Subject: FOI "Llandough Roman villa & medieval house finds were destroyed in a 1983 fire" From: Sion Buckler Direction: sent Date: Thu, 24 Sep 2026 15:05 UTC Institution: Heneb (formerly GGAT) / Historic Environment Record Refs: none Archive id: gm-1a0d3f30a932fcc1 ------------------------------------------------------------ Dear Heneb: The Trust for Welsh Archaeology, I am writing to request access to recorded information concerning the March 1983 fire at the former Glamorgan-Gwent Archaeological Trust (GGAT) warehouse in Swansea, particularly the reported destruction of archaeological finds, excavation records and photographic material from Llandough, together with records concerning the subsequent custody, preservation, transfer and integrity of archaeological records relating to Great House Farm (Tŷ Mawr), Llandough. I recognise that Heneb is an independent private company limited by guarantee and registered charity rather than a body ordinarily subject to the Freedom of Information Act 2000. However, Heneb now maintains the statutory Historic Environment Records for Wales on behalf of the Welsh Ministers. Sections 194 and 195 of the Historic Environment (Wales) Act 2023 require the Welsh Ministers to maintain publicly accessible Historic Environment Records, including information concerning archaeological investigations and their findings. I therefore ask that this request be considered under any applicable statutory information-access regime, including the Environmental Information Regulations 2004 insofar as Heneb considers that it falls within their scope. If Heneb considers that the EIR do not apply to any or all of the information requested, please state that expressly and identify the legal basis for that position. I would nevertheless be grateful if Heneb would consider the request voluntarily as an information-access request, particularly where the information forms part of, or supports, the statutory Historic Environment Record or associated archaeological archive maintained on behalf of the Welsh Ministers. I have copied Cadw and the Royal Commission on the Ancient and Historical Monuments of Wales because the request concerns the statutory HER system and records said to have been transferred or accessioned into the National Monuments Record of Wales. The request is for existing recorded information only. I am not asking Heneb to create a new report or undertake fresh archaeological interpretation. Purpose and evidential context This request arises from a wider forensic examination of the surviving documentary record concerning Great House Farm (Tŷ Mawr), Llandough. Two companion forensic critiques, dated 21 September 2026, have been prepared concerning respectively Cadw and GGAT/Heneb. They are not presented as proof of dishonesty, bad faith, corruption or deliberate destruction. Rather, they identify a series of documentary gaps, inconsistent records and questions which cannot properly be resolved without access to the underlying primary records. In particular, the GGAT critique identifies questions concerning the Trust's historical roles as archaeological adviser, contractor, investigator, curator and record-holder, and concerning the provenance and subsequent custody of the 1990 Great House Farm assessment and associated material. The purpose of this request is therefore to establish, from the records themselves, what material existed, what was lost, what survived, where it was held, when it was transferred, and whether the present HER and archive accurately represent the historical record. The two distinct archaeological areas at Llandough For the avoidance of doubt, I ask that the following be treated as separate investigations. *1. Llandough Farm / Roman villa area south of St Dochdwy's church* GGAT undertook excavation in this area in 1978–79, with the HER identifying event GGATE001109 as "Llandough Farm". The associated site record concerns an Iron Age/Roman villa complex with later early-medieval burial activity. *2. Great House Farm (Tŷ Mawr) area north of St Dochdwy's church* GGAT undertook an archaeological assessment/evaluation of Great House Farm in 1990, followed by the substantially larger Cotswold Archaeological Trust excavation in 1994. These should not be conflated in the records or in any response to this request. Part A — March 1983 warehouse fire I have identified contemporaneous newspaper reports concerning the March 1983 fire at the GGAT Swansea warehouse. Those reports state that substantial quantities of archaeological material were destroyed and specifically identify finds from Llandough among the losses. They also report the destruction of a photographic studio/darkroom and a substantial quantity of photographic material. I therefore request: *1.* Any surviving inventory, catalogue, accession register, storage list, box list, find list, archive schedule or other contemporaneous record identifying archaeological material held at the Swansea warehouse immediately before the fire. *2.* Any surviving inventory, assessment or other record identifying material from the 1978–79 Llandough Farm excavation which was destroyed, lost, damaged or rendered unrecoverable in the fire. *3.* Any records identifying Llandough photographic material lost in the fire, including, where recorded: - original negatives; - contact sheets; - prints; - transparencies/slides; - photographic registers or catalogues; - site photography logs; and - duplicate or working copies. *4.* Any post-fire salvage, recovery, reconciliation or damage-assessment records concerning archaeological material or photographic material recovered from the warehouse. *5.* Any insurance claim, loss schedule, valuation, stock reconciliation, internal audit, board/minute record, memorandum or other contemporaneous document assessing the scale or nature of the archaeological and photographic losses. *6.