dogger bank creyke beck - planning inspectorate · 2016. 6. 28. · 1 introduction ... 11 statutory...

DOGGER BANK CREYKE BECK

F-EXC-CG-003-EH HAP_ON_V3 © 2014 Forewind Page ii


F-EXC-CG-003-EH HAP_ON_V3 © 2014 Forewind Page iii

Document Title Dogger Bank Creyke Beck

Statement of Common Ground

English Heritage and Humber Archaeology

Partnership

Forewind Document Reference F-EXC-CG-003-EH_HAP_ON_V3

Issue Number Issue 3

Date 28 February 2014

Drafted by Sarah Chandler / Annie Calder

Checked by Tamsyn Rowe

Date / initials check TR 28-Feb-2014

Revision History

Date Issue

No.

Remarks/ Reason for Issue Author Checked Approved

11 Oct 13 Draft

V2

First draft issued Sarah

Chandler

Tamsyn

Rowe

Tamsyn

Rowe

20 Dec 13 Draft

0.1

Updated in response to comments

from HAP comments, and put into

tabular format.

Annie

Calder

Tamsyn

Rowe

Tamsyn

Rowe

25 Feb 14 Issue

2

Updated in response to HAP and

EH comments, internal legal

review.

Annie

Calder

Tamsyn

Rowe

Tamsyn

Rowe

28 Feb 14 Issue

3

Updated in response to HAP

comments

Sarah

Chandler

Tamsyn

Rowe

Tamsyn

Rowe


F-EXC-CG-003-EH HAP_ON_V3 © 2014 Forewind Page iv

Contents

1 Introduction .................................................................................................................. 5

1.1 Reason for this document .................................................................................. 5

1.2 Application Elements within this SoCG .............................................................. 5

1.3 Structure ............................................................................................................ 5

2 Background .................................................................................................................. 7

2.1 Development description .................................................................................... 7

2.2 Consultation Schedule ....................................................................................... 8

3 Matters of Specific Agreement ........................................................................................11

2.3 Onshore Cultural Heritage ................................................................................11

2.4 Issues unresolved .............................................................................................14

4. Confirmation of Agreement with English Heritage .......................................................15

5. Confirmation of Agreement with Humber Archaeological Partnership .........................16

Table of Tables

Table 2.1 Summary of pre-application consultation between Forewind and English

Heritage/Humber Archaeology Partnership ................................................. 8

Table 2.2 Summary of post-submission consultation between Forewind and English

Heritage/Humber Archaeology Partnership. ................................................ 10


F-EXC-CG-003-EH HAP_ON V3 © 2014 Forewind

1 Introduction

1.1 Reason for this document 1.1.1 This Statement of Common Ground (SoCG) has been prepared between Forewind and English

Heritage (EH), and Humber Archaeology Partnership (HAP) to set out the areas of agreement and

disagreement between the three parties in relation to the proposed Development Consent Order (DCO)

for Dogger Bank Creyke Beck.

1.1.2 Forewind is a consortium comprising RWE, Scottish and Southern Energy, Statkraft and Statoil.

Forewind is committed to securing all the necessary consents required for the development and

construction of offshore wind farms in the Dogger Bank Zone.

1.1.3 The Guidance for the examination of applications for development consent for nationally significant

infrastructure projects (CLG, February 2012) and The Infrastructure Planning (Examination Procedure)

Rules 2010 highlight the importance of the agreement with stakeholders and submission of SoCG to the

Major Applications and Plans Directorate within the Planning Inspectorate (PINS) during the

Examination stage. A SoCG is defined as a written statement prepared jointly by the applicant and any

interested party, which contains agreed factual information about the application and is a means of

clearly stating any areas of agreement and disagreement between two parties in relation to the

application. It is also useful to ensure that the evidence at the examination focuses on the material

differences between the main parties which might lead to a more efficient examination process.

1.2 Application Elements within this SoCG

1.2.1 EH is the Government’s advisor on all aspects of the historic environment and has a statutory role in the

planning system. With regards to the Dogger Bank Creyke Beck application English Heritage was

consulted with specific reference to designated cultural heritage assets including Grade I and Grade II*

listed buildings and scheduled monuments. They had particular input into the potential impacts on the

setting of Beverley Minster.

