4 April 2005

Your ref: 01/01315/OUT

Dear Hannah Blackburn,

Germany Beck site east of Fordlands Road, Fulford, York

Thank-you for your letter of 1 April and the accompanying Historic Landscape Appraisal for Fulford by MAP. I would like to take this opportunity to respond to this report, as well as to renew the official objection of the Battlefields Trust to the proposal for outline permission by Persimmon Homes and Hogg Builders, in particular to the proposed route of the access road to the proposed site for housing.

You have already received a copy of the peer review endorsed by the Battlefields Trust by Glenn Foard of the earlier report by MAP.

The main over-riding concern is that there has still not been a thorough archaeological survey conducted to the standard required for a site of potential historical significance. Before any consideration as to whether permission should be granted to this application a systematic high-quality research program must be carried out to see whether further archaeological evidence exists for the battle of Fulford on the application site. As I believe you are aware, the Fulford Battlefield Society has led a research-programme on part of the site, which has found a large number of artefacts, many of which are currently undergoing analysis in part to see which may come from the 11th century.

It is extremely disturbing that MAP’s report can state categorically that ‘there is no evidence at all that it [the Battle of Fulford] took place on the site of the proposed development’ (para. 9.1.) This is simply not the case, with a range of historical, archaeological, geological and landscape evidence pointing to the land alongside Germany Beck being the site of at least part of the battle. Indeed, in earlier documentation the developers themselves admit to this as being the ‘probable’ or ‘likely’ site of the battle. Moreover, part of the reason for a lack of archaeological evidence is no doubt due to the refusal of the landowner of part of the site to allow archaeological survey work to take place. It is worth quoting again part of Glenn Foard’s report on MAP’s earlier work, relating to battlefield archaeology:

‘In their conclusion MAP make the sweeping statement that, given the absence of physical evidence related to the battle recovered in the field investigations undertaken on the site, ‘the battle did not take place on the area of land around Germany Beck’. They also suggest that the failure of past development in the area to provide any supporting evidence while it did produce Roman and prehistoric remains challenges the identification of Fulford at the site of the battle. This simply demonstrates their complete lack of knowledge of the nature of the physical evidence likely to exist on a battlefield and the ease with which it can be located. If this latter argument was followed then one would have to draw the conclusion that the battle of Hastings did not in fact take place at Battle!

In making their assessment of the lack of battle archaeology from the Germany Beck site and more generally from the Fulford area, MAP have failed completely to take into account the points raised in our earlier submission with regard to the problems in the investigation of battle archaeology of the early medieval period. We have already clearly explained that most of the techniques to which they refer and the particular methodology by which they were undertaken, and this appears also to be true of the new work in the On line Pond Area as well, are wholly unsuited to addressing questions regarding the archaeology of battle. The criticism of the methodology of their trial trenching made in our previous submission still holds true, and apply equally to the newly reported trenching of the On Line Pond Area. No attempt is made in their new reports to address these criticisms.

They make reference in their Assessment (3.25) to a metal detecting survey, but provide no statement as to the methodology and how this was defined in order to address the specific needs of the investigation of battle archaeology. They make no mention and include no references in their bibliography which would lead one to believe that they have examined any papers on the techniques of metal detecting survey on historic battlefields, even though key papers were listed in our previous submission, or to have applied the basic principles of battlefield metal detecting survey that we outlined. If they are referring to the metal detecting of topsoil mentioned but not explained in the Historic Landscape Appraisal document, or if it is to work that was reported in their previous reports, which were copied to the Battlefields Trust by the Planning Archaeologist and dealt with in our previous submission, then that work cannot be considered an adequate investigation to determine the battle archaeology potential of the Germany Beck site.

The taphonomy of the battlefield has not been considered, even though this was specifically referred to in our previous submission. The fundamental principles of such an assessment have been defined by Janaway & Tilbrook in connection with much later battlefields. In the absence of such an assessment the conclusions drawn by MAP as regards the lack of battle archaeology from previous investigations of this site cannot be accepted. Without a detailed understanding of taphonomy it cannot be established whether the lack of artefacts is simply a result of unsuitable conditions for the survival particularly of ferrous items.

Indeed, given the weight that MAP attribute to the failure to locate any evidence of battle archaeology, it is remarkable to note that nowhere in their discussion do they actually define what the archaeology of a battle of the 11th century might be expected to comprise, in what density and distribution, let alone whether the nature of the ground conditions and current and past land use would enable it to have survived. As they have not defined any of these things, then one wonders how they manage to assess the suitability of their methodology of trenching, fieldwalking, metal detecting and geophysical survey to locate such evidence.

