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Should an archaeologist recommend a development in the planning application comments
Is it that clear. Aren't a lot of consultants trying to make out that they are neutral and somehow constrained by a code of conduct and ethics like preservation in situ. The NPPF heritage statements are part of the pre application submissions. These submissions are supposed to be by the "applicant". NPPF says "As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary." We seem to come in as a "where necessary" and it still appears that the applicant is the submittant.

Paragraph 128 seems to say that a further desk based and field evaluation may be required. What it doesn't say is at what stage might the desk based or the field evaluation be required. Seems to me that it was intended to be pre application but that once the application is in, the requirement will result from consultee comments.

The comments in my local planning application section are split between "public comments" and "consultee comments". Public comments seem to be headed as neutral, objections or supports. What seems pertinent about these public comments is that if the decision gets appealed to public inspector that only public that made the original representations can make representations to them (is that true?). Obviously the decision would only go to an inspector mostly because an appeal had been made by the developer in which employ you are so your heritage statement presumably gets in. My instinct is that I want the heritage statement to be in my name as that is a product like any other that I am selling the client as would an evaluation and that it would be my name in an inquiry. In which case shouldn't the heritage statement be placed in public comments for "supports" when the decision is pending.
.....nature was dead and the past does not exist

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