dogger bank - planning inspectorate... · response to the offshore aspects of the dogger bank draft...

DOGGER BANK CREYKE BECK

Offshore English Heritage SoCG © 2014 Forewind Page ii

Document Title Dogger Bank Creyke Beck

Statement of Common Ground

English Heritage (offshore)

Forewind Document Reference

Issue Number

Date 25 February 2014

Date Issue No. Remarks / Reason for Issue Author Checked Approved

12/12/13 1.1 First issue to EH MS SB SB

05/02/14 2.1 Updated after EH comments MS SB SB

24/02/14 3.1 Final for approval MS SB SB

25/02/14 3.2 Final MS SB GL


Offshore English Heritage SoCG © 2014 Forewind Page iii

Contents

1 Introduction .................................................................................................................. 4

1.1 Reason for this document .................................................................................. 4

1.2 Structure ............................................................................................................ 4

1.3 Programme ........................................................................................................ 4

2 Background .................................................................................................................. 5

2.3 Consultation ....................................................................................................... 6

3 Marine Archaeology ..................................................................................................... 8

3.1 Matters of Specific Agreement ........................................................................... 8

3.2 Issues unresolved .............................................................................................10

4 Historic Seascape Character .......................................................................................11

4.1 Matters of Specific Agreement ..........................................................................11

4.2 Issues unresolved .............................................................................................11

5 Confirmation of agreement ..........................................................................................12

Table of Tables

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

Heritage ....................................................................................................... 6

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

Heritage ....................................................................................................... 6


Offshore English Heritage SoCG © 2014 Forewind

1 Introduction

1.1 Reason for this document

1.1.1 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 Statements

of Common Ground (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.

1.1.2 This SoCG will be prepared jointly with English Heritage to set out the areas of agreement and

disagreement between the two parties in relation to offshore elements of the proposed Development

Consent Order (DCO). A separate SoCG is being prepared between Forewind and English Heritage in

relation to onshore elements of the proposed DCO. A SoCG between Forewind and English Heritage

has been requested by PINS and the date for its submission has been set as 4 March 2014.

1.2 Structure

1.2.1 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-submission

consultation that has subsequently occurred.

1.2.2 The consequent sections then summarise the agreed positions between English Heritage and Forewind

pertaining to offshore archaeology and cultural heritage. Where statements are not agreed, these are

detailed after the table of agreed statement, in a more detailed format to describe the position of both

parties.

1.3 Programme

1.3.1 The first stage of two-stage pre-application statutory consultation process took place in December

2011. During that time Forewind made available the Preliminary Environmental Information 1 (PEI1)

document for stakeholder review and comments and all relevant consultation responses were taken

under Forewind’s consideration and helped to shape the draft of the ES.

1.3.2 The second phase of consultation took place in the second quarter of 2013 where Forewind submitted a

draft ES for consultation under Section 42 and 47 of the Planning Act 2008. Stakeholders had the

opportunity to comment on the proposal, and comments were received, considered and incorporated

where appropriate (see Table 2.1).

1.3.3 After discussing comments with stakeholders and updating the draft ES according to these, Forewind

submitted the final application for Dogger Bank Creyke Beck on 30 August 2013. The application was

accepted for examination by the Planning Inspectorate on 25 September 2013.



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. Dogger Bank Creyke Beck will comprise:

Offshore

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

associated support and access structures;

Two offshore high voltage direct current (HVDC) converter platforms with foundations fixed to the

seabed;

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

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;

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;

Up to 10 offshore meteorological monitoring stations with foundations fixed to the seabed;

Subsea cables between the elements of offshore infrastructure described above;

Offshore export cables carrying electricity from the offshore HVDC converter platforms to the

Holderness coast; and

Ancillary works including: cable and pipeline crossing structures; protection against foundation

scour and subsea damage, cable protection measures and vessel-mooring facilities.

Onshore in the East Riding of Yorkshire

Underground cable transition joint bays at the landfall, north of Ulrome on the Holderness coast;

Underground HVDC export cables running approximately 30 kilometres from the landfall transition

joint bays to the two converter stations;

Two converter stations located between Beverley and Cottingham adjacent to the A1079 and with

associated roads, fencing, landscaping and drainage;

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

Ancillary works including: temporary working areas, permanent and temporary access roads, and

service corridors.

2.1.3 The ‘Offshore’elements of Dogger Bank Creyke Beck are the subject of this SoCG. The elements

covered under ‘Onshore in the East Riding of Yorkshire’ are covered in the onshore English Heritage

SoCG.



2.1.4 For further information on the potential impacts to the environment as a result of the proposed offshore

wind farm, please refer to the Environmental Statement for Dogger Bank Creyke Beck, available on the

PINS website (http://infrastructure.planningportal.gov.uk/projects/yorkshire-and-the-humber/dogger-

bank-creyke-beck/?ipcsection=app).

2.2 Identification of Stakeholders 2.2.1 Forewind recognises that effective and meaningful consultation is an integral part of its development

activities and is committed to ensuring that it maintains a transparent approach to its consultation and

engagement activities.

2.2.2 Forewind has sought to ensure that relationships with stakeholders are established from an early stage

of development. Therefore, contact was made with a large number of stakeholders to inform them of

Forewind’s initial development proposals. Regular consultations have been maintained with key

stakeholders since 2010.

2.2.3 The remainder of this Statement of Common Ground (SoCG) document focuses on matters of specific

agreement, or disagreement between Forewind and English Heritage.

2.3 Consultation

2.3.1 Stakeholder engagement with English Heritage in relation to Dogger Bank Creyke Beck is summarised

in Tables 2.1 and 2.2 below.

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

Date Form of consultation Summary

27 April 2010 Workshop English Heritage attended an initial Dogger Bank Zone

Appraisal and Planning Workshop in Newcastle.

11 November

2010 Consultation response Scoping response received from English Heritage.

12 January 2012 Phone call Call to discuss the seascape assessment.

27 January 2012 Meeting Update meeting to discuss the offshore archaeological and

seascape assessments.

19 September

2012 Meeting Workshop held with offshore archaeology stakeholders.

10June 2013 Consultation response

Response to the offshore aspects of the Dogger Bank draft

environmental statement as part of the final stage of

statutory consultation.

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

Heritage

Date Form of consultation Summary

12 September

2013 Meeting

A meeting to discuss the final application, further

geotechnical work and the process for Statements of

Common Ground going forward.

8 November 2013 Relevant

representation

English Heritage submitted a relevant representation to the

Planning Inspectorate as part of the s56 consultation on the



final Dogger Bank Creyke Beck application (Appendix 1).

19 December

2013 Meeting

A meeting to discuss the Teesside A & B application and

first draft of the Creyke Beck SoCG.



3 Marine Archaeology

3.1 Matters of Specific Agreement

The following statements are the key agreed positions between Forewind and English Heritage, in

relation to Marine Archaeology:

A. Consultation

3-A-1: It is agreed that English Heritage have been adequately consulted during the pre-application

period for Dogger Bank Creyke Beck.

3-A-2: It is accepted that outstanding concerns regarding the environmental impact assessment

exercise presented in the ES, raised in English Heritage’s relevant representation, have been

addressed by the response provided in Appendix 2.

