CORRESPONDENCE

Comments on C. W. Wright's "Ideas in palaeontology:prejudice and judgement"

David Norman, Peter Doyle, Colin Prosser, Nicholas Davey& Stewart Campbell

Nature Conservan cy Council , Northminster House, Peterborough, PEl IVA .

In a recent, celebratory, issue of the Proceedings, e.W. Wright (1989) reviewed what he considered to beseveral common ideas or themes in palaeontology.While he is perfectly entitled to hold his opinions, andshould be free to express them, we would like to claima brief ' right of reply' to the points which he chose tomake on the subject of conservation and the activitiesof the "Nature Conservancy". We wish to do thisbecause e. W. Wright appears to be perpetuatingseveral misconceptions concerning the Nature Con­servancy Council (renamed from the NatureConservancy in 1973) and the status of sites notifiedby NCC as Sites of Special Scientific Interest (SSSI) .

The points which we consider important in hisstatement on this subject are summarised below in theform of direct quotes, and we will deal with each intum.

1. "The idea that access to quarries, cliffs and so forthshould be regulated or licenced by a bureaucracy,Nature Conservancy or what not, is insufferable."followed shortly by "Yet I believe that the NatureConservancy is considering SSSIing cliffs."

The idea that NCC licences or regulates access to allits sites is erroneous. Notification of a geological siteas an SSSI very rarely results in regulation orprevention of access; this is, and always has been,entirely the right of the owner/occupier. To beexplicit , notification simply serves to inform everyowner/occupier, the local planning authority and theSecretary of State for the Environment (or appropri­ate Secretaries of State for Scotland and Wales), ofland considered to be of special scientific interest.

Geological SSSI have been identified by theGeological Conservation Review (GCR) of the NCCwhich has involved a network of geologists in a 12year period of assessment of all geological sites inGreat Britain. For inclusion within the GCR, sitesneed to be of national or international importance togeology. Such sites vary enormously but includeamongst others: working (as well as disused) quarries,railway and road cuttings, river and coastal cliffsections and foreshores.

The key feature of the notification procedure is the

establishment of a list of Potentially DamagingOperations (PDOs); this is a list of activities,considered by NCC staff to be potentially damaging tothe scientific interest of a site. We must emphasisethat owners/occupiers are not necessarily prohibitedfrom undertaking any PDO, but they have a statutoryrequirement to consult NCC over their intention to doso. Where "operations" are considered to bedamaging, NCC will seek discussion with theowner/occupier over possible modifications to theproposals. Negotiations may produce a change inmanagement of the site in order to safeguard, or evenenhance the scientific interest, and can result in alegally binding Management Agreement between theowner/occupier and the NCe.

So, to pick out e. W. Wright's evident exasperationat the thought of cliffs being notified as SSSI , it is verylikely that sea cliffs, if they are eroding, may attractlocal authorities (through concerned local residentsperhaps) who may wish to stabilise the cliffs byerecting coastal protection measures (rock armour,gabions , wave-return walls etc.). Such activities canbe inimical to the geology of the cliffs: if not buryingthem under a mass of concrete, then interruptingnatural erosion, causing grading and finally vegetationand loss of good exposures. In these instances it is ourjob to marshal scientific arguments using the GCRnetwork and other specialists to prevent such loss atsites . If we fail in this then we can rightly be criticised,but not when the conception of what we do isincorrect.

In short, what we are trying to do is not restrictaccess to sites , but ensure, through the consultationscheme (PDO list), that Britain's most important siteshave a future for geologists for the purposes ofresearch and education. Perhaps this is a case wheree. W. Wright has mistaken conservation forpreservation. Many geological sites have a dynamiccomponent which militates against any 'mothballing'of sites.

