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Galloper Wind Farm Project HRA Screening Report

Galloper Wind Farm Limited

July 2011 Final Report 9V3083

Document title Galloper Wind Farm Project

HRA Screening Report

Document short title GWF HRA Screening

Status Final Report

Date July 2011

Project name Galloper Wind Farm Project

Project number 9V3083

Client Galloper Wind Farm Limited

Reference 9V3083/Screening-Final/303/Exet Version No. Raised by Approved by Date of issue Client Review V1.0 Royal Haskoning Rob Staniland 16.03.2011 May 2011

V2.0 Royal Haskoning Peter Gaches 17.05.2011

V3.0 S. Strong/J. Snowball Peter Gaches 28.07.2011

Drafted by Royal Haskoning

Approved by Peter Gaches

Date/initials check PG 28.07.2011

Approved by

Date/initials approval

Approved by

Date/initials approval

GWF HRA Screening 9V3083/Screening-Final/303/Exet Final Report July 2011

EXECUTIVE SUMMARY This document provides the necessary information to enable Natural England and the Joint Nature Conservation Committee (JNCC), as the Governments statutory nature conservation bodies, to undertake a Habitat Regulations Assessment (HRA) screening exercise on the potential impacts from the Galloper Wind Farm (GWF).

The requirement for this assessment is set out under the Council Directive 92/43/EEC on the conservation of natural habitats and of wild flora and fauna (the ‘Habitats Directive’) wherever a project that is not directly connected to, or necessary to the management of a Natura 2000 site has the potential to have a significant effect on the conservation objectives of the site.

This assessment has been prepared with due consideration given to the information provided in the Infrastructure Planning Commission’s (IPC) tenth advice note on ‘Habitat Regulations Assessment relevant to nationally significant infrastructure projects (NSIP)’. The advice note sets out the stages that must be gone through for NSIPs to get approval for Development Consent Order (DCO) applications.

The formal opinion of the statutory nature conservation bodies on the requirement for HRA has been provided within the GWF Scoping Opinion.

Nine European sites have been assessed in the Habitat Regulations Assessment screening stage to determine potential significant effects, those being:

• The Alde-Ore Estuary Special Protection Area (SPA), Ramsar and European Marine Site: potential impacts on lesser black-backed gull;

• The Outer Thames SPA: potential in-combination impacts on red-throated diver;

• The Sandlings SPA: potential impacts on nightjar and woodlark; • The Minsmere to Walberswick SPA and Ramsar: potential impacts

on designated species and their habitats; • The Flamborough Head and Bempton Cliffs SPA: potential impacts

on gannet; • The Orfordness to Shingle Street SAC: potential impacts on

designated habitats; • Alde, Ore and Butley Estuaries SAC: potential impacts on designated

habitats; • Minsmere to Walberswick Heaths and Marshes SAC: potential

impacts on designated habitats; and • The Margate and Long Sands candidate Special Area of

Conservation (cSAC): potential impacts on the designated habitats. Within this report detail is provided on the HRA process, the project and an opinion on the potential for likely significant effects to these sites. The opinions provided in the likely significant effects tables have been informed,


where necessary by technical notes, which provide greater detail on the subject. In conclusion, Galloper Wind Farm Limited (GWFL) recognise that Appropriate Assessment may be necessary for potential impacts on the Alde-Ore SPA lesser black-backed gull population as a result of potential collision risk. Information will be provided within the GWF HRA Report (currently in preparation) which will be submitted as part of the DCO application, alongside the GWF Environmental Statement (ES). The information to inform the Appropriate Assessment within the HRA Report will enable the competent authority to make an Appropriate Assessment as laid down in Article 6(3)) of the 2010 Habitat Regulations (as amended).

Through ongoing consultation with the JNCC and Natural England, GWFL will ensure that information provided will be sufficient to alloa a complete and robust Appropriate Assessment. It is recommended that if an Appropriate Assessment is required, that this should be limited to a consideration of the effects of collision risk mortality on the integrity of the SPA lesser black-backed gull population and the ‘disturbance’ component of the conservation objective.

It is recommended that there is sufficient evidence that there will be no significant effects on the integrity of any other European sites and therefore these sites can be screened out from further consideration in the HRA process. In line with IPC tenth advice note on ‘Habitat Regulations Assessment relevant to nationally significant infrastructure projects’ (IPC, 2011), it is the intention of GWFL to submit a ‘No Likely Significant Effects Report’ with the DCO application for the sites that are screened out.


CONTENTS Page

1 INTRODUCTION 1 1.1 Background 1

2 PROJECT OVERVIEW 5 2.1 Site Location 5 2.2 Project Components 6 2.3 Project Timescale 12

3 OUTLINE OF THE HABITATS REGULATIONS ASSESSMENT PROCESS 12 3.1 Introduction 12 3.2 Procedure and Process 13 3.3 Consultation on the HRA 18

4 INFORMATION ON THE INTERNATIONAL SITES AND THEIR QUALIFYING FEATURES 20 4.1 Internationally Designated Sites within the UK 20 4.2 Identification of European Sites Potentially Affected by the GWF

Project 20 4.3 Alde-Ore Estuary European Marine Site 28 4.4 Alde-Ore Estuary SPA (and Ramsar) 29 4.5 The Sandlings SPA 30 4.6 Minsmere to Walberswick SPA (and Ramsar) 31 4.7 Outer Thames SPA 33 4.8 Flamborough Head and Bempton Cliffs SPA 34 4.9 Margate and Long Sands cSAC 35 4.10 Alde, Ore and Butley Estuaries SAC 36 4.11 Orfordness to Shingle Street SAC 36 4.12 Minsmere to Walberswick Heaths and Marshes SAC 37

