Back to list Sheringham and Dudgeon Extension Projects

Representation by Royal Society for the Protection of Birds (RSPB) (Royal Society for the Protection of Birds (RSPB))

Date submitted
14 November 2022
Submitted by
Other statutory consultees

Sheringham and Dudgeon Extension Projects Development Consent Order Application Planning Inspectorate Reference: EN010109 Text of Relevant Representation from the Royal Society for the Protection of Birds (RSPB) 14 November 2022 INTRODUCTION The RSPB supports the deployment of renewable energy projects, providing that they are sited in appropriate places and designed to avoid potential adverse impacts on wildlife. We are grateful for the constructive pre-application discussions that have taken place with Equinor in respect of this proposal, particularly through the Evidence Plan process. While methodological concerns remain, progress towards resolving a number of issues was made during the pre-application discussions for this project. We continue to have significant concerns relating to the project’s in-combination and cumulative collision risk and displacement impacts including their assessment. In respect of the Applicant’s derogation case, there is particular concern regarding the compensation measure proposals. OFFSHORE ORNITHOLOGY IMPACTS - SUMMARY OF RSPB POSITION We have significant concerns regarding the findings of some of the impact assessments and as such consider that an adverse effect on the integrity (AEOI) on the following qualifying features of the Flamborough and Filey Coast Special Protection Area (SPA), North Norfolk Coast SPA or Greater Wash SPA cannot be ruled out: Project in combination with other plans and projects – RSPB AEOI conclusions In-combination impacts on the following features of the Flamborough and Filey Coast (FFC) SPA, North Norfolk Coast (NNC) SPA or Greater Wash (GW) SPA: - Kittiwake: cannot rule out adverse effect on site integrity due to the impact of collision mortality on the Flamborough and Filey Coast SPA population - Gannet: cannot rule out adverse effect on site integrity due to the impact of combined collision and displacement mortality on the Flamborough and Filey Coast SPA population - Guillemot: cannot rule out adverse effect on site integrity due to the impact of displacement mortality on the Flamborough and Filey Coast SPA population - Razorbill: cannot rule out adverse effect on site integrity due to the impact of displacement mortality on the Flamborough and Filey Coast SPA population - Sandwich tern: cannot rule out adverse effect on site integrity due the impact of collision mortality on the North Norfolk Coast and Greater Wash SPA populations - Red-throated diver: cannot rule out adverse effect on site integrity due the impact of displacement on the Greater Wash SPA population Whilst we recognise that the individual contributions from the two extension projects alone may be less than some of the other OWF located nearby, this does not make their cumulative and in combination impacts any less significant. We welcome that a derogation case has been submitted with the DCO application, and this will form the focus of our comments through the examination. We still have some outstanding methodological concerns regarding the assessments, notably for gannet and red-throated diver, and will expand on these at further stages of the Examination. Impact assessment, Flamborough and Filey Coast SPA For gannet, notwithstanding the methodological concerns detailed below, the Applicant’s own combined displacement and collision assessment shows that the FFC SPA population is likely to be 53.5-51.9% lower after the lifetime of the wind farms than it would be without the developments in-combination with other developments, or 30.0-23.6% lower if the macro-avoidance correction factor is applied. In the context of the current outbreak of Highly Pathogenic Avian Influenza there is considerable uncertainty as to the continued viability of this population. As such, it is not possible to rule out an Adverse Effect on the Integrity of the FFC SPA gannet population for the projects in-combination. For kittiwake, the Applicant’s assessment shows that the FFC SPA population is likely to be 20.6% lower in-combination with other developments. Given the FFC SPA restore objective for this species’ population and the vulnerability of the population, both locally and in the wider biogeographic region, the RSPB agrees with the Applicant it is not possible to rule out that an Adverse Effect on Integrity exists in-combination. For guillemot, the Applicant’s own displacement assessment, with probable displacement rate of 60% and mortality rates of 1 and 5%, shows that the FFC SPA population will be 