1.2.2 HAP the archaeological advisor to East Riding of Yorkshire Council and Hull City Council. They provide

cultural heritage advice on planning, development and site management and maintain the Sites and

Monuments Record for the East Riding and Hull. For the Dogger Bank Creyke Beck project their

predominant involvement was to advise on the scope of archaeological evaluation and to approve

written schemes of investigation (WSI) for fieldwork.

1.2.3 Given the remits of both EH and HAP, the scope of this SoCG will cover the full environmental

assessment, fieldwork and DCO requirements for Onshore Cultural Heritage, for both consultees.

1.2.4 In addition, the Rule 6 letter issued by the Planning Inspectorate on Thursday 9 January 2014 states

that the Examining Authority (ExA) would like Forewind to engage EH and HAP in a SoCG in order to

reach agreement on matters with particular reference to archaeology and heritage assets.

1.3 Structure

1.3.1 This document starts by setting out the background to the development and the stakeholders who are

entering into the SoCG. It also summarises the pre-application consultation, and any post-application



consultation that has subsequently occurred.

1.3.2 Table 3.1 of this SoCG lists those matters agreed and unresolved with EH and HAP. Table 3.1 follows

the sequence of sub-headings within Chapter 27 of the ES as detailed below.

1.3.3 Sequence of sub-headings in the ES Chapters:

1.3.3.1 Guidance and consultation;

1.3.3.2 Methodology;

1.3.3.3 Existing environment;

1.3.3.4 Assessment of impacts - includes worst case definition;

1.3.3.5 Interrelationships;

1.3.3.6 Cumulative Impact Assessment ;

1.3.3.7 Draft DCO



2 Background

2.1 Development description

2.1.1 The Dogger Bank Zone is between 123 and 290 kilometres (77 to 180 miles) off the east coast of

Yorkshire and extends over an area of approximately 8639 km2 (3336 square miles). The water depth

ranges from 18 to 63 metres (59 to 206 feet).

2.1.2 Dogger Bank Creyke Beck will be the first stage of development of the Dogger Bank Zone, and will

comprise two wind farms, each with a generating capacity of up to 1.2GW (total generating capacity of

up to 2.4GW). The two wind farms will connect to the existing National Grid substation at Creyke Beck,

in the East Riding of Yorkshire.

2.1.3 Dogger Bank Creyke Beck will comprise the following offshore elements:

2.1.3.1 Up to 400 wind turbines with supporting tower structures, foundations fixed to the

seabed and associated support and access structures;

2.1.3.2 Two offshore high voltage direct current (HVDC) converter platforms with

foundations fixed to the seabed;

2.1.3.3 Up to eight offshore collector platforms with foundations fixed to the seabed;

2.1.3.4 Up to four offshore accommodation or helicopter platforms with foundations fixed

to the seabed and including facilities for vessels and helicopters for operations

and maintenance activities;

2.1.3.5 Offshore platforms may be co-located on a single foundation, resulting in a

combined offshore platform comprising two or more of the platform structures

described above;

2.1.3.6 Up to 10 offshore meteorological monitoring stations with foundations fixed to the

seabed;

2.1.3.7 Subsea cables between the elements of offshore infrastructure described above;

2.1.3.8 Offshore export cables carrying electricity from the offshore HVDC converter

platforms to the Holderness coast; and

2.1.3.9 Ancillary works including: cable and pipeline crossing structures; protection

against foundation scour and subsea damage, cable protection measures and

vessel-mooring facilities.

2.1.4 The onshore elements are all located within the East Riding of Yorkshire, and comprise:

2.1.4.1 Underground cable transition joint bays at the landfall, north of Ulrome on the

Holderness coast;

2.1.4.2 Underground HVDC export cables running approximately 30 kilometres from the

landfall transition joint bays to the two converter stations;

2.1.4.3 Two converter stations located between Beverley and Cottingham adjacent to the

A1079 and with associated roads, fencing, landscaping and drainage;

2.1.5 Underground high voltage alternating current (HVAC) export cables running



approximately two kilometres from the converter stations to the National Grid

substation at Creyke Beck, where connection works will be carried out; and

2.1.6 Ancillary works including: temporary working areas, permanent and temporary

access roads, and service corridors.

2.2 Consultation Schedule 2.2.1 Forewind and its onshore cultural heritage contractor URS, have had regular engagement with EH and

HAP representatives since October 2010 when the initial request for a Scoping Opinion was submitted

to the then Infrastructure Planning Commission (IPC). A summary of key consultations is provided in

Tables 2.1 and 2.2 below. Table 2.1 documents the key consultations up to the date of the application

submission on 29 August 2013, and Table 2.2 documents the post-application consultation.

