Representation by Historic England (Historic England)
- Date submitted
- 29 February 2024
- Submitted by
- Other statutory consultees
Response to: Notice of acceptance of an application for a Development Consent Order, East Yorkshire Solar Farm (Reference No. EN010143) ON BEHALF OF THE HISTORIC BUILDINGS AND MONUMENTS COMMISSION FOR ENGLAND (HISTORIC ENGLAND) (“HBMCE”) Application by East Yorkshire Solar Farm Limited. The Historic Buildings and Monuments Commission for England is generally known as “Historic England”. Historic England was established under the National Heritage Act 1983 and is the lead body for the heritage sector and the Government’s principal adviser on the historic environment. It is a statutory consultee on all Nationally Significant Infrastructure Projects. We have been notified by you of the acceptance of the DCO application and wish to Register as an Interested Party. Historic England’s interest in this scheme is focused on the following designated and non-designated but nationally important heritage assets: 1) Archaeology: We have reviewed the assessment of the archaeological resource identified in the applicant’s Cultural Heritage Desk-Based Assessment (ES vol 2, Appendix 7-2, Document Reference: EN010143/APP/6.2, November 2023). There are no Scheduled Monuments within the site boundary of the Scheme area. There are several Scheduled Monuments outside the Scheme area, but within the 1km and 3km buffer zone areas, and therefore considered to be within the setting of those Scheduled Monuments. The applicant states that because little archaeological research has been carried out in the area, with little result, the archaeological potential is therefore 'low' or 'negligible' (section 6.1). We do not consider that this is the case. NPS EN1 – Overarching National Policy statement for Energy makes it clear that the construction, operation and decommissioning of energy infrastructure has the potential to result in adverse impacts on the historic environment above, at and below the surface of the ground. It goes on to set out that the applicant should undertake an assessment of any likely significant heritage impacts of the proposed development, and as a minimum the applicant should have considered the relevant Historic Environment Record and assessed the heritage assets themselves using expertise where necessary according to the proposed development’s impact, and where a site includes or available evidence suggests it has the potential to include heritage assets with an archaeological interest, the applicant should carry out appropriate desk based assessment and if this is insufficient a field evaluation impact. It is clear that there are archaeological deposits in the area, but the assessment does not provide the necessary detail. For example, the section on the post-medieval (6.1.8), has a focus on former field boundaries and seems to gloss over the potential for WW1 and WW2 archaeology. We would expect that further detail (assessment and analysis) is provided as to the potential for archaeological deposits in the Scheme area, thereby permitting greater understanding as to how this would be dealt with as part of the assessment of impact. Potential research themes, para 6.2.1: The suggested themes are not particularly helpful, although we recognise that the text says they will be updated. At present we consider the proposed text to be a 'place holder' for more developed and relevant content. The research themes are to be updated and agreed with the Local Authority Principal Archaeologists as a matter of urgency, so that we can then better understand the possible impact and propose appropriate mitigation. 2) Setting and its contribution to significance: Numerous Listed Buildings and one Conservation Area (Howden) lie within the 1km and 3km buffer zones. The assessment of impact on the significance of Howden and its Minster church (5.1.8 onwards) is well-written and considered. We like the approach used to present both Chronological (4.8 onwards) and Thematic (5.1.1 onwards) assessments. This latter section addresses the points made in our original communications to the applicant about trying to assess landscape scale change and the dynamics of moving through the landscape. Although the supporting text and references to the legislation, policy and guidance identify the published setting guidance (https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/heag180-gpa3-setting-heritage-assets/), we would remind the applicant not to over-rely on views and viewpoints. The published guidance clearly states that setting is about how a place is 'experienced', but that sense of 'experience' is often missing from analyses and the assessment of significance of places. We consider that the balance in the text between 'views/viewpoints' and 'experience' is better than in many DBAs, but we would urge the applicant that when they write the statements of significance for individual places, they identify the contribution that setting makes to significance, give appropriate weight to 'experience', and identify the impact on significance and not the significance of the impact. This assessment phase (and the criteria to be used for assessment), should be a core part of current and continuing stakeholder meetings, allowing the stakeholders to judge the efficacy of the approach used before submission of any final DCO documentation. 3) Cumulative impact: There are numerous solar farms proposed (and some consented) for the Humberhead Levels, the southern end of the Vale of York and the Vale of Holderness. These several schemes cross local authority boundaries, and represent considerable landscape scale change. There does not appear to be any assessment of the Scheme in light of the numerous other schemes in the area. It is critical to be able to understand what the impact from this scheme in conjunction with the other schemes might be. Submission of this assessment should be conducted as soon as possible.