39.4-9.5% lower after the lifetime of the wind farms in-combination with other developments than it would be without the development. As such, it is not possible to rule out an Adverse Effect on the Integrity of the FFC SPA guillemot population for the projects in-combination. For razorbill, the Applicant’s own displacement assessment, with probable displacement rate of 60% and mortality rates of 1 and 5%, shows that the FFC SPA population will be 22.7-5.0% lower after the lifetime of the wind farms in-combination with other developments than it would be without the development. As such, it is not possible to rule out an Adverse Effect on the Integrity of the FFC SPA razorbill population for the projects in-combination. Impact assessment, North Norfolk Coast SPA For sandwich tern, the Applicant’s own combined displacement and collision assessment shows that the North Norfolk Coast SPA population will be potentially 62.4% lower after the lifetime of the wind farms in-combination with other developments than it would be without the development. As such, the RSPB agrees with the Applicant that it is not possible to rule out an Adverse Effect on the Integrity of the North Norfolk Coast SPA sandwich tern population for the projects in-combination. Impact assessment, Greater Wash SPA For sandwich tern, the Applicant has not presented a population viability analysis for the consequences of the mortality arising from displacement and collision. In the absence of this the RSPB is unable to reach conclusions with regard to Adverse Effects on the Integrity of the Greater Wash SPA population for the projects in-combination. For red throated diver, as described below, the Applicant has not fully considered the Conservation Objectives relevant to that population. As such, it is not possible to rule out an Adverse Effect on the Integrity of the Greater Wash SPA population for the projects in-combination. IMPACT ASSESSMENT – METHODOLOGICAL CONCERNS The RSPB’s key concerns with the impact assessment relate to the use of avoidance rates in gannet collision risk modelling, the application of a macro avoidance correction to bird density inputting into CRM, a lack of consideration of impacts compounded by HPAI, and insufficient consideration for the conservation objectives of the Greater Wash SPA with regard to red-throated diver. Gannet modelling For collision risk modelling, the Applicant has presented Avoidance Rates as recommended by the SNCBs (JNCC et al, 2014) Whilst the RSPB agrees with almost all of the SNCB’s recommended rates, we differ with regard to gannet. We are content that 98.9% is suitable for non?breeding birds, but do not agree that this figure should be applied to the breeding season due to the lack of available evidence relating to breeding birds. Furthermore, GPS tracking of gannets breeding on the Bass Rock has shown variation in the two?dimensional foraging behaviour of birds across the breeding season (prior to chick?rearing, and during chick?rearing), between sexes, and between years (Cleasby et al. 2015a, Lane et al. 2020, Lane and Hamer 2021). Three?dimensional tracking of gannets during chick?rearing has revealed that flight height and flight speed both vary according to behaviour, sex and wind conditions (Cleasby et al. 2015b, Lane et al. 2019, Lane et al. 2020,) and similar patterns have been recorded in other seabirds (Masden et al. 2021). As the misspecification of these parameters contributes to the model error component of avoidance rate (Johnston et al., 2021) such variability should result in differential avoidance rates. As such we recommend the use of the default seabird avoidance rate of 98% for gannet during the breeding season. The Applicant has also, in the Report to Inform Appropriate Assessment (RIAA) [paragraph 1456] reduced the density of birds inputted into collision risk modelling by 0.600 to 0.800 to take into account macro avoidance. This approach follows suggestions in Cook (2021), the recommendations from which have not yet been adopted by the SNCBs. Cook (2021) is currently being reviewed and revised by two projects, one funded by JNCC and one by Natural England. Until these projects have reported, the RSPB do not accept this approach. As well as the reliance on a report that has not been placed before the examination, the RSPB also highlights potential issues with this approach, that is, seasonality and within-windfarm avoidance The seasonality point is that, as described above, gannet will show different levels of macro- avoidance dependent on breeding status and the consequent constraints of central place foraging. For within-windfarm avoidance, the revised approach continues to use the “all gulls” avoidance rate for the