Comment

Commercial renewable energy development and the historic environment: Key points from Historic England Advice Note 15

The new Historic England Advice Note (15) considering commercial renewable energy development and its effects upon the historic environment is a timely document, given the projected increase in renewable energy developments as we push to meet the requirements of The Climate Change Act (2008) and reach the target of Net Zero by 2050.

Senior Heritage Consultant, Hannah Tweedie, outlines the key points which prospective developers should be aware of when assessing potential sites and promoting developments through the English planning system.

The advice note considers a wide range of renewable energy development types, including onshore and offshore wind, solar, biomass and energy from waste, as well as making reference to the required associated infrastructure - substations, underground cables, grid connections and battery storage facilities. Reference is also made to the different consenting regimes which can apply to large scale renewable energy developments (i.e. DCO / NSIP) and the need for EIA.

Taking account of heritage assets

The document discusses the various different ways in which heritage assets should be taken into account during the planning and consenting process as a whole. Recognition that heritage assets should be considered from the earliest phases, when local policies and plans identifying areas suitable for such developments are being prepared, is welcomed.

Also welcome is the emphasis which the document places on the need for development proposals to be based upon a detailed understanding of the heritage environment. The document states that potential impacts on the significance of heritage assets (either direct or upon setting) should ideally be avoided through sensitive design, or alternatively be reduced and mitigated as much as possible; even for those elements of renewable energy developments where it might at first seem that location is largely down to pragmatic reasons (for example a substation requiring a location close to a generation facility).

Types of impact

The types of impact on heritage assets which might occur from particular development types, which types of mitigation might be relevant in each case, as well as links to other specific sources of guidance is presented, providing a helpful overview.

The section relating to offshore wind farms and their associated onshore grid connections is particularly helpful in providing a brief explanation of the wide variety of types of heritage assets which can be found offshore and within the intertidal zone, and the difficulties which can be encountered when seeking to understand and categorise the historic or archaeological importance of poorly documented shipwrecks and other heritage assets in this area.

The document also provides a helpful explanation on the reasoning why some impacts on historic environment assets (such as impacts of ground breaking works on buried archaeology) are considered permanent and irreversible, and yet others (such as impacts on setting of assets) might be considered temporary and reversible. Given the current and likely future increase in re-powering schemes, it is encouraging to see Historic England recognising that the reuse of existing foundations and cabling etc., in such schemes, has an important role to play in avoiding new impacts on the heritage resource.

Impacts on setting

Perhaps one of the biggest issues relating to proposals for energy infrastructure is the potential impact on the setting of heritage assets, a matter which has featured heavily in contemporary appeal decisions and case law including the Barnwell Manor decision. In this context it is reassuring to see that guidance recognises the difference between an assessment of impact on the setting of heritage assets, and the assessment prepared by a landscape consultant as part of a landscape and visual impact assessment (LVIA), whilst also recommending that the two assessments should be carried out in parallel, with conversation between the two consultants.

Impacts on significance vs. the environmental and social benefits of renewable energy

Finally, it is encouraging to note that the document recognises the significant environmental and social benefits which stand to be realised from the generation of renewable energy and the transition towards net zero. Whilst any harmful impacts on the significance of designated heritage assets require clear and convincing justification, including explanation of the benefits of proposals, case law recognises that the environmental and social benefits arising from renewable development can be capable of outweighing identified harm.

Overall, the advice note is a welcome addition to the suite of Historic England documents. By taking commercial renewable developments as its starting point, the note provides a helpful consolidation of information on the wide range of historic environment issues which are of relevance to renewables developers, with helpful signposting of other associated advice and guidance.

Our Heritage and Townscape team includes both Heritage and LVIA consultants, and we are experienced at working together to assess the development potential of individual sites, as well as working as part of a wider design team to devise design mitigation solutions which both minimise landscape and visual impacts, whilst also seeking to minimise effects upon the setting and significance of heritage assets. We also have experience advising on strategies which can help to offset impacts on the significance of heritage assets, and strengthen local landscape character.

If you would like more information about the services we offer please contact Hannah Tweedie.

17 March 2021