B. Legislation, Policy and Guidance

3-B-1: It is accepted that the legislation and guidance documents listed in paragraph 2.1.12 of

Chapter 18 of the ES (ref 6.18) are appropriate for the assessment of impacts of Dogger Bank

Creyke Beck on marine and coastal archaeology.

C. Methodology and Worst Case Scenarios

3-C-4: It is accepted that the definitions of archaeological value as presented in Table 3.3 of Chapter

18 of the ES (ref 6.18) are appropriate for use in the EIA.

3-C-5: It is accepted that the values of significance derived in Table 3.4 of Chapter 18 of the ES (ref

6.18) are appropriate for use in the EIA.

3-C-6: It is accepted that the use of the maximum number (300 per project) of conical gravity base

turbine foundations presented in Table 5.1 of Chapter 18 of the ES (ref 6.18) represents the worst

case for direct construction impacts on marine archaeological receptors.

3-C-8: It is accepted that the use of the maximum number (seven per project) of semi-submersible

gravity base platform foundations presented in Table 5.1 of Chapter 18 of the ES (ref 6.18)

represents the worst case for direct construction impacts on marine and coastal archaeological

receptors.

3-C-9: It is accepted that the realistic worst case lengths of export, inter-array and inter-platform cable

length and cable protection presented in Table 5.1 of Chapter 18 of the ES (ref 6.18) are the

worst case for direct construction impacts on marine and coastal archaeological receptors. These

maximum cable lengths and cable protection volumes are appropriately secured through

Requirement 6 of the DCO.

D. Existing Environment

3-D-1: It is accepted that the geophysical surveys, as presented in Appendices A – C to Chapter 12 of

the ES (ref 6.12.1 – 6.12.3), are appropriate for the collection of environmental data and analysis

to inform the baseline for Dogger Bank Creyke Beck.

3-D-2: It is accepted that section 4 of Chapter 18 of the ES (ref 6.18) adequately describes the

baseline environment for the purposes of the environmental assessment for Dogger Bank Creyke

Beck.



E. Assessment of Impacts – Construction, Operation, Decommissioning and Cumulative Impact

Assessment

3-E-1: It is accepted that, with the mitigation secured in all Deemed Marine Licences (DMLs), the

residual impacts on Marine Archaeology receptors from the construction, operation and

decommissioning stages of Dogger Bank Creyke Beck in isolation are predicted to be negligible

(see Table 12.1 of Chapter 18 of the ES(ref 6.18)).

3-E-2: It is accepted that, with the mitigation secured in all DMLs, the residual adverse impacts on

Marine Archaeology receptors from the construction, operation and decommissioning stages of

Dogger Bank Creyke Beck cumulatively with other plans, projects and activities (as listed in Table

10.1 of Chapter 18 of the ES (ref 6.18)) are predicted to be negligible (see section 10 of Chapter

18 of the ES (ref 6.18)).

3-E-3: It is accepted that the development of Dogger Bank Creyke Beck has the potential to have a

positive impact due to any discoveries contributing significantly to a greater understanding of the

offshore archaeological resource, provided any studies are completed to professional

archaeological standards and results produced are made publicly available, as set out in Appendix

B1 to Chapter 18 of the ES (ref 6.18.2).

F. Mitigation and Monitoring

3-F-1: It is agreed that the use of archaeological exclusion zones around known wrecks (presented in

Tables 7-9 of Appendix B to Chapter 18 of the ES (ref 6.18.2) mitigates any potential direct

impacts of Dogger Bank Creyke Beck.

3-F-2: It is agreed that micrositing of the construction activities at the landfall around known

archaeological receptors presented in Table 11 of Appendix B to Chapter 18 of the ES (ref

6.18.2) mitigates any potential direct impacts of Dogger Bank Creyke Beck.

3-F-3: It is agreed that micrositing of Dogger Bank Creyke Beck assets and activities around known

fisherman’s fasteners presented in Table 10 of Appendix B to Chapter 18 of the ES (ref 6.18.2)

mitigates any potential direct impacts of Dogger Bank Creyke Beck.

3-F-4: It is agreed that the use of the Offshore Renewables Protocol for Archaeological Discoveries

(ORPAD) is appropriate mitigation for any potential direct impacts of Dogger Bank Creyke Beck

on unknown marine and coastal archaeological receptors, as referenced in paragraph 8.3.3 of

Appendix B to Chapter 18 of the ES (ref 6.18.2).

3-F-5: It is agreed that the monitoring of Archaeological Exclusion Zones as set out in paragraphs of

8.4.13 to 8.4.16 of Appendix B to Chapter 18 of the ES (ref 6.18.2) are appropriate for the

purposes of monitoring the indirect effects of Dogger Bank Creyke Beck.

G. DCO and DMLs

3-G-1: It is accepted that, after the proposed amendment to the wording of the deemed Marine Licences

as requested by English Heritage (Appendix 1), DMLs 1 & 2 conditions 9 (g) and DMLs 3 & 4

conditions 6(f), adequately secures the mitigation and monitoring referenced in points 3-F-1 to 3-

F-5 above. It is considered that explicit mention of the high level WSI as set out within the

environmental statement, Appendix B to Chapter 18 of the ES (ref 6.18.2), provides more

certainty around the document being referenced within the condition:

1 On the Dogger Bank Creyke Beck Application Documents CD (dated August 2013) Application Reference: EN010021 the Chapter 18

Appendices are misnamed. Appendix A is found in pdf document entitled Appendix B and Appendix A is found in pdf document entitled Appendix B. However, this is not the case for the application documents uploaded to the PINS website which are labelled correctly.



“…a written scheme of archaeological investigation in relation to the Order limits in accordance

with Chapter 18 Appendix B of the Environmental Statement, industry good practice and after

discussions with English Heritage to include…”

3-G-2: It is accepted that there are separate DMLs for the generation and transmission assets for both

Creyke Beck A and B. Each DML currently has its own condition requiring a WSI (see 3-G-1) and as

such each project is already required to produce its own scheme specific WSI. Therefore, the condition

requested in English Heritage’s relevant representation (Appendix 1), for scheme specific WSIs to be

produced rather than an over-arching WSI for the whole application is no longer required.

3-G-3: It is accepted that the MMO will sign off the final layout and will consult with the statutory bodies

including English Heritage. This will therefore give English Heritage the opportunity to comment on the

final layout and therefore a provision in the DCO to reflect archaeological anomalies being avoided in

the design layout, as requested in English Heritage’s relevant representation (Appendix 1), is no longer

required.

3-G-4: It is accepted that, subject to DML 1&2 condition 13(2)(b) and DML 3&4 condition 10(2)(b)

being amended to the following “one high resolution bathymetry and side-scan survey of the area(s)

within the Order limits in which it is proposed to carry out construction works, including a 500m buffer

area around the site of each works. This should include the identification of sites of historic or

archaeological interest (A1 and A3 receptors) and any unidentified anomalies larger than 5m in

diameter (A2 receptors), which may require the refinement, removal or introduction of archaeological

exclusion zones and to confirm project specific micrositing requirements (for A2 receptors)”, English

Heritage’s concerns regarding including seabed anomalies or sites of historic or archaeological interest

in the survey conditions have been addressed (Appendix 1).

