“The 10-year heritage research at Roșia Montană cannot be contradicted by a three-day visit”
As explained in a previous opinion piece, I am an archaeologist with York Archaeological Trust and formerly the CEO of Oxford Archaeology, which has been involved with the Roşia Montană Project (Project) since 2008.
It was brought to my attention that a report written in September 2010, with additional summary in 2011, by A Wilson – D Mattingly – M Dawson titled ‘Statement of Significance: Cârnic Massif, jud Alba Romania’ (WMD Report), was recently made public in Romania. The authors of the WMD Report visited the Project for only three days and took just two months to consider a selection of the documentation relating to Roşia Montană’s heritage, work undertaken over more than a decade by many hundreds of professionals, both Romanian and international, in their various fields of archaeology.
In summary, my analysis of the WMD Report highlights that its consideration of the significance of the site (in relation to a claim that Roşia Montană possesses an equivalent significance to World Heritage Sites) and its comments on the conservation strategy contain numerous factual inaccuracies. Statements in the WMD Report that are presented as fact can only be considered legitimately as assertion or opinion, leading to significant misrepresentation of the archaeological and heritage program conducted in the context of the mining project proposed by RMGC. In each of these areas I find that the WMD Report has significant deficiencies in the conclusions reached.
In terms of a professional assessment of archaeological significance, the WMD Report is compromised by substantive and demonstrable factual errors and fallacies of argumentation. In particular:
- the poorly developed data-set for Roman mining, acknowledged by the leading specialists in mining archaeology, does not permit authoritative statements to be made with reference to the unique or unusual qualities of the mines at Roşia Montană;
- parallels are in fact known to attributes which it is claimed are unique within Cârnic massif;
- the intact character and completeness of the Roman archaeology is poorly and inaccurately assessed;
- the extent of the research programme on the heritage that has been undertaken in relation to RMGC’s proposal has not been understood or is poorly represented, leading to gross misrepresentation of the scale of work done over more than a decade. For example, it is erroneously claimed that pre- and post Roman periods have not been researched, while the scale of the architectural analysis is not appreciated.
- The physical evidence for medieval mining is significantly over-stated.
- There is an inadequate comparative analysis of the Austro-Hungarian mining leading to an over-statement of its significance.
The claims of an equivalence of importance that is commensurate with World Heritage Site status is unsustainable against the deficient assessment of significance, but is further compromised due to the lack of any detailed consideration of the other essential components that would be required to demonstrate Outstanding Universal Value as required by the World Heritage Convention: namely an assessment of integrity and authenticity, and a comparative analysis of Roşia Montană – indeed the WMD Report fails to mention the Austro-Hungarian mining site of Banská Štiavnica that is already inscribed on the World Heritage List.
With respect to the recommendation in the WMD Report that the site is retained in situ in its totality, my analysis concludes that the recommendation is inappropriate, built as it is on:
- an over-statement of the site’s significance;
- a lack of appreciation of the poor conservation state and poor integrity of much of the heritage due to sustained mining, in particular over the past 250 years, that has had an immense impact on earlier phases of heritage and left a largely unremediated, heavily polluted environment; and
- a lack of professional appreciation of the scale of costs involved in a programme aimed at total conservation (conservatively estimated as in the order of $200-300 million).
Numerous major development projects within Europe have levels of heritage impact comparable to that at Roşia Montană, where heritage management is undertaken in a more sophisticated manner, as proposed by RMGC, using a variety of strategies from selective preservation in situ in conjunction with preservation-by-record.
In terms of public debate of the WMD Report, ‘arguments from authority’ have been used to sustain its conclusions, in particular as one of its authors is based at the University of Oxford. The inherent weakness of this form of argument and the fallacies that can develop from this position are well understood within academic discussion and should not obscure rational engagement with the issues.
It should be noted that the project has never sought to pursue a route of only minimal compliance with the requirements to mitigate the heritage impacts of the mining proposal. Thus it launched a major research campaign unparalleled in the history of Romanian archaeology, while in the area of underground mining archaeology it sought the advice and involvement of one the leading international mining archaeologists, Dr Beatrice Cauuet from the University of Toulouse.
Finally, the lack of dialogue between the WMD Report authors and the archaeologists that have been involved on the project for more than a decade is highly regrettable, as it would have eliminated many of the errors in the report that influence its conclusions.
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