5 CONSIDERATION OF POTENTIAL EFFECTS 38 5.1 Screening to determine potential for the GWF project to adversely

effect designated features 38 5.2 Plans and Projects for Assessment of In-combination Effects 47

6 CONCLUSIONS 69

7 REFERENCES 72

APPENDIX A – ORNITHOLOGICAL CONSULTATION MEETING MINUTES 75

APPENDIX B – ORNITHOLOGICAL TECHNICAL REPORT: HRA SCREENING 76

APPENDIX C – TECHNICAL NOTE: PHYSICAL PROCESSES WITH REGARD TO MARGATE AND LONG SANDS CSAC 77

GWF HRA Screening 9V3083/Screening-Final/303/Exet Final Report - 1 - July 2011

1 INTRODUCTION

1.1 Background

1.1.1 In July 2009, The Crown Estate announced that it would be running a tender round for developers to apply for extensions to existing Round 1 and 2 offshore wind farm sites. This ‘Extensions Round’, known as ‘Round 2.5’, was devised to plug a perceived supply chain gap between the completion of Round 2 wind farms and the start of construction of Round 3 projects.

1.1.2 SSE Renewables Developments UK Ltd (SSER) and RWE Npower Renewables Ltd (RWE NRL) have been awarded the rights to develop an offshore wind farm in the Outer Thames Strategic Area (SEA) by The Crown Estate under Round 2.5 of the Offshore Wind Licensing Arrangements. This is subject to SSER and RWE NRL being successful in gaining the necessary consents for the construction and operation of the wind farm. Since the site award SSER and RWE NRL have formed a joint company venture to develop the project, termed Galloper Wind Farm Limited (GWFL).

1.1.3 The location of the proposed site, known as the Galloper Wind Farm (GWF), is shown in Figures 1.1 and 1.2.

1.1.4 GWFL propose to submit applications for the necessary consent for the proposed GWF Project in Q3 2011.

1.1.5 The Round 2 development around which the proposed GWF Project is based is known as the Greater Gabbard Offshore Wind Farm (GGOWF). This 500MW project comprises an offshore wind farm, export cabling to a landfall on the Suffolk coast at Sizewell and onshore infrastructure (including a substation) to connect the project to the national grid network.

1.1.6 The GGOWF was awarded consent for development in 2007, following the submission of an Environmental Statement (ES) in 2006. GGOWF construction commenced in June 2009 and is due to be commissioned in 2012. Once complete, GGOWF will comprise of 140 Siemens 3.6MW wind turbine generators (WTG).

1.1.7 The GGOWF is owned by Greater Gabbard Offshore Winds Limited (GGOWL), a 50/50 Joint Venture between SSER and RWE NRL.

1.1.8 This document follows on from the GWF Scoping Opinion (IPC, 2010) and has been produced to facilitate consultation on the initial stage of the Habitat Regulations Assessment (HRA) for the GWF Project, namely, screening of the project with respect to its potential to have a likely significant effect on relevant sites of international nature conservation importance.

1.1.9 The HRA Report is currently in preparation and will be submitted alongside the ES as part of the Development Consent Order (DCO) application for the GWF project.


1.1.10 The document is set out in a number of sections and the following is provided:

• A brief overview of the GWF Project;

• An outline of the Habitats Regulation Assessment process and the role of screening within this process;

• A summary of information on the designated sites of nature conservation interest to be included in the HRA;

• An initial view of the potential for the project to lead to a likely significant effect with regard to the designated features of the international sites under consideration; and

• A list of the other plans and projects which will be assessed for the in- combination element of the likely significant effect test.


2 PROJECT OVERVIEW

2.1 Site Location

2.1.1 The proposed GWF development area is 27.1km from the Suffolk coastline at its closest point. The development area lies predominantly to the east of GGOWF with a small area to the west of the southern site as shown in Figure 1.1.

2.1.2 The Crown Estate’s Round 2.5 selection process considered applications for extensions to consented Round 1 and 2 sites that satisfied a number of criteria including:

• The proposed extension must share a substantial part of one or more boundaries with the original site;

• No maximum size of extension is set, however, the scale of the extension should be appropriate for the scale of the original site;

• The extension proposal should demonstrate synergies with the original site (e.g. of construction, operation, improvement of economics and / or grid connectivity);

• No extension will be permitted to encroach within a radius less than five kilometres of any nearby Round 1 or 2 sites, except with the express agreement of the tenant of the existing nearby site; and

• The proposed extension must not adversely affect delivery or operation of the original site or any neighbouring site.

2.1.3 The proposed location for the GWF is considered to provide the least overall

environmental risk, whilst maintaining compliance to The Crown Estate stipulations.

2.1.4 The proposed onshore GWF development comprises a 132kV GWF substation, a 400kV National Grid substation and associated sealing end compounds to tie into the existing overhead power lines. These two substations are located adjacent to one another approximately 1km inland on the Suffolk coast. They are situated to the north of Sizewell Gap road, immediately to the west of the existing GGOWF substation site.

2.1.5 The combined substation footprint sits predominantly within arable land although it also includes part of a block of woodland (Sizewell Wents) and part of Broom Covert (a block of semi-natural grassland used predominantly for grazing).

