Representation by Norfolk Wildlife Trust (Norfolk Wildlife Trust)
- Date submitted
- 14 November 2022
- Submitted by
- Members of the public/businesses
Offshore 1. Avoidance of chalk reef features of the Cromer Shoal Chalk Beds (CSCB) Marine Conservation Zone (MCZ) ¬– we support the commitment to avoid all the exposed chalk features of the MCZ. Evidence to verify this should be provided to regulators during construction. 2. Long term habitat losses to cable protection – we welcome the commitment by the developer to minimise the use of cable protection in the MCZ but remain concerned at the potential cumulative impacts of habitat loss to this when considered alongside existing losses within the MCZ from other energy and similar infrastructure. 3. We note the worst case scenario of 1,800m2 of long-term habitat loss to rock armour and similar. Whilst described in the applications documents as only a small percentage of the total area of the MCZ (and below any % significance threshold), this must be considered cumulatively with the other pressures on the soft sediment features of the MCZ (from existing hard infrastructure and cable protection from other offshore wind and oil and gas developments and fishing activity). We also seek clarification regarding the 1800m2 worst case scenario and whether it includes operational requirements or just installation. Whilst it is recognised that neither of the original Sheringham and Dudgeon wind farms have not had to undergo any reburial or repair operations to date, operations-phase requirements must be included in the application to assess the long-term impacts on the MCZ. 4. Measures of Equivalent Environmental Benefit (MEEB) - MEEB Option 1, Oyster Bed Planting. a. We welcome that the project has committed to monitoring for the lifetime of the project in order to deliver against the conservation objectives. As provision of MEEB is in the public interest, it is important that the monitoring data is made publically available for transparency and to further the development of best practice in the industry. b. We are concerned that the preferred option, provision of new oyster beds, will not provide equivalent ecological function to the features of the MCZ that would be lost or damaged. Defra best practice guidance (Defra, Best practice for developing compensatory measures in relation to Marine Protected Areas, 2021) states that MEEB should address the specific damage caused by the permitted activity and focus on providing the same ecological function or where this is not technically possible, provide functions and properties that are comparable to those that originally justified designation. We maintain the position previously expressed by the Wildlife Trusts that this would not provide either the same ecological function as subtidal coarse sediment, subtidal mixed sediments and subtidal sand or provide functions and properties that are comparable to those that originally justified designation. Therefore it is difficult to see how this could be determined to be MEEB as per the Defra guidance. c. Due to our concerns regarding the differing ecological function of the developer’s preferred MEEB option, we repeat our previous recommendation that avoidance options should be considered further. 5. MEEB alternatives: a. Whilst the developer has indicated a preference for the oyster bed MEEB option, other alternatives have not been absolutely ruled out. We are not supportive of the following options: i. Removal of anthropogenic features – marine litter/debris removal; ii. Site extension/designation; and iii. Removal of anthropogenic features – disused b. We are particularly concerned and strongly do not support the inclusion of the Removal of Marine Litter, due to the challenges this measure has caused for other recent offshore wind farms where it has been consented as a compensatory measure. Onshore Ecology & Ornithology – Chapter 20 6. We support the proposed use of HDD under features of ecological importance to avoid impacts entirely. 7. Whilst Impact 12 correctly identifies the impacts on bat commuting routes from the need to maintain easements at points where the terrestrial cable route crosses hedgerows or similar linear habitats, we strongly disagree with the characterisation and estimation of the impact scales in paragraphs 306-307 of this chapter. 8. Where sections of such routes are lost to open space, for bat species which are reluctant to cross open space due to fear of predation the necessary change in commuting routes will increase energy costs and place extra stress on the colonies that rely on them. Paragraph 307 describes the impact as ‘potential disruption of commuting and/or foraging bats being experienced across more than one active bat season and therefore may affect access to feeding locations or potentially temporary or maternity roosts that may be located outside the SEP and DEP DCO limits’. Where the text refers to ‘more than one active season’ this should actually refer to the long term impacts that would occur over the multiple decades of the operational phase. In addition, supporting information on the likely impacts on maternity colonies and other roost sites outside of the DCO limit but functionally linked and dependent on the commuting routes impacted within the DCO limit appears to be absent. Paragraph 308 states that the impact is only of ‘localised disturbance and/or loss of habitat, that does not threaten the long-term viability or function of the receptor’ but no supporting information on the presence or absence of receptor maternity colonies or similar in functionally linked areas outside the DCO limit has been provided, and therefore we seek clarification regarding the evaluation of the impact as minor as we believe this to be incorrect. 9. The terrestrial Outline Ecological Management Plan notes a potential moderate adverse impact on Hall Hills/ Ringland Covert County Wildlife Site depending on the level of post-construction enhancement that can be agreed with the landowner. Clarity is sought on the proposed mitigation and compensation measures needed should agreement not be possible with the landowner.