Representation by Historic England (Historic England)
- Date submitted
- 14 November 2022
- Submitted by
- Other statutory consultees
The Historic Buildings and Monuments Commission for England (Historic England) is a statutory consultee in relation to the historic environment, the lead body for the heritage sector and the Government’s principal adviser on the historic environment. We summarise our representation regarding this proposed project as follows. We are aware that whilst SEP and DEP are the subject of this DCO application, it is possible that either one or both projects could be developed, and if both are developed, that construction may be undertaken either concurrently or sequentially. 1. Environmental Statement (ES), Volume 1, Chapter 14 (Offshore Archaeology and Cultural Heritage), describes the adoption of the design envelope approach and has identified, as the worst-case scenario forty-three 18MW Gravity Based Structure (GBS). However, we cannot advise as to the risks to either the known or unknown historic environment, as it is not apparent what depth of seabed excavation and seabed levelling will be required to safely install GBSs across the proposed development areas. 2. Chapter 14 describes site-specific geophysical surveys conducted for this extension project. However, it is mentioned that there are survey data gaps in the proposed development areas. In our Written Representation we will offer advice as to whether the present assessment is sufficient to characterise the areas identified for development. We note that the Applicant has included an Outline Written Scheme of Investigation: Offshore (Doc Ref: 9.11), which should set out the methodological approach for data capture across the entire development area as should be acquired post-consent, if permission is obtained. In our Written Representation we will provide further advice regarding the substance of the Outline Written Scheme of Investigation (WSI): Offshore. 3. The Applicant describes the use of historic datasets and geophysical data acquired for this project. However, it is apparent that geotechnical survey work was only conducted within the proposed electricity export cable corridor. It is therefore important that the Outline WSI provides for analysis to be conducted on geotechnical materials obtained from the proposed array areas. We will provide further advice as may be necessary in our Written Representation. 4. The Applicant has used geophysical data acquired for this project to determine the presence of anomalies and other seabed features of possible archaeological interest, as well as the presence of charted wrecks. Furthermore, it is important that the Applicant acknowledges the risk that this project could encounter previously unknown historic and archaeological sites. There are also archaeological interests associated with the proposed landfall location for the electricity export cables at Weybourne for which we will provide further comment. We will also advise further if the WSI should be subject to review with the relevant local authority, as relevant to any intertidal area as might be impacted by this proposed project. 5. Embedded mitigation measures are described inclusive of Archaeological Exclusion Zones, further investigation where avoidance is not possible and implementation of a Protocol for Archaeological Discoveries. Regarding potential impacts, we recognise the identification of project phases inclusive of Construction, Operation and Decommissioning. We concur with the statements provided regarding potential monitoring requirements and we will provide further comment regarding the assessment summary in our Written Representation. 6. ES Volume 1, Chapter 21 (Onshore Archaeology and Cultural Heritage) describes data and information sources and identification of known heritage assets. We also note the attention given to further investigation and data gathering, as could be progressed post-consent (vis. geoarchaeological and palaeoenvironmental potential) and the inclusion of an outline Onshore WSI (Doc Ref: 9.21). Regarding the identification of designated heritage assets within the 1km study area, we will provide further comment in our Written Representation. We will also provide further comment, as may be necessary, regarding the heritage settings assessment and any cumulative impacts associated with the proposed onshore substation and associated buildings.