12                          Cultural Heritage Impact

12.1                   Legislation and Standards

12.1.1             As the eastern end of the CBL will be constructed on the reclaimed land of Area 86A, there will be no land based cultural heritage impact. This study focuses on the marine archaeological impact.

12.1.1.1      In accordance with the EIA Study Brief, a Marine Archaeological Investigation (MAI) was commissioned to cover the seabed which would be impacted by the construction of the CBL.  The aim of the MAI was to locate and assess the significance of any underwater cultural heritage which may be present on the seabed in the areas that will be impacted by the construction of the CBL and associated facilities, and recommend mitigation measures if found to be necessary.

12.1.1.2      The MAI covered the study area shown in Figure 1 (in Appendix 12.1) marked as the alignment corridor.  This included a significant buffer zone to allow for possible changes to the alignment and the impact of working vessels during construction.

12.2                   Legislation and Standards

12.2.1             The following legislation is applicable to the assessment of archaeological and historic resources in Hong Kong.

(a)    Antiquities and Monuments Ordinance

(b)   Environmental Impact Assessment Ordinance

(c)    Technical Memorandum on Environmental Impact Assessment Process

(d)   Guidelines for Marine Archaeological Investigation

12.2.2             Antiquities and Monuments Ordinance

12.2.2.1      Legislation relating to antiquities is set out in the Antiquities and Monuments Ordinance (Chapter 53 of the Laws of Hong Kong), which came into force on 1 January 1976. The Antiquities and Monuments Ordinance provides statutory protection against the threat of development on Declared Monuments, historical buildings and archaeological sites to enable their preservation for posterity.

12.2.2.2      The Ordinance contains the statutory procedures for the Declaration of Monuments. The legislation applies equally to sites on land and underwater.  The purpose of the Ordinance is to prescribe controls for the discovery and protection of antiquities in Hong Kong. A summary of the key aspects of the legislation relevant to the current study is presented below.

12.2.2.3      Human artefacts, relics and built structures may be gazetted and protected as monuments. The Antiquities Authority may, after consultation with the Antiquities Advisory Board (AAB) and with the Chief Executive’s approval, declare any place, building, site or structure which the Antiquities Authority considers to be of public interest by reason of its historical, archaeological or palaentological significance.

12.2.2.4      The discovery of an Antiquity, as defined in the Ordinance must be reported to the Antiquities Authority (the Authority), or a designated person. The Ordinance also provides that the ownership of every relic discovered in Hong Kong after the commencement of this Ordinance shall vest in the Government from the moment of discovery.

12.2.2.5      No archaeological excavation may be carried out by any person, other than the Authority and the designated person, without a licence issued by the Authority. A licence will only be issued if the Authority is satisfied that the applicant has sufficient scientific training or experience to enable him to carry out the excavation and search satisfactorily, is able to conduct, or arrange for, a proper scientific study of any antiquities discovered as a result of the excavation and search and has sufficient staff and financial support.

12.2.2.6      Once declared a site of public interest, no person may undertake acts which are prohibited under the Ordinance, such as to demolish or carry on building or other works, unless a permit is obtained from the Antiquities Authority.

12.2.2.7      The Ordinance defines an antiquity as a relic (a moveable object made before 1800) and a place, building, site or structure erected, formed or built by human agency before the year 1800. Archaeological sites are classified into two categories, as follows:

·        Declared Monument – those that are gazetted in accordance with Cap. 53 by the Antiquities Authority and are to be protected and conserved at all costs; and

·        Recorded Archaeological Sites – those have not been declared but recorded by the AMO under administrative protection.

12.2.2.8      It should also be noted that the discovery of an antiquity under any circumstances must be reported to the authority, i.e. the Secretary for Development or designated person. The authority may require that the antiquity or suspected antiquity is identified to the authority and that any person who has discovered an antiquity or suspected antiquity should take all reasonable measures to protect it.