2.1.6 The onshore development also includes the buried 132kV export cable from the landfall on Sizewell beach to the GWF 132kV substation (including the onshore transition pit). Addition buried cabling is also proposed between the National Grid 400kV substation and the sealing end compounds.


2.2 Project Components

2.2.1 The proposed GWF project (up to 504MW in capacity) currently comprises the following components:

• Offshore wind farm array (WTG’s and foundations);

• Inter-array cabling;

• Offshore substations, collection and accommodation platforms;

• Offshore meteorological mast(s);

• Export cabling to shore;

• Onshore transition pits;

• Onshore cabling; and

• Onshore 132kV substation and National Grid 400kV substation; and

• Sealing end compounds to tie in with existing overhead power lines..

2.2.2 Table 2.1 provides further detail on these components.

Table 2.1 Project summary details

Item Detail Notes Project capacity Up to 504MW WTGs 3.6MW to 7MW Maximum tip height of 195m (above LAT)

Two 3.6MW WTGs are under consideration; one with a 107m diameter rotor and the other with a 120m diameter rotor.

Foundations Monopile, space-frame, gravity base structure or suction can.

A number of foundation options remain in consideration at this stage, given the water depths and early stage of project design.

Offshore substations Up to 2 on jacket foundations

Likely to be one in each extension area mostly likely installed on jacket foundations

Collection platform Up to 1 Most likely to be installed on jacket or monopile foundation

Accommodation platform

Up to 1 Most likely to be installed on jacket or monopile foundation

Meteorological masts Up to 3 Most likely to be installed on monopile foundation

Export cable Up to 3 cables North of the existing GGOWF route Landfall Sizewell Refer to Figure 1.1 Transition pit Sizewell Refer to Figure 1.2 Onshore cables Underground Up to five cables required 400kV substation Sizewell Located adjacent to the existing GGOWF

substation 132kV substation Sizewell Located adjacent to the proposed 400kV

National Grid substation


Item Detail Notes Sealing end compounds

Sizewell To tie into existing overhead lines and remove any requirement for additional electricity towers.

2.2.3 The proposed GWF site comprises three development areas, the boundaries (in WGS 84) of which are detailed in Table 2.2).

Table 2.2 GWF site boundaries

Corner Easting Northing Longitude Latitude A 426790 5759183 1° 56’ 02.67” 51° 58’ 42.60” B 430795 5761506 1° 59’ 30.90” 51° 59’ 59.61” C01 437729 5760502 2° 05’ 35.13” 51° 59’ 30.07” C02 437783 5760458 2° 05’ 37.95” 51° 59’ 28.67” C03 437916 5760363 2° 05’ 44.98” 51° 59’ 25.64” C04 438055 5760276 2° 05’ 52.32” 51° 59’ 22.90” C05 438199 5760199 2° 06’ 59.94” 51° 59’ 20.46” C06 438348 5760132 2° 06’ 07.79” 51° 59’ 18.34” C07 438501 5760074 2° 06’ 15.85” 51° 59’ 16.53” C08 438657 5760027 2° 06’ 24.09” 51° 59’ 15.06” C09 438817 5759989 2° 06’ 32.47” 51° 59’ 13.92” C10 438978 5759963 2° 06’ 40.94” 51° 59’ 13.12” C11 439133 5759947 2° 06’ 49.05” 51° 59’ 12.68” C12 439325 5759934 2° 06’ 59.14” 51° 59’ 12.33” D 440306 5759427 2° 07’ 50.89” 51° 58’ 56.29” E 441324 5758719 2° 08’ 44.67” 51° 58’ 33.77” F 441289 5756246 2° 08’ 44.38” 51° 57’ 13.72” G 440684 5753290 2° 08’ 14.51” 51° 55’ 37.84” H 433042 5749837 2° 01’ 36.87” 51° 53’ 42.96” I 432029 5749380 2° 00’ 44.24” 51° 53’ 27.72” J 431181 5748998 2° 00’ 00.14” 51° 53’ 15.00” K 431320 5759119 2° 00’ 00.14” 51° 58’ 42.60” L 431061 5740482 2° 00’ 00.00” 51° 48’ 39.35” M 431766 5740761 2° 00’ 36.60” 51°48’ 48.66” N 432782 5741151 2° 01’ 29.38” 51° 49’ 01.73” O 438660 5743407 2° 06’ 34.87” 51° 50’ 17.18” P 436911 5734868 2° 05’ 09.10” 51° 45’ 40.12” Q 428513 5730729 1° 57’ 54.17” 51° 43’ 22.53” R 422305 5734815 1° 52‘ 27.41” 51° 45’ 31.80” S 422886 5737271 1° 52’ 55.73” 51° 46’ 51.58” T 426487 5738887 1° 56’ 02.40” 51° 47’ 45.60” U 425224 5735568 1° 54’ 59.04” 51° 45’ 57.60” V 426696 5731876 1° 56’ 18.60” 51° 43’ 58.80” W 430975 5734151 2° 00’ 00.00” 51° 45’ 14.40” X 431006 5736446 2° 00’ 00.00” 51° 46’ 28.67”

2.2.4 The offshore wind farm array will cover an area of up to 174km2 and consist of up to 140 WTGs depending on the size class used (with 3.6MW to 7MW being considered). This means that the wind farm array may range from 72 *


7MW WTGs to 140 * 3.6MW WTGs (as depicted in Figures 2.1 and 2.2), or a number of variations in between, involving other WTG sizes. The precise location and internal arrangement may be amended following consultation or for technical reasons.

