Thanet Extension 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.

Thanet Extension Offshore Wind Farm

Received 12 September 2018
From Kent Wildlife Trust

Representation

Kent Wildlife Trust (KWT) is the county’s leading nature conservation charity which manages over 60 nature reserves covering over 8,000 hectares across Kent. We are supported by over 31,000 members and some 1,000 registered volunteers. KWT aims to protect and improve habitats in the countryside, coasts, seas and towns for the benefit of wildlife.

This representation focuses on our longstanding strong objection to the onshore cable landfall route, and includes comments regarding offshore cables and monitoring proposals.

Onshore landfall option:

We strongly object to the chosen landfall option of Pegwell Bay due to the direct impacts on its important nationally and internationally designated habitats. Sandwich and Pegwell Bay comprises a National Nature Reserve (NNR), Site of Special Scientific Interest (SSSI), Special Area of Conservation (SAC), Ramsar site and Special Protection Area (SPA). We believe that alternative routes with less of an impact on designated areas have not been adequately assessed. KWT has repeatedly requested the evidence behind the claim made by the applicant that there is ecological parity between the chosen landfall (Pegwell Bay) and other potential (since discounted) landfall options; however the evidence provided to date has been limited.

When an onshore ecological surveying programme was circulated by the applicant, it was stated that ecological surveys would be carried out along two potential onshore cable routes (Pegwell Bay and Sandwich Bay landfall route options). However, the majority of ecological surveys (with the exception of ornithological surveys) were only carried out along one route – the Pegwell Bay landfall route. The applicant has therefore not provided comparative ecological data from other potential onshore options. Full and comparable ecological surveys should have been carried out on both potential onshore routes before the landfall decision was made in order to influence this decision.

Without adequate evidence KWT cannot accept arguments of parity since the original options show high levels of variability in areas of designated onshore and intertidal habitats affected. KWT therefore maintains its overarching objection to this development.

Assessment of Impacts:

KWT do not agree that examining the features of designated sites in isolation (for instance, when conducting recommended Marine Conservation Zone (rMCZ) assessments, SSSI assessments) is sufficient. A more thorough and comprehensive approach is to conduct full assessments which encompass the designated site as a whole, not just the designated features.

The Marine Management Organisation (MMO) has granted permission to the Dover Harbour Board to dredge part of the Goodwin Sands rMCZ, which is in close proximity to the proposed development. Therefore, the applicant will need to evaluate the cumulative impacts of the proposed dredging activity alongside the current proposal.

Benthic Cabling Impacts:

We approve of the turbines and offshore export cable corridor being micro-sited to avoid areas of biogenic reef. However, we would like to see the evidence behind the suggestion that biogenic reefs are likely to reform over the top of buried offshore cables. We seek reassurance that the offshore cables will be buried to a sufficient depth (at least 1m) in order to reduce the impacts of Electromagnetic Field (EMF) on benthic species and reduce the likelihood of the cables becoming exposed.

Monitoring:

We believe that post-construction benthic monitoring should be incorporated into the conditions of the Deemed Marine Licence (DML). This will provide comparative data for pre- and post- construction conditions in and around the windfarm which can be added to existing datasets and literature on UK windfarms to help inform future offshore developments. This would also follow best practice and is a way of examining whether the pre-construction assumptions made by the applicant were accurate.
We suggest that post-construction monitoring of the cable route is carried out to measure the presence or absence of biogenic reefs and species on the sediment overlaying the cables.