* Any correspondence concerning the fire or its archaeological losses with Cadw/Welsh Historic Monuments, the Welsh Office/Welsh Government, Amgueddfa Cymru/National Museum Wales, RCAHMW, local authorities, funding bodies, insurers, fire authorities or other archaeological organisations. *7.* Any GGAT annual report, internal report, memorandum or other record discussing the fire, the losses, salvage, replacement of records, reconstruction of catalogues or subsequent archive-management arrangements. Part B — What survived from the 1978–79 Llandough excavation *8.* Any surviving GGAT records showing what material from the Llandough Farm excavation survived the 1983 fire, including finds, site records, plans, drawings, photographs, notebooks, context records, catalogues, reports and publication material. *9.* Any surviving records showing where surviving Llandough material was subsequently stored, transferred, deposited or otherwise held. *10.* Any transfer, accession or deposit records identifying material from the Llandough excavation now held by Heneb, Amgueddfa Cymru/National Museum Wales, RCAHMW, the Archaeology Data Service or another repository. *11.* If Heneb no longer holds material formerly held by GGAT from this excavation, please provide any recorded information showing when and how that material ceased to be held by GGAT or its successor organisations. Part C — Great House Farm (Tŷ Mawr): the 1990 GGAT assessment *12.* Any records showing the complete archival history and custody of the GGAT 1990 archaeological assessment of Great House Farm, including the report associated with HER record GGAT02038s. *13.* Please provide any surviving records showing: - the date on which the assessment was completed; - the date on which it was received or entered into GGAT records; - its original file or archive reference; - where the original and working copies were held; - any subsequent movement between GGAT offices, stores or repositories; - any transfer or deposit to RCAHMW/the National Monuments Record of Wales; - the date and reference of any such accession; and - the identity and present location of associated archive material. I understand that the 1990 assessment was accessioned into the National Monuments Record of Wales on *20 March 2019*. Please confirm whether that date is correct and provide the underlying accession, transfer, deposit or cataloguing record. *14.* If the assessment was not accessioned into the National Monuments Record until 2019, please provide any recorded information showing where the assessment and associated archive material were held between completion of the assessment and that accession. *15.* Please provide any surviving pre-1990 or 1990 GGAT material relating to Great House Farm/Tŷ Mawr, including correspondence, field notes, photographs, plans, drawings, draft reports, site notebooks, assessment notes and archaeological planning correspondence. *16.* Please specifically provide any surviving material corresponding to, or identified as, *Appendix B* and *Appendix E* of the 1990 GGAT assessment, together with any records showing whether either appendix has been lost, separated from the principal report, transferred elsewhere, superseded, or otherwise disposed of. *17.* Any records concerning the preparation, internal review, approval, issue and circulation of the 1990 assessment and its appendices. *18.* Any records concerning the commissioning, procurement, quotation, specification, fee, contract, invoice or other administrative arrangements under which GGAT undertook the 1990 Great House Farm assessment. *19.* Any records showing what information supplied by GGAT about Great House Farm was entered into, amended within, cross-referenced within, or omitted from the then South Glamorgan/West Glamorgan Sites and Monuments Record. *20.* Any audit trail, change history, correction record or equivalent metadata showing subsequent amendments to the relevant HER records and references for Great House Farm/Tŷ Mawr. Part D — Relationship between the 1990 assessment and the 1994 excavation *21.* Any records showing what information or archive material from the 1990 GGAT assessment was supplied to, transferred to, or made available to Cotswold Archaeological Trust in connection with the 1994 excavation. *22.* Any correspondence between GGAT and Cotswold Archaeological Trust concerning the archaeological potential, results, interpretation, extent or recording of the Great House Farm site. *23.* Any records showing whether the 1990 GGAT trench plan, archaeological potential map, appendices or conclusions were used to determine the location, extent or methodology of the 1994 excavation. *24.* Any records identifying any material change between GGAT's 1990 assessment and the findings of the 1994 excavation, including any contemporary acknowledgment within GGAT's records that the 1994 findings differed materially from the conclusions or zoning of the 1990 assessment. Part E — The 1994 Cotswold Archaeological Trust excavation archive *25.* Any records held by Heneb concerning the surviving archive of the 1994 Great House Farm excavation, including information on where the archive was deposited or transferred. *26.* Any records showing the date, destination and scope of any transfer or deposit of the 1994 excavation archive, including: - finds; - human-remains records; - context sheets; - plans and drawings; - photographs; - catalogues; - databases; and - specialist reports. *27.* The published excavation record states that *1,026 inhumation burials were examined*, whereas the current Heneb HER record states *858 inhumations*. Please provide any records held by Heneb which explain the difference between these figures, including whether they represent different stages of excavation, different archaeological categories, different counting methodologies, or subsequent correction or revision of the HER. *28.