2.2.5 It will not necessarily be the case that all the WTGs used will be of the same capacity or dimensions. Furthermore, the separation distances will vary depending on WTG size. The Development Consent Order (DCO) to be applied for will seek the flexibility to follow this approach, as with the Section 36 consents for Round 2 projects. The limiting factor on the project will be the total capacity (up to 504MW) rather than the number of WTGs.

2.2.6 The maximum height of the WTGs will be up to 195m above mean sea level (MSL) to the blade tip in the vertical position. The nacelles and rotor will be mounted upon a cylindrical steel tower; which will in turn be supported by a foundation, the design and type of which is yet to be determined.

2.2.7 Monopile, space-frame, gravity-based structures (GBS) and suction can foundations are being considered for this project. It is possible that a variety of foundation types may be used depending on the water depth and ground conditions (i.e. monopiles used in the water depths less than 35m and space-frame foundations (such as multi-jackets) or GBS used in deeper water).

2.2.8 When the export cable reaches landfall, up to four Horizontal Directional Drilling (HDD) ducts will be created to enable the export cables to be brought through to the onshore transition pits. This method of cable installation involves drilling an arc between the two points so that the cable can be passed across an area with significantly less impact than other cable installation techniques.

2.2.9 An onshore 132kV substation and National Grid 400kV substation will be constructed as part of the GWF. The combined substation footprint measures approximately 3ha (as shown in Figure 1.2). This represents an indicative size, location and orientation at this stage and may be subject to amendment following additional consultation or dependent upon technical constraints.

2.2.10 The onshore 132kV substation and National Grid 400kV substation will be fully considered within this HRA screening report, and throughout this report is simply referred to as ‘the substation’.

Worst case scenario

2.2.11 As a result of the design flexibility identified within this section, careful consideration has been given to all potential impacts that may result from the GWF development. It been ensured that the assessment made within this Report is reflective of the realistic worst case scenario for the parameters under investigation. In addition, the subsequent HRA Report (in preparation), which will include a No Significant Effects Report as well as the necessary information to inform the Appropriate Assessment, will also be based on a


realistic worst case development scenario to ensure that any of the development permutations have been captured within the assessment


2.3 Project Timescale

2.3.1 At present, construction is planned to commence in 2014 with completion by mid 2017, covering three summer periods. Once built, the offshore wind farm will be operational for 25 years. At the end of its lifespan, the project may be decommissioned or repowered.

3 OUTLINE OF THE HABITATS REGULATIONS ASSESSMENT PROCESS

3.1 Introduction

3.1.1 The Habitats Directive protects habitats and species of European nature conservation importance. Together with Council Directive (2009/147/EC) on the conservation of wild birds (the ‘Birds Directive’), the Habitats Directive establishes a network of internationally important sites designated for their ecological status. Special Areas of Conservation (SACs) and Sites of Community Importance (SCIs) are designated under the Habitats Directive and promote the protection of flora, fauna and habitats. Special Protection Areas (SPAs) are designated under the Birds Directive in order to protect rare, vulnerable and migratory birds. These sites combine to create a Europe-wide ‘Natura 2000’ network of designated sites, which are hereafter referred to as ‘European Sites’. The term ‘European Site’ also includes European Marine Sites.

3.1.2 In the UK, the Offshore Marine Conservation (Natural Habitats, & c.) Regulations 2007 (as amended in 2010) and the Conservation of Habitats and Species Regulations 2010 (Habitats Regulations) transpose the Habitats Directive and Birds Directive into national law. The offshore regulations apply to the UK’s offshore marine area which covers waters beyond 12 nautical miles, within British Fishery Limits and the seabed within the UK Continental Shelf Designated Area. The Habitats Regulations form the legal basis for the implementation of the Habitats and Birds Directives in terrestrial areas of the UK and territorial waters out to 12nm. Therefore European Sites which include an offshore component are protected under both sets of UK regulation.

3.1.3 The Conservation of Habitats and Species Regulations 2010 incorporate all SPAs into the definition of ‘European sites’ and, consequently, the protections afforded to European sites under the Habitats Directive apply to SPAs designated under the Birds Directive.

3.1.4 UK Government policy (ODPM Circular 06/2005) states that the Habitats Regulations provide for the protection candidate SACs (cSAC), SACs and SPAs and, as a matter of policy, the Government has chosen to apply the same procedures in respect of Ramsar sites and potential SPAs (pSPA), even though these are not European sites as a matter of law. This will assist the UK Government in fully meeting its obligations under the Birds Directive and Ramsar Convention. Prior to its submission to the European


Commission as a cSAC, a proposed SAC (pSAC) is subject to wide consultation. At that stage it is not a European site and the Habitats Regulations do not apply as a matter of law or as a matter of policy. However, as stated in Government policy (ODPM Circular 06/2005) planning authorities should take note of this potential designation in their consideration of any planning applications that may affect the site.

3.2 Procedure and Process

3.2.1 Regulation 61 of the Habitats Regulations defines the procedure for the assessment of the implications of plans or projects on European sites. Under this Regulation, if the proposed development is unconnected with site management and is likely to significantly affect the designated site, the competent authority must undertake an ‘appropriate assessment’ (Regulation 61(1)). The Department of Communities and Local Government (DCLG, 2006) guidance on ‘Planning for the Protection of European Sites: Appropriate Assessment’ recommends a three stage process:

• Screening: Determining whether the plan or project ‘either alone or in- combination with other plans or projects’ is likely to have a significant effect on a European site (or sites) – This Report.

