Representation by Historic England (Historic England )
- Date submitted
- 24 January 2020
- Submitted by
- Other statutory consultees
PINs Registration and Relevant Representation Form Section 56 Planning Act 2008 Date notified: 25 November 2019 Response deadline: 27 January 2020 Project: The Proposed East Anglia North ONE Offshore Windfarm Response made by: Dr Will Fletcher Our ref: PL00088303 PINs Ref:EN010077 Telephone:01223 582710 The Historic Buildings and Monuments Commission for England (HBMCE) is better known as Historic England, and we are the Government’s adviser on all aspects of the historic environment in England - including historic buildings and areas, archaeology and historic landscape. We have a duty to promote conservation, public understanding and enjoyment of the historic environment. HBMCE are an executive Non-Departmental public body and we answer to Parliament through the Secretary of State for Digital Culture, Media and Sport. In addition to our remit for the conservation of the historic environment the National Heritage Act (2002) gave HBMCE responsibility for maritime archaeology in the English area of the UK Territorial Sea. Representation: The applicant has provided a full Environmental Statement and Historic England’s full written representation will comment on aspects and concerns that we have established with regards to the impact of the scheme upon the on- and offshore historic environment. In relation to the off-shore historic environment, the large number of geophysical seabed anomalies recorded within the PDA highlights the potential for significant historic environment features to be present. Our concern is therefore to ensure that the Outline Offshore Archaeological Written Scheme of Investigation considers how the construction can be designed sensitively to take into account known and potential heritage assets. In the event of the project being consented, we are concerned to ensure the appropriate depth for a continuous stratigraphy is incorporated into the planning of the geotechnical survey. With boreholes and vibrocores stored and maintained to maximise archaeological objectives. This is to mitigate impacts on archaeological deposits of high potential. We have identified that the resulting proposals of embedded and additional mitigation - through schemes of investigation - have the potential to successfully mitigate impacts to the historic environment through avoidance, but these present opportunities to better reveal the significance of the heritage assets found within the proposed development area (see ES Chapter 16). We consider that the projects potential contribution to new knowledge arising from such investigations (EN-3, paragraph 2.6.142) can be linked to additional socio-economic beneficial effects, such as the provision and enhancement of educational facilities for the community (EN-1, paragraph 5.12.3). Given the scale of the development and the cumulative impacts within this region of the southern North Sea, we feel these outcomes should be included as part of the mitigation. On-shore, our principal concern is in relation to the proposed development of the sub-station and the cumulative impact of this new infrastructure on the significance of the grade II* listed Church of St. Mary at Friston. Dating from the eleventh century, the phases of building illustrate ecclesiastical design and patterns of worship, and show the significant role of the church within the community. It lies on the northern edge of the village and is appreciated in a rural and largely open landscape setting enabling views from the south and north. This enhances its prominence and adds to the appreciation of the building. The scale and appearance of the development would significantly change the character of this rural landscape setting. It would compromise and completely obscure views to the church from the north and from the church looking northwards. It would also greatly impact on key views of the church from the south, which would be seen against a backdrop of the sub-stations. We consider this would result in a very high level of harm to the significance of the grade II* church. We are aware the proposal includes screening and mitigation planting, however we have also considered this aspect of the scheme and have concerns that this will also bring about further changes to the setting of the church. We intend to expand on this more fully in our full response, and it is likely we will consider wider impacts of the proposed sub-station infrastructure and the on-shore cable route on designated and non-designated heritage assets. We have however concluded that although we do not object to the scheme in principle, we will consider an in principle objection to the location of the sub-station on historic environment grounds. Dr Will Fletcher Will.Fletcher@historicengland.or.uk