Representation by National Federation of Fishermen (National Federation of Fishermen)
- Date submitted
- 16 January 2020
- Submitted by
- Non-statutory organisations
The following is offered in response to the submitted application documents: Fisheries Liaison and Coexistence Plan It is noted that a number of fisheries mitigation measures have been identified including the appointment of a Fisheries Liaison Officer and the maintenance of an inshore fishing working group. While this is welcome, we recommend that fisheries liaison and coexistence plan is produced and secured via the DCO Deemed Marine Licence to cover inter alia how the disruption to fishing activities taking place is to be managed. This is relevant particularly given the worst-case scenario of an entire clearance of fishing activities away from the cable corridor. It also provides the basis for clarity in expectations between the applicant and potentially effected fishing businesses and so that appropriate oversight of those expectations may be /maintained. It should, for instance, include the approach for managing any necessary gear clearances and disruption during the construction phase, approaches to addressing any maintenance and remediation works occurring during the course of the project, as well as being a place holder for the full list of other related mitigation measures e.g. such as communicating marine hazards (further covered below). It is noted that this requirement was also included in the scoping opinion response of the MMO (22nd June 2018, p19). We responded to a consultation held by the MMO in May 2018 raising this matter, although this is not reflected in the commercial fisheries consultation responses document. Managing Cable Burial Risk and Fisheries Fisheries and gear types in use along the cable corridor should feature in the cable burial risk assessment with respect to the choice of any cable protection deemed necessary and in the event of cable and with respect to ongoing monitoring arrangements post-installation. Cable protection should be selected and deployed so that it does not constitute a significant risk to the snagging of fishing gears e.g. through the use of a tapered design in the case of rock berms. The fishing industry should be consulted on any choice of cable protection e.g. via the inshore fishing working group or other relevant fishing industry stakeholder depending on the location. Although not listed as a fisheries mitigation measure, the commitment contained in the DCO, Schedule 15 Part 2, Section 2 (12) condition to notify any detected cable exposure to the fishing industry. It is suggested this should also include the detection of sections of cable that are shallow buried and so at risk of contact with fishing gears. The following amendment to the condition is suggested to achieve this (in capitals): (12) In case of damage to, or destruction or decay of, the authorised development seaward of MHWS or any part thereof including [DELETE the] A STATE OF SHALLOW BURIAL OR exposure of the marine HVDC cables the undertaker must as soon as possible and no later than 24 hours following the undertaker becoming aware of any such damage, destruction or decay, notify the MMO, the MCA, Kingfisher Information Service of Seafish and the UK Hydrographic Office. Again, aspects relating to communicating hazard information to the fishing industry should be reflected in a fisheries liaison and coexistence plan.