Monday 26 September 2016

Stonehenge Visitor Numbers Kept Secret

An FOI request:

Dear Historic Buildings and Monuments Commission for England,
Please can you provide the daily visitor numbers to Stonehenge between 1st March 2015 - 31st December 2015
Yours faithfully,
Edward Shepherd

An Answer from Lynda Bennett, Historic England

I can confirm that English Heritage holds information that falls within
the scope of your request. However, I have decided to withhold this
information as I believe it to be exempt from disclosure under Section 43
(2) of the Freedom of Information Act 2000. Section 43 (2) provides an
exemption from disclosure of information which would or would be likely to
prejudice the commercial interests of any person. (A person may be an
individual, a company, the public authority itself or any other legal

A commercial interest relates to the organisation’s ability to participate
competitively in a commercial environment. I have concluded that the
information does fall within the scope of the exemption as it relates to
services provided by English Heritage and the level of usage of those

In considering the nature of the prejudice I have concluded that the
disclosure of the information would be likely to prejudice the commercial
interests of English Heritage. The charity is facing the challenge of
becoming self-funding within eight years of its launch. This is dependent
on achieving ambitious revenue targets which are, in part, connected to
Stonehenge, which accounts for a significant proportion of the charity’s
earned income. It is crucial for the on-going commercial viability of the
charity that it is able to operate in a commercial environment on a level
playing field with its competitors.

Despite being an iconic attraction, Stonehenge relies heavily on
attracting inbound tourists out of London and to do this the charity has
to negotiate and work with multiple domestic and international travel
trade operators each of whom are seeking a favourable commercial package
individual to them. At the same time, other attractions outside of London
are seeking to win this market, including those within the South West and
along the M4 corridor, including Bath and Windsor. London remains by far
the major beneficiary of inbound tourism to the UK and attractions outside
of the capital have to work hard to persuade London-based tourists to
journey outside. When they do, they typically visit on very tight
itineraries, normally only one day. Additionally there is a further
challenge at Stonehenge of managing the site during a period of major
upheaval to local traffic routes with the proposed A303 tunnel
development, which is likely to make it harder to continue to attract

The B2B pricing strategy for Stonehenge is complex with a range of
discounting measures. Disclosure of the daily figures weakens the ability
to use differential pricing as a tactic and exposes business data to other
players. This information would be useful to competitors and place
English Heritage at a distinct disadvantage particularly as its
competitors are not required to publish detailed visitor statistics, as
the vast majority are not subject the Freedom of Information Act. I
consider it is more probable than not that competitors would be likely to
use this information to target their own services and that it would likely
compromise English Heritage’s position in negotiations with travel trade

As section 43 is a qualified exemption and is therefore subject to a
public interest test I also have to consider whether the public interest
in withholding the information outweighs the public interest in disclosing

In favour of disclosure I have considered the public interest in
accountability and transparency of public authorities in the spending of
public money and facilitating the accountability and transparency of
public authorities for decisions taken by them. I have also taken into
consideration that English Heritage provides annual figures which provides
a degree of accountability and transparency in this respect.

In favour of maintaining the exemption I have considered that the grant in
aid funding received by English Heritage is tapering under the New Model
arrangements and that generating additional income is necessary to
conserve and safeguard a priceless collection of unique monuments and
sites in keeping with their status as part of England’s national heritage.
Therefore there is a strong public interest in English Heritage achieving
its key priority of becoming financially independent by 2022/23.

Having considered the above arguments I have concluded that the public
interest is best served by maintaining the exemption.

Lynda Bennett

Head of Information and Records

Information Management & Technology Department

Room 2/07, Engine House, Swindon, SN2 2EH

Friday 16 September 2016

Lost Avenues....

Robert John Langdon claimed last year that some green patches leading out of Avebury showed an avenue of stone holes;

I pointed out at the time this is just looked like the grain sprouting from where the previous crop has been laid by a path being formed.  After harvest the cultivating tractor goes back and forth dragging the seeds one way and then on return the other way.

