Representation by Historic England (Historic England)
- Date submitted
- 31 March 2021
- Submitted by
- Other statutory consultees
Planning Inspectorate Registration and Relevant Representation Form Section 56 of The Planning Act 2008 Date notified: 17 February 2021 Response deadline: 31 March 2021 Project title: The London Resort DCO Response prepared by: Rebecca Lambert, Historic England (submitted via PINS online form) Date response issued: 31 March 2021 PINs Ref: BC080001 Our ref: PL00709202 Tel: 020 7973 3630 Introduction Historic England is the Government’s statutory adviser on the historic environment. It is our duty under the National Heritage Act 1983 to secure the preservation and enhancement of the historic environment. Our objective is to ensure that the historic environment generally and in particular, designated heritage assets, are fully taken into account in the determination of this DCO. We have provided substantive pre-application advice about the scope of environmental assessment and the PEIR. The applicant has provided an Environmental Statement, Historic Environment Framework and other documentation with the application. We have considerable concerns about the risk of potential harm to designated heritage assets (and those of archaeological interest that may be of equal significance). Having reviewed the information supporting the application it appears that our concerns have not been addressed. Representation: Significance The proposal area has demonstrable historical and archaeological interest (exceptional in some areas), and contains heritage assets of national importance. These include scheduled monuments; Palaeolithic deposits (and Pleistocene geological remains) at Bakers Hole, Neolithic remains at Ebbsfleet, Roman remains at Springhead, and scheduled/Grade II* buildings at Tilbury. In addition there are archaeological deposits outside the scheduled areas that may be of equal significance. Concerns 1. Inadequate archaeological baseline assessment and evaluation The Historic Environment Framework proposes that all further archaeological evaluation will be undertaken post-determination. However, we consider that further desk based research and fieldwork is needed to characterise the archaeological resource (marine and terrestrial), and impacts on it. This work should be required in advance of, and to inform, decision making and final design, and provide clarity on how harm could be avoided or minimised. This is especially the case for the Swanscombe Peninsula, within the intertidal area, and in the Essex area. 2. Inadequate built environment and setting assessment The assessment of impacts on built heritage assets as a result of change to their setting is inadequate, particularly in relation to designated heritage assets at Tilbury. Rendered images, photomontages, and verified views, should be produced to enable adequate assessment of setting impacts. We are particularly concerned about the impact of a four-storey car park on the significance of the Terminal building (Listed at Grade II ), Tilbury Fort (Scheduled Monument) and the Tilbury Fort Barracks block (Grade II). There is also a lack of detailed information to assess the impact of the proposed new landing stage on the significance of the adjacent Terminal building. Securing the relevant requirements 1. Baker’s Hole SM/SSSI Baker’s Hole is on the Historic England Heritage at Risk Register. Proposals in this area should seek to avoid harm, and actions that could make this situation worse. Opportunities to address our concerns, and conserve and enhance the monument, need to be explored further. The draft HEF proposes a Management Plan, but we consider additional provision should be made to address our concerns, and be detailed in that document before the DCO is determined. 2. Tilbury Terminal The proposed conservation and repair works to Tilbury Cruise Terminal and Riverside Station could be beneficial, but more information should be provided in the ES to enable us to assess the impact of the proposals. 3. Development Consent Order and associated documents The Development Consent Order ought to contain the relevant requirements to ensure that appropriate safeguards are in place regarding the historic environment. For example, the HEF will be a key document to ensure adequate provision for historic environment protection, mitigation and enhancement post DCO, should consent be forthcoming. Ensuring that this document has the appropriate provisions, and can be amended to reflect new information gathered through the examination process, will be critical. Policy The Applicant’s Scoping Report acknowledges that there is no specific National Policy Statement for business or commercial NSIPs, which do not have a NPS to guide the determination of DCO applications. The Examining Authority will therefore need to give careful consideration regarding the determination of this application. Historic England wish to ensure that the Examining Authority are aware of the concerns raised in relation to the historic environment and have the necessary information in order to inform its decision on this application. Historic England’s Position In view of the limited information provided with the application, we consider there is great risk to the historic environment, with potential for a high level of harm to designated heritage assets of national importance, and undesignated archaeological heritage assets of equal significance. Further information needs to be provided so that the significance of the Historic Environment and impacts to it can be more clearly understood and assessed. The applicant proposes various benefits could be available to enhance the historic environment. However insufficient detail has been provided regarding these enhancements and how they would be secured. We intend to expand on these matters more fully in our written representation. We have concluded however that we have considerable concerns about the submission and about the assessment of the historic environment that has formed the basis of the ES. For the reasons outlined above, Historic England wishes to register its interest in the examination of the London Resort DCO.