12.2.3             The Environmental Impact Assessment Ordinance

 

12.2.3.1      Since the introduction of the 1998 EIAO (Cap. 499, S16), the Antiquities and Monuments Office (AMO) have the power to request a MAI for development affecting the seabed. Its purpose is to avoid, minimise and control the adverse impact on the environment of designated projects, through the application of the EIA process and the Environmental Permit system. The EIAO stipulates that consideration must be given to issues associated with cultural heritage and archaeology as part of the EIA process.  Annexes 10 and 19 of the EIAO-TM outline the criteria for evaluating the impacts on sites of cultural heritage and guidelines for impact assessment, respectively.

12.2.3.2      The EIAO-TM identifies a general presumption in favour of the protection and conservation of all sites of cultural heritage and requires impacts upon Sites of Cultural Heritage to be ‘kept to a minimum’. There is no quantitative standard for determining the relative importance of sites of cultural heritage, but in general sites of unique, archaeological, historical or architectural value should be considered as highly significant.

12.2.4             Technical Memorandum on Environmental Impact Assessment Process

12.2.4.1      The general criteria and guidelines for evaluating and assessing impacts to Sites of Cultural Heritage are listed in Annexes 10 and 19 of the EIAO-TM. It is stated in Annex 10 that all adverse impacts to Sites of Cultural Heritage should be kept to an absolute minimum and that the general presumption of impact assessment should be in favour of the protection and conservation of all Sites of Cultural Heritage. Annex 19 provides the details of scope and methodology for undertaking Cultural Heritage Impact Assessment, including baseline study, impact assessment and mitigation measures.

12.2.5             Guidelines for Marine Archaeological Investigation

12.2.5.1      The AMO have issued Guidelines for MAI which detail the standard practice, procedures and methodology which must be undertaken in determining the marine archaeological potential, presence of archaeological artefacts and defining suitable mitigation measures. The methodology set out in the Guidelines has been followed for this investigation.

12.3                   Description of Existing Environment

12.3.1             At the commencement of the project there were no known underwater archaeological resources within the study area which is called the alignment corridor.  There are two accurately located modern shipwrecks within Tseung Kwan O Bay, but these are outside the study area and of no archaeological significance.

12.4                   Cultural Heritage Resources

12.4.1             There are no cultural heritage resources on the seabed within the study area.

12.5                   Assessment Methodology

12.5.1             In accordance with Antiquities and Monuments Office (AMO) Guidelines, the MAI comprised six tasks:

·        Task 1:            Marine Archaeological Review of previous studies relevant to this project;

·        Task 2:            Baseline Review to assess the archaeological potential of the study area from a desk based review of existing literature;

·        Task 3:            Geophysical Survey data analysis to obtain detailed information about the seabed and sub-surface sediments;

·        Task 4:            Establish archaeological potential and assess the location and significance of any seabed features requiring further investigation and evaluation;

·        Task 5:            Diver inspection of seabed features;

·        Task 6:            Assess the impact of the construction of the Cross Bay Link on archaeological resources, if present, and recommend a mitigation strategy, if necessary. 

12.5.2             Marine Archaeological Review

12.5.2.1      Extensive research was conducted to locate all previous studies relevant to the MAI.

12.5.3             Baseline Review

12.5.3.1      The aim of the Baseline Review is to compile a comprehensive inventory of cultural heritage resources in the Study Area.  It is not an exhaustive chronological history of the area.

12.5.3.2      The Review established the historical profile and potential for cultural heritage sites and included:

·        Publications on local historical, architectural, anthropological, archaeological and other cultural studies

·        Unpublished papers, records, archival and historical documents held in local libraries and other government departments

12.5.4             Archive Search

12.5.4.1      All archives holding information on shipwrecks in Hong Kong and UK were explored for relevant data.

12.5.5             Geophysical Survey

12.5.5.1      The Geophysical Survey was conducted in 2003 by the Institute of Geophysical and Geochemical Exploration.  As the previous survey covered the present study area, it was possible to re-use the data.  Figure 2 (in Appendix 12.1) shows the survey coverage and the CBL MAI study area. Figure 3 (in Appendix 12.1) shows the 2004 MAI study area.

