Representation by Historic England (Historic England)
- Date submitted
- 13 June 2024
- 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. 1. The proposed development array area includes records for 56 wrecks and obstructions recorded in the UK Hydrographic Office and Historic England’s National Record for the Historic Environment and Lincolnshire Historic Environment Record dataset. The Applicant has also discovered an additional wreck not previously recorded. Furthermore, geophysical survey data analysis has led to the identification of 23 high potential anomalies and 166 medium potential anomalies which have been assigned Archaeological Exclusion Zones (AEZs). 2. The Applicant has also explained that marine survey programmes including all geotechnical works are proposed post-consent and prior to construction (should permission be obtained). We therefore confirm that all such survey campaigns are to be designed and planned inclusive of the collection of archaeologically specific cores to meet archaeological objectives set out in an agreed Written Scheme of Investigation (WSI), building on the Outline Marine WSI submitted by the Applicant (PINs Re: APP-282). 3. It is apparent from the Environmental Statement that the impact assessment presented relies on embedded mitigation to avoid significant impact and that marine survey works and archaeological analysis and interpretation are to occur post-consent, should permission be secured. The Applicant has therefore interpreted requirements set out in National Policy Statements for Energy (published November 2023) that reflect the broad characterisation they have completed in the EIA exercise. It is also important that the Applicant has acknowledged the risk that this project will encounter both the known and presently unknown elements of the historic environment. For example, for the proposed compensation areas desk-based sources of information include 20 wreck records. 4. For terrestrial cable routing and associated works on land, we are aware that work is underway in respect of terrestrial archaeological assessment with advice led by Local Authority curators. However, we underscore the importance of effective assessment and hence risk management, especially in areas of formerly isolated dryer ground within coastal sediment/salt marsh. Such areas, and in particular their fringes, arguably pose the highest risk of important remains being identified late in process. 5. It is important that an effective approach is in place for curatorial advice and iterative investigations. Whilst not all archaeological risk can be quantified prior to submission, the earlier and better that the project can be across these matters through survey and trenching informed by deposit modelling – the less frequent and substantive construction impacts and any associated construction delays are likely to be. 6. Whilst a risk based and target approach is essential this should not exclude the testing of terrestrial areas of apparent absence, this is methodologically necessary to address the inherent limitations of initial survey techniques. For the Marine - Terrestrial interface, it is important that terrestrial and marine documentation and delivery is coordinated to avoid failure to address impacts in the intertidal zone or confusion over responsibilities, in particular, where works in support of marine are required on land and vice - versa. This should extend to the integration of analysis mindful that the existing wet/dry boundary is not where it was in past periods. 7. Appropriate design solutions to the deserted medieval village earthworks at Slackholme have been discussed and we reaffirm that directional drill at depth beneath the monument is a necessary and proportionate responses to an undesignated site of equivalent importance to a Scheduled Monument (where diversion around the whole site is not possible). 8. Development Consent Order (PINs Ref: APP-303) and Written Schemes of Investigation – In order for requirements in the DCO (in respect of archaeological mitigation) to be effective, they will need to secure the submission (post-consent) of a WSI. These documents will need to be secured in accordance with an Outline Onshore WSI (PINs Ref: APP-283)/Archaeological Mitigation Strategy consulted upon prior to DCO determination. The present wording in the draft DCO for Requirements 17(1) will require amendment to ensure the necessary consultation occurs prior to approval by the relevant planning authority. The subordinate WSI should be written by the actual contractors undertaking the work (not an intermediate consultant) and submitted for approval to the Local Planning Authority (LPA)/MMO responsible for requirement discharge, such that the discharging authority can be advised on consultation by the LPA’s archaeological curator (e.g. Lincolnshire County Council) and Historic England, as appropriate. This structure also ensures independent expert review of the conformity of the submitted subordinate WSI to the archaeological mitigation strategy (Outline WSI) approved by Secretary of State under the DCO. Curator approval of the subordinate WSI(s) is also essential to effective monitoring of delivery of fieldwork, analysis, publication and archiving. 9. We hereby confirm that the production of a scheme specific Marine WSI is required, as conditioned within the deemed Marine Licences (Schedule 10 Generation Assets and Schedule 11 Transmission Assets) of the draft Development Consent Order. However, Schedule 12 (northern artificial nesting structure 1), Schedule 13 (northern artificial nesting structure 2), Schedule 14 (southern artificial nesting structure 1), Schedule 15 (southern artificial nesting structure 2) and Schedule 16 (biogenic reef creation), do not include the equivalent of Condition for a Marine WSI (Condition 13(1)(g) as used in Schedules 11 and 12). This is an essential mitigation requirement considering the present absence of corroboration between desk-based sources of information and the absence of any geophysical data for the proposed compensation areas and the acknowledged risk of encountering elements of the historic environment. We add that the present Outline Marine WSI is sufficient, as it describes mitigation and offsetting works in relation to pre-construction, construction and operation & maintenance phases inclusive of proposed locations for installation of Artificial Nesting Structures (ANS) and creation of benthic reef. 10. We will provide further comment through our Written Representation as there are matters which require your attention to ensure that this project is most appropriately aligned with expectations set out in national policy.