|Commissioned by:||THE DEPARTMENT OF CULTURE MEDIA & SPORT|
|Conducted by:||ENGLISH HERITAGE|
|For:||THE SECRETARY OF STATE|
|Ref:||REDSAND TOWERS (U6)|
|Location:||Thames Estuary, approx 7 miles North of Whitstable|
English Heritage’s Monuments Protection Programme anti-aircraft gun sites study (Schofield 1999) sets out the context for Heavy Anti-aircraft batteries nationally and discusses the rarity and survival. The report states that:
‘All examples which are complete or near complete, with the majority of features present thus allowing the site to display its original form and function, will be described as nationally important and considered for scheduling’
The study’s recommendations were endorsed by English Heritage’s Ancient Monuments Advisory Committee (AMAC) in March 1999.
Redsand Fort is a well documented and intact example of a maritime Heavy Anti-aircraft battery in a rare sea fort form. The fort is a significant example of pioneering and ingenious wartime engineering forming part of a long history of coastal defence and fortification. Its early steel/concrete platform technology was to inform the construction of offshore oil and gas exploration platforms from the late 1940s onwards. The fort also has historic interest in its associations with the development of pirate radio in the 1960s. The fort is extremely rare; of the original compliment of six army sea forts, only one other, at Shivering Sands, survives. However, as Shivering Sands Fort lost a gun tower in a 1963 shipping collision, Redsand Fort is the most complete example. Redsand Fort is therefore considered to be of special interest and of national importance as the best surviving example of a rare Second World War sea fort type.
REASON SCHEDULING NOT APPROPRIATE
Under the Ancient Monuments and Archaeological Areas Act 1979 the Secretary of State for the Department for Culture Media and Sport has a duty to compile and maintain a schedule of monuments. Monuments added to the schedule must be of national importance and inclusion affords them statutory protection. However, inclusion of new monuments on the schedule is at the Secretary of State’s discretion.
English Heritage, in its role as advisor to the Secretary of State on potential monuments, considers, in the first instance, whether the site is of national importance and secondly, whether inclusion on the schedule will be beneficial to the long term management of the site. The statutory protection afforded by inclusion on the schedule brings with it many restrictions on what can or cannot be done to a monument by owners, occupiers and managers. In summary, interested parties would need to obtain scheduled monument consent from the Secretary of State for any works which would affect a scheduled monument prior to being able to conduct said works. For example, consent would be required for repairs, alterations, additions or removal of part of a monument. Further information on these restrictions can be found in Scheduled Monuments: a guide for owners and occupiers (English Heritage, May 1994). Nationally important sites are therefore scheduled only if this is the best way to protect them.
Redsand Fort has been assessed and found to be of national importance. However, it is not considered that scheduling will be the most appropriate form of future management. The site is remote; the fort was designed to have a finite life and is a steel and concrete structure in a hostile marine environment. In order to secure the fort for the future it will be necessary to carry out remedial works, some of which have already begun under the umbrella of Project Redsand. It is not felt that it would be in the interest of the fort to schedule it and therefore impose the resulting restrictions upon the monument. Indeed it is felt that scheduling will be too heavy handed a control which might, in fact, be detrimental to the on-going and future management of the site.
It is recommended that the site should be subject to an archaeological survey prior to repair/restoration in order to record the monument in its present condition. Given the quality and extent of the surviving records it may be that a fully catalogued internal and external photographic record would be a sufficient compliment to the original engineering drawings. Copies of the record should then be deposited with the Kent Sites and Monuments Record and the National Monuments Record in Swindon to ensure public accessibility.
A decision not to schedule the fort for reasons of its most appropriate future management must not be allowed to detract from its value as a nationally important archaeological monument. It would not, for example, negate the planned action by Project Redsand to better understand the condition of the structure and its management needs, nor to increase the public understanding of a fascinating part of the heritage of the 1939-45 conflict. Government policy towards nationally important remains is to preserve these in situ, where it is feasible. Within the constraints of the materials and methods of construction of the fort and its maritime location there is reason to believe that the site could continue to be a feature of the outer Thames Estuary for a reasonable period yet. Some positive management of the fort will prolong its existence. It is understood from colleagues in our South-east regional team that English Heritage is not able to prioritise its own limited financial resources to this end but this should not be taken to mean that such action should not be supported by other means.
Project Redsand, in its request that the site should be considered for legal protection through designation, asked that Redsand Towers should be considered for listing or scheduling. Advice on the legality of listing a structure in this location was therefore sought from English Heritage’s Legal Services who confirmed that that the forts did not qualify for listing: Acts of Parliament do not, as a general rule, extend to the United Kingdom’s territorial waters (ie: the area between the low tide line to a distance of 12 miles). The Ancient Monuments and Archaeological Areas Act (1979), under which monuments are scheduled, has an express provision at section 53 to the effect that a monument within the territorial waters of the UK may be scheduled. However, the Planning (Listed Buildings and Conservation Areas) Act 1990, under which structures are listed, has no such provision and is therefore only applicable down to the low tide line and not beyond. It is therefore not legally possible, under the current legislation, for the Redsand Towers to be listed.