East 1 Historic Environment Service

Comment Date: Mon 23 Sep 2013

We have reviewed the Cultural Heritage Assessment submitted with this planning application, which the Cornwall Council Planning Portal logs as having a Receive Date as 15/7/20013. However, this appears to be identical in content with the document of the same title previously submitted and commented on, and with the same fundamental inadequacies. We wrote to you on 30 May with our advice in response to the submitted documents at that time, expressing our concerns at the inadequacies of the Cultural Heritage Assessment, and recommended that the applicant submits the results of, a) a geophysical survey, and b) a more thorough and comprehensive visual settings assessment. English Heritage have already commented on the inadequacy of a revised LVIA in their letter to you of 17 September, so we will not comment further on this aspect except to concur with their conclusions and recommendations in this respect. As for the assessment of direct ground impacts on any surface or buried archaeological features, the applicant has failed to submit a geophysical survey of the previously specified areas of the site, or take into account the impacts that the construction that some of the turbines may have on the remains of historic WWII and Cold War airfield infrastructure (in particular concrete runways, aircraft hard standings, etc.). Without a geophysical survey to provide an evidence base for the presence or absence of buried archaeological features, their statement that ?the probability of the construction works? encountering buried sites and features of archaeological significance is considered low? (para 8.11.4) is completely without foundation. Also, as we have stated previously, a geophysical survey is a method of initial assessment and NOT suitable as a mitigation method, as the applicant suggests in their paragraph 8.8.36. For the same reason, the offer to carry out an archaeological ?watching brief? or to ?micro-site away? a turbine should anything of significant be discovered during the post-consent phase is UNACCEPTABLE to us as adequate mitigation. None of this should be a surprise to the applicant, as we have flagged this up on a number of occasions before (as cited above), as well as in our Online response to the EIA Scoping Opinion of 9 November 2012. RECOMMENDATION: The submitted Cultural Heritage Assessment fails to provide an adequate assessment of the visual impacts of the proposal on heritage assets within the recommended assessment catchment areas (as already commented on by English Heritage). The applicant also appears to have ignored our earlier advice that the results of a geophysical survey will be required as an essential initial assessment of the direct impacts on any buried archaeology, as required by the National Planning Policy Framework, Section 12, paragraph 128. This requirement is also specified in Cornwall Council?s Renewable Energy Planning Guidance Note 3: The Development of Onshore Wind Turbines (June 2013). As the applicant has failed to provide an adequate assessment of the indirect (visual) impacts, nor provided any geophysical survey results that would enable us to advise you on the direct (below ground) impacts, we OBJECT to this scheme and have no option but to recommend that this application be REFUSED. Historic Environment Service (Archaeology & Landscape)