|
THE
SADDLEWORTH ARCHAEOLOGICAL TRUST Founded
1995 |
|
HONORARY SECRETARY:
D CHADDERTON HONORARY
TREASURER: K.BOOTH
7,
SHARON AVENUE CEANN GRASSCROFT FRIEZLAND LANE SADDLEWORTH GREENFIELD OLDHAM OLDHAM OL4
4HP OL3
7EU TEL. NO:
01457 820054 TEL. NO: 01457 872092 E-mail: dchadderton1@beeb.net E-mail: kbbooth@talk21.com |
Mr. T Flanagan and Ms. Adele
Hayes, 15th January 2004
Environmental Services
Department,
Oldham Metropolitan Borough
Council,
Civic Centre,
PO Box 30,
West St.,
Oldham.
OL1 1UQ My
Ref: DC1109h
Dear Mr. Flanagan and Ms
Hayes,
PLANNING APPLICATION PA/046136/03: WINDFARM
COMPRISING 7 WIND TURBINES, ONE TEMPORARY ANEMOMETRY MAST, ONE PERMANENT
ANEMOMETRY MAST, ELECTRICAL SWITCHING BUILDING, ACCESS TRACKS AND ASSOCIATED
DEVELOPMENT ON LAND OFF HUDDERSFIELD ROAD, DENSHAW MOOR, SADDLEWORTH, OLDHAM
I am writing as Hon. Secretary of Saddleworth
Archaeological Trust to register a major objection to the above proposal to
build 7 wind turbines on part of Denshaw Moor, Saddleworth.
The grounds for our objection are as follows
:-
1) Archaeological Remains
.
1.1) The concentration of Mesolithic (Middle Stone Age) sites
close to the proposed wind turbine area is one of the highest in the British
Isles, and as the late Dr. Pat Stonehouse discusses in his Book “The Prehistory Of Saddleworth & Adjacent Areas” (The Planning Department already
hold a copy), this is probably because in this area of the Pennines, the high
part of the moorland barrier is at its narrowest. The prehistoric tribes from either side of the Pennines thus
found it easy to meet in this area to trade flints, skins, and other items.
The presence of 200 known
Mesolithic sites in the immediate vicinity of the proposed wind turbine area will
mean that there are almost certainly many more undiscovered archaeological sites in and around the
proposed area. Some of these known sites contained 40 flints, some contained at
least 140 flints and some several thousand.
It should be noted that the peat was deposited on our moors after the end of the Mesolithic
Period (circa 4000 BC), and this means that the worked flint artefacts
generally only come to light on undisturbed moorland when the overlying peat
cover is eroded away or removed by other means.
The OMBC hold, in the
Planning Department, a set of maps extracted from Dr Stonehouse’s book, “The
Prehistory of Saddleworth & Adjacent Areas”, showing the known Mesolithic
Sites around the proposed area. (These were enclosed in our previous letter
objecting to the wind turbine test mast, Ref DC1018, dated 10th
December 2002 but a further map, showing both Mesolithic and Bronze Age sites,
with the position of the proposed seven wind turbines is appended to this
letter.) Collections of worked flints
from the Mesolithic period (Dr. Pat Stonehouse’s own collection contains over
10,000) are held in the Tolson Memorial Museum in Huddersfield with the earlier
finds when Saddleworth was in the West Riding of Yorkshire.
1.2)
Another important archaeological site, that is almost under one of the
proposed Turbines, (No 1, at OS grid
reference SD 993120) is at Ragstones,
where not only the well known magnificent Bronze
Age ceremonial Flint Dagger was found, but also some flint scrapers and
other worked tools of the Mesolithic and Neolithic (New Stone Age) periods.
1.3) There
is a possibility that there is a Roman
road running across the site of the
proposed Wind Turbines that lines up with the North West gate out of the first
Castleshaw Roman Fort.
1.4) Two Mediaeval Iron Smelting Furnaces have
been discovered within the area outlined of the proposed Wind Turbine Site in
the Castleshaw valley: These are almost
certainly connected with the site of the vaccary associated
with Roche Abbey that existed at the settlement at Grange in the Castleshaw
valley in the 13th Century.
The presence of iron ore in the local rocks would indicate there might
be other sites not yet discovered.
The Significance of the remains
It is acknowledged that the Roman road and medieval smelting sites are of local or regional importance and that full archaeological excavation would, in their case, be a suitable mitigation strategy.