Table 2.1 Summary of pre-application consultation between Forewind and English

Heritage/Humber Archaeology Partnership

Date Form of Consultation Summary

October 2010 Report from Forewind to IPC

Scoping report submitted to the IPC, for wider

statutory consultation, including with HAP and

EH.

28 October 2010

Letter from HAP to IPC Statutory scoping response from HAP on the Scoping Report.

11 Nov 2010 Letter from EH to IPC Statutory scoping response from EH on the

Scoping Report.

17 January 2012 Letter from HAP to Forewind

Section 42 consultation, stage 1 - response from HAP on Onshore Cultural Heritage. HAP reiterated comments made on the scoping report with particular reference to the recommended staged archaeological scheme of works. An outline of what the Archaeology and Cultural Heritage section of an EIA should contain was provided.

18 January 2012

Letter from EH to Forewind

Section 42 consultation, stage 1 – response from EH on Onshore Cultural Heritage. EH outlined an expectation for the ES to examine the potential effects which the onshore cabling and the converter substations might have upon all designated and undesignated heritage assets along the route.

18 January 2012

Meeting with EH, Forewind and URS

Meeting to discuss project design and the proximity of Beverley Minster to the onshore works.

29 Feb 2012 E-mail from URS to HAP (Ruth Atkinson)

Written Scheme of Investigation (WSI) for geophysical survey submitted to HAP for comment.

2 March 2012

E-mail from HAP (Ruth Atkinson) to URS

(Forwarded to Forewind)

Response from HAP on the WSI stating the works could proceed under the methodology outlined.



2 May 2012

Meeting with HAP and URS

Meeting to discuss gaps in characterisation of the cultural heritage baseline, in relation to recent work not on the HER list.

28 August 2012

Email from URS to HAP Draft WSI for the trial trenching issued to HAP for comment.

10 September 2012

Meeting with Forewind, URS and HAP

Meeting to agree WSI for Trial trenching.

19 Sep 2012 Email from URS to HAP WSI for trial trenching re-submitted to HAP, in line with HAP comments received on 10 September 2013.

9 October 2012

Email from HAP to Forewind

HAP had no comments on Dogger Bank Creyke Beck HVAC Cable Route Report circulated to the Converter Station Community Working Group.

17 October 2012

Email from URS to HAP Progress update with initial trial trenching results for seven of the sites completed.

7 Nov 2012

E-mail from HAP to Forewind

Agreed to the Converter Station Community Working Group minutes and reiterated trial trenching evaluation as being worthwhile.

7 December 2012

Report from URS to HAP

Draft Cultural Heritage Baseline and draft Interim Report on Phase 1 of the trial trenching submitted to HAP for comment.

29 January 2013

Comments on Interim report from HAP

Comments on draft Interim Report on Phase 1 of the trial trenching received from HAP.

9 January 2013

Meeting with EH, Forewind and URS

Meeting to provide project update and discuss the setting of Beverley Minster.

2 May 2013

Meeting with EH and Forewind

Meeting to provide a project and EIA update, and to discuss Beverley Minster.

10 May 2013

E-mail from HAP to URS

Section 42 consultation, stage 2 - response from HAP on Onshore Cultural Heritage.

15 May 2013

Meeting with HAP and Forewind

Meeting to discuss trial trenching and introduction to the SoCG. The need for full archaeological investigation pre-construction was discussed.

28 May 2013

Letter from EH to Forewind

Section 42 consultation, stage 2 - response from EH on Onshore Cultural Heritage.

11 June 2013 Letter from ERYC to Forewind

Section 42 consultation, stage 2- response from East Riding of Yorkshire Council. Comments from HAP appended.

14 June 2013

Letter via e-mail from URS to EH

Letter addressing comments EH raised during the S42 consultation.



Table 2.2 Summary of post-application consultation between Forewind and English

Heritage/Humber Archaeology Partnership

Date Form of Consultation Summary

15 Oct 2013

Meeting with EH and Forewind

Meeting held to discuss the SoCG.

7 Nov 2013 Email from HAP to Forewind

Detailed comments on the trial trenching programme, and the contents of the draft SoCG provided by HAP.

26 Nov 2013 Meeting with HAP, URS, Forewind

Meeting to discuss the trial trenching programme and the content of the SoCG, and address comments raised by HAP on 7 Nov 2013.

