RRA Raises Archaeological Concerns on St Martin’s CAB site planning application

The RRA raised concerns regarding Archaeology and Validation Procedures that should be followed with respect to the revised Desk-Based Archaeological Assessment (DBA) dated 18 February 2026, which appeared on the planning portal on 19 February;

At the point of validation, it was concerning that the DBA originally uploaded to the planning portal was inaccessible and could not be opened for several weeks. This meant that the application did not meet the validation requirement for adequate archaeological information for a site within an Archaeological Priority Area.

     2.  The a revised DBA dated 18 February 2026 was u0loaded to the planning Portal

The DBA discloses that

• archaeological potential of the south site is not fully understood…”
• “…a programme of archaeological evaluation will be required…”
• “…the scope… would be prepared following consultation with GLAAS.”

     3. Requirement for pre‑determination evaluation

Given the DBA’s conclusion that the extent and character of archaeological remains are unknown, the application cannot be determined without:

• formal advice from GLAAS, and
• clarity on whether pre‑determination evaluation is required.

This cannot be left to a condition unless GLAAS explicitly confirms that approach is acceptable.

4  Consultation with Historic England and GLAAS

The LPA did not consult Historic England and GLAAS until 20th February to access the archaeological assessment (DBA).   The proposed development raises issues connected to both a scheduled monument and non-designated archaeology. So a joint response will be presented to LBH Planning in due course.

5 New Consultation Period now expires 25th March

A new consultation period commenced on 20th February that has been extended further to expire on 25^th March (due to a further press ad published on 4^th March)

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