Representation by Natural England (Natural England)
- Date submitted
- 17 March 2022
- Submitted by
- Other statutory consultees
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. Natural England confirms that we wish to be registered as an interested party in respect of this Nationally Significant Infrastructure Project. Our relevant representations (submitted separately by email) cover a range of themes and issues within our remit, as follows: • Soils and agricultural land classification (including best and most versatile land) • European Sites • Sites of Special Scientific Interest • Protected species and priority habitats • Biodiversity net gain Natural England’s headline points are that on the basis of the information submitted: • Natural England is satisfied that we generally agree with the findings of the Environmental Statement that construction & operation of the proposed scheme will not have a significant adverse effect on statutory designated sites, subject to embedded and other proposed mitigation measures being detailed and agreed and secured in the DCO. • Agricultural land use and soils: the applicants agricultural land classification (ALC) survey followed published ALC methodology and provided clear justification for correcting existing post-1988 survey data where used. 37.3ha of best and most versatile (BMV) (Grades 1, 2 and 3a in the Agricultural Land Classification (ALC) system) land was identified within the Order limits. We consider that the proposed development, if temporary as described, is unlikely to lead to significant permanent loss of BMV agricultural land, subject to: o The development has a maximum operational life of 40 years o The land is returned to agricultural use at the end of this period o Low disturbance methods are to install the photovoltaic panels o A decommissioning and re-instatement plan is prepared and submitted prior to the panels being removed. • Breckland SPA: we agree with the conclusions in the Environmental Statement that there will be no adverse effect on the integrity of this site however further details are required on the provision, management and monitoring of offsetting habitat for Stone Curlew. • Chippenham Fen and Snailwell Poor’s SSSI, designated as Chippenham Fen Ramsar site, a component part of Fenland SAC; we agree with the conclusions in the Environmental Statement that hydrological, air pollution and impacts to aquatic invertebrates can be ruled out. o However further details are required to validate the conclusion of no adverse effect on the integrity of the site with regards impacts of noise and light pollution. • We welcome the proposals to create biodiverse habitats within the Order limits but details of its construction, long-term management, maintenance and monitoring should be agreed with Natural England and secured in the DCO. o Further information is required to determine the maximum number of Stone Curlew impacted by the proposed development as the surveys carried out did not meet the minimum recommended survey requirements for this species. This in turn will inform the suitability of the quantity and location of offsetting habitat proposed. o Further information is required on the establishment, management and monitoring of offsetting habitat for Stone Curlew for the duration of the construction, operation and decommissioning of the proposed development. o Natural England request input into the detailed habitat creation strategy for the proposed grassland and wetland adjacent to Chippenham Fen with regard to design, habitat creation and establishment methodology, and long-term management. Chippenham Fen is managed by Natural England as a National Nature Reserve. o Further information is required on the provision and management of measures to offset impacts to other protected species and loss of priority habitats. o Further information is required on the status of offsetting habitats at and after decommissioning of the development including securing ongoing management if they are retained. • Snailwell Meadows SSSI: we agree with the conclusions in the Environmental Statement that the proposed development will not damage or destroy the interest features for which the site has been notified • Brackland Rough SSSI: this site is downstream of Sunnica West Site B and no evidence has currently been provided that there will be no hydrological impacts to this site. • Devil’s Dyke SAC and Rex Graham Reserve SAC: further assessment is required to rule out air pollution impacts on these sites from the project in-combination with other plans and projects. • Havacre Meadows and Deal Nook County Wildlife Site: it is not currently clear how impacts to this site will be avoided during the construction of the grid connection route. • Biodiversity Net Gain: calculations have been carried out using the Biodiversity Metric 3.0 but the calculation does not distinguish between mitigation for impacts to statutory designated sites, priority habitats and other mitigation for farmland birds, badger, scarce arable plants and other protected species which should be excluded from biodiversity net gain calculations using the metric. Natural England advises that, if approved, the project must be subject to all necessary and appropriate requirements which ensure that unacceptable environmental impacts either do not occur or are sufficiently mitigated