Hornsea Project Three Offshore Wind Farm

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Hornsea Project Three Offshore Wind Farm

Received 20 July 2018
From The Royal Society for the Protection of Birds

Representation

Relevant Representation for the Royal Society for the Protection of Birds

Our involvement with Hornsea Project Three
The Royal Society for the Protection of Birds (the RSPB) has been involved with the Hornsea Three project as a member of the Onshore Ecology and Offshore Ornithology Expert Working Groups (EWG). This involvement follows the RSPB’s engagement and attendance at the Examinations of Hornsea Project One and Two.

Through this process we have endeavoured to inform the design of the scheme to minimise the risk of harm to the natural environment and in particular its ornithological interests. Despite welcome constructive pre-application consultation and discussions, serious concerns with the offshore aspects of the Application remain.

Onshore Ornithology
The RSPB considers that further, inexpensive measures, can (and should) be undertaken by Ørsted to ensure that the construction of the export cable route avoids possible adverse effects on the pink-footed goose population of the North Norfolk Coast SPA and Ramsar site. We will continue to discuss this with Ørsted in the hope that it will be possible to secure these measures.

Offshore Ornithology
The Project site lies within the foraging range of seabirds from the Flamborough Head and Bempton Cliffs Special Protection Area (SPA), designated for kittiwake and England’s only gannet breeding colony. The proposed revision of this SPA (the Flamborough and Filey Coast pSPA) is likely to result in a boundary extension and adding gannet, guillemot, puffin and razorbill to the qualifying features. In relation to the Hornsea Three project we are concerned about the potential impacts on gannet, guillemot, kittiwake and razorbill (all SPA or pSPA species).

Offshore the issues are more fundamental and far more significant in terms of the project, concerning the methodologies used to assess the risk of harm to seabirds and the use of those outputs to evaluate the likely impacts of the scheme.

Methodology
In particular:
• We remain concerned that the survey effort across the Hornsea Three area has been inadequate with only 20 months being undertaken (an improvement from the 12 originally suggested). We welcome the work undertaken at the recommendation of the RSPB and Natural England (NE) reviewing historical boat-based survey work for Hornsea One and Two but this, while welcome, does not provide sufficient evidence that a minimum of two complete years of survey data, as recommended by NE and the Joint Nature Conservation Committee, was not necessary.
• We do not agree with breeding guillemot and razorbill being screened out from the assessment. While we agree that it is unlikely that birds recorded at the proposed development site are breeding birds from the pSPA, it remains likely that a large proportion of these birds are associated with the pSPA colony, such as juveniles and non-breeders that will subsequently breed at the colony. The pSPA is the closest breeding colony to the site therefore birds present in the breeding season are most likely an important constituent of that colony and must be considered in the assessment.
• We also do not agree that herring gull should be screened out of the Environmental Impact Assessment. While Hornsea 3 lies outwith the mean maximum foraging range presented in Thaxter et al., (2012), the species is currently red listed in Birds of Conservation Concern and considered to be at a high risk of collision. Numbers in the Hornsea 3 survey area can be relatively high in the breeding season (221 in June 2017), therefore further consideration should be made in the assessment.
• We have concerns about the manner in which biological seasons have been defined by Ørsted’s consultants. These should follow the definition of ‘Breeding Season’ as presented in Furness (2015), not ‘migration free breeding season’ except where colony specific evidence suggests otherwise.
• We do not agree with the way Ørsted’s consultants have used the Band Extended Model and Avoidance Rates to calculate the likely collision risk impacts for gannet and kittiwake. The 2014 BTO Avoidance Rate Review Report, commissioned by Marine Scotland, and the subsequent peer reviewed paper (Cook et al,2018) demonstrated that insufficient information exists for a robust Avoidance Rate to be set for gannet and kittiwake for use with the Band Extended Model. Consequently, and as recommended by the Statutory Nature Conservation Bodies (SNCBs) Option 3 of the Band Extended Model cannot be used to calculate the collision risk for these species. Despite this, the approach is used by the Applicant in their Habitats Regulations Assessment document. Furthermore, the assessment fails to use the Avoidance Rate for kittiwake with the Basic Band Model as recommended by the SNCBs.
• We do not agree with the changes in Nocturnal Activity Factor, a parameter used in collision risk modelling, for kittiwake and gannet. The supporting analysis does not include all available data and, does not account for the distinction between the definition of daylight as used in the Band Model and with the official concept of ‘twilight’ and ‘night’, including civil, astronomical and nautical twilight. Nor does it account for the potential interaction between survey timing and diurnal behavioural patterns. Seabird foraging activity often peaks at first and last light. There is a danger that these peaks are not accounted for in the assessment either because they have been removed from the analysis by an overly simplified definition of day and night or because the survey was carried out at a time of much lower activity
• We have concerns with the correction factors applied to in-combination assessment estimates of mortality. These are to ‘correct’ for the differences in the consented and as-built scenarios for other offshore wind farms and for perceived inaccuracy in the Nocturnal Activity Factors applied to gannet and kittiwake collision risk estimates. These corrections represent an oversimplification, failing to distinguish between projects that still have permission to theoretically build out to consented capacity or where a new consent would be needed for further development. In addition, the changes in Nocturnal Activity Factor are not justified as discussed above and it is likely that this has led to the in-combination impacts of the scheme being downplayed.
• We continue to disagree (as we did with Hornsea One and Two) about the Apportioning Rates used to evaluate the proportion of the guillemot, kittiwake and razorbill populations in the Hornsea Three area that will have come from the Flamborough and Filey SPA/ pSPA. The analysis is not suitably precautionary and does not fully take account of all available tracking data.
• The Population Viability Analysis model used to evaluate the impacts of Hornsea Three on the gannet and kittiwake populations of the pSPA (and SPA in the case of kittiwake) have been run over only 25 years, whereas Ørsted are seeking approval for the scheme to run for 35 years. If the model is updated accordingly the impacts on gannet and kittiwake will be higher.

These and other areas of disagreement between the RSPB and Ørsted have been aired extensively at the Hornsea Project One and Two Examinations and, despite these extensive discussions there remains significant differences of opinion between the parties as to how the impacts should be assessed. As mentioned above the RSPB is grateful for the helpful pre-application discussions and we are continuing to discuss and explore options with Ørsted to ensure that the Examining Authority has all the information it needs to consider the issues without unnecessarily consuming Examination time.

Offshore ornithology impacts
As a result of the methodology concerns set out above, the RSPB considers that the impacts have not been adequately assessed and, as such do not consider that the risk of an adverse effect on the integrity of the SPA/pSPA and its species can be ruled out, alone or in-combination:
• The impact upon the kittiwake population of the SPA/ pSPA alone and in-combination with other plans and projects.
• The impact upon the gannet population of the pSPA in-combination with other plans and projects.
• The screening out of the breeding guillemot and razorbill population of the pSPA means that the Habitats Regulations Assessment has not considered the impacts of Hornsea Three upon these species.

In addition, we do not think that herring gull should not have been screened out from the Environmental Impact Assessment.

Conclusions
For the reasons outlined above, we consider that it is not possible to ascertain no adverse effects on the integrity of the SPA/pSPA and its species, alone or in-combination.