3.2 Issues unresolved

3.2.1 There are no issues unresolved between Forewind and English Heritage regarding marine archaeology.



4 Historic Seascape Character

4.1 Matters of Specific Agreement

4.1.1 The following statements are the key accepted positions between Forewind and English Heritage, in

relation to Historic Seascape Character:

A. Overall

4-A-1: It is accepted that the legislation and guidance documents listed in section 2.2 of Chapter 20 of

the ES Seascape and Visual Character (ref 6.20) are the principal documents of relevance for

the assessment of impacts of Dogger Bank Creyke Beck on Seascape and Visual Character.

4-A-2: It is accepted that the impact assessment methodology is appropriate for adequate assessment

of impacts on historic seascape character, as presented in section 3 of Chapter 20 of the ES (ref

6.20).

4-A-3: It is accepted that paragraphs 3.3.7 and 3.3.8 and figure 3.2 in Chapter 20 of the ES (ref

6.20) provide an accurate description of the baseline historic seascape character relevant to

Dogger Bank Creyke Beck.

4-A-3: It is accepted that impacts associated with Dogger Bank Creyke Beck on historic seascape

character are not expected to be significant (minor adverse or below), as assessed in sections 6

and 7 of Chapter 20 of the ES (ref 6.20).

4-A-4: It is accepted that concerns raised within English Heritage’s relevant representation (Appendix

1) regarding Historic Seascape Character have been addressed by clarifications in Appendix 2

and Appendix 3.

4.2 Issues unresolved

4.2.1 There are no issues unresolved between Forewind and English Heritage regarding historic seascape character.



6 Appendices

List of attached appendices:

Appendix 1 – English Heritage relevant representation submitted to the Planning Inspectorate on 8

November 2013 in relation to the Dogger Bank Creyke Beck final application; and

Appendix 2 – Forewind response to the English Heritage relevant representation.

Appendix 3 – Historic Seascape Character clarification note



Appendix 1 – English Heritage relevant representation submitted to the Planning Inspectorate on 8 November 2013 in relation to the Dogger Bank Creyke Beck final application

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CREYKE BECK RELEVANT REPRESENTATION

Relevant Representation Number 56

Date 8 November 2013

Stakeholder Name

Stakeholder Group English Heritage

Relevant Representation

English Heritage is the Government’s advisor on all aspects of the historic environment in England – including historic buildings and areas, archaeology and the historic landscape – and has a duty to promote public understanding and enjoyment. 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. Our remit in conservation matters intersects with the policy responsibilities of a number of other government departments – particularly the CLG, with its responsibilities for land-use planning matters. The National Heritage Act (2002) enabled English Heritage to assume responsibility for maritime archaeology in the English area of the UK Territorial Sea. However, we are aware that part of the export cable and the proposed arrays are located in the UK marine area adjacent to England and therefore any comment we offer is given without prejudice to our responsibilities under the aforementioned Act. We understand that the proposed development comprises two offshore turbine arrays (Dogger Bank Creyke A and Dogger Bank Creyke B) and associated array cables, collector stations and converter stations located within Tranche A (Dogger Bank Round 3 Offshore Wind Farm Zone); and an offshore export cable corridor to a proposed landfall location on the Holderness coast (Yorkshire). Comments on the Environmental Statement: Chapter 18 Marine and Coastal Archaeology Paragraphs 4.3.27, 4.3.28 and Table 4.7 – we noted the detail provided regarding the identification of A1 anomalies within Creyke Beck A and B and the export cable corridor route and we concur with the principle that the precautionary principle is applicable and that each should be considered of high archaeological value. Paragraph 4.3.38 – we also acknowledge the summary detail provided in this paragraph regarding potential interest in different maritime receptors (prehistoric and historic) as may be present within the Creyke Beck A and B development areas (inclusive of export electricity cable). Figures 4.6, 4.7a, 4.7b, 4.7c, 4.7d – These figures provided useful detail to indicate the locations of all recorded wrecks, documented losses, UKHO records and geophysical anomalies; this information should be directly applied to the detail of any draft scheme specific archaeological Written Schemes of Investigation that are produced to ensure AEZ's are located correctly prior to any construction phase.

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Section 4.4 – In our response to the draft Environmental Statement (ES) we requested that details must be brought forward from the relevant section of the archaeological technical report (Appendix A). We therefore must stress the important that this section of the ES should provide indicative records derived from reports of aircraft losses attributed to this area. It is therefore relevant that any discussion with the ES regarding the historic “value” of aircraft crash sites must first establish the potential to encounter such sites. Section 4.5 (Historic Seascape Character) – We understand that Historic Seascape Character (HSC) spatial data used for this section of the ES was derived from pilot HSC project for the area between Scarborough and Hartlepool; although the methodological approach derived from this pilot project is now being applied nationally. However, the brief analysis presented in paragraph 4.5.3 appears to be contradictory. The text suggests that primary historic character of the area is perceived to be associated with the “fishing industry”, but the paragraph concludes that the “current” character is “dominated by dense industrial and shipping activity” and therefore tolerant to change as envisaged by this proposed development. It therefore appears that the historic character type as described by the HSC spatial data has been disregarded in preference to considering change only in reference to “current” character. Paragraph 4.5.5 – The use of the term “seascape” in this paragraph should have been clearly explained in reference to how it is used within Chapter 18 and Chapter 20 and any differences in interpretation of terminology as relevant to the historic environment. Section 5 (Assessment of Impacts – worst case definition) – the detail of this section seemed to be focused on consideration of the construction scenarios i.e. the phasing of construction of Creyke Beck A and B and we noted the assumption that both projects are considered to have the same impact (on coastal and marine archaeological receptors) whether constructed concurrently or separately. Table 5.1 – In our response to the draft ES we stated that within this table in the row “seabed preparation” any reference to “Shallow excavation to smooth out seabed…” should include detail about the actual depth of seabed penetration to qualify the use of the term “shallow”. We note in the column “Worst case (per project)” that average excavation depth of 0.75m, but no explanation is provided about what this average depth of excavation could be attributed to; for example, is it relevant to cable burial or conical gravity base foundations etc? We consider it very important that the ES should have provided clarity about actual depth of seabed preparation and penetration, and not just estimated footprint area for any anticipated foundation design that could be employed by this project. We consider this matter relevant to any assessment that is conducted in reference to Rochdale Envelope principles. In our response to the draft ES we stated that in the Row “Wind turbine layout and spacing” we drew attention to the use of the term “coincident” and we note that the text now refers to the final layout corresponding with positions of known receptors. It remains that case that figures are or will be required to illustrate the spatial extent of the different turbine foundation designs and any direct or indirect impact on archaeological receptors. In row “Installation of foundations” we appreciate the detail provided regarding the proposed installation process, but information must be provided regarding anticipated seabed penetration required for successful installation. We consider this information should be available as estimates are provided regarding the jack-up vessel spud leg penetration to 26.4 metres. Paragraph 6.2.18 – We noted reference to EN-1 policy and how any work to advance understanding of a heritage asset, that cannot remain in-situ, is to be conducted in accordance with an archaeological Written Scheme of Investigation (WSI) agreed with the MMO and English Heritage “…if in English Waters”. It is essential that Forewind provide a