It should also be added that the consultationprocedure of notification can also have beneficialconsequences for geologists. For example , we canlearn of developments which may actually improve the

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92 DAVID NORMAN, PETER DOYLE, COLIN PROSSER, NICHOLAS DAVEY & STEWART CAMPBELL

geological quality of the site (reopening old quarries,trenching-and thereby opening up new sections--orre-excavating old ones); this can provide opportunitiesfor observation or collection which might nototherwise occur, given the parlous state of funding togeology in tertiary education and the limitations tothe funds of geologists of private means.

2. " ... fossils are of no use to man or beast unlessand until collected." and, "Far more dangerous for theprogress of palaeontology, it seems to me, thanovercollecting is undercollecting. And nothing is morelikely to put off would be collectors than regulation andthe need to get permission from some quango."

We are completely in accord with Wright's firstsentiment and, as stressed above, it is the continuedavailability of such sites to geologists that is our mainconcern. There are very few sites at which we havespecifically listed fossil collecting as a PDO and couldtherefore be said to be 'regulating' fossil collecting. Ifthere is some form of regulation over site visits, thenthis tends to be implemented only where fossils areknown to be particularly rare, and perhaps found inisolated lenses (fissure or cave deposits, channel lagdeposits, clay lenses), where a removal en masse by acommercially-minded collector (thereby considerablyenhancing 'rarity value') is a real possibility. There arealso a small number of sites where fossil collecting isregulated as part of a Management Agreement drawnup between the owners and the NCC; this has beeneither as a response to pressure from geologistsfearing the effects of commercial collectors on sites(notably Scottish Devonian fish sites in the late 1970'sand early 1980's), or in response to requests fromlandowners concerned, or inconvenienced, by the'nuisance' of fossil collectors calling on busyproperties (particularly farms) and disturbinglivestock.

3. " ... I deplore the fact that sites where I could findfossils as a boy now exhibit nothing but bash marksfrom visiting students." and "I deplore the idea thatfossils have a money value and certainly the annualdescent of voracious German fossil dealers on toDorset sites arouses disgust." coupled with " ... theneed for the young collector to learn how to become apalaeontologist far outweighs the protection of vestedacademic and other interests."

This series of statements identifies the intellectualdilemma in which many geologists find themselvesover the issue of fossil collecting/collectors. On theone hand they are aware of the enormous debt thatwe all owe to collectors in the past and some notableones in the present, many of whom have helped foundthe great national collections by donating or sellingtheir private collections. On the other hand, whenconfronted with the local depredation of some sites bycommercially motivated collectors (especially their

'own' favourites), geologists--of whatever status-s-canbe horrified!

What is the answer? There is no simple answer, asthe NCC has found to its cost! In the past, attemptshave been made (by NCe) to restrict collecting atsome fossil sites (see above) following vocal andwritten pressure from palaeontologists, only to findthat in later years published opinions have almosttotally reversed (Norman & Wimbledon, 1988).

So long as people can make a living out of collectingfossils, which can be sold for (relatively) high pricesto museums, sites which are known to producecommercially valuable fossils will suffer from overcol­lecting, The vulnerability of such sites (especially ifthey have been assessed by the GCR as being of SSSIstatus) then depends upon the nature of the depositsand the intensity of collecting-a situation whichrequires awareness and monitoring by NCC and otherorganisations in case the crucial scientific merit of thesite is brought into jeopardy.

Of course young fossil collectors need to learn theirtrade if they are to become palaeontologists.However, this begs a much more important question,which is: as a matter of policy, should large parties ofstudents be directed to not only visit but also collect,without any restriction, from nationally or interna­tionally important sites (SSSI) in order to improvetheir skills? There are after all thousands of geologicalsites identified and registered with the NationalScheme for Geological site Documentation; these"form a marvellous back-up to the SSSI network andmay have an important rOle in geological education ata variety of intellectual levels.

4. "Very occasionally there is a small inland sectionshowing particularly important tectonic or otherfeatures that collecting might obscure, and these arecandidatesfor SSSIs."