It is considered by the University of
Manchester Archaeological Unit that because the site is close to, and
surrounded by the greatest concentration of Mesolithic Sites in the British
Isles, together with other prehistoric remains, that any prehistoric remains
within the wind turbine area must be considered to have at least Regional Significance.
The University of Manchester Archaeological Unit
also consider that:
“In the event the study area was found
to contain Mesolithic remains with exceptional elements such as a high density
of sites, a particularly good level of survival and a high diversity of special
features, the significance of those sites could be raised from regional to
national.”
Guidance to Planners on
significance of remains
It should be noted that in the English Heritage Guidance paper “MANAGING LITHIC SCATTERS, Archaeological guidance for planning authorities and developers 2000”, pages 6 and 7, the following guidance is given on the importance of lithic scatters such as we have in the vicinity and possibly in the as yet undisturbed area of the proposed development; -
“Although
scheduling is unlikely in most cases, a lithic scatter will have particular
importance if:
i)
Clear boundaries have been identified, making it recognisable
as a discrete site
ii) The
high quality of artefacts recorded from a recent collection episode (eg fresh
condition; sharp edges; unusually large quantities of small chips and debitage)
suggest buried archaeological deposits have only recently been disturbed; such
scatters are more likely to be discrete, and other less durable artefacts such
as pottery may be present
ii)
Additional evidence (from excavation,
geophysical survey or aerial photographs) suggest the presence of buried
structural remains with which the artefacts are believed to be associated
iii)
There is evidence for part of the site
not having been disturbed at all
iv)
A scatter has been either dated or
interpreted with confidence
v)
The artefacts recorded suggest
diversity within the scatter, whether in terms of repeated occupation over
centuries or even millennia (for example where diagnostic artefacts of more
than one period are present); or if evidence exists for various tasks having
been performed.
In general terms, sites meeting any three
of these criteria are sufficiently rare in England to be considered of National
Importance and should be treated accordingly under the terms of planning policy
guidance. In view of their national rarity, exceptions will include scatters of
Palaeolithic, Mesolithic and Early Neolithic date, for which criterion (v)
(above) and one other will be sufficient to demonstrate national importance.”
Some
of the known sites in the moorland close by the proposed wind turbine site
(March Hill, Readycon Dean) do meet the
requirements in the above list whereby they can be considered to be of national importance, taking either nos. (i), (iii) & (v), or
(v) and (ii) for Mesolithic scatters.
The proposed wind turbine site, being as yet
unexcavated, should as a precautionary principle, be included as part of this
whole South Pennine Mesolithic scatter site.
In line with PPG 16, all the
South Pennine sites mentioned above should consequently be physically preserved
in situ.
Other
Guidance to Planners
We note that OMBC have
written guidance on wind power installations and some relevant paragraphs
relating to Archaeology are now quoted:
1)
The
OMBC Supplementary Guidance Note No 18 on Wind Power has the following
paragraph in section 6.19: -
"Archaeological remains contain irreplaceable information about
our past, and form part of our cultural heritage. They are also non renewable and vulnerable to damage and
destruction. Sensitive management is therefore essential to ensure they
survive. PPG 16 "Archaeology and
Planning" gives advice on proposals which may affect archaeological
remains. Where nationally important remains and their setting are affected by
proposals they should normally be physically preserved."
Oldham MBC adopted the South Pennines Inter-Authority Planning Policy Principles for Wind Power Developments in March 1994 in which it was stated:
"The South Pennines Planning Authorities support in principle the use of wind energy for power generation, provided that this does not effect the valued characteristics of the area, its landscape and ecology and its historic and amenity attributes."
And
"In considering proposed wind
power applications, and their access tracks, associated buildings and
connections to the National Grid or local users, Planning Authorities will have
particular regard to:
B) The impact on the historic character
and cultural heritage of the area particularly in respect of: -
Conservation Areas and Listed Buildings
sites
of archaeological importance."
Paragraph
BE2.7 in the current 1996 adopted Unitary Development Plan, still in force,
reads:
“The
Council will not permit a development proposal where there is evidence to
suggest that the site may contain archaeological remains, unless the developer
has arranged for the preservation in situ of any remains or, if this is not
possible, a comprehensive investigation and recording before the commencement
of development.”
Paragraph C 1.12 in the
First Deposit Draft U D P 2001 and the para. C 1.12 in the Revised Deposit
Draft Plan 2003 both repeat this statement but add another paragraph:
“Development
which would damage significant
archaeological remains will only be permitted in cases where it can be
demonstrated that the benefits of allowing the development outweigh those of
preservation of the remains”
Paragraph 12.54 in the
Revised Draft Deposit Plan states:
“…………………In considering developments, the Council will aim to ensure that
neither the monument, archaeological site or its setting will be adversely
affected.”