12.5.5.2      SDA Marine returned to the original report and extracted the data relevant to this study rather than use the interpretation presented in the 2004 MAI.

12.5.6             Survey Specifications

12.5.6.1      The following equipment was deployed:

·        DF32000MK II Echo Sounder

·        Valeport VLR740 Automatic Tide Logger

·        NT-s00D DGPS Differential Signal Receiver

·        Season TRACKER  Navigation System

·        Delph Seismic Reflection System

·        EPC-1086 Printer

·        Bar Check Plate

·        Side Scan Sonar System – Edge Tech 560A

The survey equipment was used to survey a grid 25m x 25m which ensured 100% coverage of the study area.

12.5.7             Visual Diver Survey

12.5.7.1      The aim of the diver inspection was to locate 8 seabed targets and establish their archaeological potential.  The diver survey was completed on the 28th and 29th September and 10th and October 2009.

12.5.7.2      A team of four divers worked from a sampan. Each target was located using Differential Global Positioning (DGPS). The boat was positioned above each target and a shot weight was placed on the seabed marked by a buoy on the surface as shown in Figure 4 (in Appendix 12.1).  The drop position was checked against the target position on a digital chart. The diver then used this shot weight as the centre point of circular searches at 0m, 3m, 5m, 10m, 15m and 20m radius from the shot weight. 

12.5.7.3      The diver was equipped with a hand held video camera to record the contact and associated seabed features. A metal probe was used to look for buried objects. The video had a remote TV monitor in the boat’s wheelhouse which displayed the video footage in real time.  This facilitated managing the diver from the surface via the through water communications.

12.6                   Construction Phase Assessment

12.6.1             Marine Archaeological Review

12.6.1.1      The following reports were examined in detail to extract the data directly relevant to the current study and define the scope of additional work needed.

 

2000. Marine Archaeological Investigation. Road P2 of Tseung Kwan O Development. Prepared for the Antiquities and Monuments Office. SDA Marine Ltd.

12.6.1.2      A comprehensive MAI was completed.  The Baseline Review established high potential for shipwrecks based on documented historical evidence. The results can be applied to the current study as they cover the whole of Tseung Kwan O Bay.

12.6.1.3      The Geophysical Survey data was not relevant to the current study as it only covered a small section in the North West corner of Tseung Kwan O Bay which is outside the alignment corridor.

 

2003. Further Development of Tseung Kwan O Feasibility Study. Geophysical Surveys and Water Sampling (Term Contract).  Contract No. GE/2001/20. Agreement CE87/2001 (GE).  Institute of Geophysical and Geochemical Exploration, MCR, PRC.

12.6.1.4      IGGE were appointed by GEO to complete the Site Investigation. The objectives of the survey were ‘to determine the sub-seabed stratum to map features (anomalies), manmade objects on or beneath the seabed within the study area’ (Page 1).

12.6.1.5      The study area is shown in Figure 2 (in Appendix 12.1) and the alignment corridor for the Cross Bay Link has been added to show that there is 100% coverage of the current study area. 

12.6.1.6      The survey included echo sounding, side scan sonar and seismic profiling.  The data was of sufficiently high resolution to be used for the MAI.

2004. Further development at Tseung Kwan O – Feasibility Study.  Agreement Number CE 87/2001. Marine Archaeological Investigation. Assessment of Archaeological Potential. Task 3. Archaeo-environments Ltd.

12.6.1.7      This study was commissioned in 2004 to cover the Cross Bay Link and Western Coast Road projects.  The study area is shown in Figure 3 (in Appendix 12.1).  As it includes the current study area the results can be directly applied to this project.

