Hornsea Project Three Offshore Wind Farm

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Hornsea Project Three Offshore Wind Farm

Received 16 July 2018
From The Wildlife Trusts

Representation

The Wildlife Trusts (TWT), with more than 800,000 members, is the largest UK voluntary organisation dedicated to conserving the full range of the UK’s habitats and species. This representation focuses on offshore marine mammal and benthic impacts. However, we also support the Norfolk Wildlife Trust’s submissions regarding onshore biodiversity impacts.

Marine Mammals
TWT has concerns regarding the impact of underwater noise from construction on marine mammals, in particular, cumulative disturbance to harbour porpoise. We have concerns regarding the approach to the cumulative and in-combination assessment. In addition:
1. TWT does not agree with the current proposal on underwater noise management. The science underpinning the approach is weak, it is difficult to deliver and does not encourage noise reduction.
2. Underwater noise should be managed at a regional seas level using noise limits. Noise limits should apply across all construction activities associated with offshore wind farm development. This approach is used in Germany, the Netherlands and Belgium, and should be applied in English and Secretary of State waters, ensuring consistency across the Southern North Sea.
3. Due to cumulative underwater noise impacts, underwater noise mitigation should be conditioned as part of planning consents.
4. Fishing should be included in cumulative/in-combination assessments; it is not part of the baseline.
5. Detailed monitoring of noise levels and harbour porpoise population activity should be undertaken at a strategic level to verify predictions made in planning applications and to provide information for the growth of the offshore wind sector.
6. Strategic mitigation and monitoring should be implemented through a conditioned levy payment which would also establish and support a Southern North Sea underwater noise management steering group.
7. TWT value the relationship developed with applicants during the pre-application stage. Due to the uncertainties on marine mammal mitigation and monitoring at examination, we wish to be named on any associated documents for consultation post-consent e.g. MMMPs, In-Principle Monitoring Plan.

Cabling and benthic impacts
TWT is pleased that that applicant has rerouted the offshore cable to avoid impacts on the chalk reef within Cromer Shoal Chalk Beds MCZ. However, a more detailed assessment on The Wash and North Norfolk Coast SAC is required to give greater certainty of no adverse effect. More realistic expectations on cable burial and protection within the SAC is required, which should be conditioned if consent is granted.

The science to support the impact assessment on ocean quahog is weak. The cumulative impact assessment for ocean quahog does not consider fishing, which is one of the main threats to this species. This should be taken account of in a more detailed assessment.

General:
We have some concerns regarding the assessment methodology and subsequent conclusions drawn across some assessments.

We would also like to raise that fishing is not included in cumulative/in-combination assessments. TWT does not consider fishing to be part of the baseline. Following the commencement of judicial review proceedings by TWT against Dogger Bank Wind farms, we were given assurances that fishing would be included in future offshore wind farm assessments.