEA 1993a; 1993b; 1994) have floundered, with the result that figures up to 1991/2 are probably better than for some later years for which no digests are available. The second, more particularly archaeological, relates to the fact that because archaeological desk-based assessments and field evaluations are often carried out early in the preparation of an application these programmes are sometimes finished and the reports issued before it is decided to incorporate the results in an Environmental Statement. Where there is no information in the issued reports about the use of a piece of work within the broader context of an Environmental Impact Assessment it is almost impossible to link the investigations with the wider programme. To overcome the first of these, members of the AIP research team examined the collections of Environmental Statements held by the DETR in London which may be considered the best available sample of such documents providing almost complete coverage. How many, when, and where? About 150 Environmental Statements containing sections dealing with the archaeological evidence were found for the period (Darvill et al. 1995, 40). One of the earliest to include archaeology was that prepared for the UK landfall sites on the Channel Tunnel Project in Kent (KAT 1985; Darvill 1986). 20 More than 680 Environmental Statements that include archaeology within the scope of their studies have been recorded for the period ; a considerable increase in the number of such reports produced. Since the introduction of Environmental Assessment regulations, about 2000 Environmental Statements have been produced according to official figures recorded by the DoE and DETR. Illustration 21 shows the changing pattern of Environmental Impact Assessment projects year-on-year in relation to the number of recorded examples with archaeological contributions. As can be seen, the overall number of Environmental Statements completed rises sharply between 1985 and 1991 after which it fluctuates considerably with peaks in 1993 and 1999 and troughs in 1991 and This pattern shows some resemblance to the cyclical pattern of planning applications as a whole (cf. Illustration 2). However, the number of Environmental Statements that include archaeological contributions show a slightly different pattern up until 1995, after which the two trends are remarkably similar and suggest the full integration of archaeological inputs to the Environmental Impact Assessment procedures. It is still too early to tell, however, whether the increase in 1999 is attributable to the effects of the revised legislation. 38

3 Table 6. Number of recorded E nvironmental Statements containing a section dealing with the archaeological impact in relation to the overall number of Environmental Impact Assessments carried out in England annually 1990Ð99. [Data: DoE /DETR and AIP. Samples as shown.] Total Schedule 1 Projects Schedule 2 Projects Schedule unknown Total recorded with archaeological contribution All EAs (DoE/DETR) Percentage Environmental Statements with an archaeological contribution Overall, 681 archaeological contributions to E nvironmental Statements have been recorded for the period 1990Ð99, about 42% of all such statements having an archaeological section (Table 6). 21 T his superficially rather low percentage of E nvironmental Statements containing archaeological contributions appears to be confirmed when compared with the results of an earlier study which found that about 48% of E nvironmental Statements in a sample of 100 examples produced in 1988Ð89 had an archaeological component (Jones 1993, 31). However, the average conceals some important trends. A s Table 6 shows, since 1995 the proportion of E nvironmental Statements which include archaeological studies has hovered around 60%, more than three times the level for the first half of the decade. A gain this suggests that archaeological studies are now well integrated with the E nvironmental Impact A ssessment process. A rchaeology is not included in all E nvironmental Impact A ssessments because the studies are selectively scoped by L PA s. Comparative data are hard to come by, but taking as a sample the 416 E nvironmental Statements produced between 1990 and 1999 that were found to contain an archaeological component, it is possible to analyse the other subjects represented within the reports examined (Table W18). 22 B y definition, archaeology was represented in 100% of these E nvironmental Statements because this was the basis on which the sample was initially selected. For other studies, the sample is perhaps more representative. E cology and landscape were both represented in about three-quarters of the documents examined, water in about 61%, highways and traffic in about 58%, and human beings in about 47%. If the sample here is taken as being representative of scoping practices for subjects other than archaeology, then it is relevant to compare the overall figure for the 1990s of 42% with archaeological sections with the sample examined here which reveals that historic buildings and structures were considered in about the same proportion of cases (38%). In the wider long-term context it will be interesting to see whether, in due course, the explicit listing of archaeology within the UK regulations increases the incidence of inclusion (cf. DE T R 1999a, paragraph 89). Table 6 looks at the distribution of work carried out in relation to the defined Schedules. Here it can be seen that Schedule 1 projects with archaeological components appear to be extremely rare, although by far the greatest number of archaeological contributions examined by AIP researchers could not easily be assigned to one or other of the Schedules that had prompted their production. W est M idlands Nor th W est South W est North E ast South E ast Y or kshir e and H umber side E ast M idlands E aster n G r eater L ondon Illustration 22. Distribution of Environmental Impact Assessments with archaeological components undertaken in England The boundaries of the English Heritage regions are shown. [Data from AIP.] 39

