CONTEXT Prompted by the consideration of Fort Staddon for designation as a scheduled monument, the integrated set of C19 defences on the coastline at Staddon Heights outside Plymouth, Devon have been given a comprehensive assessment. This includes the consolidation and amendment of some designations, and the consideration of some assets that are not currently designated. Lord Howard Battery falls into the latter category.

HISTORY AND DESCRIPTION This coastal battery, built 1905-09, with was put in place for the purpose of covering merchant ships anchored in Jennycliff Bay and the channel through the Sound to Plymouth Dockyard. It was mounted by two, 6” Breach Loading (BL) guns; they were removed by 1927, mounted again in 1941 and dismounted for the final time in 1946. The emplacements were in-filled during the late C20 and the remains of the battery incorporated into a public park by Plymouth City Council. The remains consist of two in-filled concrete gun pits, a concrete parapet and an earthen rampart. The magazine was sited underground, between the gun pits. Small terraces in the slope behind the parapet may be the site of battery observation posts and to the north of a late-C20 café (on the east side of the battery), is a concrete blockhouse with firing-slits in the walls that was probably used during the First World War. It has been suggested that the below ground remains of the gun pits, mounting and magazines may survive.

DISCUSSION The 1979 Ancient Monuments and Archaeological Areas Act (1979) states monuments are scheduled by reason of their archaeological, historic, architectural, artistic or traditional national importance. The Department for Culture, Media and Sport’s policy document, Scheduled Monuments & nationally important but non-scheduled monuments (October 2013), sets out the non-statutory criteria which provide further guidance on assessing national importance. They state that when archaeological sites are assessed for scheduling, the key considerations are period, rarity, documentation, group value, survival/condition, fragility/vulnerability, diversity and potential. Monuments are assessed under those of the criteria relevant to their type. They should not be regarded as definitive, but as indicators which contribute to a wider judgment based on the individual circumstances of a case. Archaeological sites are assessed for their national importance, which is the key indicator of their significance. Those which are identified as of national importance may then be scheduled, if this is considered to be the most appropriate tool for their future management. Sites may be considered to be of national importance; but the Secretary of State may still use her discretion not to add the site to the Schedule.

Lord Howard Battery is not recommended for scheduling for the following principal reasons: * Archaeological interest: in comparison with the other military structures and forts around Staddon Heights, which predominantly date from the mid-C19, the early-C20 Lord Howard Battery, is relatively late and not part of the major phase of building work in this area; * Survival: all of the superstructure, with the exception of the blockhouse, has been demolished and the two gun emplacements, although still in position, have been in-filled; * Potential: it has been suggested that the underground remains of the battery including the magazine store may survive; however, it is not clear how much of the below ground remains are still intact.

CONCLUSION Although Lord Howard Battery is of some historic interest as a military structure and as part of the extensive Staddon Heights defences, and has clear local interest, changes have compromised its character and appearance to the extent that it lacks the level survival necessary to demonstrate national importance.