• Appropriate Assessment: Determining whether, in view of the European site’s conservation objectives, the plan or project ‘either alone or in-combination with other plans or projects’ would have an adverse effect (or risk of this) on the integrity of the site. If not, the plan can proceed.

• Mitigation and Alternatives: Where the plan or project is assessed as having an adverse effect (or risk of this) on the integrity of a site, there should be an examination of mitigation measures and alternative solutions. If it is not possible to identify mitigation and alternatives it will be necessary to establish the 'imperative reasons of overriding public interest' (IROPI). This is not considered a standard part of the process and will only be carried out in exceptional circumstances.

3.2.2 All three stages of the process are referred to cumulatively as the Habitats Regulations Assessment, to clearly distinguish the whole process from the step within it referred to as the ‘Appropriate Assessment’.

3.2.3 In respect of step 3, the integrity of a site is defined as the coherence of the site’s ecological structure and function, across its whole area, which enables it to sustain the habitat, complex of habitats and/or populations of species for which the site has been designated (EC, 2001). An adverse effect on integrity, therefore, is likely to be one which prevents the site from making the same contribution to favourable conservation status for the relevant feature as it did at the time of designation.

3.2.4 English Nature’s (now Natural England’s) Habitats Regulations Guidance Note 1 (HRGN1) (EN, 1997), describes how appropriate assessment


(i.e. step 2 above) should be undertaken. This guidance bases the assessment on a series of nine key steps. These steps include consultation, data collection, impact identification and assessment, recommendation of project modification and/or restriction, and reporting. Table 3.1 below sets out these steps.

3.2.5 In the determination of likely significant effect, guidance has been provided in English Nature’s Habitat Regulations Guidance Note 3 (HRGN3 (EN, 1999), ‘The Determination of Likely Significant Effect under the Habitats Regulations’. This involves a preliminary consideration of whether a qualifying feature is likely to be directly or indirectly affected (in which case there is a presumption that a significant effect is likely). In such a case, a fuller consideration should then be applied, using further analysis and information, to confirm and justify the presence or absence of likely significant effect. Appropriate assessment is needed in cases where a likely significant effect is identified. Figure 3.1, taken from HRGN3, sets out the recommended steps in the process.

3.2.6 A likely significant effect is, in this context, any effect that may be reasonably predicted as a consequence of a plan or project that may affect the conservation objectives of the features for which the site was designated, but excluding trivial or inconsequential effects.

Table 3.1 Key steps in Appropriate Assessment

Step Description of requirements

1 Defining the need for Appropriate Assessment.

2 Consultation with relevant nature conservation agency(ies).

3 Consultation with other organisations (e.g. Environment Agency, etc.).

4 Definition of the designated status of the site, the qualifying interests and the site’s conservation objectives.

5 Provision of further information – this information includes information already available, new information from surveys and assessments of a technical nature.

6 Consideration of the potential effects.

7 Assessment of the influence of any potential impacts on the integrity of the site.

8 Avoiding adverse effects.

9 Conclusion regarding the potential for the scheme to adversely affect the integrity of the designated site.

3.2.7 In April 2011, the Infrastructure Planning Commission (IPC) published its tenth advice note, on ‘Habitat Regulations Assessment relevant to nationally


significant infrastructure projects (NSIP)’. The advice note sets out the stages that must be gone through for NSIPs (refer to Figure 3.2) and should not be seen as interpreting or overriding the above mentioned legislative framework, but should be also read in conjunction with the Habitats Directive, the 2010 Habitats Regulations (as amended), relevant Government Planning Policy, and European guidance.

3.2.8 The Advice Note clarifies the information to be provided with development consent order (DCO) applications as prescribed in the Infrastructure Planning (Applications: Prescribed Forms and Procedures) Regulations 2009 SI No. 2264 (the APFP Regulations). In accordance with Regulation 61(2) of the Habitat Regulations (as amended) anyone applying for DCO for an NSIP must provide the competent authority with such information as may be reasonably be required “for the purposes of the assessment” or “to enable them to determine whether an Appropriate Assessment is required”.

3.2.9 The APFP Regulations carry forward the requirements of the 2010 Habitat Regulations (as amended) into the application process for NSIPs by requiring sufficient information to be provided within the application to enable an Appropriate Assessment to be carried out, if required. This Report represents the pre-application stage (Stage 1) whereby Screening for Significant Effect on European Sites is undertaken (refer to Figure 3.2). This Report has been prepared inline with the IPC tenth advice note and complies with the ‘issues for the developer to consider and include within their HRA screening assessment’ (refer to page 12 of IPC, 2011).


Figure 3.1 Step-by-step approach to determining whether a significant effect is likely on a European site (HRGN3)


Figure 3.2 Flow chart illustrating the relationship between DCO applications and HRA

processes


3.3 Consultation on the HRA

Scoping consultation

3.3.1 Consultation is important in gaining views on the proposed project, gaining wider acceptability and helping to facilitate the process of obtaining the required permissions, licences and consents. Consultation was initiated early in the scoping phase of the GWF project and formal opinions of JNCC and Natural England on the requirement for HRA were provided within the GWF Scoping Opinion. In addition, extensive consultation has taken place with JNCC and Natural England in relation to ornithological issues, Appendix A provides a record of the ornithological consultation meetings involving the aforementioned consultees. These have been used along with the scoping opinions to prepare this document.