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clear explanation about what are considered to be “English Waters”. We understand that the proposed Creyke Beck A and B turbine array areas and part of the electricity export cable are to be located within the UK marine area (as defined by Marine and Coastal Access Act 2009) adjacent to the 12 nautical mile limit of the English area of the UK Territorial Sea. It is also understood for marine planning purposes, as provided through the 2009 Act, that the UK marine area adjacent to England (not subject to the authority of any Devolved Administration) is considered to be part of the English offshore planning area. Therefore it must made clear to all parties that any and all relevant archaeological WSIs for this proposed project are to be agreed with the MMO and English Heritage wherever located. Paragraph 6.2.20 – We noted reference to the production of a “high level WSI” and we confirm that we have previously acknowledge receipt of Dogger Bank Round 3 Zone: 2010 Geotechnical Site Investigations - Archaeological Written Scheme of Investigation prepared by EMU Ltd (Ref: J/1/26/1733, dated 21/9/10), which was designed to only address geo-archaeological investigations. We have considered the detail of the high level archaeological WSI provided in Appendix 18b and we appreciate that the approach adopted for an overall WSI to be produced for the purposes of examination that considers the entire project and the different ways in which it could be delivered as described by the ES. However, for the purposes of the Development Consent Order (including Deemed Marine Licences) we require specific condition to ensure that the following commitment stated in paragraph 1.1.11 is delivered: “Scheme specific WSIs will be produced for each of the Dogger Bank Creyke Beck projects once the scheme design has been finalised. The scheme specific WSIs will detail the specific packages of archaeological works that have been agreed. Individual method statements for each package of works will be produced to detail the nature of archaeological works to be carried out…” We will therefore provide the necessary advice to inform the preparation of all archaeological WSIs required for this proposed project to ensure matters such as “Responsibilities and Communication” contain the correct contact details. We also noted the attention given in the “high level” WSI appendix to HSC (section 3.6), but that no methodological approach was explained to how this matter will be addressed by the WSI. We therefore must conclude that this is a specific matter to be addressed by the scheme specific WSIs to be produced in agreement with the MMO. Figures 6.1a, 6.1b, 6.1c, 6.1d and 6.2 – we noted the illustrations provided regarding the proposed Archaeological Exclusion Zones (AEZs) for this project as described in the accompanying text of the ES (i.e. the spatial extent of the proposed AEZs). We also acknowledge the attention directed to the identification and locations of A2 anomalies to be avoided in design layout. It is relevant to add that such provision must be adequately reflected in the detail of the draft Development Consent Order (including deemed Marine Licences). Section 7.4 (Creyke Beck development areas) – we noted that no detail seems to be provided about depth of seabed preparation to support installation of the different foundation designs proposed for this project. Section 7.4 (Historic Seascape Character) – the text states that there will be “no change to the current character” and therefore it is not explicitly clear that this assessment has been conducted in reference to Historic Seascape Character type and we cannot offer any further comment. Section 10.5 (Cumulative effect on the archaeological resource) – We noted the attention directed at action to identify, agree and implement AEZs and the identification of risks

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associated with encountering previously unknown features of archaeological or historic interest. We also noted the attention given in paragraph 10.5.9 to the National Planning Policy Framework and the UK Marine Policy Statement regarding dissemination and publication of archaeological information and we must also direct your attention to similar provisions within National Policy Statements for Renewable Energy Infrastructure (EN-3). Section 12 (Summary) – This section contained important detail about the relevance of on-going marine geophysical and geotechnical survey work to inform delivery of this proposed development. Please note that to support this objective we will provide advice that the deemed Marine Licence and the WSIs are capable of identifying these data for acquisition, analysis/interpretation and reporting. Chapter 21b Seascape and Visual Character We noted the statements made in this chapter, in reference to HSC, to limited sensitivity due to “low heritage value”. However this term does not appear to be defined or otherwise qualified. Therefore in reference to the response we made to the draft ES that the introduction of the wind farms will alter the character of the historic seascape (at surface level) to “Renewable energy installation” and that the methodological approach to be addressed in any relevant scheme specific WSI will determine the relative sensitivity of historic character when describing how change is accommodated. Chapter 27 Onshore Cultural Heritage The remit of English Heritage is related to the conservation and management of nationally important heritage assets, English Heritage also provides heritage advice to local authority officers. In this respect we would look to support the aims and objectives of other heritage specialists such as Conservation Officers and Historic Environment Record staff who might be involved in the mitigation of the impacts of the proposal. This should be borne in mind when considering our comments below. In general terms the documentation currently supplied and the measures suggested to mitigate the impact of the proposal on the significance of cultural heritage assets are acceptable to English Heritage, although we are disappointed to note that our observations concerning the methodology underpinning the ‘Definition of terms relating to the significance of cultural heritage receptors’ (Table 3.1) in the ES has been ignored (our letter of 28th May 2013). This has several implications: • Table 3.1 remains inaccurate. Grade II buildings are nationally important and therefore not of ‘Medium significance’, and also not comparable with ‘Locally listed buildings’. • The suggested requirement for the definition of terms in Table 3.1 has not been undertaken. As stated in our letter, we do not agree that some assets have ‘no historic, evidential, aesthetic or communal interest’. All places are of value to someone, and the text should use the word ‘value’ (not ‘interest’) to keep it consistent with the National Planning Policy Framework (NPPF); and • If the methodology is faulty, it is possible that the impacts of the proposal on the significance of heritage assets have not been correctly evaluated. Draft Development Consent Order: Schedule 7 Deemed marine licences under the Marine and Coastal Access Act 2009 – Parts 1B and 2B We require amendment of Condition 9(g) as follows: “A written scheme of archaeological

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investigation in relation to the Order limits in accordance with the high level written scheme of investigation, industry good practice and in agreement with English Heritage to include – “ This amendment is important in reference to Condition 10(1) that requires, among other things, the agreement with the MMO of any protocol or scheme at least four months prior to the intended start date of construction. We require amendment of Condition 13(1)(b) to add the following: “…and inclusive of seabed anomalies or sites of historic or archaeological interest that lie within that 500m buffer;” Draft Development Consent Order: Schedule 7 Deemed marine licences under the Marine and Coastal Access Act 2009 – Parts 3B and 4B We require amendment of Condition 6(f) as follows: “A written scheme of archaeological investigation in relation to the Order limits in accordance with the high level written scheme of investigation, industry good practice and in agreement with English Heritage to include – “ This amendment is important in reference to Condition 7(1) that requires, among other things, the agreement with the MMO of any protocol or scheme at least four months prior to the intended start date of construction. We require amendment of Condition 10(2)(b) to add the following: “…and inclusive of seabed anomalies or sites of historic or archaeological interest that lie within that 500m buffer;”



Appendix 2 – Forewind response to the English Heritage relevant representation


© 2013 Forewind Page i

December 2013

Appendix 2 – Forewind response to English Heritage relevant representation


Page 3 © 2013 Forewind

1 Forewind Response

N.B – English Heritage’s comments from their relevant representation (8 November 2013) are cited in bold, Forewind’s responses are provided in italics beneath each point.

