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Uncertainty in relation to the environmental impact assessment (EIA) of archaeological heritage
For the professional the Diploma in EIA and SEA managment Dr. Charles Mount completed a project entitled:

A critical review of what constitutes an allowable degree of uncertainty in relation to the assessment of archaeological heritage within the environmental impact assessment process in Ireland

Project presented to University College Dublin in partial fulfilment of the
requirements for the diploma course in EIA and Sea Management 2010


This project examined uncertainty in relation to the assessment of archaeological heritage in Ireland. It reviewed the requirements of the Environmental Impact Assessment Directive and European and national guidance documents and policy. It noted that national policy in Ireland is that EIA should involve the carrying out of archaeological assessment including, where appropriate, test excavation. It reviewed the main sources of current knowledge relating to archaeology and noted that these under-present archaeology by as much as 94%. It noted that methods of assessment such as geophysical survey and test excavation can provide the missing information. However, in the EIAs examined these assessment methods were not employed or used inconsistently with a resulting uncovering of substantial quantities of unassessed archaeological remains at construction stage. It concluded that encountering some archaeological remains during the development process as a result of the limitations of the methods of assessment does constitute an allowable degree of uncertainty. However, not employing adequate assessment techniques as part of the EIA process resulting in impacts on large numbers of unassessed archaeological sites is an unacceptable degree of uncertainty. An outline of EIA Directive and Irish National policy are presented below.



The European environmental impact assessment directive
The assessment of archaeological heritage in relation to developments that are judged to have a significant environmental impact is mandated by the EIS Directive 885/337/EEC on the assessment of the effects of certain public and private projects on the environment (amended by 97/11/EC). Article 5 of the directive, which has been transposed into Irish national law by the Planning and Development Act 200 and Statutory Instrument No. 600 of 2001 states that:

1. In the case of projects which, pursuant to Article 4, must be subjected to an environmental impact assessment in accordance with Articles 5 to 10, Member States shall adopt the necessary measures to ensure that the developer supplies in an appropriate form the information specified in Annex III inasmuch as:

(b) the Member States consider that a developer may reasonably be required to compile this information having regard inter alia to current knowledge and methods of assessment.

This section of the Directive requires a developer to have regard to current or existing knowledge about Annex III information, but also requires the developer to have regard for current methods of assessment.

As both types of information, current knowledge and that obtained through methods of assessment, are placed together as a requirement the Directive intends that the two be complementary. Where gaps are identified in current knowledge these should be filled through methods of assessment.

National legislation
The EIA Directive was transposed into Irish law through Part X of the Planning and Development Act 2000, which replaced the previous EIA regulations. Under this act the new Irish EIA regulations transposed the Directive exactly, stating that an EIS shall contain the information specified in paragraph 2 of Schedule 6 to the extent that

(ii) the person or persons preparing the EIS may reasonably be required to compile such information having regard, among other things, to current knowledge and methods of assessment, (S.I. No. 600/2001 Part 94. (b)(ii))

Schedule 6 of S.I. No. 600/2001 states that the information to be contained in an EIS should include:

1(c) The data required to identify and assess the main effects which the proposed development is likely to have on the environment.

2(c) a description of the likely significant effects (including direct, indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative) of the proposed development on the environment resulting from:

- the existence of the proposed development,
- the use of natural resources,
- the emission of pollutants, the creation of nuisances and the elimination of waste, and a description of the forecasting methods used to assess the effects on the environment;

The reference to forecasting methods recalls the reference to methods of assessment in the Directive and emphasises that the intention is not to rely solely on current knowledge in the assessment process.

Irish national archaeological policy
The national policy in regard to archaeological heritage and the assessment of archaeology in relation to EIS is laid out in Framework and Principles for the Protection of the Archaeological Heritage published by the Minister for Arts, Heritage, Gaeltacht and the Islands in 1999.

Section 3.3 sets out the policy on the protection of archaeological heritage in relation to preservation in situ and states:

There should always be a presumption in favour of avoiding developmental impacts on the archaeological heritage. Preservation in situ must always be the first option to be considered rather than preservation by record in order to allow development to proceed, and preservation in-situ must also be presumed to be the preferred option.

Section 3.3 also sets out the policy on the protection of archaeological heritage in the context of development and states:

Archaeological assessment is a method of, and the first step in, ensuring that the approaches of preservation in-situ and preservation by record are applied appropriately. In certain circumstances it may, on the basis of the results of archaeological assessment, be considered appropriate to carry out archaeological monitoring. However, archaeological monitoring is not an end in itself, rather a method of ensuring that preservation in-situ or preservation by record take place as appropriate

Having regard to the national significance of the archaeological heritage as a cultural and scientific resource of great importance and to the non-renewable nature of that resource, the Minister considers that the costs of archaeological work necessitated by development are a legitimate part of development costs.

Section 3.6.6 sets out the policy on the protection of archaeological heritage in relation to environmental impact assessment and states:

Environmental impact assessment should, unless there are substantial grounds to show that it is not necessary, involve the carrying out of archaeological assessment including, where appropriate, test excavation.

Certain circumstances (e.g. the existence of standing structures on a location which it is proposed to develop) might prevent the carrying out of test excavation prior to the authorisation or approval of development. In such circumstances it should be a condition of authorisation or approval of development that test excavation be carried out before the commencement of development works with a potential to affect archaeological deposits or sub-surface features. Such works include all sub-surface and construction works. The conditions of authorisation or approval of development should also provide for securing, as appropriate, preservation by record or preservation in-situ of archaeological deposits, features and structures; if necessary through alterations to the design of the development.

Section 3.6.4 sets out the policy on the protection of archaeological heritage in relation to the scope of archaeological assessment it states:

Archaeological assessment may, as appropriate, include documentary research, field-walking, examination of upstanding or visible features or structures, examination of existing or new aerial photographs or satellite or other remote sensing imagery, geophysical survey, topographical assessment, general consideration of the archaeological potential of the area or areas affected by a development based on their environmental characteristics, or archaeological testing.

To summarise the national policy states that preservation in situ of archaeological heritage must always be the first option considered in a development proposal. Archaeological assessment is the first step to ensuring that preservation is applied appropriately. Where an environmental impact assessment is being carried out this should involve the carrying out of archaeological assessment and where appropriate test excavation. Archaeological assessment may include existing information (documentary research, existing aerial imagery, etc.) as well as field walking, geophysical survey, topographical assessment or test excavation.





   
Projects
The environmental impact assessment of Cam Quarry, Co. Roscommon
The development of a new quarry at Cam, Co. Roscommon near Athlone lead to the archaeological assessment of an extensive area of pre-modern field systems.
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Brownstown Quarry Project
Since 2003 Dr. Charles Mount has been project managing the multi-period archaeological investigations at Brownstown, Co. Kildare. Summaries of the investigations carried out at the site are appended.
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Archaeological impact assessment of a quarry at Killough, Co. Tipperary
Continuing development at Killough, Co. Tipperary required the archaeological impact assessment (AIA)of the heritage in the surrounding area.
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