modelling, while using adjusted densities accounting for macro avoidance. The RSPB considers that within-windfarm avoidance may need to be adjusted to account for the lower manoeuvrability of gannets compared with gulls, and consequent lower ability to take last minute reactive behaviour to avoid rotating turbines. The RSPB is also similarly concerned with the application of a macro avoidance correction factor in the sandwich tern collision risk models. Red-throated diver displacement The conservation objectives for the Greater Wash SPA are: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring; · The extent and distribution of the habitats of the qualifying features · The structure and function of the habitats of the qualifying features · The supporting processes on which the habitats of the qualifying features rely · The population of each of the qualifying features, and, · The distribution of the qualifying features within the site. There is clear evidence of the displacement of red-throated divers from offshore wind farms (e.g. Furness et al. 2013, Mendel et al., 2019) with a significant effect detectable 10-15km from the wind farm (Heinänen et al. 2020). The Greater Wash SPA is 7km from SEP and 16km from DEP. The numbers of red throated divers, their distribution within the SPA and their ability to use all suitable habitat contained in the SPA are relevant to the SPA conservation objectives but are not considered by the Applicant. If red-throated divers are displaced from part of the SPA which would otherwise be suitable for them the effect is to reduce the functional size of the SPA, undermining the conservation objectives. The RSPB therefore cannot rule out the impact of displacement on the integrity of the Greater Wash SPA, arising through the project alone (SEP) and in combination. HIGHLY PATHOGENIC AVIAN INFLUENZA (HPAI) A new virulent form of bird flu, Highly Pathogenic Avian Influenza (HPAI), that originated in poultry in east Asia has now killed tens of thousands of wild birds in the UK and around the world. First confirmed in Britain during winter 2021/22, it has had major impacts on populations of seabirds across Scotland, and there have been an increasing number of confirmed cases appearing across England, including east coast seabird colonies, such as the Flamborough and Filey Coast SPA. There was also significant mortality of Sandwich terns at Scolt Head Island, part of the North Norfolk Coast SPA; a population for which a restoration target has been set. It is currently unclear what the population scale impacts of the outbreak will be, but it is likely that they will be severe. This scale of impact means that seabird populations will be much less robust to any additional mortality arising from offshore wind farm developments. It also means that there may need to be a reassessment of whether SPA populations are in Favourable Conservation Status. With such uncertainty as to the future of these populations, there is the need for a high level of precaution to be included in examination of impacts arising from the proposed development. DEROGATION CASE Based on the RSPB’s conclusions on adverse effect on integrity, the RSPB considers a derogation case is required if the Secretary of State for Business, Energy and Industrial Strategy (BEIS) is to consider consenting a damaging project. The RSPB welcomes the information provided by the Applicant to enable its derogation case to be reviewed. As part of any derogation case, the RSPB considers compensation measures would be required for the following species, should the Secretary of State decide to consent the Application as it is currently proposed: • sandwich tern, • gannet, • kittiwake, • guillemot, and • razorbill. The RSPB welcomes the constructive dialogue by the Applicant with stakeholders to explore potential compensation measures for these species. RSPB APPROACH TO ASSESSING COMPENSATION PROPOSALS The RSPB has reviewed both the EC (2018) and previous Defra (2012) guidance on compensatory measures. Both are in broad alignment as to the principles to adopt when considering compensatory measures. We supplement this based on the RSPB’s practical experience of applying the principles when assessing compensatory measures. We will use the combination of the EC guidance and the RSPB’s experience in this field to assess the Applicant’s compensatory measures. Below, we summarise some of the key elements of that approach before setting out our initial comments on the Applicant’s compensation proposals. These are necessarily initial comments as it is the RSPB’s view that there is still substantive work to be done with regards to the compensation proposals, based on agreement of the nature and scale of predicted