“The National Federation of Fishermen’s Organisation (NFFO) represents the interests of commercial fishing businesses in England and Wales. We are registering as an interested party for this project as we feel that there are potential impacts to the commercial fisheries in the proposed area. Please treat this submission of an Interested Party as a response from both the NFFO and Welsh Fishermen’s Association (WFA_CPC). The WFA-CPC are members of the NFFO and have concerns as well as our other regional members. Commercial fisheries have existed in the proposed region for generations, both UK and EU fleets, and are already faced with extensive spatial restrictions such as existing offshore wind developments, offshore cables, Marine Protected Areas and legislative restrictions in the region. Further displacement of commercial fishing in the region will result in economic harm, through loss of earnings from the ground and additional operating costs due to increased steaming times during construction and operation of the project as well as contributing to the spatial squeeze on fisheries in the region. As with many responses the NFFO generate to wind farm applications, we have concerns about the lack of contemporary and site-specific data presented in the fish and shellfish ecology assessments, and a lack of focus on key commercial species that have a range that overlaps with the development area, specifically shellfish. Data presented from surveys to characterise sediment composition is presented as the correct methodology for sampling fish and shellfish, an incorrect assumption. Data has been presented from other wind farm projects and used to interpret impacts of the Morgan Transmission Assets project, often from surveys that have not used the correct methodology for the assumptions made. The assumption of commercial fisheries, specifically mobile gear, being able to return to the area post construction is used to reduce the impacts assessed. However, there is little evidence from current operational wind farms that mobile gear has returned to activity levels similar to pre-construction. Whilst there is some evidence of mobile gear operating in wind farms, this is only at the single vessel level and not at a fleet level. We feel that the assumption of no displacement effects observed during construction for all the different fishing gear sectors is vastly underestimated, assessed as negligible on all occasions. The only justification for this seems to be they can disperse into other areas. This is not the case, especially in areas such as this, with extensive existing offshore developments, alongside legislative and conservation restrictions and two other wind farm developments being constructed in the region. Displacing a diverse fishing fleet into an already crowded marine space will have an impact on those fishing businesses. We welcome the development of a Fisheries Liaison and Co-existence Plan and see this as an integral and important step to minimise and if needed mitigate impacts on the region's fisheries. However, we feel that a Statement of Common Ground will be needed to ensure that the fisheries concerns, that to date have not been accounted for in the assessment, are considered during the decision to consent the Morgan Generation Assets project.”