Representation by National Trust (National Trust)
- Date submitted
- 13 June 2024
- Submitted by
- Members of the public/businesses
The National Trust wishes to register as an interested party in respect of the application for a Development Consent Order for the Outer Dowsing Offshore Windfarm Projects. Renewable Energy Development The Trust believes strongly in the need to grow renewable energy and reduce the UK’s and the Trust’s use of fossil fuels. We are supportive of renewable energy as a matter of principle and believe that appropriate development can play an important role. We welcome renewable schemes that are holistically designed to take into account the effects on the environment including wildlife, landscape and cultural heritage including the cumulative effects of similar schemes impacting related species and landscapes. National Trust’s Interest in the Proposal The National Trust’s interest in this application relates to the Applicant’s Habitats Regulations Assessment and the proposal for a ‘without prejudice’ derogation case for guillemot and razorbill in relation to the Flamborough and Filey Coast Special Protection Area, as set out in submitted document APP-259 (7.7.6 Without Prejudice Additional Measures for Guillemot and Razorbill Evidence and Road Map). Paragraph 1 of this document states that the Report to Inform Appropriate Assessment (RIAA; Document 7.1) concluded that there would be no Adverse Effect on Integrity (AEoI) to the common guillemot, Uria aalge (hereafter 'guillemot'), and razorbill, Alca torda features of the Flamborough and Filey Coast (FFC) Special Protection Area (SPA) due to displacement, both when considering the project alone and in combination with other plans or projects. However, paragraph 2 states “Following consultation with Natural England and other relevant consultees through the Evidence Plan Process, the project has however provided a ‘without prejudice’ derogation case for both guillemot and razorbill in relation to the FFC SPA; alongside this, a number of options for Project alone and collaborative compensation measures have been developed as far as possible. In the event that the Secretary of State determines potential for Adverse Effect on Integrity (AEoI) and considers that compensation is required, the Project has provided sufficient confidence that compensation measures are available, securable and deliverable”. It is understood that the primary compensatory measure proposed is predator control at the Plemont Seabird Reserve in Jersey. However, should further compensation be deemed necessary, then further measures discussed in the abovementioned document could also be provided. The document sets out a list of sites selected for compensation. This includes sites owned by the National Trust in Devon and Cornwall. The National Trust has had an initial discussion with the Applicant’s consultants to find out more about the proposed compensation proposals. These are at an early stage of development. Although some initial survey work has been undertaken, further surveys will be carried out over the coming months to inform the proposals. The proposals are not yet developed enough for the Trust to be able to advise whether we would support the compensatory measures on our land in the south-west of England and whether we consider they would be securable and deliverable. The National Trust therefore wishes to register as an Interested Party and will provide updates to the Examining Authority on our position as the compensation proposals are developed in more detail.