adverse effects on integrity. This is critical to inform discussions on: - what ecologically effective compensation for those impacts could comprise; - the options to be considered to provide such compensation; and - the detailed consideration of possible locations and designs to implement ecologically effective compensation with a reasonable guarantee of success. In summary, the criteria for designing compensatory measures include: - Targeted – appropriate to the impact(s) predicted; - Effective – based on best scientific knowledge. Measures where there is no reasonable guarantee of success should not be considered; - Technical feasibility –taking into account the specific requirements of the ecological features to be reinstated; - Extent – directly related to quantitative and qualitative aspects of the elements of integrity likely to be impaired and estimated effectiveness of the measure(s); - Location – located in areas where they will be most effective in maintaining the overall coherence of the National Site Network for the impacted species; - Timing - must provide continuity in the ecological processes essential to maintain the structure and functions that contribute to the National Site Network. Each compensation measure should be fully functional before any damage occurs; - Long-term implementation – legal and financial security required for long term implementation. Must be in place prior to consent being granted. The length of time the compensation measures should be secured for must be based on the combination of the lifetime of the development plus the time it will take the affected seabird population to recover from the impacts. Compensatory measures must be additional to existing obligations e.g. measures necessary to site management of an SPA or SAC to restore or maintain a designated feature to favourable status. We also consider that there must be an appropriate level of detail on the proposed compensation measures provided sufficiently in advance of the start of the examination to enable interested parties to assess it fully. This is critical to enable proper scrutiny of any compensation proposals by interested parties and the Examining Authority. This is summarised below. At this stage, despite the work carried out by the Applicant and the material presented, we do not consider the necessary detail has been provided to enable proper scrutiny of the compensation measures. LEVEL OF DETAIL REQUIRED The RSPB considers it important not to leave all/most of the critical issues to be addressed post-DCO consent. The RSPB considers that detail about the location, design, implementation, monitoring and review of any proposed compensatory measures is needed to: inform the application and examination process and enable proper public scrutiny, including relevant agreements, consents, and permissions. This should provide the Secretary of State with the necessary confidence as to whether those measures can be secured and implemented with a reasonable guarantee of success, thereby protecting the coherence of the National Site Network. We note that these details should be settled before DCO consent is decided, and be available as part of the application documentation. This will enable potential interested parties the opportunity to fully review and assess the adequacy of the compensation measures before deciding whether to formally register as an interested party and submit a relevant representation. The required details include: - Nature/magnitude of compensation: sufficient detail to enable agreement on the scale of compensation required in relation to the predicted impacts, including the detailed compensation objectives, associated success criteria and timeline; - Location: legal securing of proposed compensation sites with ability to scrutinise design, evidence of relevant consents and relevant legal agreements to secure land; - Monitoring and review: detailed monitoring and review packages agreed in advance including terms of reference and ways of working for any “regulators group” to oversee implementation of measure; - Compliance and enforcement: details and evidence of how the proposed compensation measures will be reviewed by the relevant regulator and the legal mechanisms available to those regulators to review and enforce any approved compensation plans. This is especially important if the proposed measures lie outside the jurisdiction of the decision-making authority (as is the case with some of the measures suggested by the Applicant). We consider it is unsafe to assume an outline compensation measure can be translated in to a detailed and workable measure “on the ground” at a later date and all the necessary consents and agreements successfully