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The controversial planning application by property developer Andrew Long to build a spa facility and small swimming pool in the listed White Hart hotel in the centre of the historic cathedral city of Lincoln has taken a personal turn with an architect for the project submitting a covering letter to Lincoln Council’s planning portal which attacks personally a critic of the scheme, professional archaeologist and TV producer Dr Samantha Stein.

Described as a COVER LETTER – SUPPLEMENTARY INFORMATION, the letter appears
over the signature of Mr Paul A Ponwaye who is a director of the project architects, Lincoln based John Roberts Architects.

Mr Ponwaye is listed on the networking website Linked-In as having been a director of the company since 2003.

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Controversially the letter claims,

“Unfortunately, Dr Stein has used her influence locally and nationally in an attempt to prevent the development by portraying the proposals in a way that is significantly inaccurate and misleading. Dr Stein’s campaign calls into question the professionalism and expertise of the Applicant’s consultant archaeologist Prosect [sic] Archaeology Ltd, the contracting archaeologists Allen Archaeology Ltd and that of the City Archaeologist.”

The letter continues,

“Dr Stein has demonstrably less relevant expertise in this particular aspect of archaeology than the professional archaeologists supporting the Applicant and that of the City Archaeologist.”

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Critics of the letter suggest that the inclusion of such personal criticism in an official document, can only be designed to prejudice readers, including potentially councillors who are due to decide the application at a public planning meeting, against the arguments Dr Stein is putting forward, while giving Dr Stein no opportunity to respond.

The line of criticism adopted by Mr Ponwaye is particularly inexplicable because, while Mr Ponwaye emphasises Dr Stein’s experience as a Geoarchaeologist, with the implication this experience is somehow less relevant than that of the project’s archaeology
consultants, Dr Stein’s profile on Linked-In, which could have been accessed easily by Mr Ponwaye as he is also a member, shows that, in addition to having worked on a number of developer funded projects, Dr Stein also spent almost two years with the national archaeological regulator Historic England as a Science Advisor [SA].

The Historic England website, also easily available, states,

“Historic England’s Science Advisors (SAs) provide support and advice to local authorities determining planning applications affecting archaeological sites and the archaeological units carrying out these excavations.”

In other words, Dr Stein’s CV shows she is every bit as qualified to comment on a planning matter as the project team.

The letter itself can also be fairly described as materially misleading in that, while singling out Dr Stein for specific criticism, the letter does not mention that an expert case worker at the Council for British Archaeology [CBA] submitted independently a written
comment regarding the application which agrees with a number of Dr Stein’s criticisms of the project.

Neither does the letter state that, as the CBA confirm in their recommendation, the objections to the spa scheme specifically relate to the excavation of a swimming pool, not to the spa scheme in general.  Although in fairness to the project team Mr Ponwaye made clear to thePipeLine that as far as they are concerned, without the swimming pool there is no spa project.

Nonetheless, the latest additions to the planning documents submitted by the applicant Mr Long, and published online by the City of Lincoln Council, suggest that the applicant, through John Roberts Architects, appears to have taken on board and attempted to action some of the exact same criticisms which Dr Stein and the Council for British Archaeology have recorded.

It seems therefore Dr Stein’s only sin is to have criticised Mr Long and John Roberts Architects plans for the hotel spa in public, leading to the bizarre situation where the applicant, through Mr Ponwaye, has acknowledged through its revisions and in the covering letter, that the criticisms made by Dr Stein and the Council for British Archaeology now seem to them valid, while using the same document to attack Dr Stein personally for expressing those opinions.

thePipeLine asked Mr Ponwaye why his letter singled out Dr Stein for personal criticism, but not the CBA which made many of the same criticisms of the application?

Mr Ponwaye told us,

“The difference between the comments made by the CBA and Dr Stein’s is that the CBA provided consultation to the LPA on the application in one succinct letter. The CBA have not sought to influence others through the use of local and social media or called for members of the public to object to the proposals.”

thePipeLine asked Mr Ponwaye and John Roberts Architects a further series of questions related to the covering letter and its apparent attack on Dr Stein.

thePipeLine asked, does John Roberts Architects accept that the Covering Letter PAP/8329W can be read as a deliberately aggressive, materially misleading, and even
misogynist attempt to delegitimise and silence an expert female voice in a way which is not appropriate in public life?

