Our ref: TOR0049/JBHD ARCHAEOLOGICAL PLANNING Planning & Public Protection Service Torfaen County Borough Council Panteg Way New Inn Pontypool NP4 0TW 15th December 2014 FAO: Norman Jones Dear Sir Re: Proposed Land Reclamation and Coal Recovery Scheme: Land at Varteg Hill, Varteg. Pl.App.No.: 14/P/00637. Thank you for sending the details of this application. The supporting information includes Chapter 13 of the ES relating to Historic Landscape and Archaeology, undertaken by CGMS. As you will be aware form previous correspondence, there has been extensive correspondence regarding the archaeological resource within this site, and previously a desk-based assessment was undertaken in 2010. Subsequently, as a result of the updating of the proposal, we recommended that the archaeological desk based assessment should be updated to include new relevant data included in the Historic Environment Record curated by this trust and adopted by Torfaen CBC. The assessment states that sources including GGAT HER have been searched, and reference is made to the Southeast Wales Industrial Ironworks Landscape Project, and the event number given in the text, however, the text refers to 2005, and the bibliography to 2005-2010, although the detailed Year 6 Report which includes comprehensive and detailed identification and mapping of the sites within the area is not mentioned. The Year Six Report deals with the extractive and core ironwork areas of the Eastern Valleys and the Varteg area forms a section of this, not only with the describing of the sites themselves but also analysing the infrastructure for minerals extraction, water collection and management, transport and supply. We would have expected to see the referencing of the detail of this in the assessment, as it not only details the history and extent of more than one hundred sites in the immediate area and ascribes levels of significance between A and D, but also explains the sequencing of industrial working. A single map overlay is reproduced but with no analysis or explanation of the sites and data, which was revisited and updated in 2010, although the data again refers to 2005. Given the importance of the World Heritage Site, in which the northern part of the proposed development area sits, and the Registered Historic Landscape, of which parts of two Character Areas are within the development boundary, there is clearly a need to have a detailed and informed assessment in order that the impact of the proposals can be properly understood and in turn to ensure that a detailed mitigation strategy would be based on current and correct knowledge. Unfortunately, the assessment does not meet the professional standards necessary, as it has not included the details of the Ironworks Project, whilst referencing it, and the results of the assessment are therefore flawed. In addition, the bibliography lists amongst sources consulted Coflein and Archwilio, which by their terms and conditions must not be used for planning or development control purposes, as they are public access with limited data: details viewable at (www.rcahmw.gov.uk/HI/ENG/Search+Records/Explore+Coflein/What+is+Coflein%3 F/ and www.cofiadurcahcymru.org.uk/arch/archwilio_pages/english/conditions.html ). The bibliography also notes the Register of Air Photography, but there are no details within the text as to any flyovers or photographs available that were viewed, or the date of the visit to the Register; likewise, the Tithe Map is referenced but there is no described detail or reproduction. References to leases for workings are not seen, and presumably have not been consulted. Regarding the impact on the setting of the World Heritage Site, international documentation and guidance, for instance the Quebec Declaration (2008, ICOMOS: Preservation of the Spirit of Place) have not been consulted. It is our opinion that the assessment does not meet current professional standards, by not containing or having considered the full information and underlying data available, its conclusions are therefore flawed. There is no record of there having been detailed consultation with appropriate bodies regarding the integration of the industrial sites and the work undertaken that has formed the basis of the existing research. We therefore recommend that the report is not fit for purpose and should be revisited to ensure compliance with current professional standards, and that therefore the determination of the application should be deferred until a suitable document is submitted. If you have any questions or require further advice on this matter please do not hesitate to contact us. Yours faithfully Judith Doyle BA MCIfA Acting Archaeological Planning Manager .