secured. By providing these details it should ensure these issues are properly addressed before the Secretary of State is required to make a decision on whether to grant DCO consent and ensure, among other things, that it is possible to: - Identify the detailed location and mechanism(s) of the proposed compensation measure; - Identify the relevant consenting and/or licensing mechanisms required; - Identify any potential impacts of the proposed measure on the receptor site(s) and surrounding environment and carry out appropriate screening; - Identify any particular impact assessment requirements necessary which might arise from likely direct and indirect effects of the compensation measure on other receptors; - Be satisfied that the relevant legal consents are secured before any decision on DCO consent. If consent has not been granted, the Examining Authority and Secretary of State would know in advance. The criteria, guidance and associated requirements set out above will guide how the RSPB assesses the compensation measure proposals submitted as part of the application. COMMENTS ON VARIOUS COMPENSATION PROPOSALS The Applicant has summarised its compensation measures in section 5.7 of APP-064 (Appendix 1 – Compensatory Measures Overview). It distinguishes between project-led measures (paragraph 36) versus collaborative and strategic measures (paragraph 37) which may become available. Further detail is provided in separate documents submitted as part of the application. The RSPB will scrutinise each of these measures in detail to assess the amount of weight and confidence that can be placed in each, and to determine whether they are capable of meeting the criteria and level of detail required, as outlined above. However, in general, significantly more detail should be presented to the examination for scrutiny by the Examining Authority and Interested Parties to enable a full assessment of the different compensation proposals, including all the necessary detail, permissions and consents. Below, we make very brief commentary against each species for which compensation measures have been proposed, highlighting some of the issues raised by review of the application documents. Further detailed submissions will be made in the RSPB’s written representation. Sandwich tern Sandwich tern compensation measures are outlined in APP-069 (Sandwich Tern Compensation Document). - Nesting habitat improvements and restoration of lost breeding range at Scar Point, Loch Ryan (project led) – see comments below. - Improved breeding success at SPA sites other than NNC - Farne Islands SPA (project-led). - Prey enhancement through sandeel stock recovery and sprat stock protection and ecosystem-based management (strategic): no specific mechanism is presented for securing this measure, therefore the RSPB considers little or no weight can be placed on it at this stage. We support the conclusion that an AEOI on integrity of the Greater Wash SPA and North Norfolk Coast SPA cannot be ruled out. We agree that management measures considered within the North Norfolk Coast and other SPAs cannot be considered compensation measures, as they should form management necessary to restore and maintain Sandwich terns in favourable condition; additionality cannot be demonstrated. We have engaged with the developer over delivery of new sites for Sandwich terns. We have some concerns about the Loch Ryan proposal which appears to be constrained by rising land and woodland and the Applicant acknowledges there is uncertainty about whether or not Sandwich terns would recolonise Loch Ryan if provided with restored breeding habitat, and how quickly this may occur. We consider the compensation package should include a greater number of sites to provide confidence that sufficient capacity will be created to accommodate Sandwich terns and ensure that suitable options are available for birds to have options to breed and build resilience into the SPA network. The addition of a single site will make limited contribution to addressing the resilience. Our comments through the Examination will focus on the Sandwich tern evidence base, the assessment assumptions and conclusions, and the quality and appropriateness of the compensation package to address impacts on Sandwich terns. Kittiwake Kittiwake compensation measures are outlined in APP-072 (Kittiwake Compensation Document). - Nest site improvements to enhance breeding success: relies on demonstrating improved breeding success in urban locations where success is argued to be constrained by human disturbance or predation. Potential locations suggested (e.g. in Lowestoft and Tyne) but none apparently secured at the time of the application. Challenges include but are not