Representation by Historic England (Historic England)
- Date submitted
- 5 October 2018
- Submitted by
- Other statutory consultees
Historic England is a Non-Departmental Public Body that advises government about the historic environment and has a statutory role in the planning system. Central to our role is the advice we give to applicants, local planning authorities and government departments on development proposals affecting the historic environment. We provide pre-application advice where this will help inform proposed development that might affect heritage assets. We have provided pre-application advice to the applicant during their consultations, including substantive written advice about the scope of environmental assessment and the two PEIRs. We remain concerned about the risk of potential harm to heritage assets in some respects, which are summarised below.
The archaeological potential of the northern grassland: The archaeological potential of this area is not well enough understood at present to effectively avoid harm by design. We welcome the intention to adopt a “worst-case scenario” approach to assessment of archaeological potential and to undertake investigation to inform the design when access becomes available. Flexibility to redesign the scheme should be allowed so that if archaeological remains of equivalent significance to scheduled monuments are discovered they can be preserved but it is not clear to us that this has been adequately provided for.
Historic buildings: In our view there will be considerable harm to the heritage significance of unlisted historic buildings within the airfield as a result of their demolition or changes to their setting. Further investigation and assessment of historic structures is needed to ascertain their importance and condition, and subsequently whether it is desirable and feasible to preserve them and their settings.
Historic character of the airfield: In our view the ES did not adequately describe the historic character of the airfield. We think that the open grassland character evokes the wartime airfield use, constitutes an historic area in its own right and contributes to the heritage significance of the wartime buildings, the museums and the memorial garden. The proposed development would be very harmful to historic character so we think that the potential to reduce harm by amending the design should be explored.
Rochdale envelope / flexibility of the design: The ES does not provide sufficient detail about design flexibility to give us confidence that major harm to important heritage assets will be avoided. For example it does not adequately describe the likely extent and depth of ground disturbance, the worst possible effects on heritage significance or the provision for flexibility in the quantum of development, design and construction methods.
Effects on heritage assets beyond the development site: There will be some harm to some listed buildings as a result of increases in aircraft noise. Noise impacts should be reduced as far as possible.
The conduct of further assessment and liaison: The Kent County Council Heritage Team should be the applicant’s principal advisor regarding heritage assets. Historic England is willing to also advise where we can add value. We continue to advise the applicant about a proposed Statement of Common Ground but have not yet come to an agreement with them.