3.3.2 The formal scoping opinions of JNCC and Natural England highlighted four sites of concern with regard to potential significant effects, those being:

• The Alde-Ore SPA

“At this stage we are of the opinion that an Appropriate Assessment will be required for lesser black-backed gulls associated with the Alde-Ore Estuary SPA, for impacts, such as collision risk, related to the Galloper wind farm project only”.

• The Outer Thames SPA

“We are also of the opinion that screening for an Appropriate Assessment will be required for impacts, due to displacement and disturbance, on red-throated divers associated with the Outer Thames SPA in combination with other plans or projects”.

• The Sandlings SPA

“At the February meeting, outline above, Natural England advised that the site to the south of Sizewell Gap Road will be in close proximity to the Sandlings SPA, and a Habitat Regulations Assessment would need to be undertaken if that site goes forward.

If onshore works are to be progressed at the site to the south of Sizewell Gap Road Natural England would advise that screening for an Appropriate Assessment would be required for impacts on nightjar and woodlark associated with the Sandlings SPA1”.

1 Two potential substation sites were proposed during the EIA Scoping exercise. One to the south of Sizewell Gap Road (referred to within NE’s correspondence) and a site to the north of Sizewell Gap Road. As a result of this consultation, and other considerations, the site to the north of Sizewell Gap Road has been taken forward as the preferred option.


• The Margate and Long Sands cSAC

”We are concerned by the potential cumulative impacts on coastal processes arising from the Galloper proposal, including cable routes and onshore infrastructure, in combination with other proposed development in the vicinity of this site.….It is possible that disruption of, or changes to, coastal processes and sediment movements may lead to significant effects on the coastal and marine habitats of these SACs”.

Summary

3.3.3 As a result of the specific consultee concerns raised during the scoping process, further studies were undertaken to provide additional information to support the conclusions drawn in this Report. Specifically, these studies provide further details relating to the assessment of impacts on the Outer Thames SPA (red throated diver), Alde-Ore Estuary SPA (lesser black backed gull) and the Margate and Long Sands cSAC. These additional reports comprise:

• An ornithological technical report for HRA screening (Appendix B); and

• A technical note on physical processes with regard to Margate and Long Sands cSAC (Appendix C)

3.3.4 No further studies were considered necessary for the remainder of the

European sites assessed within this Report.

Further consultation

3.3.5 A meeting held with JNCC and Natural England held on 18th January 2011 included discussion and agreement on the approach to Appropriate Assessment for the lesser black-backed gull and agreement on HRA issues involving red-throated diver (refer to Appendix A).

3.3.6 A draft version of this HRA screening report and supporting Ornithological Technical Report was issued to the JNCC and Natural England for discussion on 19th May 2011. The JNCC and Natural England responded with comments on the 23rd June 2011. In order for a decision to be made on Likely Significant Effects, Further information was requested in regard to:

• Cumulative effects of collision risk on northern gannet (Morus bassanus, hereafter referred to as “gannet”) from the nearest colony at Flamborough Head and Bempton Cliffs SPA;

• Potential impacts on red throated diver associated with the Outer Thames SPA; and

• Potential impacts on coastal habitats associated with the Minsmere to Walberswick Heaths and Marshes SAC.


4 INFORMATION ON THE INTERNATIONAL SITES AND THEIR QUALIFYING FEATURES

4.1 Internationally Designated Sites within the UK

4.1.1 Statutory international designated sites in the United Kingdom (UK) include Ramsar wetland and Natura 2000 sites, known as Special Protection Areas (SPA) and Special Areas of Conservation (SAC). These should be taken as including Sites of Community Importance (SCIs); potential SPAs (pSPAs); candidate, possible and draft SACs (cSACs, pSACs and dSACs). Collectively, these are known as European Sites and include European Marine Sites.

4.1.2 Ramsar sites are wetlands of international importance, designated under the Ramsar Convention on Wetlands of International Importance (The Ramsar Convention) and primarily provide habitat for waterbirds. The Ramsar Convention, which came into force in 1975, is an intergovernmental treaty that aims to stop the loss of wetlands. The government’s policy is to afford Ramsar sites the same level of protection as that provided for Natura 200 sites.

4.1.3 SPAs are statutory designated sites that are classified under European Union (EU) law in accordance with Article 4 of the European Council (EC) Directive on the conservation of wild birds (79/409/EEC) (known as the Birds Directive). They are classified for rare and vulnerable birds, listed in Annex I to the Birds Directive, and for regularly occurring migratory species.

4.1.4 SACs are sites designated under EU Directive 92/43/EEC on the conservation of habitats and of wild flora and fauna (known as the Habitats Directive), because they make a significant contribution to conserving the 189 habitat types and 788 species identified in Annexes I and II of the Directive.

4.2 Identification of European Sites Potentially Affected by the GWF Project

4.2.1 This section provides a general description of each of the relevant European sites and specifically focuses on the qualifying interest features that have been identified as having the potential to be affected by the GWF Project.

4.2.2 Within the IPC Scoping Opinion statutory nature conservation bodies (SNCBs) identified four sites of relevance to the GWF project, as detailed in Section 3.3. However, this HRA screening report has given consideration of a wider array of European Sites to ensure that a comprehensive review is undertaken for the project.

4.2.3 Those sites in the vicinity of the GWF project and those which have been included in this assessment comprise (as set out in Table 4.1).


4.2.4 European Marine Sites of relevance to the GWF include:

• Alde-Ore Estuary European marine site (28km from the GWF site; 5km from onshore substation).

