Representation by National Federation of Fishermen's Organisations (National Federation of Fishermen's Organisations)
- Date submitted
- 27 January 2020
- Submitted by
- Non-statutory organisations
We offer the following relevant representation prepared following examination of application documents. We previously responded to the pre-application consultation. While a number of issues raised have been addressed, a number remain outstanding. The following is a summary of these issues, which are further detailed in a supporting letter. 1. The worst-case scenario is not sufficiently defined with respect to the application of advisory safety zones around installations and commercial fisheries clearance. Given that there exists no tangible evidence of towed gear fisheries significantly occurring among constructed wind farms, a precautionary approach for the purposes of a worst-case impact assessment should apply that assumes that no-towed gear fishing activities will resume. 2. The potential use of Service Operation Vehicles and the application of safety zones to them should be clarified and associated impacts assessed. 3. To better inform the potential for fisheries access, SPR should provide clarification over what circumstances it would regard damage to cables resulting from fishing activity to be the result of wilful intent or negligence on the part of a fishing vessel operator. 4. A number of proposals have not been factored into the Cumulative Impact Assessment including Marine Conservation Zone designations in English waters designated in 2019, as well as other marine protected areas and offshore wind farms in Danish waters. 5. Existing plans and projects are not factored into the cumulative impact assessment and are assumed to form part of the baseline. We consider this will mask impacts already being endured by impacted fishing businesses. 6. We identify a range of additional measures, principally to minimise safety risk associated with seabed hazards, including taking account of predominant fishing tows when designing inter-array cabling and consulting and communicating with fishing interests over cable plans, risk information from post-lay and monitoring surveys, factoring in fishing activities into cable burial risk assessments, protection of exposed cables until remediation works are completed and advancing warning systems communicating seabed hazards to the fishing industry. 7. We suggest an amendment to DCO/DML notification requirements for cables to include shallow buried as well as exposed cables.