Representation by Essex Wildlife Trust (Essex Wildlife Trust)
- Date submitted
- 21 June 2024
- Submitted by
- Members of the public/businesses
Essex Wildlife Trust is the county’s leading conservation charity, committed to protecting wildlife and inspiring a lifelong love of nature. Founded in 1959 by volunteers, we protect over 8,400 acres of land across 88 sites and are supported by 39,000 members. We are an evidence-based organisation, applying relevant legislation and policy in tandem with our specialist expertise to assess the impacts of development on wildlife and habitats. We manage several nature reserves bordering and within the following statutory designated sites, all of which have undergone an assessment of Likely Significant Effects (LSE) as part of the scheme’s HRA process: • Outer Thames Estuary SPA • Essex Estuaries SAC • Colne Estuary SPA/Ramsar • Hamford Water SAC/SPA/Ramsar • Abberton Reservoir SPA/Ramsar • Stour and Orwell Estuaries SPA/Ramsar • Blackwater Estuary SPA/Ramsar We also have an interest in the state of the marine environment in the inshore and offshore zones of the North Sea off the Essex Coast, including the Southern North Sea SAC, with an aspiration for 30% of our land and seas to be well managed for nature by 2030. While currently there are 178 Marine Protected Areas (MPAs) in English waters, covering 51% of inshore and 37% of offshore waters, few of these are subject to positive management measures. The world is experiencing a climate and biodiversity emergency. Wildlife, habitats and ecosystem functions are under ever-increasing stress and destruction from development, land use changes and the climate emergency. In the UK alone, 41% of species are in decline, 15% are under threat of extinction and there has been a 13% fall in the abundance of nature since 1970. It is therefore vital that development plays its part in mitigating its own impact and contributing positively to nature’s sustained recovery. We support action to tackle climate change and recognise the serious threat to nature if action is not taken. However, fulfilling UK ambitions for green energy infrastructure as a major decarbonisation pathway to limit climate change will fail if they do not achieve environmental protection, recovery, and enhancement of marine and terrestrial habitats, species, and carbon stores. The scale of OWF planned in the North Sea makes it one of the most significant activities with the potential to impact on wildlife and ecology in our coastal waters and the wider North Sea, arguably second only to fishing. To realise the potential contribution of OWF to decarbonising the energy sector and helping to mitigate the worst impacts of climate change on society and nature, it must protect and support nature’s recovery on land and at sea. The Wildlife Trusts (TWT), of which Essex Wildlife Trust is a member, have long advocated for greater strategic coordination in the planning, design, and delivery of offshore electricity generation together with the offshore and onshore electricity transmission infrastructure needed to distribute electricity generated offshore to where it is needed, to reduce environmental and consenting risks. To this end TWT was represented on the Offshore Transmission Network Review (OTNR) Expert Advisory Group and participated in strategic forums such as the Offshore Wind Evidence and Change (OWEC) Programme. RWE and VE should have regard to the findings of the OTNR and other relevant strategic forums and where possible incorporate their recommendations on reducing adverse impacts on marine and terrestrial ecology. Better coordination of offshore energy generation and transmission infrastructure will reduce the consenting risks and delays that have faced recent OWFs. Strategically planned offshore energy generation and electricity transmission infrastructure (including onshore elements) provides the opportunity for strategic approaches to compensating for residual environmental impacts that cannot be avoided or adequately mitigated. There is significant potential for such measures to have a greater overall positive impact on the environment and biodiversity and take compensation beyond the level of no net loss into achieving net positive effects. Whilst we recognise that Biodiversity Net Gain policies and delivery frameworks are more developed for terrestrial and intertidal habitats than they are for the marine environment, we would still expect VE to aim to achieve an overall net positive impact on biodiversity and ecology in the marine environment. We will be examining the Developer’s application to determine whether, in our view, RWE and VE have fully explored opportunities for strategic compensation and enhancement approaches and measures to contribute to realising this aim. The areas of concern we wish to address through the DCO process are: • Impacts on Margate and Long Sands SAC • Impacts on the Southern North Sea SAC • Impacts on the Outer Thames Estuary SPA • Impacts on the Essex Estuaries SAC • Impacts on the Colne Estuary SPA/Ramsar • Impacts on Hamford Water SAC/SPA/Ramsar • Impacts on Abberton Reservoir SPA/Ramsar • Impacts on the Stour and Orwell Estuaries SPA/Ramsar • Impacts on the Blackwater Estuary SPA/Ramsar • Impacts on terrestrial habitats and protected species, including the Great Holland Pits Local Wildlife Site (LoWS) and EWT nature reserve Topics that we wish to comment on include: • Physical habitat loss and/or disturbance • Marine mammals, including Harbour Porpoise (underwater noise, collision risk, changes to prey distribution and abundance) • Ornithological impacts both offshore and onshore • Impacts on terrestrial mammals, including Bats, Hazel Dormice, Otters, Water Voles and Badgers • Impacts on Reptiles and Amphibians • Impacts on benthic and intertidal ecology • Impacts on fish and shellfish • Impacts on Fisher’s Estuarine Moth • Offshore mitigation and compensation proposals • Onshore Biodiversity Net Gain (BNG) proposals