* Any records showing whether material from the 1994 excavation remains with Heneb/GGAT, Cotswold Archaeology, Amgueddfa Cymru/National Museum Wales, RCAHMW, the Archaeology Data Service or another repository. *29.* I understand that archive material relating to the 1994 excavation was deposited in or around 2014. Please confirm whether this is correct and, if so, provide the relevant accession/deposit information and identify the repository concerned. Part F — Archive management following the 1983 fire *30.* Any records concerning the archive-management arrangements implemented by GGAT following the 1983 fire for the preservation, cataloguing, duplication, storage and eventual deposition of excavation archives, photographs and associated records. *31.* Any records showing whether records affected by the fire were reconstructed, recreated, copied, replaced or otherwise restored, and which archaeological projects were affected by any such work. *32.* Any records concerning subsequent reviews of the completeness of excavation archives affected by the fire. *33.* Any retention schedules, disposal schedules, archive policies, accession procedures or records-management guidance used by GGAT during the relevant period which governed the retention or disposal of archaeological project records and photographs. Part G — Present completeness and custody of the archaeological record *34.* Any surviving GGAT/Heneb records identifying missing, lost, destroyed, separated or otherwise unaccounted-for archive components relating to either the Llandough Farm excavation or Great House Farm/Tŷ Mawr. *35.* Any records showing whether the 1978–79 Llandough excavation archive, the 1990 Great House Farm assessment and the 1994 Great House Farm excavation archive were ever cross-referenced, reconciled or treated as related archaeological records. *36.* Any records identifying discrepancies between the historical GGAT records, the present Heneb HER, the National Monuments Record of Wales and the published archaeological reports concerning these sites. Part H — Heneb's statutory HER role and custody of information *37.* Please identify the legal and administrative basis on which Heneb maintains the relevant Historic Environment Record on behalf of the Welsh Ministers, including any agreement, contract, service specification, grant agreement, memorandum of understanding or other instrument governing that arrangement. *38.* Does Heneb consider that information forming part of the statutory Historic Environment Record is held: a. by Heneb in its own capacity; b. by Heneb on behalf of the Welsh Ministers; or c. on some other legal or administrative basis? Please explain. *39.* Where historical GGAT material now held by Heneb forms evidence supporting a statutory HER record, please identify whether the underlying source archive is regarded as part of the HER itself, associated reference material, or a separate archaeological archive. *40.* If any of the information requested above is held by Heneb solely on behalf of the Welsh Ministers, please identify the relevant Welsh Government/Cadw body responsible for access to that information and the applicable access regime. Searches and records no longer held I appreciate that some historical records may no longer survive. Where information requested above is no longer held, please state that clearly and, where recorded information exists concerning its destruction, disposal, transfer, loss or separation, please provide that information. For each material category where the original record is no longer held, please provide any surviving record showing: - when it ceased to be held; - why it ceased to be held; - whether it was destroyed, lost, transferred or otherwise disposed of; - whether any replacement, copy or reconstruction was made; and - the repository or organisation to which it was transferred, where applicable. If Heneb's searches establish that a record formerly known to exist cannot now be located, please identify the relevant search terms, archive locations or record systems searched and the outcome of those searches, insofar as such information is itself recorded. Where records have been transferred to another body, please identify that body together with any accession, archive or reference number known to Heneb. Scope and cost If Heneb considers that this request is too broad or that responding to it would exceed any applicable statutory cost limit, please identify the specific questions or categories causing the difficulty and advise how I can narrow the request while retaining the central questions concerning: 1. the scale and nature of the archaeological and photographic losses in the March 1983 warehouse fire; 2. what material from the 1978–79 Llandough excavation survived; 3. the complete custody history of the 1990 Great House Farm assessment and its appendices; 4. the relationship between that assessment and the 1994 excavation; 5. the whereabouts and completeness of the 1994 excavation archive; and 6. the present accuracy and provenance of the relevant HER records. If some information is already publicly available or is held by another body, please identify the relevant repository and, where possible, provide the relevant archive, accession or catalogue reference rather than simply directing me to the organisation generally. This request is made in the public interest and is intended to establish the documentary record. It should not be read as an allegation that any individual or institution acted dishonestly, in bad faith, corruptly, or deliberately destroyed or concealed evidence. I would be grateful for confirmation of receipt and for the request to be dealt with under the appropriate applicable information-access regime. Regards, Sion Buckler (Ret'd Sergeant) Royal Signals Cyber/ Electronic Warfare Professional and Life Member