The UK Policy
and Planning Guidance Note 16 “Archaeology and Planning” has several relevant
paragraphs similar to the above.
Paragraph 6 states:-
“Archaeological Remains should be seen
as a finite, and non-renewable source, in many cases highly fragile and
vulnerable to damage and destruction. Appropriate management is therefore
essential to ensure they survive in good condition. In particular care must be taken to ensure that archaeological
remains are not needlessly or thoughtlessly destroyed. They can contain
irreplaceable information about our past and the potential for an increase in our
future knowledge. They are part of our
sense of national identity and are valuable both for
their own sake and for their role in education, leisure and tourism.“
In the recently published
book “Prehistoric Peoples of the Pennines” by Ms. P A Spikins, published by the
West Yorkshire Archaeological Service, Ms. Spikins
expresses her worries that the remaining Mesolithic Sites on the Pennine moors
are being destroyed at an ever increasing rate, partly by overgrazing by sheep
and partly by human activities. She
also points out that because of this destruction, the National Trust in the
Marsden Moor area adjacent to the proposed wind turbine site has banned any
further archaeological excavations.
2) Landscape Value
The area of land on which
the turbines are proposed to be built has intrinsic preserved relic landscape
value quite apart from the archaeological points made above.
At the time reservoirs were
built in the 1880 to 1891 period, by Oldham Corporation, the whole area of the
fields, walls, roadways leading to the farms, the remains of Dowry Castle House
and other dwellings, the Public Highway known as Rapes Highway and other
features such as the Boxing Hole were frozen in time. The area around the
reservoirs was left virtually untouched for over 110 years: no buildings,
caravan sites, or any other developments that would affect the water collecting
ground were allowed, and as result the landscape is almost exactly as it was in
1890.
In the 1996 Adopted U D P,
several paragraphs in sections OE1 and OE2 relate to the continued need to
protect open land in the Borough from inappropriate development.
In the Revised Deposit Draft
U D Plan, 2003, Section C1, paragraph 2.5 b describes the Borough’s Historic
character as being:
“..essentially
defined by its moorland scenery – the stone built farmsteads and former
industrial villages of the Pennine uplands”
Para 12.6 states :-
”With these points in
mind, the Council will make the conservation of the borough’s historic
buildings, structures and areas a priority. It will exercise careful and
detailed control over new development and pursue suitable opportunities to
ensure funding for heritage-led regeneration.”
In the same revised Deposit
Draft Plan document, in Section OE2.1, relating to Landscape, paragraph 11.77
states:
“Insensitively
located buildings, telecommunications equipment and wind farms can also
adversely affect landscape quality”
Again in the same revised
Deposit Draft Plan document, Section NR3.1states:
“The
Council will permit developments which generate energy from renewable sources,
where the development, or any ancillary infrastructure or buildings, would not
result in an unacceptable impact on:
a)
residential/workplace amenity or human
health,
b)
the visual amenity of the local area
including landscape character,
c)
local natural resources, including air,
and water quality,
d)
biodiversity, nature conservation or
historical/archaeological interests,
e)
public access to the countryside.
Paragraph 13.84 in NR3.3
then states:
“Wind Turbines and their associated
infrastructure, such as access roads, and grid connections, inevitably involve
disruption to the ground in the course of construction, especially the
foundations required for the turbines themselves. In light of this it is
possible
that
disruption to sites of archaeological interest could be caused by such
developments. Criteria d) of Policy NR3.1 seeks to ensure that
historical/archaeological interests are taken into account when applications
for such developments are being considered, and additionally any proposal for
such a development would be assessed against Policies C1.11, and C1.12 in
section 12 of the Plan which relate specifically to sites of archaeological
importance.”
3) Environmental Archaeology
English Heritage
state in their official Guidance paper “ENVIRONMENTAL
ARCHAEOLOGY. A guide to the theory and practice of methods, from sampling and
recovery to post-excavation” 2002, the following definition:
“Environmental
Archaeology concerns ecological, social and economic reconstruction. These
themes can be examined in relation to changes through time, evidence of
specific activities or events and interaction with contemporaneous landscape”.
In the case of the area of Saddleworth under consideration typical
situations are: -
Heathlands
and upland moors - environmental
remains such as charcoal, charred plant macrofossils, pollen and spores,
phyolithics and diatoms can be recovered. These remains will allow radiocarbon
dating using the charcoal and analysis of the pollens etc. to throw light on
the vegetation history of the area from as far back as c.8000BC.