12.6.1.8      The MAI comprised a Baseline Review and analysis of Geophysical Survey data to establish archaeological potential.

12.6.1.9      The Baseline Review confirmed high archaeological potential based on historical evidence. The review is mostly a summary of the 2000 SDA Marine Report for Road P2 which is summarised in Section 12.6.2 below.

12.6.1.10 The analysis of the geophysical survey concluded that there were a number of unidentified objects which the report recommended should be inspected by divers.  The inspection was not carried out.    

12.6.2             Baseline Review

12.6.2.1      The Baseline Review completed in 2000 by SDA Marine Ltd for Road P2 of Tseung Kwan O Development under contract to the Antiquities and Monuments Office covers the same study area as the current project.  It is therefore possible to re-use this information and a summary is provided below.

 

Maritime Activity in the Vicinity the Study Area

12.6.2.2      Tseung Kwan O, also known as Junk Bay, is located at the eastern entrance to Victoria Harbour. The entrance is sometimes called Fat Tong Mun (Temple Entrance or Temple Gate).  The area got its name due its popularity as a resort for Chinese junks and sampans in the past, because of its relatively sheltered position during typhoons.  The villages that formerly skirted the coast of Junk Bay, Hang Hau (Stream Mouth), Yau Yue Wan (Cuttlefish Bay), Tseung Kwan O (Military General’s Rocky Entrance), Pak Shing Kok (Hundred Victories Cape) now far inland, were all at one time on the coast. Junk Bay was originally much larger and more extensive than it is today as reclamations have filled in the bay (Davis, 1949).

 

Early Maps of Junk Bay 

12.6.2.3      In pre-British times Junk Bay was shown (as Fat Tong Mun) in the Cheng Ho navigation map of the China coast in 1425 AD.  This map is believed to be based on the earlier map Mau K’un map executed from 1422-1430 AD by his grandson Mau Yuen-I, published in a book called Mo Pei Chi (Notes on Military Preparation, published in 1621 (Empson, 1992)). The map indicates the routes taken by vessels of a 15th century Imperial Chinese fleet under the command of Admiral Cheng Ho. 

12.6.2.4      There are references to Junk Bay in a 1723 map of Kwang Tung produced by Chiang Ting Sik in his book called Ku Kam To Shu Chap Sing.  It is also positioned in ‘Map of the entire coastline’ by Chan Lun Kwing in his book Hoi Kwok Man Kin Luk (A Record of the Countries of the Sea, printed in Ngai Hoi Chu Chan in 1744 (Figure 5 in Appendix 12.1)  (Empson, 1992).

12.6.2.5      The Kang Hsi Emperor commissioned the Jesuit Fathers to undertake a detailed map of China, which was reprinted in part in 1737.  The Jesuit map relies heavily on pre-existing Chinese maps of coastal waters.  Hong Kong waters are charted in this map, found in Nouvelle Atlas de la Chine, published in Paris in 1737.   Further reference appears in the San On Yuen Chi a cartogram from the 1819 Directory of San On County, wherein Hong Kong is located (Figure 6 in Appendix 12.1).  Another Chinese map of Kwangtung Province, dated from 1820, reportedly the work of a Taoist priest, clearly identifies Junk Bay (Empson, 1992).   

12.6.2.6      A good subsequent Chinese map that records the south-eastern waters of Victoria Harbour is of San On District, in the 1864 edition of the Sun On Gazetteer (Figure 7 in Appendix 12.1).

12.6.2.7      These maps are particularly important as they indicate that Junk Bay was established as a known coastal settlement from the 15th century.  Although there is no documentary material recording what took place there the fact it merited mapping is significant.

12.6.2.8      The first map which clearly depicts Hong Kong harbour in detail is an 1810 marine chart (Figure 8 in Appendix 12.1).  This chart was prepared for the East India Company by Daniel Ross and Philip Maughan, Lieutenants of the Bombay Marine. 

