English Heritage
"English Heritage is the Government’s advisor on all aspects of the historic environment in England. English Heritage is an Executive Non-departmental Public Body sponsored by the Department for Culture, Media and Sport (DCMS) and we report to Parliament through the Secretary of State for Culture, Media and Sport. The National Heritage Act (2002) enabled English Heritage to assume responsibility for maritime archaeology in the English area of the UK Territorial Sea. However, for development projects that occur in any adjacent area of UK Continental Shelf any advice that we offer is done so without prejudice to our responsibilities. We have reviewed ‘Galloper Wind Farm Project – Environmental Statement’, prepared by RWE npower renewables and SSE Renewables (dated October 2011) and we offer the following comments: Chapter 19 Archaeology and Cultural Heritage (dated October 2011, Document Reference 5.2.19): Onshore historic environment Following successful pre-application consultations with English Heritage and the County Archaeological Service we are satisfied that an adequate desktop assessment has been completed and that part of the development site has been subject to field evaluation with the results incorporated into the application. We are satisfied that the scheme is unlikely to have a significant detrimental impact on the setting of nationally designated heritage assets. Whilst there is a need for further archaeological evaluation we feel that this can be undertaken in advance of construction if consent is granted for the scheme as it is unlikely, based on the work to date, that nationally important heritage assets will be affected and there should be adequate flexibility to avoid or protect remains in the unevaluated areas including the temporary construction areas as opposed to the substation site. We advise that in accordance with national policy guidelines (Policy HE12.3 of PPS5) planning conditions to record and advance the understanding of the significance of the heritage asset before they damaged or destroyed should be conditional of any consents for the scheme. Offshore historic environment The preparation of the Archaeological Written Scheme of Investigation (WSI), in agreement with English Heritage (and any relevant local authority), is very important and we direct your attention to Model Clauses for Archaeological Written Schemes of Investigation: offshore renewables projects published by The Crown Estate in December 2010. Please note that a WSI provides an agreed statement on methodologies for subsequent data analysis and interpretation and we recommend that the WSI is prepared by a body affiliated to a professional association, such as the Institute for Archaeology. It is particularly important that any desk-based review of available records is corroborated by data obtained from any geotechnical and geophysical surveying campaign commissioned for this project. For example, archaeological interpretation of geophysical survey data to inform the installation programme so that if any floating barge or jack-up barges are employed using an anchor spread they do not impact any sites or other anomalies of archaeological potential. We noted that reference was made to Archaeological Exclusion Zones (AEZs) as a mitigation measure and, subject to the final design for this project, we expect further discussion regarding selection of AEZs, as described in Technical Appendix Report 19.B (Marine Archaeological Study), and associated monitoring requirements to support their effective identification, assessment and avoidance, as per the terms of the draft deemed Marine Licence. We only accept that any residual impacts might be of ‘negligible significance’ if the developer ensures that copies of any agreed archaeological assessment reports are deposited with the National Monuments Record; this requirement is completed by submitting an English Heritage OASIS (Online AccesS to the Index of archaeological investigationS’) form with a digital copy of the report. Notification of the completion of the OASIS form is to be sent, by the developer, to the relevant local authority for any aspect of this project that occurs within the boundaries of a terrestrial local planning authority. Similarly, the statement made in 19.10.14 regarding cumulative benefits of offshore development can only be realised if that information, once accepted, is placed in the public realm, as per the terms of the draft deemed Marine Licence. We noted that particular attention was directed at ‘known archaeological sites and geophysical anomalies of potential anthropogenic origin’, but this does not adequately address cumulative development pressures on palaeo-environment features and elements that may contain archaeological material, as detailed in sections 19.4.38 to 19.4.48 (see also figure 19.7) and in Appendix 19.B. However, such matters should be addressed through the production and delivery of an agreed WSI and the application of an Archaeological Reporting Protocol so that appropriate action is taken if the project encounters any unidentified archaeological sites or other material of archaeological interest. Technical Appendix 4, Report 19.B – Galloper Wind Farm Project Environmental Statement Technical Report: Archaeology and Cultural Heritage – Marine Archaeology Study. Prepared by Wessex Archaeology (Ref: 66803.05, dated September 2011). We noted the detail provided in Table 10 (‘worst case project design for archaeology) and section 5 (potential impacts during construction phase) which should be addressed by the WSI to be prepared for this project. We are prepared to accept the statement made in 5.5.4 regarding the placement of 100m buffers around identified sites of potential archaeological interest, although we require clarification about how the buffer will be drawn in reference to the different design scenarios, and how the final scheme layout will take account of these buffers (see 5.5.5 and Figures 15 and 16). We also concur with the statements made in 9.1.18 in reference to the ‘complete recovery of cores to aid interpretation of the palaeochannels identified during assessment…’ and we must also draw your attention to a statement made in 9.1.19 in regard to ‘a scheme specific WSI’ to be produced and delivered in agreement with English Heritage, as per the terms of the draft deemed Marine Licence. Draft Development Consent Order (including deemed Marine Licence), dated November 2011 (Document Reference: 3.1) – We support the terms of the draft deemed Marine Licence as set out in Schedule 6, Part 2 (Conditions) which are necessary to deliver the required mitigation measures as identified by the Environmental Statement prepared for this proposed project."