Peats
and organic deposits from wet ditches and upland moors – again it is
possible to recover charcoal and charred plant macrofossils to facilitate dating.
Other remains that can be recovered are waterlogged plant remains, insect
remains, molluscs, bones, ostracods, pollens and spores, diatoms and wood. The
recovery of these remains enables information relating to the historic flora
and fauna of the area to be collated.
Apart from the
above, the information collected enables climatic conditions to be recorded for
each archaeological period.
It has been
shown that both natural and archaeological palaeoenvironmental deposits can be
combined to provide new insights into the impact of humans on the landscape.
Little research relating to
Environmental Archaeology has taken place in Saddleworth, the exception being
that under-taken by Brayshay in 1998 at High Moor (SD97100624), Castleshaw Moor
(SD00451150), Dean Clough (SD98701260), and Castleshaw Roman Fort Vicus (c SD99880965)
It is more than possible
that widespread destruction of the Environmental Archaeology will take place
within the area of the wind farm if it is allowed to proceed. Turbine and
lifting crane foundations, access roads, cable trenches and the general works
required, not to mention the random meanderings of heavy machinery onto the
area generally will destroy an archaeological landscape that has survived since
history began and it has to be preserved for future generations to explore and
enjoy.
The OMBC Supplementary Guidance Note No 18 on Wind Power has a paragraph, 6.18, that recognises the unique character of the peat land sites in OMBC. This paragraph reads:
"Proposals for development affecting peat land sites must be treated with particular care because these sites provide particularly rich, distinctive and increasingly rare habitats. The unique character of peat land depends on the maintenance of waterlogged conditions. The hydrological implications of wind turbine developments may therefore require examination on peat land sites."
Longer term
destruction will probably take place as a result of the drying out of the peat
arising from increased water run-off caused by the trenches, drainage ditches,
roadways made for the heavy construction vehicles and the mass concrete
foundations that would be built on the sloping sites of the proposed wind
turbine area. This would lead to the complete loss of ten thousand years of
environmental archaeology, stretching right back to the last ice age.
Discussion
It is submitted that in the
sections that have been quoted above, that the Council’s own written policy
statements would lead to a conclusion that planning approval for this wind
turbine installation must be refused.
The Saddleworth Archaeological Trust would
also submit that whilst the whole area where this wind turbine proposal is
being made, considered at present to be of Regional
Archaeological Importance,
has such a wide span of archaeological finds, ranging from the end of the Ice
Age with the Mesolithic finds, right through the ages to late medieval
bloomeries and a preserved Victorian landscape, that the area is approaching a
level of National Archaeological
Importance.
This submission is
reinforced by the guidance in the English heritage paper “Managing Lithic Scatters, Archaeological Guidance for planning
authorities and developers” because the areas of Mesolithic scatter in the
Readycon Dean and March Hill areas, that lie adjacent to the proposed wind
turbine site, infer that this whole South Pennine area under discussion is of NATIONAL IMPORTANCE and that the finds
should be preserved in situ.
Erection of a group of large 2000KW wind turbines would irrevocably
damage the archaeology of the whole area of moorland. Very large foundations are needed for turbine towers to
withstand the bending moment of the wind, 300 tonne concrete pads are needed
for the erecting cranes, hard surfaced, deep foundation, access roads would be
needed to bring in the heavy machinery and for maintenance, cable trenches,
electrical switchgear buildings, drainage ditches and overhead electricity
lines on posts would also be necessary.
PPG 16 states that if
archaeological remains are of National
Importance, the presumption should be that they are preserved in
situ.
As such, it appears to us
that the output of electricity,
at 2000 Kilowatts per turbine (maximum output) but reduced by the variation of
wind speed over the year to an annual average of only 33%, i.e. 667 Kilowatts per turbine (for an
installed cost per turbine of £1.4 Million) does not demonstrate in any way a benefit that outweighs the
preservation of these regional or national important remains. (Para. C1.12 in the OMBC new draft UDPs)
An additional observation is that the output
from one turbine is only slightly more that the output of power from one 44
tonne lorry engine, and the savings in the emissions of greenhouse gases by
installing one turbine are insignificant compared to economies in the reduction
of energy that could be obtained by, for example, switching carriage of goods
in a small number of 44 tonne road vehicles to rail in the UK or by pursuing a
vigorous policy of energy conservation across the whole country.