1.1.1 English Heritage is the Government’s advisor on all aspects of the historic environment in

England – including historic buildings and areas, archaeology and the historic landscape – and

has a duty to promote public understanding and enjoyment. 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. Our remit in conservation matters intersects with the policy responsibilities of a number

of other government departments – particularly the CLG, with its responsibilities for land-use

planning matters. The National Heritage Act (2002) enabled English Heritage to assume

responsibility for maritime archaeology in the English area of the UK Territorial Sea. However,

we are aware that part of the export cable and the proposed arrays are located in the UK marine

area adjacent to England and therefore any comment we offer is given without prejudice to our

responsibilities under the aforementioned Act.

1.1.2 Noted

1.1.3 We understand that the proposed development comprises two offshore turbine arrays (Dogger

Bank Creyke A and Dogger Bank Creyke B) and associated array cables, collector stations and

converter stations located within Tranche A (Dogger Bank Round 3 Offshore Wind Farm Zone);

and an offshore export cable corridor to a proposed landfall location on the Holderness coast

(Yorkshire).

1.1.4 Noted

Comments on the Environmental Statement:

Chapter 18 Marine and Coastal Archaeology

1.1.5 Paragraphs 4.3.27, 4.3.28 and Table 4.7 – we noted the detail provided regarding the

identification of A1 anomalies within Creyke Beck A and B and the export cable corridor route

and we concur with the principle that the precautionary principle is applicable and that each

should be considered of high archaeological value.

1.1.6 Noted

1.1.7 Paragraph 4.3.38 – we also acknowledge the summary detail provided in this paragraph

regarding potential interest in different maritime receptors (prehistoric and historic) as may be

present within the Creyke Beck A and B development areas (inclusive of export electricity

cable).

1.1.8 Noted

1.1.9 Figures 4.6, 4.7a, 4.7b, 4.7c, 4.7d – These figures provided useful detail to indicate the locations

of all recorded wrecks, documented losses, UKHO records and geophysical anomalies; this

information should be directly applied to the detail of any draft scheme specific archaeological

Written Schemes of Investigation that are produced to ensure AEZ's are located correctly prior

to any construction phase.

1.1.10 Forewind acknowledge that this data will be used in developing the Written Schemes of Investigation,



as requested by English Heritage.

1.1.11 Section 4.4 – In our response to the draft Environmental Statement (ES) we requested that

details must be brought forward from the relevant section of the archaeological technical

report (Appendix A). We therefore must stress the important that this section of the ES should

provide indicative records derived from reports of aircraft losses attributed to this area. It is

therefore relevant that any discussion with the ES regarding the historic “value” of aircraft

crash sites must first establish the potential to encounter such sites.

1.1.12 The ES Chapter is intended to provide a summary of the detail provided in the technical appendices.

Forewind considers the content of the chapter to be sufficient in terms of establishing the presence

(known or otherwise) and potential value of features of archaeological and cultural heritage interest, in

order to guide the reader through subsequent sections, to the overall conclusions on impact

significance. Section 4.4 acknowledges that there is potential to encounter as yet unobserved aircraft

remains anywhere in the study area and assigns value and potential impact significance appropriately

on this basis.

Forewind understands that English Heritage may wish to see more detail in the ES Chapter, but

maintains the position that this detail is presented in the full technical report and that its location is

clearly signposted. Forewind does not believe that increasing the length of the chapter to provide

additional detail, as requested, would alter the findings of the impact assessment.

1.1.13 Section 4.5 (Historic Seascape Character) – We understand that Historic Seascape Character

(HSC) spatial data used for this section of the ES was derived from pilot HSC project for the

area between Scarborough and Hartlepool; although the methodological approach derived

from this pilot project is now being applied nationally. However, the brief analysis presented in

paragraph 4.5.3 appears to be contradictory. The text suggests that primary historic character

of the area is perceived to be associated with the “fishing industry”, but the paragraph

concludes that the “current” character is “dominated by dense industrial and shipping activity”

and therefore tolerant to change as envisaged by this proposed development. It therefore

appears that the historic character type as described by the HSC spatial data has been

disregarded in preference to considering change only in reference to “current” character.

1.1.14 The Dogger Bank irrefutably has strong practical and emotive connections with the fishing industry.

However, the cultural character of the Creyke Beck marine study areas (MSAs) (according to the

Scarborough to Hartlepool pilot) has been shaped by all four of the following:

• Communications: telecommunications;

• Navigation: navigation hazard (wrecks and obstructions) and navigation area/route;

• Fishing and mariculture: fishery (beam trawling), fishery (hazardous foul ground), fishery

(netting and lining) and fishery (seine netting); and

• Industry: extractive industry (hydrocarbon).

As Forewind is assessing the HSC’s sensitivity to the installation of a new element of offshore wind in

terms of the MSAs ability to accommodate change, this necessarily entails the consideration of the

current character – and how this has been formed by historic processes.

Thus, while in popular imagination the fishing industry is a primary cultural value associated with

Dogger Bank, the HSC of Creyke Beck MSAs have, in practice, been formed by the fishing industry

together with high levels of navigation, communications and industry.

Installation of cables will thus result in no change (because the MSAs already include cables) and

while the installation of wind turbines will introduce a new element into the HSC, the dense industrial

and shipping activity (including the fishing industry on a vastly different scale to that encountered in the



past) is considered to be tolerant to change and able to adapt to accommodate elements associated

with offshore renewables. This is particularly the case given that the installation is temporary and the

HSC will have recoverability following decommissioning.

1.1.15 Paragraph 4.5.5 – The use of the term “seascape” in this paragraph should have been clearly

explained in reference to how it is used within Chapter 18 and Chapter 20 and any differences

in interpretation of terminology as relevant to the historic environment.

1.1.16 The ‘seascape’ assessed in Chapter 20 is to do with visual impact and setting, not ‘historic seascape

character’. The two have been confused previously but there is now greater clarity from English

Heritage about how the two differ and this sentence is perhaps erroneous here. The two are

nonetheless assessed separately within the ES as is demonstrated by Paragraph 4.6 (Setting).

1.1.17 Section 5 (Assessment of Impacts – worst case definition) – the detail of this section seemed to

be focused on consideration of the construction scenarios i.e. the phasing of construction of

Creyke Beck A and B and we noted the assumption that both projects are considered to have

the same impact (on coastal and marine archaeological receptors) whether constructed

concurrently or separately.

1.1.18 Noted

1.1.19 Table 5.1 – In our response to the draft ES we stated that within this table in the row “seabed

preparation” any reference to “Shallow excavation to smooth out seabed…” should include

detail about the actual depth of seabed penetration to qualify the use of the term “shallow”. We

note in the column “Worst case (per project)” that average excavation depth of 0.75m, but no

explanation is provided about what this average depth of excavation could be attributed to; for

example, is it relevant to cable burial or conical gravity base foundations etc?

1.1.20 Forewind believes that the cell referred to clearly states that the numbers provided are related to the

installation of foundations and ancillary infrastructure. There is no mention of cables in the cell. Cable

installation is covered in a subsequent cell, which states a maximum burial depth of 3.0m.

1.1.21 We consider it very important that the ES should have provided clarity about actual depth of

seabed preparation and penetration, and not just estimated footprint area for any anticipated

foundation design that could be employed by this project. We consider this matter relevant to

any assessment that is conducted in reference to Rochdale Envelope principles.

