Thanet Extension Offshore Wind Farm

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Thanet Extension Offshore Wind Farm

Received 12 September 2018
From Historic England

Representation

On 1st April 2015 Historic England was vested (retaining the formal title of the Historic
Buildings and Monuments Commission for England) and is now the government service
championing England’s heritage and giving expert, constructive advice. Historic England
has had significant pre-application discussion with the applicant, providing comments on
the Scoping and PEIR stage. Historic England has maintained a constructive partnership
and been fully engaged with the applicant at this stage of the planning process on all
aspects of the historic environment and its heritage assets, on land (onshore) and on the
seabed (offshore).

We summarise our representation regarding this proposed project as follows:

1. We note that the levels of harm caused by the proposal to onshore designated heritage assets have been amended since the PEIR report. We are not in a position to comment in detail on these amended levels of harm, but will provide substantive comments at the DCO response stage. We do however question the report’s assessment of the harm to Margate’s Conservation Area which has been assessed as negligible and the assessment of the relationship between the buildings within it to the sea.

2. We do not agree with the stated level of impact upon onshore geoarchaeological
deposits. Further assessment of this impact, and appropriate geoarchaeological mitigation, should be discussed with Ben Found of Kent County Council (KCC). The availability of geoarchaeological data is disparate for the area; any further geoarchaeological assessment should therefore be undertaken with the aim of contributing to an overall, integrated deposit model for the Wantsum Channel Area.

3. Further assessment of the potential for 20th century anti-invasion defences at and
buried archaeology relating to the possible Caesarian invasion site (both in Pegwell Bay), may also be necessary to inform design of a route that will avoid harm as far as possible; these matters should be discussed further with Ben Found.

4. KCC’s Heritage Team is best also placed to advise the applicants about their detailed scheme design and archaeological work, but we are ready to contribute if we can add value, particularly if archaeology of national significance emerges. Archaeological mitigation of unavoidable harm is likely to be necessary.

5. With regard to implementing the Offshore Written Scheme of Investigation (WSI),
in accordance with any Development Consent Order (DCO) (including a Deemed Marine Licence) secured for this proposed project, Historic England considers clear and systematic time-framed method statements will be required to optimise survey opportunities. Each planned package of work - in addressing the need for appropriate mitigation for predicted impacts to potential archaeology - should also include the objectives of local and national research frameworks.

6. We note and welcome (from the Offshore Archaeology and Cultural Heritage – Document Ref: 6.2.13, para. 13.4.26 and WSI respectively) that gaps in existing geophysical/geotechnical data will be acquired prior to construction. In the planning of the geotechnical survey it is important that the appropriate depth for continuous stratigraphy is incorporated - to mitigate impacts to deposits of high archaeological potential. Additionally boreholes should be stored and maintained to maximise archaeological objectives.

7. Within the Draft DCO (Document Reference 3.1), the wording under the subheading
‘Pre-construction plans and documentation’ in Schedule 11 (Deemed Licence under the 2009 Act – Generation Assets) and Schedule 12 (Deemed Licence under the 2009 Act – Export Cable System) requires amendment and we will supply revised wording in our Written Representation.

8. Close to the proposed development is the Goodwin Sands, an extremely dynamic mobile sand bank, well recognised as a major seafaring navigational hazard over the centuries, containing sediments conducive to the preservation of significant heritage assets. Added to this, at times, sediments can cover heritage assets at substantial depths masking their identification by standard methods of geophysical survey techniques. The applicant is therefore encouraged to accurately address and consider the changing nature of the seabed, in relation to the total depth and width of the trenches required for the installation of the export cables, and in respect to the high potential for buried objects of archaeological interest.