4 Illustration 23. Percentage of Environmental Impact Assessments with archaeological components undertaken for the main development types requiring Environmental Impact Assessment. [Data from AIP. Sample comprises 401 investigations.] Illustration 22 shows the geographical distribution of recorded Environmental Assessments with an archaeological component issued between 1990 and The overall distribution is wide, with concentrations in the Midlands and East Anglia. Some Environmental Impact Assessments are carried out offshore and within the inter-tidal zone, especially in connection with seabed aggregate extraction and mineral prospection. Types of development Illustration 23 shows an analysis of the kinds of development represented amongst a sample of Environmental Statements with archaeological components. The single largest group, representing about 17% of such projects, relates to road schemes, with mineral extraction (16%) and service infrastructure works (14%) coming in close behind. All three kinds of development represent high-profile schemes in which the industries concerned have developed strong and positive approaches to meeting environmental concerns which are articulated through codes of practice and operating statements (CBI 1991; DoE 1989b; HA 1993). The remaining schemes, collectively accounting for just over half of all archaeological studies in Environmental Impact Assessments, embrace an extremely wide range of development types. The most recent changes to the Environmental Impact Assessment regulation (in 1999) make assessment mandatory for works undertaken by statutory undertakers such as oil and gas pipelines and overhead power lines above certain thresholds. This is likely to have a considerable effect on the number and range of projects undertaken by archaeological contractors. No information is available regarding the general land-use situation of schemes subject to Environmental Impact Assessment with an archaeological component, but a review of all projects carried out to 1989 revealed an urban:rural split of 32%:68% (Wood and Jones 1991, Table 9). 40

5 Commissioning bodies Environmental Impact Assessments are relatively expensive and time-consuming undertakings. In general, most relate to large-scale projects whose development budgets can absorb such expense more easily than smaller-scale projects. However, as the revised regulations shift the emphasis a little from general perceptions of the scale and possible impact of the project to a case-by-case scrutiny of the sensitivity of the environment in which it will take place (cf. Grant 1999b, 10) it is likely that in future there will be more rather smaller schemes involved. The majority (67%) of Environmental Impact Assessments were commissioned by developers, but other bodies such as the Department of Transport, water companies, and county councils were also major commissioning agencies (Table W19). Changing contributions from each over the course of time reflect the shifting socio-political importance accorded to various kinds of public work. This is especially marked in the case of road schemes, which peaked in 1993 and 1994, and the high level of developer-funded schemes from Methodologies and approaches Because of the nature of Environmental Impact Assessment, and the requirements set out in the regulations, the archaeological methods deployed include those familiar within desk-based assessment and field evaluation. The LPAs receiving an Environmental Statement have specific roles under the regulations, and developers and receiving authorities must agree the scope of the work. Ultimately, however, it is the developer who is responsible for the content of the Statement that is finally submitted (DoE 1989a, 10). The preparation of Environmental Impact Assessments is typically carried out by planning consultants and environmental consultants, although many commission reports on certain aspects of the project from sub-contractors who specialize in particular fields. Archaeology is one such matter which is sometimes tackled in-house by multi-disciplinary consultants while on other occasions the work is contracted out to archaeological contractors and consultants. More than 180 consultants and contractors were recorded as being involved in the preparation of the archaeological components of Environmental Impact Assessments. Table W20 lists the top twenty contractors involved in the production of archaeological contributions to the Environmental Statements recorded by the AIP researchers between 1990 and However, many reports were found in which the originator of the archaeological elements was not recorded; these no doubt represent the results of work by a number of other contractors not otherwise represented on the list, as well as additional reports generated by those who are. In general, however, the number of Environmental Impact Assessments carried out by individual contractors and consultants is relatively low compared with other areas of activity, even accepting that some additional hidden projects lie amongst those for which full details are not available. 41