1.1.22 Forewind acknowledges that English Heritage consider clarity about actual depth of sediment

preparation and penetration to be important. However, Forewind believes that it has provided a

realistic, but suitably precautionary assessment within the ES. As stated in paragraph 3.5.6 of Chapter

5 Project Description, the seabed conditions within Dogger Bank Creyke Beck are such that only

limited seabed preparation is anticipated. Detail of actual depths is not possible until the detailed

design of the projects takes place. However, Forewind considers 0.75m to be a realistic, yet

precautionary average that can be applied to inform the assessment. As acknowledged in the ES, the

depth of preparation may exceed this depth in areas of sandwaves, but these are not anticipated to be

frequently encountered. Forewind does not believe that the outcomes of the impact assessment would

be affected by an attempt to provide additional clarity on seabed penetration depths. The potential risk

to features of archaeological and/or cultural heritage interest have been assessed appropriately and in

accordance with relevant guidance.

1.1.23 In our response to the draft ES we stated that in the Row “Wind turbine layout and spacing” we

drew attention to the use of the term “coincident” and we note that the text now refers to the

final layout corresponding with positions of known receptors. It remains that case that figures

are or will be required to illustrate the spatial extent of the different turbine foundation designs



and any direct or indirect impact on archaeological receptors.

1.1.24 Noted – No action necessary.

1.1.25 In row “Installation of foundations” we appreciate the detail provided regarding the proposed

installation process, but information must be provided regarding anticipated seabed

penetration required for successful installation. We consider this information should be

available as estimates are provided regarding the jack-up vessel spud leg penetration to 26.4

metres.

1.1.26 As stated in paragraph 12.3.14 of Appendix A to Chapter 18 Marine and Coastal Archaeology (ref

6.18.1), the leg penetration depth is a very conservative worst case scenario and would vary

depending on local seabed conditions. With respect to penetration depths for monopile foundations,

from experience on other wind farm installations, indicative penetration depths could be expected to be

in the order of 40-55m. However, Forewind would like to emphasise that geological conditions are

highly site specific and as such these values may differ for Dogger Bank Creyke Beck. In addition,

there has been little practical experience with monopile foundations for 6MW+ turbines, as such little

field data exists and design approaches may vary.

1.1.27 Paragraph 6.2.18 – We noted reference to EN-1 policy and how any work to advance

understanding of a heritage asset, that cannot remain in-situ, is to be conducted in accordance

with an archaeological Written Scheme of Investigation (WSI) agreed with the MMO and English

Heritage “…if in English Waters”. It is essential that Forewind provide a clear explanation about

what are considered to be “English Waters”. We understand that the proposed Creyke Beck A

and B turbine array areas and part of the electricity export cable are to be located within the UK

marine area (as defined by Marine and Coastal Access Act 2009) adjacent to the 12 nautical

mile limit of the English area of the UK Territorial Sea. It is also understood for marine planning

purposes, as provided through the 2009 Act, that the UK marine area adjacent to England (not

subject to the authority of any Devolved Administration) is considered to be part of the English

offshore planning area. Therefore it must made clear to all parties that any and all relevant

archaeological WSIs for this proposed project are to be agreed with the MMO and English

Heritage wherever located.

1.1.28 Acknowledged, Forewind confirm they are happy for the archaeological WSIs to be agreed with the

MMO and English Heritage.

1.1.29 Paragraph 6.2.20 – We noted reference to the production of a “high level WSI” and we confirm

that we have previously acknowledge receipt of Dogger Bank Round 3 Zone: 2010

Geotechnical Site Investigations - Archaeological Written Scheme of Investigation prepared by

EMU Ltd (Ref: J/1/26/1733, dated 21/9/10), which was designed to only address geo-

archaeological investigations. We have considered the detail of the high level archaeological

WSI provided in Appendix 18b and we appreciate that the approach adopted for an overall WSI

to be produced for the purposes of examination that considers the entire project and the

different ways in which it could be delivered as described by the ES. However, for the purposes

of the Development Consent Order (including Deemed Marine Licences) we require specific

condition to ensure that the following commitment stated in paragraph 1.1.11 is delivered:

“Scheme specific WSIs will be produced for each of the Dogger Bank Creyke Beck projects

once the scheme design has been finalised. The scheme specific WSIs will detail the specific

packages of archaeological works that have been agreed. Individual method statements for

each package of works will be produced to detail the nature of archaeological works to be

carried out…”



1.1.30 This commitment has been included in the draft Marine Licence - Reference DML 1&2 Condition

9(1)(g) and DML 3&4 Condition 6 (1)(f) (ref 3.1).

1.1.31 We will therefore provide the necessary advice to inform the preparation of all archaeological

WSIs required for this proposed project to ensure matters such as “Responsibilities and

Communication” contain the correct contact details. We also noted the attention given in the

“high level” WSI appendix to HSC (section 3.6), but that no methodological approach was

explained to how this matter will be addressed by the WSI. We therefore must conclude that

this is a specific matter to be addressed by the scheme specific WSIs to be produced in

agreement with the MMO.

1.1.32 HSC is included in 3.6 of the WSI as part of the baseline summary and section 5.3 of the WSI

reiterates the conclusions of the HSC assessment in the ES that impacts to the HSC will be minor.

Hence no mitigation is required and requires no further comment in the WSI; high level or scheme

specific.

1.1.33 Figures 6.1a, 6.1b, 6.1c, 6.1d and 6.2 – we noted the illustrations provided regarding the

proposed Archaeological Exclusion Zones (AEZs) for this project as described in the

accompanying text of the ES (i.e. the spatial extent of the proposed AEZs). We also

acknowledge the attention directed to the identification and locations of A2 anomalies to be

avoided in design layout. It is relevant to add that such provision must be adequately reflected

in the detail of the draft Development Consent Order (including deemed Marine Licences).

1.1.34 Noted

1.1.35 Section 7.4 (Creyke Beck development areas) – we noted that no detail seems to be provided

about depth of seabed preparation to support installation of the different foundation designs

proposed for this project.

1.1.36 Forewind has provided further detail on the depths with respect to seabed preparation within the final

application (see Table 13 of Appendix A to Chapter 18 of the ES (ref 6.18.1)), as requested by English

Heritage during the final stage of statutory consultation. This is based on indicative excavated volumes

and the associated area required for seabed preparation, which are then used to give an indicative

average excavation depth. The actual depth may vary across each location as seabed features and

sandwaves may be encountered. A value has been provided for a worst case of 300 x 4MW wind

turbine gravity base foundation installations per project. Seabed preparation would most commonly be

required for gravity base solutions and other foundation designs would only rarely be expected to

require seabed preparation.

1.1.37 Section 7.4 (Historic Seascape Character) – the text states that there will be “no change to the

current character” and therefore it is not explicitly clear that this assessment has been

conducted in reference to Historic Seascape Character type and we cannot offer any further

comment.

1.1.38 In Section 7.5 the text states that installing new cables will result in no change to the HSC, as there are

already cables present. It recognises that the wind turbines and ancillary structures will result in a

change but that this change is considered moderate, when considered on a spatial scale across

Dogger Bank and the North Sea, and the significance of the effect of this change is thus considered

minor adverse. Note that the HSC includes telecommunications, navigation and industry as well as

fishing.

It perhaps should also be underlined that ‘current’ character refers to the Historic Seascape Character

as it is today having been formed by historic processes (telecommunications, navigation, fishing and

industry). This is the Historic Seascape Character to which the impact is occurring.



