Understanding environmental impact is crucial to sustainability and community quality of life.

South Sebastopol Archaeology and Historic Landscape Re-evaluation

7. Commentary on the Archaeological Impact Assessment conducted by the Glamorgan/Gwent Archaeological Trust for RPS Chapman Warren.

7.1 I read the Archaeology section of the Impact Assessment after I undertook my own field observations recorded above. Not only do my findings challenge those contained in this section, but I find also that it contains severe internal contradictions and inconsistencies sufficient to undermine it as a credible text. This is due in part to what I consider to be poor workmanship and in part to the inadequacies of the procedures used and required by the planning process.

7.2 At the core of my concern is the pattern of contradiction which seems to have been generated by a sloppy desktop appraisal, compounded by the lack of coherent and critical fieldwork.

‘This is a massive unresolved anomaly and the clarity of the author's vision … is not shared with us.’

7.2.1 On page 26 §2.9.9 the conclusion is reached: ‘Over the subsequent century, most of the remaining land was enclosed, and buildings were constructed, initially as farm buildings serving outlying blocks of estate land, but by the end of the 19th century as separate farmsteads (see also Section 2.6 and Appendix A1).’ The basis for this argument seems to be an analysis of a survey made for the 1792 Monmouthshire Canal Act Which, however, ‘shows little detail’ (previous sentence). By ‘remaining land’ the author seems to mean the landscape in the development area other than enclosed fields around Tir Brychiad and the woodland in the central area. The implication is that there is evidence for unenclosed heathland or woodland elsewhere in the area at around 1792. No such evidence is cited. The author then states that there is no Parliamentary Enclosure Award documenting this action which would have been extensive and required such an Act. The lack of evidence appears to ring no alarm bells for the author. The chronology asserted here is repeated in §2.9.14 where it is further implied that seven units of land ownership sprung into existence between 1792 and 1840. This seems to back up a Landmap level 3 survey (§2.9.13) which asserts that the area in the vicinity of Maesgwyn and Tir Brychiad is a ‘post-medieval landscape of moderate value’. However, §2.9.12 asserts that ‘the medieval and later landscape can be traced with some confidence, and activity appears to be focused on the farmstead sites’. What the medieval aspects of the landscape are is unclear, but nothing has been attributed to this period elsewhere in the text and the implication is that everything is actually post-medieval (including the landscapes around the farmsteads of Tir Brychiad and Maesgwyn). This is a massive unresolved anomaly and the clarity of the author's vision in §2.9.12 is not shared with us. The interpretation of a post-medieval chronology (quite false in my view anyway) lies at the heart of the evaluation of the landscape and so the unresolved contradiction fundamentally undermines it. This is compounded by sloppy use of the Canal and Tithe Maps which would not be acceptable to any landscape historian who anyway would be alarmed at the thought that such large tracts of lowland were available for enclosure between 1792 and 1840 in Wales. This misinterpretation is compounded by the next two contradictions:

7.2.2 On page 26 §2.9.10 the final sentence introduces the key interpretation that the long-term predominance of land use in this landscape was pasture: ‘Edlogan retained its emphasis on pastoral land-use into the 20th century’, citing evidence from 17th century wills for extensive cattle farming, albeit acknowledging both some arable production and the valuable grazing rights on Mynydd Maen. However, in §2.9.7 Tithe Survey information clearly indicates a mixed farming regime for the fields around the main farmsteads. What is clear, I think, is that the grazing rights on the mynydd sustained the cattle, supported by fodder from the lowlands, while the land around the farmsteads was for arable production probably in some kind of rotation. The text, however, strives to give the impression of a landscape with little diversity and of low importance, despite the clear evidence to the contrary.

7.2.3 This is compounded by reference (§2.9.8) to ‘limited activity in the past’ and (§2.9.12) to ‘a low intensity of activity in the past’, a conclusion drawn from test pits dug for purposes other than archaeology (largely geology) and from results derived from sites nearby, but not within the development area. Why there were no excavations specifically designed for the purposes of archaeology is bewildering and one can only believe that this is a self-fulfilling prophesy: the archaeology was not rigorously searched for because it was not believed to exist. The author also does not make it clear what precisely is meant by ‘limited activity’. One can only assume that what is missing are the traces of ‘material culture’ or finds, such as pottery. What appears not to have been considered is the general paucity of finds for many periods including the Middle Ages and early modernity in the upland areas of Wales. This is caused by highly acidic soils and by the low levels of product dispersal among the rural cultures of upland Wales. Again, however, there is a desire to underline the impression of little diversity and low importance. It is an oft-quoted mantra in archaeology and other science that ‘absence of evidence is not evidence of absence’. In upland landscapes it is essential to drive the search for evidence very hard and be prepared to use a variety of evidence sources. The normal expectation, given the pollen record in most of the upland, is that these areas have been complexly farmed, and continuously occupied from the Iron Age at least, if not the Bronze Age.

‘there is no reference to … the best text on this subject currently available.’

7.2.4 It is worth mentioning other minor errors noted in passing: the date of the Tithe survey is 1842 not 1840 (§.9.7); the ancient parish boundary is not ‘ignored by the field boundaries’, except among the medieval ‘intakes‘ on the mynydd, a relationship which would be expected for this date (§2.9.l4); and there is no reference to the PhD thesis of Paul Courtney of 1983 on the Rural Landscape of Eastern and Lower Gwent, the best text on this subject currently available.

7.3 I would also like to make special reference to the Landmap survey which is cited in the text (§2.9. 1 3). While this exercise, conducted by CCW, is an excellent overview of the diversity of Welsh landscapes it is not so good for the determination of individual small areas and very bad at dealing with previously unrecognised forms of landscape. The determinations which make up the mosaic of the historic maps are based on general pre-conceptions about how the past landscape of Wales works and uses an array of pre-determined types. This is compounded by the work being done by people who are not analytical landscape historians or archaeologists. In the case, for example, of enclosures, particularly ones which are still extant, there is a tendency to believe that they are entirely a process of modernity, namely the ‘Enclosure Movement’. There is now plenty of evidence across the country that such landscapes could have been created at any one of many points over the last 4000 years and been perpetuated. However, it takes a bold spirit and a knowledge of current thinking to step outside of the strait-jacket of proscribed typology. Landmap is thus a self-affirming procedure and of little use as evidence in its own right, since it depends on some fairly superficial judgements often undertaken on the basis of map and air photograph inspection rather than fieldwork. So in §2.9.13 area the statement ’the History Aspect study identified an area (I-I10) in the vicinity of Maesgwyn and Tir Brychiad as a post-medieval agrarian landscape of moderate value, is intrinsically valueless as a judgement.

7.4 The question that then arises in my mind about all of this is: who was responsible for ensuring that the Archaeology impact assessment was up to standard and sufficiently rigorous? Is it the Glamorgan-Gwent Archaeological Trust who are responsible for development control in this area for Torfaen Council? If not them, then who? If it is GGAT, can we expect them to criticise the quality of work of the consultant contractor, which is GGAT? The question of the degree and process of quality control in this case should at least be put.