limited to: demonstrating improved breeding success over the long-term against a detailed evidential baseline, demonstrating additionality against other kittiwake nesting initiatives already underway in selected locations. - Construction of new artificial breeding sites (onshore or offshore): the RSPB notes and agrees with the Applicant’s comment that concerns have been raised by stakeholders around the potential for diminishing returns with an increased number of new artificial nesting structures for kittiwakes. Such measures are currently unproven as compensation measures e.g. delivering against an agreed set of compensation objectives. In addition, there is significant legal uncertainty at this time in respect of the ability to repurpose offshore structures for this use as the view of BEIS and the Offshore Petroleum Regulator for Environment & Decommissioning (OPRED) has not been established at this point. - Prey enhancement through sandeel stock recovery and ecosystem-based management (strategic): no specific mechanism is presented for securing this measure, therefore the RSPB considers little or no weight can be placed on it at this stage. Should more detail be presented the RSPB will review its position. Guillemot and razorbill Compensation measures for guillemots and razorbills are set out in APP-074 (Gannet Guillemot and Razorbill Compensation Document). We note that for two of the measures the Applicant relies, in part, on submissions made by Hornsea Project Four, without reference to the detailed and critical comments by the RSPB and Natural England on those proposals. - Bycatch reduction (project-led and collaborative): the applicant refers to various possible measures to achieve bycatch reduction, although no specific measure with the necessary detail is proposed to enable a proper assessment as compensation. Any proposal must be evidenced and specific to a particular fishery in order to determine if it will result in sustained bycatch reduction for each species beyond the lifetime of the OWF. This typically requires multi-year trials which have not been carried out prior to application. Therefore, the Applicant’s claim of there being no delay to compensation delivery are not proven. Reference is made to use the use of looming eye buoys (LEB) as one potential measure. LEBs are an experimental prototype measure that has been developed by the RSPB/BirdLife International in collaboration with Fishtek Marine. It has not been proven to be an effective measure for bycatch reduction with respect of guillemot and razorbill at the time of writing. The Applicant appears to place reliance on claims made by Orsted in its submissions to the Hornsea Four examination. The RSPB carefully reviewed the evidence presented by Orsted, was highly critical of it and considers that at this stage little weight can be placed on it as a viable compensation measure (see sections 6 and 9 of the RSPB’s REP6-069 to the Hornsea Four examination). - Predator eradication from a breeding colony (collaborative): no specific measure is proposed by the Applicant. Reference is made to proposals by Hornsea Project Four in respect of Guernsey, again without reference to the detailed comments made by the RSPB and Natural England on those proposals at the end of the examination. The RSPB’s REP6-069 to the Hornsea Four examination sets out its detailed concerns with those proposals. As such, little weight can be placed on it as a viable compensation measure at this time. - Prey enhancement through sandeel stock recovery (strategic): no specific mechanism is presented for securing this measure, therefore the RSPB considers little or no weight can be placed on it at this stage. Should more detail be presented the RSPB will review its position. Gannet Compensation measures for gannet are set out in APP-074 (Gannet Guillemot and Razorbill Compensation Document). - Enhance the conservation of wintering and migrant shorebirds and waterfowl at Loch Ryan, Scotland (non like-for-like compensation): this cannot be considered as compensation. It is not compliant with the requirement to protect the overall coherence of the National Site Network for gannet. The RSPB notes the Applicant refers to draft Defra guidance, which has not been published in final form. The RSPB was highly critical of the element of Defra’s draft guidance relied on by the Applicant as the RSPB considers it does not comply with the legal requirements for compensation under the Habitats Regulations as such measures cannot protect the overall coherence of the National Site Network for the impacted species. - Bycatch reduction (project-led and collaborative): this comprises a research proposal to establish the scale and pattern of bycatch