12.6.2.9      On the signing of the Treaty of Chuen-pi in 1841, HMS Sulphur, commanded by Captain Sir Edward Belcher, was commissioned to undertake a hydrographic survey of Hong Kong Island and the surrounding waters.  Produced in the meticulous style typical of the Royal Navy, this chart is remarkable for its accuracy and detail.  It takes into account depth soundings in a number of areas, which still form the basis of charts in unchanged areas (Morse, 1926).  In this map, Junk Bay is clearly detailed up to the further reaches of Tseung Kwan O which remain uncharted.  Junk Island is clearly delineated, and Joss House Bay is likewise charted (Figure 9 in Appendix 12.1). 

Pirate Activity in Junk Bay

12.6.2.10 Piracy was a persistent problem in Hong Kong waters.  Detailed documentary material provides evidence for intense activity in the Junk Bay (Lo, 1963). Of particular relevance to the current study are the activities of the pirate leader Chêng Lien-ch'ang.  He and his brother, based on Lantau, had been part of a pirate force that gained a victory over government troops at Kwangtung in 1619 AD.   Following this victory Chêng Lien-ch'ang entrenched himself in the hills behind Lei Yue Mun. 'Because of his devilish cunning and his love of fighting' (Lo, 1963), the hill where Chêng Lien-ch'ang encamped came to be called Devil's Peak. He also built on the shore of Lei Yue Mun a Tin Hau temple which is still in active use today. Behind the temple was a secret cave in Devil's Hill used as the hiding place for his plunder.

12.6.2.11 Historical documents record that all of the seven sons of Chêng Lien-ch'ang followed his father's profession of piracy. After his death the eldest son, Chêng I, assumed leadership, sharing with Kuo P'o-tai and Wu Shih-êrh the title of 'The Three Buccaneers of the South Seas'.  Eventually Chêng I encountered a typhoon while crossing the sea to attack lands to the south and was drowned.  The six hundred ships based at Lei Yue Mun passed into the hands of his wife, who continued to resist the combined action of the Imperial Navy and the Portuguese fleet based at Macau. Eventually she was forced to yield to the mercy of the Government when both Kuo P'o-tai and Chang Pao-tsai surrendered to the Imperial Authority (Murray, 1987).

 

Maritime Trade

12.6.2.12 The whole Junk Bay area has a long history as a shipping corridor and trade route. From the Sung Dynasty (960-1279) onwards, a constant and rich traffic of trading junks sailed along the coast of Guangdong province carrying goods from the ports of northern China to Guangzhou at the mouth of the Pearl River.  The strait between Tung Lung Island and the mainland is called Fat Tong Mun or Buddha Temple Entrance. This was one of the main entrances to the harbour and during the Sung Dynasty, a stone pagoda was built to guide ships (Lo, 1963).

12.6.2.13 Another important indicator of the intensity of shipping and piracy activities is the fort on Tung Lung Island overlooking the Fat Tong Mun Channel (Lui, 1990). The Ching Dynasty (1644-1911) naval station of Tung Lung is situated on the north east of Tung Lung Island.  Tung Lung is also known as Tam Long Chau or Southern Temple Island and there are temples both to the north and south of Fat Tong Mun (Williams, 1976). 

12.6.2.14 The Tung Lung fort was one of a number of garrisons established during the late Ming and early Ching dynasty to protect coastal shipping from pirates.  The fort itself was built during the Kang Hsi period (1662-1722) as part of the anti-Ming loyalist anti-pirate activity of that period (Nixon, 1980).

12.6.2.15 Piracy remained an active threat in Hong Kong waters during the 19th Century. L.C. Arlington, who spent six years between 1893-9 in charge of a Customs Station on Kowloon, wrote in his autobiography:

'During my time in Kowloon territory piracies were so common that we regarded it as extraordinary if a day passed without one.  Indeed, it was the daily routine for junk masters to report at the Customs Station that they had been pirated and all their cargo looted' (Hayes, 1983).’

