Draft Overarching National Policy Statement for Energy (EN-1) & the Draft NPSs for Fossil Fuels, Renewables, Gas Supply and Gas and Oil Pipelines, and Electricity Networks (EN 2-5) (DCCE)
Submission from ALGAO:England
ALGAO is the national body representing local government archaeology services at County, District, Metropolitan, Unitary and National Park authority level. These provide advice to all the District, Unitary and other local government bodies in the country. ALGAO: England co-ordinates the views of its member authorities (106 in total) and presents them to government and to other national organisations. It also acts as an advisor to the Local Government Association (LGA) on archaeological matters. The range of interests of our members embraces all aspects of the historic environment, including archaeology, buildings and the historic landscape.
The historic environment is vulnerable to change, once destroyed archaeological evidence is lost for ever. Mitigation strategies can be developed for historic assets that are under threat, the broad approach is set out in PPG15: Planning and the Historic Environment (1994); and PPG 16: Planning and Archaeology (1990) – which are to be updated in PPS 15 and its supporting Guidance. Where preservation in situ cannot be achieved recording of archaeology by excavation or building analysis is possible. The historic environment can make a positive contribution to planning for new development and new communities, and promoting a sense of place, but needs to be assessed and integrated into the planning process from the start of the decision-making process.
We welcome this opportunity to comment on these consultations, as major infrastructure projects have the potential to impact considerably on the historic environment in general, and archaeological remains and historic structures in particular. The need to have a comprehensive understanding of historic assets that may be affected by any proposal is paramount, to enable informed and appropriate measures to be secured to protect such assets, or the interest in them.
To this end we support the Overarching Energy policy (EN-1) and it’s measures to protect the Historic Environment (section 4.23). This clearly draws on the consultation draft of Planning Policy Statement 15, which we broadly support, although we did comment on a number of matters of detail, which we hope may be taken on board when the final Statement is issued. Some of our comments here will reflect those made of the draft PPS 15.
It is extremely useful that our members are identified in footnote 62 as a source of advice and information on the historic environment. Whilst many of our members are based in County Councils, others are with Local or Unitary Authorities, as well as some National Park Authorities, therefore we suggest using the term 'Local Authority Historic Environment Advisers' in this text, rather than 'County Archaeologists'.
4.23 Historic Environment
In response to questions 2 – 7, in relation to the Historic Environment policies, there are a number of measures that need clarifying to enable the IPC to have confidence that adequate information has been submitted to them, on which they can base their decisions. Thus:
4.23.7 It is important to clarify that whilst there are many known assets already recorded, in Historic Environment Records (HERs) for instance, these may point to the potential for further discoveries to be made, particularly buried archaeology. Thus an ES should consider both the significance of what is known, but also identify what more needs to be known through additional investigation (covered in 4.23.8). We would therefore suggest adding this sentence to the end of this paragraph:
The potential for unidentified assets to be present on the site should also be considered.
4.23.8 Taking the above comments into account, this paragraph is correct to identify that site evaluation has two roles, 1) to assess the extent and nature/importance of known assets, as well as 2) the extent and nature of any that are suspected to lie there. This therefore might be clarified with slight re-ordering of the paragraph at the beginning:
Where a development includes or potentially includes assets with an archaeological interest, the applicant should carry out appropriate desk-based assessment as part of any application for consent. Evaluation is required where there is a need to discover the extent and nature of significance in order to inform a decision. In some circumstances, it may also be necessary for the applicant to undertake field surveys...etc
4.23.11 We think it essential that the archaeology advisors to the local planning authority, who base their advice on the HERs that they maintain, should be explicitly identified as expert advisers, providing, as they do, advice to local communities, other professionals, and statutory consultees. We would therefore like to insert "Local Authority Archaeology Advisers" in the second to last line.
4.23.19 To offer clarity to the developer, the last line of this paragraph might be worded:
They should deposit the archive generated with a local museum or other public depository.
4.23.20 To ensure that consents granted by the IPC are implemented in line with local planning authority practice, we suggest that a sentence be added to the end of this paragraph:
This written scheme of investigation should be agreed with and approved by the Local Authority Archaeology Adviser
4.23.21 The wording of this paragraph is potentially misleading, as many archaeological assets are undiscovered, the potential for finding these on the development site is what the pre-application desk-based assessment and site evaluation are expected to establish. Thus any discovery made during construction will be unpredictable, and the probability of this hard to establish. It is however prudent for the developer to make a contingency for unexpected discoveries in their risk management.(1) In such circumstances the expert advice of the local authority historic environment adviser should be sought. This paragraph might therefore be rewritten:
The IPC should ensure that appropriate contingencies are in place for the identification and treatment of unexpected heritage assets discovered during construction or other works. These should be implemented with the approval of the Local Authority Archaeology Adviser.
4.24 Landscape and Visual Impacts
We believe that the historic character of our landscape should have more explicit recognition in these policies, in line with the European Landscape Convention and the emerging PPS 15 Guidance. We understand that further guidance will also be forthcoming on 'Setting', which should be taken into account.
4.24.2 mentions 'landscape character assessments' as an evidence base for assessing landscape impacts. We would point to the additional resource of historic landscape characterisation that has been prepared for most English counties, at different levels of rural and urban landscape character (2), which bring out the major contribution that human agency has made to the creation of the natural landscapes around us. The need to preserve what is important about the historic character of our environment should be recognised.
(1)See: 'Archaeology and Development – a good practice guide to managing risk and maximising benefit' Barber et al CIRIA C672, 2008
(2)See: 'Using Historic Landscape Characterisation' Clark et al English Heritage & Lancs. CC, 2004; 'Characterisation' English Heritage Conservation bulletin 47, Winter 2004-5
ALGAO Planning and Legislation Committee