The lack of relevant expertise and experience of the author(s) of the MAP report in regard to the battle archaeology is summed up in the report’s final paragraph. There it is claimed that a further programme of excavation and watching briefs on all groundworks will ‘ensure that no evidence will be lost’. As they have not demonstrated that they understand the nature of the archaeology to be expected from an 11th century battle or the appropriate techniques to recover that evidence it is difficult to see how they can make this sweeping claim.’ (G. Foard, February 2004.)

This apparent lack of appreciation for the nature of battle-related archaeology for a battlefield of the 11th century remains a serious problem in MAP’s new Historic Landscape Appraisal. In para. 9.7 it is claimed that the application site has been subjected to ‘rigorous archaeological investigation’. This simply is not true, unless the results have not been made available to us. The Battlefields Trust submits that truly rigorous archaeological investigation must take place, along the lines suggested above by G. Foard, before further thought can be given to this application. The concerns raised in G. Foard’s report relating to the battle archaeology remain.

There are several statements in the MAP report to suggest that because the landscape has changed or re-modelled since the time of the battle the battle cannot be appreciated. This is patently not the case, as with almost any battlefield there will have been some landscape change, and yet surely the authors of the MAP report do not suggest that all battlefields cannot be appreciated and/or interpreted because of this. To take a battlefield from the same year as Fulford, Hastings, where there have been significant post-battle changes, most notably with the construction of an abbey, which included much landscaping. Despite this, the battlefield of Hastings is a most rewarding site to visit. The landscape changes at Fulford, if the site of the battle is as the Battlefields Trust and most other sources suggest is correct, are minor when compared to those at Hastings. In para. 9.2 MAP claims that there is no consensus of opinion as to the site of the battlefield. Although there is some disagreement, the Battlefields Trust would attest that consensus does exist to place the battlefield to the east of the Ouse, along the course of the Germany Beck. This consensus includes the developers, at least earlier in the planning process. The new MAP report does contain some useful discussion about the nature and age of the Germany Beck, although further archaeological investigation is needed to discover what form the drainage channel took in the 11th century.

One of the most important considerations for the City Council should be the value of the site as the battlefield. This value is in part historical and educational, but also economic. While it is accepted that more housing is needed, an alternative must be found to the proposed access road which cuts across the suggested site of the battlefield. The successful combination of development and archaeological/historical exploration and interpretation can be seen clearly at Coppergate. The potential exists at Fulford to have the same degree of success and benefit for necessary development on the one hand, but also heritage and tourism development on the other. The potential is there to create what would be a national leader for a battlefield park. This could combine archaeological work and research projects (possibly in part through co-operation with such leaders as the University of York’s departments of Archaeology and Medieval Studies, as well as the Council for British Archaeology and the York Archaeological Trust) with creating a tourist attraction on the edge of York, close to good road access, which could help to ease congestion within the inner city, while still providing benefits to the city and the visitor. The battle of Fulford provides great possibilities as can be seen with the proven success of the Jorvik Centre.

It is incorrect when the MAP report suggests the battlefield of Stamford Bridge has secured statutory protection due to it being ‘sufficiently well-known’ (para. 8.1.2) This is incorrect on two counts. Firstly the battlefield of Stamford Bridge like all others on the ‘Register of Historic Battlefields’ does not receive any statutory protection, merely that it has to be treated as a material consideration during the planning process, due to its registration. Secondly, Stamford Bridge was not registered due to it being better known than Fulford. Moreover, modern development has tragically proceeded apace at Stamford Bridge, resulting in the almost total loss of the battlefield, whereas at the unregistered site of the battle of Fulford, much of the landscape is still undeveloped. Therefore, the potential remains at Fulford to preserve, understand, interpret and present the battlefield in a way which is no longer possible at Stamford Bridge. It would be a very sad legacy if two of the three battlefields of 1066 were to be destroyed by modern development, when the opportunity was clear and available to preserve and interpret this historic site and event for future generations.

Battlefields are a rare and precious resource, with early medieval battlefields being particularly so. There are only three registered battlefields from the period before AD1100 in the whole of England. If a road is put across the battlefield of Fulford, it should be treated as an act of civic vandalism on the same scale as if the Shambles were turned into a modern shopping mall or Clifford’s Tower and motte knocked down to make way for a larger car park. The battlefield of Fulford should be treated as one of York’s many historic treasures. To obliterate it should be unthinkable.

Yours sincerely,




Michael Rayner (Co-ordinator, The Battlefields Trust)