Chinese Maritime Customs Station

12.6.2.16 In the Qing Dynasty (1644-1911), vessels passing through Fat Tong Mun and Tathong Channels stopped at a customs station on Fat Tong Chau or Junk Island, before proceeding west to the Pearl River delta.  It is located with strategic significance at the eastern exit of the harbour.  In April 1979, following the recovery of pieces of a broken pillar, the Antiquities and Monuments Office undertook a brief survey of the area (Bard, 1980). Broken stones, rubble, tiles and grey bricks were found and granite-slab steps with remains of door hinges were uncovered.  At the south end two column bases were discovered. This material indicated that an imposing structure had stood on the site. Large boulders, clearly deliberately aligned, were observed at low tide about the centre of the beach.  It was suggested that these could be the remains of a large wooden pier or slipway.

12.6.2.17 After the signing of the Treaty of Tientsin in 1858, Chinese Maritime Customs Stations were established at Ma Wan, Cheung Chau, Lai Chi Kok and at Junk Island. Armed Maritime Customs cruisers regularly patrolled the waters nearby looking for contraband (Sayer, 1975).  The Maritime Customs station was closed, along with the others in the immediate vicinity of Hong Kong, after the Second Convention of Peking in 1898.  The Maritime Customs Station buildings gradually fell into disrepair after they were abandoned.

12.6.3             Archive Search

12.6.3.1      The UK Hydrographic Office (UKHO) holds a database of surveyed shipwrecks in Hong Kong, including those not shown on Admiralty Charts.

12.6.3.2      Admiralty Chart number 3279 (Figure 10 in Appendix 12.1) shows two shipwrecks close to the study area.  Further information about these wrecks was obtained from the (UKHO) who undertook the original surveys of the wrecks.

12.6.3.3      At position 22o 17' 07.4'' N, 114o 14' 47.6'' E there is a shipwreck (Hydrographic Office reference number 111303151) in 15 m of water with wreckage standing up to 5.1 m above the seabed.  The origin of the wreck is unknown. The site was surveyed in October 1997.

12.6.3.4      At position 22o 16' 59.7'' N, 114o 14' 46.4'' E there is a shipwreck (Hydrographic Office reference number 111303138) in 21.8 m of water with wreckage standing 8.2 m above the seabed.  The origin of the wreck is unknown.  The site was surveyed in October 1997.

12.6.3.5      Although these wrecks lie just outside the study area, their presence could be significant. Both wrecks had considerable amounts of material still present on the seabed.  This indicates that the seabed environment has not caused the wrecks to break up despite the fast currents in the area and their proximity to the main shipping lane.  There are only 49 charted shipwrecks in Hong Kong waters and it is significant to note that two lie close to the study area.

12.6.3.6      The UK Hydrographic Office was contacted again in June 2009 to get an update on the status of the wrecks.  Both wrecks have now been cleared as they represented a possible navigation hazard.

12.6.3.7      The UKHO holds old navigation charts of the study area.  The 1907 chart is presented as Figure 11 (in Appendix 12.1).  This chart is particularly interesting as it shows the study area before any reclamation has taken place.

12.6.4             Geophysical Survey

12.6.4.1      The results presented below are from a new interpretation of the data and are not the same as the results presented in the 2004 Archaeo-Environments report. This was to ensure that the results were directly relevant to this study.

 

Side Scan Sonar Data

12.6.4.2      A total 18 unidentified objects were found during the survey.  Of these, five are situated within the alignment corridor.

12.6.4.3      The details are set out in the table below and a copy of the data showing each object is presented in Figures 12 to 15 (in Appendix 12.1). The descriptions of the objects on the data were made by IGGE and are from a site investigation rather than archaeological perspective. It was not possible to make an accurate identification until a diver survey was carried out.

Table 12.1 Unidentified Objects from Side Scan Sonar Survey

Unidentified Object No.