Notification of inland sites alone ignores the pointof notification which is that, as explained above (1),this procedure is intended to maintain the availabilityof all geological sites, not just certain inland ones.

The limitations to Wright's argument can be seenby considering one particular type of geological site,that of a coastal nature. Coastal sites, particularlythose in the southern half of Britain comprising softsedimentary rock, are often the most vulnerable toloss. There have been longstanding battles to save theBartonian stratotype from being obscured by coastalprotection schemes (the outcome of which will bedecided in a forthcoming Public Inquiry, Earth ScienceConservation, 26, 1989); if this section of the coasthad not been notified, would these clay cliffs stillbe accessible, bearing in mind regional pressuresfor coastal protection measures?

Although success cannot be guaranteed at thisPublic Inquiry, at least there is an opportunity to airall the scientific arguments for maintenance of the

CORRESPONDENCE 93

cliff. Without the consultation requirement, implicit innotification, what chance would these cliffs have had ,faced by the Borough Council 's proposals?

As members of a "quango", we must expect to behanded the occasional brickbat or derogatorycomment, especially when, despite our efforts tomaintain our geological sites at Public Inquiries,decisions go against us. However , it is exasperating to

be subjected to comments about our activities whichare based upon inaccurate knowledge . We hope thatin this letter we have clarified some aspects of ourwork and laid to rest some , depressingly familiar,misconceptions. We are open-minded and we dolisten to all opinions on matters relating to geologicalsite conservation . We are interested in conservation asit applies to all geologists and welcome any views.

References

NORMAN, D. B. & W. A . WIMBLEDON. 1988.Palaeontology in the NCe. Geology Today, 4, 194-96.

WRIGHT, C. W. 1989. Ideas in palaeontology: prejudiceand judgement. Proc. Geol. Ass. , 100,293-96.

Reply to comments by D. Norman et ale

c. W. WrightThe Old Rectory, Seaborough, Beaminster, Dorset, DT8 3QY.

I am delighted to see this full explanation of NCCaims, policies and methods. I hope that when I visitan SSSI I shall be proved wrong in the fears that laybehind my short and very summary discussion.

Yet I know that if I visit Havencliff near here (partof a Reserve, not SSSI) to check some point ofammonite biostratigraphy at the Cenomanian­Turonian boundary I shall be confronted with athreatening notice about access. I see too thatnotification of a geological site as SSSI "very rarelyresults in regulation or prevention of access"-so itsometimes does . "There are very few sites at whichwe have specifically listed fossil collecting as aPDO "-so there are some. "If there is some form ofregulation over site visits, then this tends to beimplemented only where fossils are known to beparticularly rare and perhaps found in isolated

lenses"-i .e. where they are likely to be missedaltogether or eroded and lost before anyone rescuesthem. I entirely agree with Norman and his colleaguesthat there are dilemmas. Indeed I expressed some ofthem briefly. In turn I believe that they would agreewith my conclusion that "regulation is only acceptablewhere the alternative is manifestly worse . I do notthink that this often applies in palaeontology."

Finally, I had and have no intention of makingderogatory remarks about those who carry out animportant and difficult task . It is, however , the casethat there is a widespread trend of regulation bycentral or local government or industry (South Africaand West Germany spring to mind) that makes moredifficult the activities of amateur palaeontologists onwhich, at least in the fields in which I am expert,scientific advance still to a very large extent depends.

Errata

In the paper by D. Curry published in Proceedings,100(3),339-52, there is a contradiction between Fig. 5and the commentary in the text on pages 345 and 346.To remove this, make the following corrections:

p. 345, column 2, 5 lines up-s-alter to read 'which

is probably drowning due to subsidence or a risein sea level; without relative subsidence theunconformity ... 'p. 346, column 1, line 3~alter 'uplift or a fall . . .' to'subsidence or a rise . . .'p . 346, column 1, line 33--alter 'uplift' to'subsidence' .