Insights · Risk & Evidence

You Have to Show There Is No Heritage, Not Just Say So.

The absence of a finding is not evidence of absence. On a financed project, you are asked to show there is no heritage, not just say so.

By Neil Fairburn · Director, Cultural Heritage Risk Management Ltd

A biodiversity specialist I follow recently described a project that spent six months resisting a single ecology survey, then ran it anyway and confirmed there was no problem. The same trap catches cultural heritage constantly, and the lesson is identical: it is easier to show there is no issue when you have the evidence than to insist there is none.

Her story went like this. An initial survey found tracks that could have belonged to one of two species, one common and one critically endangered, and the tracks alone could not say which. She recommended a targeted survey to settle it. The client resisted for six months, then ran the survey, which confirmed the harmless species. Six months lost to avoid a few weeks of work.

Cultural heritage produces this pattern more often than almost any other discipline, because heritage is the risk you cannot see. A desk study flags that an area might hold graves, a sacred site, buried archaeology, or intangible heritage tied to a living community. None of it is certain, and none of it is cheap to confirm, so the temptation is to do the minimum: record that nothing definite was found, and move on. But nothing definite found is not the same as nothing there. The absence of a finding is not evidence of absence, and on a financed project that distinction is the whole game.

Saying so is not the same as showing so

When a heritage question is raised, and on a serious project it will be, by a lender's reviewer, an ICOMOS advisory mission, a regulator, or a community holding knowledge that no map records, the project is asked one thing. Show us. Show us you looked, show us what you found, or evidence why there is nothing to find. A team that gathered the evidence early answers in a week. A team that only asserted there was no issue has to go back and survey under the worst possible conditions, with works stopped, a lender watching, and a community already uneasy. The same survey, done reactively, now costs many times as much and sits on the critical path.

That is the false economy. Skipping the survey does not remove the risk, it defers the risk and inflates it. The chance find during construction, the grave uncovered by a dozer, the sacred grove a community names only once the machines are close, these are not bad luck. They are the question you declined to answer, arriving at the least convenient moment. IFC Performance Standard 8, and the lenders who hold you to it, do not ask you to promise there is no cultural heritage. They ask you to demonstrate it, and demonstration means evidence, not assurance.

A clean result is an asset, not a wasted cost

The instinct that a survey confirming nothing is money wasted has it exactly backwards. A scoping study that finds nothing significant, a letter from the heritage authority confirming no known heritage, a baseline that records the ground and the buildings before works begin, is not a cost with no return. It is the asset that clears the work front, satisfies the lender, and closes the question before it can stop your programme. You are not paying for a finding. You are buying the evidence that lets you keep moving when someone asks.

The biodiversity specialist ended on a line that belongs on every project noticeboard: if a question arises, the quickest way forward is to answer it. Heritage is the same, except the questions tend to arrive later, cost far more to answer late, and come wrapped in community trust and reputational exposure that an ecology survey does not carry. Biodiversity under Performance Standard 6 and cultural heritage under Performance Standard 8 are the two living safeguards on a financed project, and they fail in the same way: quietly, through the survey nobody wanted to pay for.

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