5 Feb 2014 Meeting with HAP, URS Forewind

Meeting to discuss the SoCG and DCO wording.

6 Feb 2014 E-mail from EH to Forewind

Comments on SoCG issued by EH.



3 Matters of Specific Agreement

2.3 Onshore Cultural Heritage

ID Statement on which Forewind seeks Agreement Forewind English Heritage Humber Archaeology

Partnership

A. Guidance and Consultation

3.1.A.1

Appropriate legislation, planning policies and guidance relevant to the Onshore Cultural Heritage impact assessment for Dogger Bank Creyke Beck, are listed in section 2.2.1 of chapter 27 of the Environmental Statement. Forewind followed the relevant legislation, planning policy and guidance documents with regards to the cultural heritage assessment.

Agreed Agreed Agreed

3.1.A.2

In addition to the policies identified in chapter 27, policies ENV6 and ENV7 of the Joint Structure Plan for Kingston upon Hull and the East Riding (adopted 2005) are also relevant to the Creyke Beck project. The Joint Structure Plan policies provide the strategic planning framework within which the local plan policies identified in chapter 27 sit. Forewind has followed these policies with regards to the cultural heritage assessment.


3.1.A.3

In addition to the policies identified in chapter 27, the full extent of Policy E35 of the Beverley Borough Local Plan is relevant to this development, and in particular paragraph two which reads: “On other sites, sufficient information should be provided to enable the archaeological impact of any development to be assessed. Permission will be granted if the applicant can demonstrate that full provision has been made, preferably for the protection of the monument in situ, or as a last resort, if appropriate, the proper investigation and recording of the site. Where development is considered permissible, conditions on planning obligations may be required to ensure proper recording and investigation.” Forewind has followed this policy with regards to the cultural heritage assessment.

Agreed Not applicable. 3.1.A.3 requested by HAP.

Agreed

3.1.A.4

Forewind has adequately consulted the relevant onshore cultural heritage statutory consultees throughout the appropriate stages of the development. The consultation schedule (in section 2 of this SoCG) is a fair and accurate record of pre and post-application consultation on cultural heritage issues.


B. Methodology

3.1.B.1 Characterisation of the existing environment has been undertaken to agreed methodologies and standards. The desk study was completed in accordance with the Standard and Guidance for Historic Environment Desk-Based Assessment (Institute of Field




Archaeologists (IfA) 2012) and the Code of Conduct (IfA 2010).

3.1.B.2 The geophysical survey was completed in agreement with a Written Scheme of Investigation (WSI) approved by HAP and was conducted in accordance with the appropriate standards and guidance as outlined in that WSI.


3.1.B.3

The 2012 trial trenching work was completed as far as possible, in agreement with a Written Scheme of Investigation approved by HAP and conducted accordance with the Standard and Guidance for Archaeological Field Evaluation (Institute of Field Archaeologists (IfA) 2011) and the Code of Conduct (IfA 2010). Further evaluation to inform mitigation measures will be undertaken in accordance with an updated Written Scheme of Investigation to be approved by HAP.

Agreed Not applicable, defer to HAP

Agreed

3.1.B.4 The methodology for the assessment of impacts as described in Section 3.3 of chapter 27 of the ES, has been conducted in accordance with EH guidance – Conservation Principles Policy and Guidance (EH 2008), and The Setting of Heritage Assets (EH 2011).


3.1.B.5

The methodology underpinning the ‘Definition of terms relating to the significance of cultural heritage receptors’ (as outlined in Table 3.1 of Chapter 27 of the ES) has been appropriately applied on a relative scale using assessment criteria developed from the National Planning Policy Framework (NPPF) and National Policy Statement for Energy EN-1. Significance levels are applied on a relative scale in accordance with the EIA process, and are not an absolute statement of significance.


3.1.B.6

The setting and significance of designated heritage assets within the wider landscape have been correctly examined. It was agreed that the proposed converter station would not compete vertically with Beverley Minster and there will be no loss of significance of this heritage asset either through direct impacts upon the Minster or impacts upon its setting, as such third viewpoints were not necessary for this assessment of impacts.

Agreed Agreed Not applicable, defer to EH

C. Existing Environment

3.1.C.1

The baseline assessment of the existing environment was sufficient for the identification of onshore heritage assets. Further evaluation to inform mitigation measures will be undertaken post-consent and additional archaeological remains will be identified during the course of the fieldwork.