of gannet in Portuguese waters and to investigate the merits of different bycatch reduction measures. The RSPB recognises there is a need for such research. However, it does not comprise a feasible compensation measure for any predicted adverse effects on integrity on FFC SPA gannets. Such research will take many years to complete and may not produce viable bycatch reduction measures. Therefore it cannot be relied on as a compensation measure at this stage and we cannot see how this will change prior to the end of the examination. Red-throated diver The species could be affected by vessels moving through the northern section of the Outer Thames Estuary SPA from Great Yarmouth and also affected by vessel movements and turbine construction in the Greater Wash SPA. We will set out fuller comments on these and other issues relating to the Applicant’s derogation submissions in our main written submission. Finally, the RSPB reserves the right to add to and/or amend its position in light of changes to or any new information submitted by the Applicant. REFERENCES Cleasby, I.R., Wakefield, E.D., Bodey, T.W., Davies, R.D., Patrick, S.C., Newton, J., Votier, S.C., Bearhop, S., Hamer, K.C. 2015a. Sexual segregation in a wide-ranging marine predator is a consequence of habitat selection. Marine Ecology Progress Series, 518, 1-12 Cleasby, I.R., Wakefield, E.D., Bearhop, S., Bodey, T.W., Votier, S.C., Hamer, K.C., 2015b. Three-dimensional tracking of a wide-ranging marine predator: flight heights and vulnerability to offshore wind farms. Journal of Applied Ecology, 52, 1474–1482. Cook A.S.C.P. (2021) Additional analysis to inform SNCB recommendations regarding collision risk modelling. BTO research report 739 EC (2018) Managing Natura 2000 sites – The provisions of Article 6 of the ‘Habitats’ Directive 92/43/EEC (21/11/18) C(2018) 7621 final. Due to the further details this EU guidance provides, we believe it is important to also consider along with the Defra guidance Furness, R. W., Wade, H. M., & Masden, E. A. (2013). Assessing vulnerability of marine bird populations to offshore wind farms. Journal of environmental management, 119, 56-66. Heinänen, S., Žydelis, R., Kleinschmidt, B., Dorsch, M., Burger, C., Mork?nas, J., Quillfeldt, P. and Nehls, G., 2020. Satellite telemetry and digital aerial surveys show strong displacement of red-throated divers (Gavia stellata) from offshore wind farms. Marine environmental research, 160, p.104989. Joint Nature Conservation Committee (JNCC), Natural England (NE), Natural Resource Wales (NRW), Northern Ireland Environment Agency (NIEA), Scottish Natural Heritage (SNH) 2014, Joint Response from the Statutory Nature Conservation Bodies to the Marine Scotland Science Avoidance Rate Review Johnston, D.T., Thaxter, C.B., Boersch-Supan, P.H., Humphreys, E.M., Bouten, W., Clewley, G.D., Scragg, E.S., Masden, E.A., Barber, L.B., Conway, G.J., Clark, N.A., Burton, N.H.K., Cook, A.S.C.P. (2021) Investigating avoidance and attraction responses in lesser black-backed gulls Larus fuscus to offshore wind farms. Marine Ecology Progress Series, prepress online Lane, J.V., Spracklen, D.V., Hamer, K.C., 2019. Effects of windscape on three-dimensional foraging behaviour in a wide-ranging marine predator, the northern gannet. Marine Ecology Progress Series, 628, 183–193. Lane, J.V., Jeavons, R., Deakin, Z., Sherley, R.B., Pollock, C.J., Wanless, R.J., Hamer, K. C., 2020. Vulnerability of northern gannets to offshore wind farms; seasonal and sex-specific collision risk and demographic consequences. Marine Environmental Research. 162 Lane, J.V. and Hamer, K.C. 2021. Annual adult survival and foraging of gannets at Bass Rock, Scotland: Report to the Ornithology subgroup of the Forth and Tay Regional Advisory Group (FTRAG-O) – October 2021Masden, E. A., Cook, A. S., McCluskie, A., Bouten, W., Burton, N. H., & Thaxter, C. B. (2021). When speed matters: The importance of flight speed in an avian collision risk model. Environmental Impact Assessment Review, 90, 106622. Masden, E. A., Cook, A. S., McCluskie, A., Bouten, W., Burton, N. H., & Thaxter, C. B. (2021). When speed matters: The importance of flight speed in an avian collision risk model. Environmental Impact Assessment Review, 90, 106622. Mendel, B., Schwemmer, P., Peschko, V., Müller, S., Schwemmer, H., Mercker, M., & Garthe, S. (2019). Operational offshore wind farms and associated ship traffic cause profound changes in distribution patterns of Loons (Gavia spp.). Journal of environmental management, 231, 429-438 RSPB (2022) REP6-069. RSPB Deadline 6 submission to Hornsea Project Four examination: Annex B: Compensation Proposals. Comments on selected Deadline 5 and Deadline 5a submissions. 27 July 2022.