Norfolk Vanguard

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.

Norfolk Vanguard

Received 14 September 2018
From Eastern Inshore Fisheries and Conservation Authority


1.0 Role of Eastern IFCA
The role of Eastern IFCA is “to lead, champion and manage a sustainable marine environment and inshore fisheries” in our district, which extends from the Humber to Harwich, and six nautical miles out to sea. The proposed offshore cable route for Norfolk Vanguard Offshore Wind Farm will pass through the Eastern IFCA district. Therefore, given the potential impacts upon inshore fisheries and habitats, it is considered appropriate for Eastern IFCA to provide comment on the Environmental Statement for this development. It should be noted that our interest focuses primarily on the inshore section of the cable route corridor.

2.0 East Marine Plan policy
In all consultation responses the Authority assesses applications according to their adherence with policies detailed in the relevant marine plan, as directed under section 58(1) of the Marine and Coastal Access Act 2009. The plans relevant to the Authority’s district are the East Inshore and East Offshore Marine Plans (HM Government, 2014). We consider whether proposed developments will have a positive, negative or negligible effect on plan policies related to the Eastern IFCA vision.

2.1 Policies BIO1 and MPA1
Any activity that disturbs the seabed has the potential to have negative impacts on habitats and biodiversity. The extent of these impacts is highly dependent on seabed
habitat type, and the nature and extent of the disturbance. The export cable corridor for Norfolk Vanguard Offshore Wind Farm, which is anticipated to have a maximum long-term footprint of 150,000 m2, will run through both the Haisborough, Hammond and Winterton Site of Community Importance (SCI) and the Southern North Sea candidate Special Area of Conservation (cSAC). The cable route will also make landfall at Happisburgh South, close to the south-east border of Cromer Shoal Marine
Conservation Zone (MCZ). Eastern IFCA would like to take this opportunity to note our appreciation for the change in the route to avoid the MCZ.

2.1.1 Haisborough, Hammond and Winterton SCI
The Haisborough, Hammond and Winterton SCI is designated for a series of sandbanks which meet the Annex I habitat description ‘Sandbanks slightly covered by sea water all the time’. It is also designated for Annex I Sabellaria spinulosa reefs. The export cable corridor will run through the SCI, with installation expected to take six months of work, and anticipated cable repairs required at up to 10 km per cable pair at five-year intervals in the SCI. Temporary habitat loss, the remobilisation of sediment and disturbance is likely to result from each set of cable works, reburials and repairs.

We appreciate that Vattenfall have stated its commitment to minimising cable protection where possible within the Environmental Statement, on the back of comments about Policy CAB1 of the East Marine Plan (HM Government, 2014). The worst-case scenario examined still states that up to 4 km of cable protection could be required in the SCI per cable pair if hard substrate is encountered (total of 8 km in the SCI). Cable protection would result in direct habitat loss where protection is placed. We would like to re-emphasize that cable protection works in Haisborough, Hammond and Winterton SCI are extremely undesirable, and are not in keeping with the East Marine Plans. Every effort should be made to maximise the length of cables that are buried and maintain burial over time. Using cable armouring instead of cable burial increases the likelihood of adverse environmental and fishery impacts. For more details on this matter please review the Eastern IFCA response to the Preliminary Environmental Information Report (PEIR) for this development (Section 3.3, Policy CAB1).

We defer to Natural England for formal conservation advice on the impacts of the offshore cable corridor on both sandbanks and Sabellaria spinulosa reefs and measures that could be put in place to mitigate these impacts.

As stated in Eastern IFCA’s response to the PEIR, Vatenfall should note that Eastern IFCA are seeking fishing closures (via a byelaw) to protect sensitive features within the inshore section (within six nautical miles of the shore) of the SCI. These closures are yet to be finalised, but any works in this area will need to proactively take into consideration up-to-date closures and the latest available information on the location of sensitive species and habitats. Eastern IFCA will ensure that any changes to existing fishery closures are duly publicised.

Eastern IFCA is keen to encourage parity by encouraging regulators of non-fishing activities that could damage or disturb sensitive features (e.g. cable laying, remedial works and cable protection) to prevent or at least minimise such activities in areas closed to fishing for the protection of these features.

2.1.2 Southern North Sea Harbour Porpoise candidate SAC
The entire Norfolk Vanguard site, including its export cable corridor, lies within the Southern North Sea cSAC, a European Marine Site designated to protect harbour porpoise under the Habitats Directive as transposed by the Conservation of Habitats and Species Regulations 2010 and the Offshore Marine Conservation Regulations 2007.
Within Eastern IFCA’s response to the PEIR we requested that the impact of the project on sandeels, which are among the most important prey species for harbour

porpoise and which inhabit and spawn in the project area, was further assessed in combination with other plans and projects in the Southern North Sea.
We acknowledge that the Environmental Statement concluded that the potential for the project to significantly contribute to the cumulative impact on sandeel populations (because “the project overlaps with low intensity spawning grounds for this species with high intensity spawning areas located to the north of the project area”). This conclusion was drawn despite medium behavioural sensitivity of sandeels to underwater noise from piling and medium sensitivity of sandeels to permanent loss of seabed habitat during operation.

