Written evidence from English Heritage
1. English Heritage is the UK Government's statutory
adviser and a statutory consultee on all aspects of the historic
environment and its heritage assets. This includes archaeology
on land and under water, historic buildings sites and areas, designated
landscapes and the historic elements of the wider landscape. This
memorandum of evidence focuses on question 6.2 in the call for
evidence: Are environmental costs and benefits (including in
relation to noise) correctly accounted for in the business case?
2. English Heritage is considering closely the
details set out in the Government's consultation on high speed
rail and associated Appraisal of Sustainability (AoS). We are
investigating which historic places will be affected by the proposed
route, and evaluating the nature of that impact. In doing this
we will consider both demolitions and effects on the setting
of important heritage, such as listed buildings and scheduled
monuments. It is not English Heritage's role to take a position
on whether the line should go ahead or not.
3. In summary, English Heritage believes that
without additional work to identify those historic assets outside
the 350m buffer zone where the setting will be adversely affected
and, ideally, on the currently unknown sites of archaeological
interest within the corridor, the full extent to which the stated
sustainability objective for cultural heritage is met by this
route option cannot be properly judged.
4. The Appraisal of Sustainability sets out the
impacts upon designated assets and evaluates whether they are
supportive of the objective to "preserve and protect archaeological
assets/historic buildings/historic landscapes". No grade
I or II* listed buildings are directly impacted (ie within the
anticipated land take for construction). Two scheduled monuments,
three grade II* registered parks and gardens and 15 grade II listed
buildings are directly impacted. Two grade II* listed buildings
would be close to the construction, which would need to be carefully
managed to minimise potential impact.
5. The appraisal also considers a 350m buffer
either side of the line. This includes 11 grade I and grade II*
listed buildings and 274 grade II listed buildings. No assessment
is given of the scale of the impact upon the setting of these
assets. The desktop nature of the exercise means that no consideration
been given to whether, given the changing landscape features,
350m is a sufficient buffer for all the route. Some important
assets well beyond 350m will be impacted in some way (eg their
setting) by the new line.
6. The AoS appropriately considers that the impacts
on the GII* registered parks and gardens are highly unsupportive
of the heritage objective. However, the direct impacts on two
scheduled monuments (Grim's Ditch in the Chilterns and a Roman
villa site in the vicinity of Edgcote), likely to result in substantial
harm, have been appraised as a lower level of impact. The loss
of such nationally significant monuments ought to be appraised
as a significant impact. The AoS also erroneously categorises
Grade II buildings as regionally important: as a national designation,
this is inaccurate and must be changed.
7. It should be noted that there may be as yet
unrecognised nationally important archaeological assets that would
suffer substantial harm. Although these cannot be appraised at
this stage, their possibility means that the existing impact assessment
is only partial.
8. We are also aware of the significant impact
on landscape, including the historic landscape. We are engaged
with the lead government agency on landscape issues, Natural England,
and we anticipate that they will respond fully on this matter.
9. English Heritage will continue to work with
HS2 to minimise impacts where possible. However, the scope to
do this will be limited owing to engineering constraints. While
working with HS2 to minimise any impacts, we will also seek to
mitigate them where unavoidable. This may include the use of good
design to minimise landscape impacts, and archaeological and building
investigation and recording. Where impacts are substantial and
unavoidable, the opportunity to offset the harm through enhancements
elsewhere will be identified, as was the case at Cobham Hall in
Kent for High Speed One. In line with the Government's objectives,
English Heritage will advise that opportunities are taken to capture
evidence from the historic environment and to make it publicly
available, particularly where a heritage asset is to be lost.
This process should be informed by an innovative and coordinated
approach to maximise the benefit to the body of knowledge.
10. This memorandum does not aim to reflect the
views of other organisations within the heritage sector. We expect
that HS2, if appropriate, will liaise with those organisations