Representation by Historic England (Historic England)
- Date submitted
- 7 June 2023
- Submitted by
- Other statutory consultees
Historic England Advice - Our ref PL00763064 West Burton Solar. 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 landscapes. We have a duty to promote conservation, public understanding and enjoyment of the historic environment. We are an executive Non-Departmental public body and we answer to Parliament through the Secretary of State for Culture, Media and Sport (DCMS). Proposal West Burton Solar Project. Solar photovoltaic array and electrical storage and connection infrastructure, with a generation capacity of greater than 50 MW. Representation Historic England is minded to oppose the grant of DCO for this scheme on the basis of avoidable harm to the significance of a scheduled monument designated by the Secretary of State under S1 of the 1979 Ancient Monuments and Archaeological Areas Act (as amended) viz Medieval bishop’s palace and deer park, Stow Park (NHLE 1019229). The impact of the proposed installation within the former deer park represents substantial harm (in NPS/SPPF terms) to the significance of the monument through loss of its character as a bounded architectural space. This represents a significant environmental impact (major harmful) in EIA terms. In EIA scoping advice and PEIR comments we highlighted the setting of the following assets (without prejudice to other issues that might emerge through assessment), viz the scheduled Broxholme medieval settlement and cultivation remains (NHLE 1016797) , the scheduled Deserted village of North Ingleby (NHLE 1003570) and the scheduled Medieval bishop’s palace and deer park, Stow Park (NHLE 1019229). Stow Park, the Medieval Bishop’s Palace site and deer park is set on the Roman road from Lincoln to Doncaster a key line of communication between the Episcopal sees of Lincoln and York. Deer parks and palace / lodges offered a place for retreat, rest and entertainment of social and political peers, clients and Royal guests and were hence key spaces for the performance of the elite status of Bishops in the medieval landscape. The deer park is an architectural space, a place cut out from the overlapping and complex the medieval landscape, a place where rights were monopolised - in this instance the Bishop. At the heart of the significance of a medieval deer park is not just the functional containment and protection of deer and other resources but also their articulation as a space apart – a space imparked. This central aspect of significance would be profoundly compromised by the loss both of its rural character through the installation of panels and by it being subsumed into a new landscape of solar generation. The railway and associate ex MOD petroleum storage facility represented significant change to the former deer park by bisecting the site, but they have not fundamentally compromised the ability to experience the park as a space defined in the landscape. As one walks from the moated site at the north to the raised ground occupied by the farm buildings at the south of the park and then crosses the railway past the fuel depot to the farmstead and the south western part of the park one can still gain a sense of this as a bounded space. We made a site visit with the applicants’ consultants on 13th May 2022 to West Burton 1, 2 and 3 to initially assess impacts upon the Stow Park, Ingleby and Broxholme Scheduled Monuments. With regard to impacts upon those specific assets Historic England would have no objection to the proposals within West Burton 1 and 2 and noted that the design proposals at West Burton 2 had taken into account the setting of the Ingleby Scheduled Monument, by removing areas adjacent to the Scheduled Monument from any proposed development. On the basis of the indicative layout plans for panels within the pale (park boundary) of Stow Park we are as noted in the PEIR minded to object to installation of any part of the development within the former deer park (as defined by the lines of the scheduled Park Pale and its former course). Our concerns are focussed upon setting impacts upon the significance of the medieval bishop's palace and deer park SM 1019229 and we consider that the proposed sections of solar array sited within the medieval deer park at Stow would constitute substantial harm to the significance of the scheduled monument. We recommend that part of the scheme within the historic extent of Stow Park be deleted from the scheme as it presents avoidable and unjustified harm to the significance of a nationally important designated heritage asset. With regards to buried archaeological remains it is important that risk of avoidable / unmitigated damage to sensitive remains is well managed in proportion to their importance. This can be achieved through layout, deployment of green space and construction options for cabling and panel mounting etc. Archaeological risks can thus be well addressed, but only if there is a sound understanding of where archaeological sensitivity and importance lies across the site. Sufficiency of field evaluation is vital because some features (such as for instance early medieval burial grounds or Roman high-status buildings) would be both of high importance and high sensitivity to the insertion of panel mounting piles. Discussion is continuing as regards the extent of archaeological evaluation and deployment of intrusive and non-intrusive techniques, the reliance upon / complimentary nature of such techniques, and the timing there-of; all in the context of concerns around the management of archaeological and project risk. In the context of sufficiency of evaluation work we refer you in the first instance to the expertise of local authority archaeological advisors. It is they who will (should DCO be granted with appropriate requirements) advise upon the acceptability of written schemes of investigation (WSI) and their accordance with a robust overall archaeological strategy secured through DCO submission. Combined cable connection corridors with other Solar NSIP have the potential to minimise cumulative impacts in archaeologically sensitive areas, which we would welcome. Please confirm receipt of this relevant representation. Please copy future correspondence to e-midlands@HistoricEngland.org.uk