1.1.39 Section 10.5 (Cumulative effect on the archaeological resource) – We noted the attention

directed at action to identify, agree and implement AEZs and the identification of risks

associated with encountering previously unknown features of archaeological or historic

interest. We also noted the attention given in paragraph 10.5.9 to the National Planning Policy

Framework and the UK Marine Policy Statement regarding dissemination and publication of

archaeological information and we must also direct your attention to similar provisions within

National Policy Statements for Renewable Energy Infrastructure (EN-3).


1.1.41 Section 12 (Summary) – This section contained important detail about the relevance of on-

going marine geophysical and geotechnical survey work to inform delivery of this proposed

development. Please note that to support this objective we will provide advice that the deemed

Marine Licence and the WSIs are capable of identifying these data for acquisition,

analysis/interpretation and reporting.


Chapter 21b Seascape and Visual Character

1.1.43 We noted the statements made in this chapter, in reference to HSC, to limited sensitivity due to

“low heritage value”. However this term does not appear to be defined or otherwise qualified.

Therefore in reference to the response we made to the draft ES that the introduction of the wind

farms will alter the character of the historic seascape (at surface level) to “Renewable energy

installation” and that the methodological approach to be addressed in any relevant scheme

specific WSI will determine the relative sensitivity of historic character when describing how

change is accommodated.

1.1.44 Chapter 21b addresses the surface HSC only in terms of visual impact which concludes that the

introduction of an offshore windfarm would not result in a significant impact. Thus no mitigation is

required and this issue is not relevant to discussion within a WSI.



Appendix 3 – Historic Seascape Character clarification note

February 2014

Appendix 3 – Historic Seascape Characterisation Note



1 Historic Seascape Characterisation

1.1 Dogger Bank Creyke Beck Offshore Wind Farm

1.1.1 An assessment of the potential impact of the construction, operation and decommissioning of the

Dogger Bank Creyke Beck offshore wind farm to Historic Seascape Character (HSC) was presented in

Chapter 18 (Marine and Coastal Archaeology) and Chapter 18 Appendix A (Archaeology and Cultural

History Technical Report) of the Environmental Statement submitted to the Planning Inspectorate in

August 2013. This assessment was in isolation from the assessment of visual impact from the

development set out in Chapter 21 of the Environmental Statement (Landscape, Seascape and Visual

Character).

1.1.2 English Heritage submitted a relevant representation on 8th November 2013 which included comment

on this assessment and the approach was further discussed in a meeting with English Heritage on 19th

December 2013. This note provides further details to English Heritage on the HSC of the development

area in consideration of these comments and the subsequent clarifications supplied to Wessex

Archaeology and Forewind at the meeting.

1.1.3 The Creyke Beck A and B project areas and the export cable corridor fall within the pilot HSC from

Scarborough to Hartlepool undertaken by Cornwall County Council in 20071. It is noted that the

methodology applied to HSC in this pilot study is now being applied nationally.

1.1.4 Using the GIS data from the pilot project the HSC of the Dogger Bank Creyke Beck project areas is as

follows:

1.1.5 Dogger Bank Creyke Beck A:

Seabed:

o Coarse sediment plains (predominantly gravel);

o Fine sediment plains (predominantly sand);

o Offshore Installation (wellhead);

o Pipeline (submarine/on land); and

o Submarine Cable.

Seafloor:



o Fishery (Beam Trawling);



o Submarine Cable.

Water Column:

o Fishery (Netting and Lining);

o Fishery (Seine Netting); and

o Offshore Installation (wellhead).

Surface:




1 Val Baker, M. V. Tapper, B. Johns, C. and Herring, P. 2007. England’s Historic Seascapes, Scarborough to Hartlepool and

Adjacent Maritime Zone. English Heritage ref: 2007R021.



1.1.6 Dogger Bank Creyke Beck B:

Seabed:



o Obstruction (Foul Area);

o Offshore Installation (wellhead); and

o Pipeline (submarine/on land).

Seafloor:




o Fishery (Hazardous Foul Ground);

o Obstruction (Foul Area);

o Offshore Installation (wellhead); and

o Pipeline (submarine/on land).

Water Column:


o Fishery (Seine Netting);

o Obstruction (Foul Area); and


Surface:



o Fishery (Seine Netting);

o Obstruction (Foul Area); and


1.1.7 Dogger Bank Creyke Beck Export Cable Corridor:

Seabed:





o Submarine Cable.

Seafloor:






o Pipeline (submarine/on land);

o Submarine Cable; and

o Wreck (cluster).

Water Column:

o Fishery (Netting and Lining); and

o Fishery (Seine Netting).

Surface:

o Ferry Route;







1.1.8 In addition to the above, the GIS also shows the development coinciding with four ‘character areas’ as

defined by the HSC pilot:

Dogger Bank2:

The Dogger Bank is a very large shoal area in the central southern North Sea, with water depths less

than 30m. It is shallowest in the south-west where depths are only 10-15m and areas of natural swell are

common.

From at least the medieval period long line demersal fisheries have centred on and around the Dogger

Bank with craft sailing from Scarborough, Staithes, Robin Hood’s Bay, Flamborough and Runswick

taking cod, ling and haddock. From the late 19th century the area has been extensive trawled, for

demersals and flat fish.

Modern fishing methods have greatly reduced many fish stocks to the point of extinction. Herring is no

longer abundant in the North Sea; massive catches in the 1940s and 1950s took their toll and depleted

stocks fell to a dangerously low level. If, as a result of bans and restrictions on fishing, the North Sea

herring does recover it would require strict international legislation and the reintroduction of traditional

methods of fishing to prevent them being decimated again. Restrictions on cod and plaice have caused

the displacement of fishing activity away from traditional grounds and towards the oil and gas fields of

the North Sea.

Further offshore wrecks become increasingly dispersed although clusters occur in some areas over foul

grounds and off the Dogger Bank in particular.

The Bank comprises Devensian pro-glacial lake deposits and glacial moraine, mostly patches of gravel

and formations of calcareous sands with peat infilling glacial depressions; all overlying Pleistocene

sediments. The top of the peat is dated to 8140±50BP at -31.06m OD (Shennan et al 2000, 3033).

Across the central and southern North Sea there is submerged archaeological potential for Pleistocene

flora and faunal remains. Early or Lower Palaeolithic potential is minimal but there is greater likelihood of

Middle and Later or Upper Palaeolithic remains (including mammoth and rhinoceros teeth). Holocene

deposits may hold Mesolithic archaeological potential, both in situ and in secondary contexts (Figure

10.27). Many human artefacts, mammal remains and peat deposits have also been dredged and

reported from locations reported as The Dogger Bank. However beyond the general location of these

areas, little is known about their stratigraphic context or spatial patterning. The Dogger Bank was

isolated and inundated by c5500BC and after that the archaeological potential is purely maritime.