Mr Ponwaye replied,

“The letter is a statement of fact. Dr Stein’s gender and the gender of anyone else involved is irrelevant in this matter.
Dr Stein has presented herself as an expert and attempted to discredit the professional archaeologists who have provided archaeological input in support of the application.
They have considerably greater experience and expertise in this particular area of archaeology than Dr Stein.”

thePipeLine also asked does John Roberts Architects regard such an ad hominem attack as an appropriate part of a supposedly objective, evidence driven, planning process?

Mr Ponwaye responded,

“As stated in the covering letter Dr Stein has attempted to influence the decision-making process through her various personal appearances within the local and social media
and to portray herself as having greater expertise than the professional team supporting the applicant. The covering letter has, therefore, had to make personal reference
to Dr Stein’s comments in order to redress this and provide clarity in the minds of the decision makers.”

Asked if “…on reflection, John Roberts Architects does not regard the letter as appropriate, will John Roberts Architects withdraw the letter and apologise publicly to Dr Stein?”,

Mr Ponwaye told us,

“No apology is necessary. The letter is a statement of fact.”

Asked if John Roberts Architects regards the letter as an appropriate part of the process, will it state why it feels it is appropriate Mr Ponwaye referred us to his previous answer that the letter was “a statement of fact”.

Finally we asked Mr Ponwaye and John Roberts Architects, in the event the letter is not withdrawn and no apology is offered, to ensure fairness and maintain confidence
in the planning process, will John Roberts Architects support the City of Lincoln Council offering Dr Stein the opportunity to respond to the company’s direct criticism of her competence with the same prominence in the process as the letter from your company, the applicants architect? Mr Ponwaye told us,

“Dr Stein is entitled to make whatever representation she wishes, as she has demonstrated to date.”

thePipeLine also approached the City of Lincoln Council twice by e-mail with a series of questions including asking if the Council felt the personal attack on Dr Stein in Mr Ponwaye’s letter was appropriate in a supposedly evidence driven process and how publishing the letter on the Council’s own website was compliant with the Council’s equalities and human rights policy which states specifically that bullying will not be tolerated?

In spite of thePipeLine extending the time to respond by 48 hours, up to the time of publication the City of Lincoln Council has not responded to our questions.

Finally we also asked the two archaeological companies which are named in Mr Ponwaye’s covering letter, Allen Archaeology Ltd and Prospect Archaeology Ltd, if they were aware of the content of Mr Ponwaye’s letter before it was sent and whether they now endorsed the comments it contains about Dr Stein’s competence and conduct?

Responding on behalf of Prospect Archaeology Ltd, archaeologists Nansi Rosenberg and Naomi Field told us,

“We are astonished by your suggestion there has been any misogyny involved from the development team.  We have been listened to and appreciated as valued
members of the team at all times.  I would add that any claim that we are not experienced or expert in respect of this project is, quite frankly, insulting.
We would not, however, portray or accept that such a suggestion was in any way misogynistic, as it would appear more likely to be simply a sign of ignorance.”

Up to the time of publication Allen Archaeology Ltd has not responded to our request for comment.

As things stand Mr Ponwaye’s Covering Letter remains posted on the City of Lincoln Council planning portal unamended and with no commentary to contextualise its  comments regarding Dr Stein.

However, thePipeLine understands that far from closing down criticisms of the archaeological approaches adopted by Mr Long and his consultants, elements of the revised documents remain in question, including the stated assumption that any post Roman archaeology present on the White Hart site is of merely local significance.

Critics of the scheme argue that properly the project team can only suggest to the planners that the archaeology is of local significance and that published Historic England guidelines on the determination of archaeological significance require that such a determination can, in the end, only be made by appropriately qualified independent subject experts.

In that regard it is pointed out that understanding the period between the end of Roman rule and the Medieval period exemplified by Lincoln’s castle, cathedral and
still standing medieval houses, is of national importance, Lincoln being one of the UK’s most important cathedral cities which found itself at the centre of England’s
national and religious life, including playing a significant role in two civil wars of the Middle Ages.

thePipeLine also understands that critics of the project suggest that the deposit models cited by the White Hart project team in the latest documents may not be compliant
with current best practice guidelines?