We defer to Natural England for formal conservation advice on this matter, however we would like to once again highlight Eastern IFCA’s concern about the scale of both licensed and planned offshore activities (particularly aggregate extraction and offshore wind farm construction) in the Southern North Sea, because of cumulative effects these could have on seabed habitats. Sandeels depend on the presence of adequate sandy substratum in which they burrow and are demersal spawners that lay eggs on the seabed. Whilst we appreciate the difficulty in studying potential wide-scale impacts of all offshore activity, this is an important issue worth considering.

2.1.3 Cromer Shoal Chalk Beds MCZ
The Cromer Shoal Chalk Beds MCZ protects a range of seabed habitats, including subtidal chalk reefs, and peat and clay exposures, which provide important habitat and nursery areas for a variety of marine species, including commercially important fish and shellfish species. To meet the conservation objectives of this designation, the general management approach for protected features is to maintain at favourable condition (Defra, 2016). Eastern IFCA agree with the conclusion that the cable corridor, which is located approximately 60 m from the edge of the MCZ, will have an impact of negligible significance on the MCZ, as the MCZ is deemed to be of low sensitivity and the magnitude of impact is negligible. We do however defer to Natural England for formal conservation advice on Cromer Shoal Chalk Beds MCZ.

2.2 Policies EC3 and ECO1
In response to the PEIR, Eastern IFCA stated that we “would encourage further assessment on an ongoing basis of the cumulative impacts of all Southern North Sea wind farm activity, as well as other activities including aggregate extraction activities. The impacts of these projects on the marine environment and fisheries should be assessed in-combination, highlighting any potential cumulative effects associated with the licence application.” While we understand the response from Vatenfall that this is “not within the remit of a single project and would need to be undertaken at a strategic level and under the guidance of Regulators”, we still believe that it is the collective responsibility of all projects to comprehensively assess the cumulative impacts, under the guidance of the Regulators.

Eastern IFCA have already stated that we do not agree that already installed infrastructure and practiced licenced activities should not be included in the cumulative impact assessment. All possible cumulative impacts need to be assessed, regardless of whether an activity is already licenced, installed or otherwise. This should include, but not necessarily be limited to, planned and licensed wind farm and aggregate dredging activity in the Southern North Sea.

2.3 Policies GOV2, GOV3 and FISH1
Thank you for taking into consideration our comments regarding Eastern IFCAs support of the use of a local Fisheries Liaison Officer, the Kingfisher Information Service and Notice to Mariners to minimise disruption to fishers. We appreciate that as described in Section 14.7.1 of the Environmental Statement, Notices to Mariners, Kingfisher notifications and other notices will be issued as required to the fishing community in an efficient and timely manner. We would like to re-emphasise that this communication is extremely important to fishers’ livelihoods and should be carried out on a continuous basis and well in advance of scheduled works and closures during every phase of development. As stated within our response to the PEIR, although the level of fishing effort occurring inshore is much smaller than that applied by larger (predominantly Dutch) offshore fishing vessels, displacement (for example during construction or maintenance works, or because of cable exposure) can have disproportionately large effects on inshore fisheries, which are characterised by small vessels operating within a short range from launch sites.

2.4 Policy FISH2
2.4.1 Electromagnetic fields
Overall impacts of electromagnetic fields (EMF) are assessed as an issue of minor adverse significance to elasmobranch species within the Environmental Statement. In the context of the assessments of EMFs, Vatenfall have stated that “it is important to note that from the results of other post-consent monitoring conducted to date, there is no evidence to suggest that EMFs pose a significant threat to elasmobranchs at the site or population level”. However, we highlight that there are appreciable gaps in the scientific literature as to the potential effects of EMF emissions from subsea cables on marine fauna, and therefore there remain uncertainties in the ability of Vatenfall to determine that there will be no adverse effects on fish and shellfish ecology. Eastern IFCA is particularly concerned about the proliferation of marine electricity cables off the East Anglian coast and the potential – but very poorly understood – impacts on marine life.

Outside of the assessment of EMF impacts on elasmobranchs, Eastern IFCA would like to refer you to the recently published Marine Pollution Bulletin paper by Scott et al. (2018) on the effects of EMF on edible crab, Cancer pagarus. The impact of EMF on crustaceans is another issue worth considering due to the commercial and ecological importance of the edible crab and European lobster, Homarus gammarus, and the recent advance in scientific research on this subject.

3.0 General comments and requests
The provision of GI shapefiles for the proposed cable corridor would be extremely helpful in identifying the location of proposed works in relation to designated features of MPAs that would be affected and in relation to Eastern IFCA’s proposed restricted areas in Haisborough, Hammond and Winterton SCI. It would also be useful to have more detailed timings of the proposed activities as there is often seasonal variation in the sensitivity of some habitat features and the importance of fisheries can vary throughout the year.