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Illustration 21. The number of Environmental Impact Assessments recorded in relation to the number recorded with archaeological components for
the period 1985-99. [Data: overall numbers from DoE/DETR; archaeological components from AIP.]
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

38
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 cross-
reference 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 wide-
ranging 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 1985–90 (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 1990–99; 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 1997. 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.