Easting

Northing

Size (m x m)

601

845449.11

817003.99

17.2 × 18.5

1601

845266.47

817219.21

3.8 × 2.2

1603

845044.54

817212.27

1.8 × 2.2

1801

844545.68

817316.71

12.3 × 16.7

Target 1

844670.34

817300.21

Described in the 2004 MAI as an isolated debris field. No dimensions were given.

 

12.6.4.4      Target 1 is a feature that was identified by Archaeo-environments as having archaeological potential.  The survey data for this feature was not available or included in the Archaeo-environments report.  As it was highlighted to have archaeological significance and it is within the study area, it was included in the list of targets and was inspected by the diving team.

 

Seismic Profiler Data

12.6.4.5      A total of 19 unidentified objects were located within the survey area of which 3 are within the alignment corridor. The details of each one are set out in the table below and the data is presented as Figures 16-18 (in Appendix 12.1). On the data, the descriptions were provided by IGGE and are from a site investigation rather than archaeological perspective.

Table 12. 2 Unidentified Objects from Seismic Profiler Survey

Unidentified Objects No.

Easting

Northing

EW06-38

844900.7754

816995.04

EW09-36

845124.1938

817068.70

EW26-29

844635.9042

817490.44

 

Seabed Stratigraphy

12.6.4.6      Most of the surface sediments are mud and fine sand with some evidence for dumped construction debris. Figure 13 (in Appendix 12.1) shows some of these materials and Figure 14 (in Appendix 12.1) shows evidence for anchor scars.

12.6.4.7      Geological analysis of the seabed sediments indicates the presence of a good preservation environment for archaeological resources.  At 200m from the western edge of the survey area the Marine Deposit is 10m thick increasing to 13m in the centre of the bay.  The maximum thickness of the Marine Deposit is 18m towards the eastern end of the study area.  The Marine Deposit is called the Hang Hau Formation and consists of very soft silty mud in which archaeological resources could be buried.

12.6.4.8      The top of the Alluvium throughout the rest of the study area is relatively flat with two linear north-south running depressions identified in the centre and eastern part of the study area. These may be evidence of Pleistocene watercourses.

12.6.4.9      Figure 19 (in Appendix 12.1) shows a section across a vibro core which was taken from within the study area which demonstrates the seabed stratigraphy.

12.6.5             Archaeological Potential

12.6.5.1      The location of each of the unidentified objects was plotted onto the alignment corridor.  This is presented as Figure 20 (in Appendix 12.1).  It can be seen clearly that 8 of the unidentified objects are located within the alignment corridor.  A diver inspection was required of each one within the study area to establish its archaeological significance.

12.6.6             Visual Diver Survey

12.6.6.1      The diving team successfully located every target.  They were all identified as being modern dumped rock, identical to that seen in the rubble mound seawalls surrounding the study area.

12.6.6.2      The seismic profiler contacts EW09-36 and EW06-38 were located using the probe.  The divers were able to assess that each object was a stone block.

12.6.6.3      Additional surveys were made of sonar contacts SN35-75, EW02-31 and EW-2-24.  These all lie outside the MAI study area but could be impacted if there was a significant change to the alignment.  They were therefore inspected as a precaution.  Each of them was also found to be modern dumped rock.

12.7                   Operational Phase Assessment

12.7.1.1      As the MAI did not locate any evidence for underwater cultural heritage resources there will be no impact arising during the operational phase.

12.8                   Residual Environmental Impacts

12.8.1.1      There will be no residual environmental impacts.

12.9                   Conclusion

12.9.1.1      A comprehensive Marine Archaeological Investigation was completed which followed exactly the methodology set out by the Antiquities and Monuments Office and Annexes 10 and 19 of the TM-EIAO.  The study did not locate any cultural heritage resources. The diver survey indicated that in many areas the seabed had been disturbed by previous construction work.

12.9.1.2      Therefore, there is no further action or mitigation required.