I think the path was formed when the credulous visited a crop circle and the farmer had to create a path for them. Here's two example of crop circles on Waden Hill with a path following the same line as his avenue from Avebury.  

My sleuthing dog, Rufus, pictured, and I came across the same phenomenon on our morning walk near All Cannings this autumn.
The farmer had had to run down and mow the footpath across his field and after harvest and cultivations a very similar pattern appeared.

Click any to embiggen them.

Wednesday 14 September 2016

Stonehenge and the Preseli - mining sites

The only report I can find on the excavations in the Preseli this month so far is in Welsh, so with Dr.Google's help here is a translation:

From Golwg360

Over the weekend the research to find out whether there is a link between some of the stones at Stonehenge and Wales have taken a step forward as archaeologists start excavating a new site.

In December last year, announced the archaeological society Antiquity report suggests that some of the stones at Stonehenge Wiltshire, England, may have originated from panes in north Pembrokeshire .
Already, archaeologists have conducted research on sites in the Preseli area south of Eglwyswrw, Garn Goedog and Craig Rhos-y-Felin, and over the weekend they started digging third place close to both, on land farm Pensarn.

The research is being conducted by a team from University College London (UCL) and is being led by Professor Mike Parker Pearson, along with experts from the University of Manchester, Bournemouth and Southampton.

Work is expected to last for several weeks and the main objectives of the research is to try to establish whether there is a connection between the sites, understand the elements and transfer the neolithic stone....

Text of The Stonehenge Regulations 1997


1997 No. 2038


The Stonehenge Regulations 1997

 Made18th August 1997 
 Coming into force8th September 1997 

The Secretary of State, in exercise of the powers conferred on him by section 19(3) and (4) of the Ancient Monuments and Archaeological Areas Act 1979[1] and of all other powers enabling him in that behalf, hereby makes the following regulations: - 

Citation, commencement and revocation
    1. - (1) These Regulations may be cited as the Stonehenge Regulations 1997 and shall come into force on 8th September 1997.

    (2) The Stonehenge Regulations 1983[2] are hereby revoked.

    2.In these Regulations:

    "the deposited plan" means the plan entitled "Plan referred to in the Stonehenge Regulations 1997", signed by the Head of the Buildings, Monuments and Sites Division of the Department of National Heritage and deposited for inspection at the offices of the Secretary of State for National Heritage.
    "English Heritage" means the Historic Buildings and Monuments Commission for England;
    "monument" means the ancient monument known as Stonehenge situated on Stonehenge Down near Amesbury in the county of Wiltshire and includes any part or parts of the monument;
    "site of the monument" means the land shown on the deposited plan edged in black and hatched.
Acts prohibited
    3.The following acts are prohibited:
    (a) injuring, disfiguring, removing or otherwise interfering with in any manner the monument or any notice or any other property situated on the site of the monument;

    (b) climbing on the monument;

    (c) digging up, removing or otherwise interfering with any soil, grass or plants within the site of the monument;

    (d) bringing onto, parking or leaving any vehicle on the site of the monument otherwise than in accordance with parking authorised by English Heritage;

    (e) bringing any animal onto the site of the monument without the prior consent of English Heritage or allowing any animal to remain after such consent has been withdrawn;

    (f) lighting a fire or a firework on the site of the monument;

    (g) throwing a stone or discharging a weapon or missile of any kind from, over or onto the site of the monument;

    (h) without reasonable excuse entering or being upon any part of the site of the monument to which access is at any time restricted by barrier or prohibited by notice.
Acts prohibited unless done with written consent
    4.The following acts are prohibited unless the prior consent in writing of English Heritage has been obtained:
    (a) entering or being within the site of the monument at any time when it is not open to the public;

    (b) entering the site of the monument otherwise than by the entrance authorised by English Heritage;

    (c) organising or taking part in any assembly, display, performance, representation, review, theatrical event, festival, ceremony or ritual within the site of the monument;

