Representation by Historic England (Historic England)
- Date submitted
- 17 February 2020
- 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. There is potential for this development to impact upon the historic environment, and that without mitigation this impact will be significant in relation to some receptors, including maritime, aviation and prehistoric heritage assets within the Marine Cable Corridor and designated heritage assets within the onshore cable route. We are aware the application includes an Environmental Statement (ES) and some amendments have been made to the ES since our letter of 29th April 2019 in relation to the Preliminary Environmental Information Report stage. 2. For the onshore historic environment, we note that an Optical Regeneration Station (ORS) is to be positioned in the north-east corner of a car park, located west of Fort Cumberland (Eastney, Portsmouth) which is protected as a Scheduled Monument and Grade II* Listed Building. The ORS has a proposed height of 4m at a distance of around 250m from the glacis (an area of sloping ground constructed as a part of the outer defences) and screening is proposed. Although the positioning of the ORS should allow a partial continuation of the line of sight from the ravelin (a triangular structure located inside the main ditch of the fort as a forward defence point) towards Fort Cumberland Road, there will be some harm to the view. As a result of this we would want to see this line of sight maintained to maximum extent through the redesign or repositioning of the ORS, in agreement with Historic England. 3. The application includes an outline Marine Written Scheme of Investigation (WSI), PINS document Reference: 6.3.14.3) which sets out how the proposed project might mitigate against impact to the historic environment, to which we provided comments prior to the submission of this application. We will therefore be looking to ensure that the deemed Marine Licence within the proposed draft Development Consent Order (DCO) includes adequate provision for delivery of a project specific WSI (should consent be granted). 4. Any final and agreed Marine WSI must enable the implementation of appropriate mitigation measures to avoid and reduce the impact from the development on the known and unknown historic environment. It is important that the marine WSI provides for the application of appropriate methodologies for further investigations conducted within the proposed project development area, as a key mechanism to inform the final stages of project planning, should consent be obtained. A relevant factor therefore is the timely way in which these matters are taken into consideration prior to the commencement of construction activities. Therefore, we recommend that the WSI is produced and agreed pre-commencement i.e. before the commencement of pre-construction activities and we will provide further advice within our Written Representation as necessary regarding Schedule 15 of the draft DCO. We will also provide further advice on any other matters relating to the proposed delivery of this development in reference to the details contained within the submitted DCO application.