Representation by Historic England (Historic England)
- Date submitted
- 5 July 2024
- Submitted by
- Other statutory consultees
Historic England (retaining the formal title of the Historic Buildings and Monuments Commission for England) is the government service championing England’s heritage and giving expert, constructive advice. We summarise our representation regarding this proposed project as follows: 1. The proposed development array area includes records for 11 wrecks and obstructions recorded by the UK Hydrographic Office (UKHO). Geophysical survey data analysis corroborates five charted UKHO wreck records with five high potential anomalies and five medium potential anomalies, which have been assigned Archaeological Exclusion Zones (AEZs). The Applicant has also identified one UKHO record for a crashed aircraft within the proposed Wind Turbine Generator (WTG) array area, but without corroborating geophysical survey data. 2. The Applicant has explained that pre-construction site investigation surveys will be undertaken to provide detailed information on seabed conditions, morphology and geology layers, and to identify the presence/absence of any potential obstructions or hazards. The Applicant has also explained that detailed design work for this proposed development has yet to occur although it is anticipated that sand wave clearance will be required to facilitate cable installation and WTG foundations inclusive of piled jackets, suction buckets jackets and/or gravity bases. 3. The proposed archaeological mitigation programme set out in the submitted Outline Offshore Written Scheme of Investigation for Archaeology [Applicant Document Ref: J14; PINs Ref: APP-069], needs to adequately take account of Principle 6, as detailed in Chapter 3 – Project Description, Table 3.7 [Applicant Document Ref: F 1.3; PINs Ref: APP-010] regarding anticipated micrositing allowance and the use of Gravity Base Foundations (GBFs). In particular, anticipated depth and area of seabed excavation required for installation of GBFs and the use of micrositing and microrouting, as described in National Policy Statement EN-3 (DESNZ, November 2023) as necessary to avoid known and unknown archaeological sites. 4. It is apparent from the Environmental Statement that the impact assessment presented in Chapter 8 (marine archaeology and cultural heritage [Applicants Document Ref: F 2.8; PINs Ref: APP-026] 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. It is also important that the Applicant has acknowledged the risk that this project could encounter presently unknown elements of the historic environment. It is therefore important that any subsequent survey campaigns are designed and planned in reference to an archaeological Written Scheme of Investigation (WSI), building on the Outline Offshore WSI for archaeology submitted by the Applicant (as referenced above). We hereby confirm that the production of a scheme specific Offshore WSI is required, as conditioned within the deemed Marine Licences (Schedules 3 and 4) of the draft Development Consent Order [PINs Ref: APP-005]. 5. We will provide further comment through our Written Representation as necessary to address matters as relevant to the historic environment to ensure that this project is most appropriately aligned with expectations set out in national policy.