Representation by Sussex Inshore Fisheries and Conservation Authority (Sussex Inshore Fisheries and Conservation Authority)
- Date submitted
- 6 November 2023
- Submitted by
- Members of the public/businesses
RE: Rampion 2 Environmental Statement Consultation – Initial Representation Reference Number: DCO/2019/00005 Sussex Inshore Fisheries and Conservation Authority (IFCA) welcomes the opportunity to provide initial comment on the Environmental Statement (ES). Sussex IFCA has inputted to date through participation in the Fish Ecology Expert Topic Group (ETG), as part of the Evidence Plan Process (EPP) and provided comment on the Preliminary Environmental Information Report (PIER). The Authority has also helped inform assessments through the provision of relevant data held. General comments There is a high level of uncertainty regarding the proposed development, due to the extended use of the Rochdale Envelope. This makes it challenging to pass meaningful comments on mitigation measures for installation techniques. Therefore, there is little certainty of the actual environmental impacts of the project and how the developer will mitigate these impacts. Chapter 8: Fish and Shellfish Ecology Through the ETG process Sussex IFCA stressed that site-specific fish and shellfish surveys were considered more appropriate than solely relying on desk-based studies to inform the baseline assessment. Sussex IFCA remain concerned about the lack of up-to-date site-based survey data and the age of the baseline datasets utilised. Black seabream Sussex IFCA have had serious concerns regarding the likelihood of significant impacts to black seabream during the construction, operation, and maintenance of Rampion 2. The proposed mitigation from sedimentation and noise generation has alleviated some of these concerns however, pre-construction site-specific surveys are needed to inform micro-siting of all elements of construction to minimise the environmental impact. The Authority would also welcome clarity around how the Applicant will be held accountable on any commitments made at this stage in the process. The Authority has concerns about the impact of underwater noise in relation to disturbance of black seabream and would like to see a commitment to noise abatement technology during the nesting season. The threshold for disturbance of breeding black seabream is unknown, therefore we suggest a baseline of background noise occurring during a successful nesting season is used to inform a suitable target for noise abatement mitigation to achieve. Herring The impacts from underwater noise to herring is still a serious concern to Sussex IFCA. Herring are deemed highly sensitive, due to a combination of their restricted habitat requirements (they spawn directly onto the seabed) and their sensitivity to underwater sound over large distances. The Authority recommends a seasonal piling restriction to limit disturbance to spawning populations during the spawning season (November-January) or methods such as bubble curtains. The Authority welcomes the opportunity to submit further comments during the examination of the application and wishes to support RWE in determining the scope of the conditional mitigation, the temporal and spatial restrictions together with monitoring requirements of the marine licence. It is important that developments like Rampion 2 should not compromise the Sussex IFCA’s ability to maintain and promote sustainable fisheries and protection of the marine environment within the region. On behalf of the Authority, Yours sincerely, Dr Jen Lewis Sussex IFCA