Agreed

D. Assessment of Impacts – Worst Case Definition

3.1.D.1

The maximum realistic values for each construction and operating scenario have been incorporated into a Rochdale envelope. The key project parameters and the relative timing of the construction and operation of the two projects, which form the realistic worst case, are as described in Table 5.1 in Chapter 27 Onshore Cultural Heritage. The construction worst case scenario has been assumed during the impact assessment process. The construction worst case scenario assumes a potential for direct impacts to archaeological remains anywhere within the cable corridor (36m wide HVDC route and 38m wide HVAC route).


Agreed

E. Assessment of Impacts during Construction, Operating and Decommissioning



3.1.E.1

The ES provides a satisfactory assessment of the potential onshore cultural heritage impacts arising from construction, operation and decommissioning of the onshore elements of Dogger Bank Creyke Beck. Additional archaeological remains are likely to be identified during the course of further evaluation works that will be undertaken post-consent, and secured under the proposed wording for DCO requirement 27.


Agreed

3.1.E.2

The residual impacts of the development on known onshore cultural heritage and terrestrial archaeology during the construction phase have been appropriately predicted as minor adverse, or negligible. Additional archaeological remains are likely to be identified during the course of further evaluation that which will be undertaken post-consent, and secured under the proposed wording for DCO requirement 27.


Agreed.

3.1.E.3 The residual impacts of the development on onshore cultural heritage and terrestrial archaeology during the operating phase have been appropriately predicted as minor adverse, or negligible.


3.1.E.4 The residual impacts of the development on onshore cultural heritage and terrestrial archaeology during the decommissioning phase have been appropriately predicted as negligible.


3.1.E.5

The measures outlined to mitigate the potential impacts on known archaeology during the construction, operating and decommissioning phases (described in Table 12.1 of Chapter 27 of the ES) are appropriate to reduce predicted impacts to an acceptable level. This mitigation strategy will also apply to additional archaeological remains identified during further evaluation works that will be undertaken post-consent.


Agreed

F. Inter-relationships

3.1.F.1 The inter-relationships relevant to the assessment of onshore cultural heritage as listed in Table 9.1 of Chapter 27 of the ES are adequately considered and summarised.

Agreed Agreed Not applicable, defer to EH

G. Cumulative Impacts

3.1.G.1 The cumulative impacts relevant to the assessment of onshore cultural heritage in Chapter 27 of the ES are adequately considered and summarised.


H. Draft Development Consent Order

3.1.H.1 The description of the onshore elements within the DCO is consistent with the description presented within Chapter 5, Project Description which forms the basis of the heritage assessment in the ES.


3.1.H.3

The following proposed amendment to the DCO wording of Requirement 27 is agreed as appropriate to capture the mitigation:

Archaeology 27.—

(1) No stage of the onshore works shall commence until in relation to that stage a programme of

archaeological work has been secured in accordance with a written scheme of archaeological

Agreed Not applicable, defer to HAP.

Agreed



investigation which has been submitted to and approved in writing by the relevant planning

authority.

(2) The scheme shall:

(a) set out a pre-construction programme of archaeological evaluation which defines the extent,

character and significance of archaeological sites and the extent of areas that do not require

detailed excavation. The results of the evaluation will inform subsequent mitigation strategies;

(b) set out the programme and methodology for site investigation and recording;

(c) set out provision for the monitoring of geotechnical test pits in areas of significance as

defined by the archaeological evaluation;

(d) set out the programme for post-investigation assessment, the results of which will inform the

scope of analysis;

(e) provide for analysis of the site investigation and recording;

(f) provide for publication and dissemination of the analysis and records of the site investigation;

(g) nominate a competent person or organisation to undertake the works set out within the

written scheme of investigation; and

(h) set out provision for the notification in writing to the Curatorial Officer of the Humber

Archaeology Partnership of the commencement of archaeological works and the opportunity to

monitor such works.

(3) No stage of the onshore works shall commence until in relation to the relevant work the

relevant site investigation has been completed as approved.

(4) No stage of the onshore works shall be brought into commercial operation (excluding

commissioning) until the site investigation and post-investigation assessment have been

completed in accordance with the programme in the approved scheme and the provision made

for analysis, publication and dissemination of results and archive deposition has been secured.

(5) The written scheme in relation to the relevant work shall be carried out as approved.

2.4 Issues unresolved 2.4.1 There are no areas of specific disagreement.

dogger bank creyke beck - planning inspectorate · 2016. 6. 28. · 1 introduction ... 11 statutory...

Documents