Request for review of the South Hook draft HRA Screening Report.

1. Project description
1.1 Table 1.1 of the draft HRA Report identifies four main modes of operation, and assigns each one a scenario number. However, Appendix B (Screening of aerial emissions on SPAs/SACs and assessment of total Nitrogen mass balance) refers to two different scenarios; ?A? and ?B?. It is recommended that the operating scenarios are consistently referred to throughout all application documents.
2. The study area
2.1 The draft HRA Report states that the list of sites to consider in the HRA was agreed with CCW and EAW (paragraph 2.1.1). Evidence of this agreement should be provided.
2.2 It is recommended that Figure 2.1 uses colours which make it easier to differentiate Castlemartin Coast Special Protection Area (SPA) from Skokholm and Skomer SPA.
3. Appendix A ? Screening Matrices
3.1 For ease of reference, it is recommended that each matrix includes a descriptor of the effect, rather than ?Effect 1?, ?Effect 2?, ?Effect 3? etc.
3.2 The matrices key states that the grey shading refers to effects ?not applicable to a particular feature?. This description is misleading given that further consideration has been given to these features within the Matrices and the draft HRA Report, and footnotes have been provided. The description of the grey shading provided within paragraph 3.5.2 of the draft HRA Report is more applicable and should be inserted into the matrices to avoid confusion.
3.3 Each effect that has been screened out of the matrices should have a footnote providing a justification to this conclusion.
3.4 The draft HRA Report has considered the potential impacts of noise and vibration separately from lighting; it is therefore recommended that this is reflected within the matrices and these effects are presented separately.
4. The Scope of the HRA
4.1 Table 3.1 of the draft HRA Report identifies the potential direct, indirect or secondary impacts of the scheme (either alone or in combination with other plans or projects) on the relevant European Sites. The HRA Report should specify whether these impacts were agreed with Natural Resources Wales (NRW) (or their legacy bodies), and if so provide evidence confirming that NRW are content that all potential impacts, pathways and effects have been identified within the HRA Report.
4.2 It is unclear why the potential effects on Greater Horseshoe Bat and Lesser Horseshoe Bat differ significantly in Table 3.4 (Pembrokeshire bat sites and Bosherston Lakes SAC: Potential LSEs taken forward for further screening assessment). This should be explained within the submitted Report.
5. In-combination assessment
5.1 Paragraph 9.1.1 of the draft HRA Report states that ?the initial screening exercise (Appendix A) concluded that it was straightforward to screen out incombination effects on SACs and SPAs other than Pembrokeshire Marine SAC (habitats and species) and the migratory fish species features of Cleddau Rivers SAC (River Lamprey and Sea Lamprey)?. However, this is not explicitly stated within the matrices themselves. The matrices for all other sites do not contain footnotes for the in-combination effects during construction and decommissioning to justify this statement. To reiterate the point made above, each effect that has been screened out of the matrices should have a footnote providing a justification to this conclusion.
5.2 It would be useful for the HRA Report to include a figure identifying the location of the plans and projects that have been considered within the in-combination assessment.
5.3 We note from the draft Grid Connection Statement (GCS) (provided to PINS on 22 April 2013) that the decision on whether to cross the Milford Haven Waterway by subsea cable (i.e. trenching) or tunnel, and the route adopted, will be made after further surveys and environmental studies have been completed. The draft HRA Report has considered in-combination effects from a number of plans and projects, as identified in Table 9.1, but has not considered the grid connection. It is noted that paragraph 1.3.8 of the draft HRA Report states that the grid connection will not be considered within the HRA Report as the ?potential options for the grid connection are still being explored and it is not a formal plan or project that is available for analysis at this stage?.
5.4 It is understood that the Developer has previously agreed with the Countryside Council for Wales and Environment Agency Wales (now Natural Resources Wales) to include a high level analysis of the ecological impacts of the grid connection options currently under consideration within the separate GCS. The Planning Inspectorate notes that the draft GCS contains such an assessment, however has not considered the potential for in-combination impacts on European sites. Given that a grid connection is an inevitable requirement for the proposed development to operate, and that a high level assessment of the ecological impacts of the grid connection has been undertaken within the GCS, the Planning Inspectorate considers that the potential for in-combination effects of the grid connection should be included in the HRA Report and the Matrices. This should be considered on a worst case basis using the information presently available to the Developer. The Developer is warned that failure to include an in-combination assessment could result in an application not being accepted for examination, if the Developer does not provide enough information for the Secretary of State to undertake his or her duties under The Conservation of Habitats and Species Regulations 2010.
5.5 It is also understood that the Developer intends to undertake habitat surveys of the Milford Haven Waterway in summer 2013. The Developer should be aware that there is potential for the examining inspector(s) to request further information in this regard during the examination.
5.6 Should the application be accepted, the Planning Inspectorate will update the Matrices throughout the examination, and may draw upon information from any of the application documents and any representations received from both the Developer and interested parties. The Matrices will form part of a Report on the Implications for European Sites (RIES) which will be submitted to the Secretary of State with the examining inspector(s) recommendation report.
6. Cross-reference to other documents
6.1 Where cross-reference is made to another document, it would be helpful to be provided with the paragraph / page reference to which the reader is directed.