    (d) erecting a tent or any structure of any kind within the site of the monument;

    (e) erecting or using within the site of the monument any apparatus for the transmission, reception, reproduction or amplification of sound, speech or images by electrical or other means unless the sound emitted is audible to the user only.
Acts done by or on behalf of English Heritage or the Secretary of State
    5.An officer, servant or agent of English Heritage or the Secretary of State, acting in the performance of his duties, shall not be in contravention of regulation 3 and shall be deemed to have the prior consent in writing of English Heritage to any of the acts specified in regulation 4.

Chris Smith
Secretary of State for National Heritage

18th August 1997


(This note is not part of the Regulations)

These Regulations regulate public access to the ancient monument known as Stonehenge, near Amesbury in the County of Wiltshire.


[1] 1979 c.46.back
[2] S.I. 1983/678.back

ISBN 0 11 064841 2

The Stonehenge Regulations 1997 - The Missing Plan

Statutory Instrument 1997 No. 2038 The Stonehenge Regulations 1997 makes reference to ; "the deposited plan" means the plan entitled "Plan referred to in the Stonehenge Regulations 1997", signed by the Head of the Buildings, Monuments and Sites Division of the Department of National Heritage and deposited for inspection at the offices of the Secretary of State for National Heritage."

So I asked the Department for Culture, Media and Sport, as the successor department incorporating "National Heritage", if they could inform me of the procedure to inspect the said plan as the regulations depend on being able to do so to determine the area of land covered by the regulations.

They sent a copy of the plan:

Click to enlarge 

Link to map overlain on Google's aerial photo which shows that the old A344 isn't included:
From Simon's comment below

But I replied I want to see the original, a copy has no legal standing, where is it and how can I get to inspect it.

They don't know, it is lost;  "I can confirm that the Department does not hold the original plan. You may wish to contact Historic England or English Heritage to find the information you are seeking." was the reply.

Without the plan the regulations would appear to be useless. Accused of transgressing them  a defence would be "show me the plan to prove I was within the area". The monument itself is protected under other laws anyway.

And of course the regulations have no penalty attached so are merely a civil matter anyway.

Sunday 11 September 2016

All Cannings Superhenge Excavation 2016

At All Cannings Cross in Wiltshire there is a very shallow semicircular bank which shows up on the ground and in the Aerial Lidar. There is a hint in the latter that the bank may continue under the roads and form a more circular structure.

Natural or the palimpsest of something more interesting?

There was only one way to find out: an excavation of a trial trench.

Click to embiggen

No sign of any ditch or archaeology - a natural feature :(

Mammillated Sarsens

Russell Yeomans kindly sent me some photos of mammilated sarsens from Sidestrand and West Runton in Norfolk and a couple seen in Ipswich. I also include one that is my covert marking the resting place of my old dog George.

Mammilary;is defined as
1: of, relating to, or resembling the breasts
2: studded with breast-shaped protuberances
from the Latin mammilla breast, nipple, diminutive of mamma

UPDATE:  Rob Ixer informs me that they may be a bit too coarse to be called Mammilary and that Reniform would be a more accurate  term.

He also points out that they are probably Load Casts; "which are bulges, lumps, and lobes that can form on the bedding planes that separate the layers of sedimentary rocks. The lumps "hang down" from the upper layer into the lower layer, and typically form with fairly equal spacing. These features form during soft-sediment deformation shortly after sediment burial, before the sediments lithify. They can be created when a denser layer of sediment is deposited on top of a less-dense sediment. This arrangement is gravitationally unstable, which encourages formation of a Rayleigh-Taylor instability if the sediment becomes liquefied (for instance, by an imposed earthquake shock). Once the sediments can flow, the instability creates the "hanging" lobes and knobs of the load casts as plumes of the denser sediment descend into the less-dense layer." From Wikipedia, the free encyclopedia

(They are in order as above, click to enlarge)