Representation by Lincolnshire Wildlife Trust (Lincolnshire Wildlife Trust)
- Date submitted
- 10 June 2024
- Submitted by
- Non-statutory organisations
Lincolnshire Wildlife Trust (LWT) has been actively involved with this application since the pre-application stage, providing written responses to the applicant's published documentation and participating in virtual meetings. LWT has also communicated with other organizations, including other Wildlife Trusts, Natural England, the Environment Agency, and the RSPB. Primary Concerns 1. Cable Route through IDRBNR SAC: o The planned cable route through the IDRBNR SAC does not comply with the Crown Estate’s conditions regarding red risk features. The applicant has stated that “The offshore ECC must pass through the Inner Dowsing, Race Bank and North Ridge SAC,” but we are not satisfied with the reasoning provided or the application of the mitigation hierarchy. 2. Impact on Sandbank Feature: o The applicant inaccurately claims that there will only be a temporary impact on the sandbank feature during the construction phase and due to cable protection. 3. Assessment of Impact on SAC: o LWT disagrees with the assessment of no significant impact on the SAC, particularly regarding cable protection. This assessment does not align with past casework (HO3 decision) and fails to mention the site's unfavorable condition. The recent update from Natural England to the MPA advice package for the site has also not been considered. Pilots show that the site's features (reef and sandbanks) are already in an unfavorable condition due to existing activities, including cabling. 4. Onshore Cable Routing and Grid Infrastructure: o Concerns about the planned onshore cable routing and grid infrastructure. Additional Concerns • Timescales for Projects: Concerns about the project timelines. • Cumulative Impacts to Dogger Bank SAC: Potential cumulative impacts on the Dogger Bank SAC. • Impacts on Nursery/Spawning Grounds: Effects on important nursery and spawning grounds for sandeel, herring, and other ecologically and commercially important fish species. • Biodiversity Net Gain (BNG): Need for proper assessment and commitment to BNG. • Dredging Impacts: Evaluation of dredging impacts and disposal of dredged material. • Noise Impact Modelling: Modelling the impacts of noise and cumulative noise. • Outdated Data: Many referenced datasets are over 5 to 20 years old and not site-specific. LWT insists on current, site-specific data collection. • Inadequate Data from Hornsea Developments: Data from the Hornsea developments, 17 km away, is not suitable for the ODOW project. • Inner Silver Pit: Lack of sufficient evidence on safeguarding this habitat. • Flamborough & Filey Coast SPA and Dogger Bank SAC: Risks of adverse effects on site integrity due to potential impacts on kittiwake birds and sandbank features. • Seal Haul-Out Sites: Potential disturbances to grey seals, particularly at Donna Nook, are underestimated and require careful evaluation. • Fish and Shellfish Ecology: Reliance on outdated and non-site-specific data is inadequate. Updated local data is essential. LWT has provided detailed descriptions of these concerns and recommended measures in our formal written responses to the applicant. We are happy to share these responses upon request. Yours sincerely, Beth Fox Conservation Officer Lincolnshire Wildlife Trust