Representation by Suffolk Wildlife Trust (Suffolk Wildlife Trust)
- Date submitted
- 27 January 2020
- Submitted by
- Non-statutory organisations
East Anglia One North Offshore Windfarm DCO Application: Suffolk Wildlife Trust wishes to confine our representation to Onshore Ecology, with comments relating to offshore Marine Mammals being provided by The Wildlife Trusts. Notwithstanding the statements below, we wish to express our concerns at the current lack of a strategic approach to reducing onshore impacts of this and other future energy-related schemes such as through a sensitively designed off-shore ring main. We wish to make the following comments in respect of Onshore Ecology: In Chapter 22 (Onshore Ecology) 22.5.2.3 it is omitted that semi-natural broadleaved woodland is a UK Priority habitat under the classification Lowland Mixed Deciduous Woodland (Section 41 of the Natural Environment and Rural Communities (NERC) Act (2006)). Applying the criteria in Table 22.8, this habitat is defined as ‘medium importance’ rather than being assigned to ‘high’ as would be the case for UK Priority habitats and this then has a bearing on impact significance. Consequently, we disagree that the loss of 1.1 hectares of semi-natural broadleaf woodland is ‘low’ for long term duration, with only a temporary residual impact of ‘minor adverse’ after mitigation. We note that the mitigation proposed includes the planting of replacement woodland to result in ‘no net loss of trees’ following the completion of the works, although planting of trees cannot be undertaken on the cable route itself. We determine this planting is not mitigation and instead forms compensation under the mitigation hierarchy. Given our comments in the above paragraph, we consider the current measures proposed do not sufficiently address the impacts upon semi-natural woodland and that further compensatory habitat is required. The loss of hedgerows during construction will result in gaps of at 16.1 meters for ‘important’ hedgerows and gaps of 32 metres elsewhere, with a worst-case scenario of more than 10km being lost overall. Whilst it is proposed that these hedgerows will be replanted as soon as possible post-construction, there will still be an ensuing period of at least 5-7 years until they re-establish, potentially longer depending on seasonal weather patterns and an inability to prevent deer browsing. We are particularly concerned about the impacts upon foraging and commuting bats and that despite the implementation of the identified mitigation measures, it is stated that the temporary residual impact on this group cannot be reduced below “Moderate Adverse”. It is also stated that all hedgerows where barbastelle were recorded or which had a ‘high’ level of bat usage will be considered ‘Important’ for bats, however it is not clear how the mitigation measures identified will be implemented in these locations, other than reducing the amount of hedgerow removal to 16.1m. Given the above we feel that the mitigation measures proposed do not provide a sufficient level of detail to ensure certainty of impacts on this group and we would expect to see a more comprehensive mitigation package. In combination with other development, this scheme represents a further severance of ecological connectivity within this part of Suffolk and we are not convinced that the current proposals offset this impact. Furthermore, whilst not obligated under NSIP, we would like to see an approach that embeds Biodiversity Net Gain, rather than simply ‘no net loss’.