Deposit modelling is used to predict what archaeology lies at what depth and is an issue which is critical to the White Hart planning application, particularly if the planners take the view that damage to the nationally important Roman archaeology thought to be underlying the site must be avoided.

The technique also sit squarely within Dr Stein’s area of professional expertise as a Geoarchaeologist.

Whatever the ultimate outcome of the planning application, the ongoing controversy over the plan to build a spa and pool at the White Hart also raises some more
fundamental questions which go to the heart of the relationship of professional archaeologists with their clients in the developer funded system.

That is, what is acceptable criticism within a planning process and if a client appears to overstep the bounds of what is professionally acceptable in that planning process,
can archaeologists remain silent?

Nansi Rosenberg and Naomi Field of Prospect Archaeology Ltd, and the director of Allen Archaeology Mark Allen, are all members of the professional body the
Chartered Institute for Archaeologists [CIfA] and Rule 1.2 of the CIfA Code of Conduct, which binds members, states that,

“A member shall be mindful of their duties to society, to those that could benefit from their work, to clients and commissioners, colleagues and helpers, to the profession and to themselves; when applying their judgement to balance differing demands they shall give due regard to their fundamental responsibility to the interests of the public.”

It must be asked if that requirement to be mindful of the duty to colleagues and fellow members of the profession have been served by the failure, so far, on the part
of the archaeologists involved in the White Hart planning application, also including Lincoln City Archaeologist  , to object to the singling out of Dr Stein for such personal criticism in the professional environment of the planning process?

Meanwhile, on the matter of the public interest, there also seems to be a fundamental misunderstanding of the Planning Process exhibited in Mr Ponwaye’s response to the
attempts of Dr Stein and critics of the White Hart application like the CBA, to apply proper scrutiny and accountability to what is a nationally important issue of process
and archaeological conservation.

That is that a planning application is a debate, and a document does not become “factual” merely because a developer has hired a consultant, paid for their report and submitted the report to the local planning authority.

The clues to that fact lies in the terms used in the process, for example “A Desktop ASSESSMENT of Archaeological Potential”.

An assessment is merely an opinion and any opinion can be questioned and rightly so.

Indeed, in the specific case of the White Hart hotel spa, as Mr Ponwaye admits, the issues raised by Dr Stein and the CBA have been taken on board by the project team
and the submissions made on behalf of the project have been updated.

As Mr Ponwaye states in his covering letter,

“In the light of comments made by Dr Stein we are submitting the following additional information to further support the applications for both Full Planning Permission and Listed Building Consent.”

In other words the criticisms are now seen to be valid enough in the eyes of the project team that parts of the documentation have been rewritten, in some cases
substantially so, removing whole lines of argument.

Most of the time developer funded archaeology works reasonably well, but the inescapable conclusion to the events surrounding the application at the White Hart in Lincoln is however that the initial documentation fell short of what was required.

It follows that, had Dr Stein, the CBA and other critics of the scheme not spotted these failings and intervened the scheme might now be going ahead having received no public scrutiny at a full planning meeting and based on, what the project team itself now seems to acknowledge, was, at best, incomplete information.

It is clearly in the public interest that these issues are fully and objectively worked through as Mr Long’s proposal for the spa and pool at the White Hart hotel progresses through the planning system.

However, the fundamental question facing archaeology, and particularly developer funded archaeology, is, with archaeologists sometimes seen as hired guns whose role is to
clear the way for a developer, does the system allow for the kind of open, free, fair and professional debate which is required when equally qualified archaeologists find themselves on the both sides of the argument?

Is it my client right or wrong?

Or, in the public interest, must archaeologists maintain and more importantly exercise, the right to independent comment and criticism even if that leads to parting company with opinions expressed by their clients, or even going against that client’s best interest in getting a project approved?

The archaeological profession must also ask itself, how often planning applications are submitted with similarly flawed archaeological assessments as now seems to be acknowledged in the Lincoln case and yet are approved because the flaws are not picked up by other public spirited experts like Dr Stein and the CBA?

Certainly the public, in whose interest the CIfA Code of Conduct says this is all about, is entitled to ask that question.

It is also entitled to get a clear answer.





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thePipeLine is an independent news publication that investigates the place that heritage, politics, and money meet.

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