The Doggerland landscape represented a living space rather than merely a ‘landbridge’ connecting

Britain to mainland Europe (Coles 1998; 19994). In many ways the topography of the Danish archipelago

is analogous with the low relief of the central North Sea. It is possible to envisage the rising sea

penetrating river valleys, inlets and creeks into marshes, and separating low islands only 30m high in

places (Flemming 2004, 185). The variation in rate of sea-level rise, standstill and fall combined with local

topography, meant that land loss probably occurred in fits and starts. Deeply incised Pleistocene river

2 val Baker et al 2007, 287-290

3 Shennan, I and Andrews, J (eds), 2000. Holocene Land-Ocean Interaction and Environmental

Change around the North Sea. Geological Society, London, Special Publications, 166,

299-319. 1-86239-054-1/00.

4 Coles, BJ, 1998. Doggerland: a Speculative Survey, Proc Prehist Soc 64, 45-81.

5 Flemming, N C (ed), 2004 Submarine prehistoric archaeology of the North Sea: Research priorities

and collaboration with industry, CBA Research Report 141, English Heritage/Council

for British Archaeology



valleys would have gradually infilled with no perceptible change for decades or even centuries during the

early Holocene. However these periods of minimal change may have occasionally been followed by

periods of continual change, or dramatic change.

Today the submerged landscapes of the North Sea offer tantalising glimpses of a drowned culture, lost

and somewhat mysterious yet full of potential for further understanding, a link to a period before Britain

became an island, but one not widely known to public perception.

In recent times this area of the central North Sea will be recognised as being covered by BBC Radio 4’s

Shipping Forecast, for the sea areas ‘Tyne’ and ‘Dogger’ and the Inshore Waters forecasts for ‘Berwick

on Tweed to Whitby’ and ‘Whitby to The Wash’. The Shipping Forecast is provided by the UK

Meteorological Office on behalf of the Maritime and Coastguard Agency. It is broadcast four times a day

and consists of reports and forecasts of weather for the seas around Britain. Its unique, distinctive name

means it has a wide iconic appeal even to those not solely interested in nautical weather.

Some will always associate Dogger Bank with the First World War naval battle. Similarly Dogger Bank

may be remembered as the site of the UK’s strongest earthquake measuring 6.1 on the Richter scale.

Taking place on 7th June 1931 its epicentre was on the Bank, about 60 miles (96.6km) from the coast of

England and its effects were reported throughout Britain and even in Belgium and France.

There are two principal cables routes that pass through the study area. One set (PANGEA1) run from

the foreshore between Redcar and Marske and follow a northeasterly route to Denmark. Another set

(UK-GER6 and TGNNEUROPE) run out from Filey before sweeping north into the central part of the

area before separating, one continuing towards Denmark, the other veering east over the Dogger Bank

to Germany. Two redundant cables are recording lying in Cayton Bay.

Dogger Flanks6:

The Dogger Flanks skirt the Dogger Bank, encompassing the area between the 20-50m contours. This

area is likely to offer considerable archaeological potential, relative to the top of the Bank itself, and

prehistoric sites may survive with sufficient integrity to provide evidence for settlement patterns, flint

working sites and fish weirs together with palaeoenvironmental evidence such as peat deposits and

submerged forests remains.

While artefacts and archaeological deposits left on the upper surface of Dogger Bank are likely to be

exposed by present currents and wave action (very severe, breaking waves in 10m) it is probable that

there are far more relicts originally abandoned on the shore of this shallow sea in the area now at a

depth of about 40m. The rising sea would have had very little destructive force until the water was tens

of metres deep, and strong tidal currents were developing. Whitehead and Goodchild (1909) describe

the recovery of peat deposits or ‘moorlog’ by fishermen, especially on the north side of the basin, on the

flanks of Dogger Bank itself (Flemming 2002, 337).

Whitby – Hartlepool Ground8:

This character area covers the deeper offshore waters between the coast and the Dogger Bank, the area

of deepest water in the HSC study area.

During the medieval period the area comprised internationally important fishing grounds particularly for

herring and cod, respectively caught by nets and long lines. The fishing communities perched and

tucked away on this coast traditionally farmed inshore waters: trapping for salmon, potting for shellfish

6 val Baker et al 2007, 286-287

7 Flemming, NC, 2002. Dept. Trade and Industry. The scope of Strategic Environmental

Assessment of North Sea areas SEA3 and SEA2 in regard to prehistoric archaeological

remains.

8 val Baker et al 2007, 284-285



and crustacea, and netting for seasonal herring in distinctive local craft such as cobles, yawls and mules,

with Scarborough, Whitby, Staithes and Hartlepool the leading towns.

However, offshore fisheries were also farmed, but it was not until the advent of trawling methods and the

late 19th century adoption of steamers that heralded the era of extensive and intensive exploitation of

both pelagic and demersal fisheries. The worst affected stretch of coastline in England was that between

Berwick and the Humber, which includes the Hartlepool to Scarborough stretch (Frank 2002, 21-229).

Once internationally important fishing grounds are today in a state of remittance as strategies for

conservation of fish-stocks limit seasons and catch size.

The coastal and offshore waters of Britain have been navigated since prehistory although it is likely that

early mariners circulated round the periphery of the North Sea, ‘coasting’, by hugging the coastlines

rather than sailing directly across it. Linear routes are essentially an early-modern invention.

Nevertheless the whole area can be considered to comprise ‘navigation areas and routes’, both historic

and modern, to a greater or lesser degree.

Wrecks are numerous in the waters off the River Tees and North Yorkshire coasts. Most derive from the

early-modern period (1750-1900) of coastal trade and fishing.

1.1.9 As set out in the Environmental Statement, the values and perceptions of each of the character types,

as identified by the Scarborough to Hartlepool Seascapes project, are as follows:

telecommunications cables in the marine environment are likely to go largely unnoticed10

;

navigation hazards are readily perceived to ‘those who know’ and are readily present in people’s

consciousness due to the danger associated with them11

;

the scale of navigation routes and areas offshore are unlikely to be directly perceived by most people

viewing from land although, for some, the sea holds special meaning and evokes feelings of sense

and place with the sea as a liminal space and the activity of seafaring creating specific social

identities12

;

fishing is seen as an important element in the local economy with deep cultural attachments,

although wider perceptions are often that it is now destructive of fish stocks and the seabed13

;

the oil and gas industry is perceived as an industry in decline and attitudes are mixed14

.

1.1.10 Direct and indirect impacts to wrecks, obstructions and palaeolandscapes are assessed within the

Environmental Statement and mitigation to prevent significant impacts has been agreed and set out in

a project Written Scheme of Investigation.

1.1.11 With regard to character, however, it is clear from the above descriptions that a change to the HSC will

result from the presence of an installed offshore wind farm and the associated infrastructure. However,

the HSC, as outlined above, includes submarine cables and the installation of new cables will result in

no change.

1.1.12 During decommissioning there will be a further change resulting from the whole or partial removal of

the offshore wind farm components and the associated infrastructure.

9 Frank, P, 2002. Yorkshire Fisherfolk: A social history of the Yorkshire inshore fishing community.

Philimore, Bodmin

10 val Baker et al 2007, 227


12 val Baker et al 2007, 163-164





1.1.13 In outlining the above HSC, this note will assist English Heritage in identifying the nature of the

potential change to this character from the construction, operation and decommissioning of Dogger

Bank Creyke Beck. It is noted that the ability of this character to accommodate change is the defining

attribute in assessing the significance of this change and that English Heritage are the responsible

authority for undertaking the informed evaluation of this change.