Representation by Eastern Inshore Fisheries and Conservation Authority (Eastern Inshore Fisheries and Conservation Authority)
- Date submitted
- 11 November 2022
- Submitted by
- Members of the public/businesses
Eastern IFCA provide a response in relation to the export cable route, where it overlaps with the EIFCA district (0-6nm from the coast), and the proposed potential MEEB. In relation to the export cable route: • Eastern IFCA have agreed a byelaw which prohibits bottom towed gears from the majority of the MCZ to protect subtidal chalk features where they outcrop and where they are veneered, based on the potential for veneered chalk features to become exposed. The Applicant propose cable works which have the potential to interact with these subtidal chalk features that Eastern IFCA aim to protect through this byelaw (Closed Area Byelaw 2021). The Closed Area Byelaw 2021 will also protect subtidal mixed, sand and coarse sediment features from mobile fishing gears which will be directly impacted by cable works. • Restrictions to potting grounds and displacement of activities during cable works is of key concern. Further consultation and dialogue with industry is needed to understand the extent to which inshore potters may be impacted by cable works and ways this could be mitigated (e.g., through considering seasonal patterns in activities). Eastern IFCA’s agreed Closed Area Byelaw 2021, once in force, will prohibit bottom towed gears from the section of cable corridor that overlaps with the MCZ but there is potential for displacement of such gears which operate outside of the MCZ. • Whilst the Applicant has assessed the potential impacts of electro-magnetic fields, Eastern IFCA maintain that not enough is known about electro-magnetic field impacts on marine fauna. We do not consider this can be addressed by a single developer; instead, there is a responsibility for the marine cable industry to investigate and conduct research to reduce uncertainty. In relation to the proposed MEEB: • The evidence to suggest that the proposed area has supported Native Oyster beds in the past is limited. There is evidence to suggest that a specific set of conditions are required for beds to establish and be maintained and can be quickly lost if environmental conditions change. A feasibility study is needed. • Discussion with Kent and Essex IFCA who have a similar Native Oyster restoration project within an MCZ have highlighted that the likelihood of restoration efforts achieving densities high enough to maintain a sustainable Oyster fishery is extremely low and, if ever achieved, would take a very long time. • The biosecurity risk associated with diseases such as Bonamia could have implications for other shellfish fisheries in the area and needs to be considered in greater detail. • The management measures proposed in Appendix 1 predict that fisheries restrictions will not be required. However, this requires further consideration; if there is potential for restrictions to be put in place Eastern IFCA would not support the project because of the negative impacts it would have on fisheries and the apparent low likelihood that the bed will provide fishing opportunities in the future. Eastern IFCA’s preference would be for co-location within the windfarm array where inshore fisheries would not be impacted.