Representation by Eastern Inshore Fisheries & Conservation Authority (Eastern Inshore Fisheries & Conservation Authority)
- Date submitted
- 30 September 2020
- Submitted by
- Members of the public/businesses
The role of Eastern IFCA is to lead, champion and manage a sustainable marine environment and inshore fisheries within our district, which extends from the Humber to Harwich, and six nautical miles out to sea. As the proposed Sizewell C facility is within those boundaries, and the project may generate effects which interact with our core role, we consider it appropriate that Eastern IFCA comment on the proposed project. We acknowledge the considerable amount of work which the Sizewell team and consultants have undertaken, and the large volume of documents that this work has produced. We restrict our comments to those aspects of the potential project that interact with our remit – namely effects which may have an impact on fishing opportunities and quality (including related impacts on the wider marine environment), and any activity with the potential to directly affect access to such opportunities. Within the project there are aspects of potential impacts on features of Marine Protected Areas. We defer to the advice and comments of the relevant Statutory Nature Conservation Body in connection with these potential impacts, except where there may be an interaction with Eastern IFCA core remit. Within the project there are aspects of potential inputs of substances (whether radioactive, toxic or not) and energy (such as heat) into the marine environment. We defer to the advice and comments of the relevant authority (such as the Environment Agency) in connection with these potential impacts, except where there may be an interaction with Eastern IFCA core remit. In connection with our core remit, we retain concerns over the general approach to the assessment of potential impacts on fish populations as presented in numerous studies and publications connected with the Sizewell C project. It is the norm in such studies that effects of e.g. mortalities due to interaction with the water abstraction / fish return systems are considered against the population (or some proxy measurement) over a wide area, such as the southern North Sea (or even wider). We do not consider that this is an appropriate approach, and we suggest that such local effects need to be considered against a much more local population. We note that early proposals for the project (for instance, The Sizewell C Project 5.1 Consultation Report Appendices D.1 - D.7 Part D: Stage Two Pre-Application Consultation, Section 7.4.56) included provision for a fish deterrence system associated with the cooling water intakes. This deterrence system would have the effect of reducing the number of fish that would interact with the cooling water system. We have not identified any section within the package of material supplied that determines that such a system would have no beneficial effect, and we suggest that the option should be considered. Due to our concerns over this fundamental aspect of the assessment of effects, it is not possible for us to supply more detailed appraisal of any impacts which may arise. We are willing and eager to engage with the Sizewell C team in order to develop an appropriate approach to the assessment of impacts which interact with the Eastern IFCA remit. Eastern IFCA continually seek to improve how we respond to consultations, both in terms of efficiency and content. Therefore, if any of the points raised in this response are reflected in the outcome we would appreciate being informed. Please do not hesitate to contact me should you have any queries on the above response.