Representation by National Federation of Fishermen's Organisations (National Federation of Fishermen's Organisations)
- Date submitted
- 21 June 2024
- Submitted by
- Members of the public/businesses
The National Federation of Fishermen’s Organisation (NFFO) represents the interests of commercial fishing businesses in England and Wales. We are registering as an interested party for this project as we feel that there are potential impacts to the commercial fisheries in the proposed area. Commercial fisheries have existed in the proposed region for generations, both UK and EU fleets, and are already faced with extensive spatial restrictions such as existing offshore wind developments, offshore cables, Marine Protected Areas and legislative restrictions in the region. Further displacement of commercial fishing in the region will result in economic harm, through loss of earnings from the ground and additional operating costs due to increased steaming times during construction and operation of the project as well as contributing to the spatial squeeze on fisheries in the region. As with many responses the NFFO generate to wind farm applications, we have concerns about the lack of contemporary and site-specific data presented in the fish and shellfish ecology assessments, and a lack of focus on key commercial species that have a range that overlaps with the development area, specifically shellfish. Data has been presented from other wind farm projects and used to interpret impacts of the Five Estuaries project, often from surveys that have not used the correct methodology for the assumptions made. We feel that the commercial fisheries assessment underestimates the impacts at almost every stage. The assumption that mobile gear vessels can simply move from the area during construction reduces the level of impact these fisheries will feel. This is an oversimplification and demonstrates a lack of understanding of how the fisheries in the region have been squeezed into a smaller and smaller marine space over progressive offshore wind developments, marine legislation and offshore cabling. The spatial squeeze on fisheries in the region is one of the most extensive examples in the UK, this project is directly contributing to this expanding issue. Displacement effects are assessed as not significant for all fisheries assessed; we disagree with this assessment. We welcome the development of a Fisheries Liaison and Co-existence Plan and see this as an integral and important step to minimise and if needed mitigate impacts on the region's fisheries. However, we feel that a Statement of Common Ground will be needed to ensure that the fisheries concerns, that to date have not been accounted for in the assessment, are considered during the decision to consent the Five Estuaries project.