4.2.5 Ramsar sites of relevance to the GWF include:

• Minsmere to Walberswick (35.5km from the GWF site; 2km from onshore substation); and

• Alde-Ore Estuary (28km from the GWF site; 5km from onshore substation).

4.2.6 SPAs of relevance to GWF include:

• The Outer Thames Estuary SPA (8km from the GWF site; within the cable route corridor);

• The Sandlings (32.5km from the GWF site; 300m from onshore substation);

• Minsmere to Walberswick (35.5km from the GWF site; 2km from onshore substation);

• Alde-Ore Estuary (28km from the GWF site; 5km from onshore substation); and

• Flamborough Head and Bempton Cliffs SPA (over 250km from the GWF site and onshore substation.

4.2.7 SACs of relevance to GWF include:

• Minsmere to Walberswick Heaths and Marshes (35.5km from the GWF site; 2km from onshore substation);

• Alde, Ore and Butley Estuaries (29km from the GWF site; 5km from onshore substation);

• Margate and Long Sands (candidate SAC (cSAC)) (16km from the GWF site);

• Orfordness to Shingle Street (28km from the GWF site; 7km from onshore substation).

4.2.8 The location of these sites both offshore and onshore relative to the GWF

project is shown in Figure 4.1 (a and b) and Figure 4.2.


Table 4.1 European sites screened in the HRA process

Site Designation Site area Distance from project site

Protected features Reason for inclusion in HRA Screening

Alde-Ore Estuary SPA, Ramsar

and European

Marine Site

2416.87ha (SPA)

2533.95 (Ramsar)

28km from the GWF

site; 5km from

onshore substation.

Refer to Section 4.4

and Table 5.1

SPA highlighted by SNCBs in

IPC Scoping Opinion

The Sandlings SPA 3391.8ha 32.5km from the

GWF site; 300m from

onshore substation.


and Table 5.1

Highlighted by SNCBs in IPC

Scoping Opinion

Minsmere to

Walberswick

SPA and

Ramsar

2018.92ha (SPA)

2008.89ha (Ramsar)

35.5km from the

GWF site; 2km from

onshore substation.


and Table 5.1

A 2km onshore study area has

been chosen as works are

relatively localised in their nature

and this study area is

considered appropriate and

proportionate to the scale of the

development. This approach

was promoted within the

Scoping Report and no

objections were raised.

Outer Thames

Estuary

SPA 379771.66ha 8km from the GWF

site; within cable


and Table 5.1

Highlighted by SNCBs in IPC

Scoping Opinion




route corridor.

Flamborough

Head and

Bempton Cliffs

SPA 212.17ha Over 250km from

GWF site and

onshore substation.


and Table 5.1

Included as a result of the large

foraging range of gannet, a

designated species of the site

which has a maximum foraging

range of 300km+.

The GWF is beyond regular foraging range of any colony, most birds present, particularly in the main breeding season, are likely to be non-breeders or sub-adults that are not part of any breeding population, including Flamborough Head and Bempton Cliffs SPA.

Margate and Long

Sands

cSAC 64915ha 16km from the GWF

site

Refer to Section 4.9 Highlighted by SNCB in IPC

Scoping Opinion

Alde, Ore and

Butley Estuaries

SAC 1561.53ha 29km from the GWF

site; 5km from

onshore substation.

Refer to Section

4.10

Orfordness - SAC 901.19ha 28km from the GWF Refer to Section

The sites lie approximately

30km from the offshore project

area and both have features

with marine components. Whilst




Shingle Street site; 7km from

onshore substation.

4.11 no significant farfield effects on

physical processes are

anticipated, these sites are part

of the wider Alde Ore European

Marine Site and therefore have

been included for completeness.

Minsmere to

Walberswick

Heaths and

Marshes

SAC 1265.52ha 35.5km from the

GWF site; 2km from

onshore substation.

Refer to Section

4.12

A 2km study area has been

chosen as works are relatively

localised in their nature and this

study area is considered

appropriate and proportionate to

the scale of the development.

This approach was promoted

within the Scoping Report and

no objections were raised.


4.3 Alde-Ore Estuary European Marine Site

4.3.1 The Alde-Ore Estuary European marine site comprises the Alde-Ore Estuary SPA, the Alde-Ore Estuary Ramsar, the Alde, Ore and Butley Estuaries SAC the Orfordness to Shingle Street SAC. Much of Natural England’s advice for the site covers the marine elements of both the SPA and SAC interests (EN, 2001). Refer to the aforementioned sections for information on the SPA and SAC qualifying species and habitats. Those qualifying species of the SPA that utilise habitats above the highest astronomical tide fall outside the European marine site; similarly, those qualifying habitats of the SAC that occur above the highest astronomical tide fall outside the European marine site.

4.3.2 The qualifying species of the Alde-Ore Estuary SPA that occur in the European marine site are the breeding and wintering avocets Recurvirosta avosetta, wintering ruff Philomachus pugnax, breeding sandwich tern Sterna sandvicensis and little tern Sterna albifrons. Internationally important populations of regularly occurring migratory bird species within the European marine site are redshank Tringa tetanus and lesser black-backed gull Laurus fuscus graellsii.

4.3.3 The conservation objectives for the Alde-Ore Estuary marine site (EN, 2001) are:

4.3.4 “Subject to natural change, maintain in favourable condition the habitats for the internationally important populations of the regularly occurring Annex I bird species under the Birds Directive, in particular:

• Shingle areas;

• Intertidal mudflats;

• Saltmarsh communities; and

• Shallow coastal waters.