Should planning permission ever be given for this development, then
prior to the start of the work, a full archaeological evaluation that
would include a large number of test cores, a series of test pits and trial
trenches, followed by a series of large scale excavations would need to be
carried out at all points where the contracted professional archaeologists
designate there to be likely archaeological remains. Because of the fact that in the land round about the proposed
site a large number of important archaeological remains have been discovered,
the area of the proposed wind turbine installation is likely, in our view, to
produce a large number of archaeological discoveries. This exercise would also
need to include a wide-ranging study of the Environmental Archaeology.
The works should
be secured by means of a suitable condition, after consultation with the County
Archaeologist. (See para. BE 2.7 in the existing OMBC UDP) and the works would
include detailed and time-consuming excavation followed by extensive post
excavation analysis, report writing and publication.
The cost of, and
the time required, for such a prolonged archaeological study could well show
that the project is not viable.
Summary
In
summary the points we have made are:-
1) In the area surrounding the
proposed wind turbine site and in some cases within the area, there have been a large number of archaeological finds. The University of Manchester Archaeological
Unit currently rates these as of regional
importance.
2) It is likely that other
important prehistoric archaeological artefacts lie undisturbed in the proposed
wind turbine area and if these were found to contain Mesolithic remains with
exceptional elements, the significance for these particular sites could, in the
opinion of the University of Manchester Archaeological Unit, raise the importance to a national level.
3) In addition, the criteria for the selection of important remains
that are given by English Heritage in their paper “Managing Lithic Scatters, Archaeological Guidance for planning
authorities and developers” leads to the argument that because the areas of Mesolithic scatter in the Readycon Dean and
March Hill areas, that lie adjacent to the proposed wind turbine site are of
National Importance, this infers that this whole South Pennine area of these
Mesolithic finds, including the proposed wind turbine site, is of NATIONAL IMPORTANCE and that the finds
should be preserved in situ.
(See the map
appended that shows the closeness of the nearby Mesolithic remains.)
Several
statements in the existing UDP and in the revised UDP have been quoted;
extracts are also taken from PPG16, all of which indicate strongly that the
whole area should left undisturbed.
In our view
this is an overwhelming reason why the proposed wind turbine development should be refused.
4) The area of land of the proposed
development has intrinsic preserved landscape value. After the reservoirs were
built in the 1880s, the original landscape of Victorian fields, tracks,
bridleways and farm walls has been preserved as it was 110 years ago. Again
statements in the UDP attach high importance to preserving the visual historic
landscape character of the Borough.
Quotations from OMBC guidance show that
conservation of historic landscapes is a most important consideration and again
this is another reason why the proposed
wind turbine development should be refused.
5) The
heathland and upland peat moor proposed as the site for the development
contains a unique record of the climate, the historic flora and fauna, and of
the human impact on the landscape as far back as c. 8000 BC. Widespread destruction of the environmental
archaeology will take place within the area of the wind farm if it is allowed
to proceed.
IN CONCLUSION - the moorlands surrounding
Saddleworth are very precious to the Metropolitan Borough of Oldham. They are
unique in the sense that they contain a microcosm of the history and
archaeology of the area, starting when the Ice Age first scoured out the
scenery we see today, through the various Stone Ages, the Bronze and Iron Ages,
the Roman period with the two forts and the important road connecting the
Legionary Fortresses at Chester and York, the Viking and Medieval periods, the
Industrial Age with the Standedge Canal and Railway tunnels.
Very
few areas of Britain can boast of a continuous history from c.8000 BC to the
present time and O.M.B.C. should be thinking more of preserving and promoting,
rather than destroying the ‘Jewel in the
Crown’.
The
archaeology contained within Saddleworth is highly regarded by local, regional
and national Historians and Archaeologist together with the many visitors to
the area who come in search of OMBC’s past and recognise the very special
nature of ‘so much in such a small area’
The
vast majority of Oldham’s surviving Archaeological Heritage lies within the
Saddleworth boundary - destroy this and
what is left for future generations?
The Saddleworth
Archaeological Trust cares passionately about the preservation of our
Archaeological Heritage in the Metropolitan Borough of Oldham, and we, as
Trustees, would ask that the Borough Planners and all the Council elected
representatives please give serious consideration to the observations and
opinions in this letter and refuse planning
permission.
Yours faithfully,
David Chadderton, Hon Sec. and Trustee,
The
Saddleworth Archaeological Trust.
Trustees
:-
Kenneth Booth, FSA Scot. David Chadderton, BSc (Hons), C
Eng, MIChem E Donald Haigh,
MA, FSA