4.3.5 Subject to natural change, maintain in favourable condition the habitats for the internationally important populations of the regularly occurring migratory bird species under the Birds Directive, in particular:

• Intertidal mudflats;

• Saltmarsh communities; and

• Shallow coastal waters”.


4.4 Alde-Ore Estuary SPA (and Ramsar)

4.4.1 The Alde-Ore Estuary qualifies as an SPA under Article 4.1 and Article 4.2 of the Directive (79/409/EEC) by supporting internationally important populations of regularly occurring Annex 1 species and populations of migratory species of European importance, respectively, as detailed below.

4.4.2 The SPA is designated for breeding populations of:

• Avocet - 104 pairs representing at least 17.6% of the breeding population in Great Britain (5 year mean, 1990-1994);

• Little tern - 48 pairs representing at least 2.0% of the breeding population in Great Britain (5 count mean, 1993-4,1996-8);

• Marsh harrier Circus aeroginosus - 3 pairs representing at least 1.9% of the breeding population in Great Britain (5 year mean, 1993-1997);

• Sandwich tern - 169 pairs representing at least 1.2% of the breeding population in Great Britain (5 year mean 1991-1995); and

4.4.3 The SPA is designated for overwintering populations of:

• Avocet - 766 individuals representing at least 60.3% of the wintering population in Great Britain (5 year peak mean 1991/2 - 1995/6); and

• Redshank - 1,919 individuals representing at least 1.3% of the wintering Eastern Atlantic - wintering population (5 year peak mean 1991/2 - 1995/6)

4.4.4 In regards to the populations of migratory species of European importance, the lesser black-backed gull SPA population represents at least 17.5% of the breeding Western Europe/Mediterranean/Western Africa population (21,700 pairs, count as at 1998).

4.4.5 Since the citation date, the population has suffered a notable decline in numbers, down to 6,000 pairs in 2003 (JNCC Seabird Monitoring Programme data), and most recent counts in 2010 have recorded approximately 1,603 pairs in the Orfordness and Havergate Island colonies combined (Landguard Bird Observatory/RSPB data). The reasons for this decline are not fully understood, but are likely to be due to a combination of increased mammalian predation (M. Marsh, Landguard Bird Observatory pers. comm.), increased human disturbance, reduction in habitat quality, and the reduction of a major inland food source in the free-range pig units in the area, which suffered from outbreaks of swine fever and foot and mouth disease in 2000-01, meaning fewer pigs and thus fewer feeding opportunities for gulls (National Trust, 2010). The creation of these sub-optimal conditions is likely to have caused a reduction in recruitment to the population of young birds from nearby colonies, which would have exacerbated the effects on the breeding population.


4.4.6 The SPA also qualifies under Article 4.2 of the Directive (79/409/EEC) as it is used regularly by over 20,000 seabirds in any one season including herring gull Larus argentatus, black-headed gull Larus ridibundus, lesser black-backed gull, little tern, sandwich tern. In addition it is used regularly by over 20,000 waterfowl in any one season and supports high numbers of over wintering waterfowl including black-tailed godwit Limosa limosa islandica, dunlin Calidris alpina alpina, lapwing Vanellus vanellus, shoveler Anas clypeata, teal Anas crecca, wigeon Anas penelope, shelduck Tadorna tadorna, white-fronted goose Anser albifrons albifrons, redshank and avocet.

4.4.7 Key ‘supporting habitats’ for the conservation of the designated bird populations are covered by the SPA designation and include intertidal mud-flats, saltmarsh, vegetated shingle (including the second-largest and best-preserved area in Britain at Orfordness), saline lagoons and semi-intensified grazing marsh.

4.4.8 The conservation objectives from the Alde-Ore SPA (JNCC, 2009a) are:

4.4.9 “Subject to natural change, maintain in favourable condition the habitats for the internationally important populations of regularly occurring migratory bird species, under the Birds Directive, in particular:

• Intertidal mudflats

• Saltmarsh communities

• Shallow coastal waters”

4.4.10 The HRA Screening Ornithological Technical Report (in preparation) provides more detail of the attributes to be used in defining favourable condition for the Alde-Ore Estuary SPA.

4.4.11 In relation to vulnerability (based on Natura 2000 Data Form) the area is vulnerable to sea-level rise and coastal squeeze. According to the Natura 2000 Data Form, these issues are being addressed through The Environment Agency Local Environment Action Plan, the Estuary Management Plan and possibly managed retreat. In addition, human disturbance from recreation is minimal as this is a reasonably robust system. Flood defence policy will need to take into account risks to the site from flooding and of flood control alleviation measures. The Natura 2000 Data Form also indicates that shooting is controlled through a management plan.

4.5 The Sandlings SPA

4.5.1 The Sandlings SPA qualifies as a SPA under Article 4.1 of the Birds Directive by supporting the following internationally important populations of regularly occurring Annex 1 species (i.e. regularly supports numbers of birds over 1% of the national population):


During the breeding season –

• Nightjar Caprimulgus europaeus, 109 pairs representing at least 3.2% of the breeding population in Great Britain (Count as at 1992); and

• Woodlark Lullula arborea, 154 pairs representing at least 10.3% of the breeding population in Great Britain (Count as at 1997).

4.5.2 Key ‘supporting habitats’ for the conservation of the designated bird populations are covered by the SPA designation and include woodland and heath which support both acid grassland and heather-dominated plant communities with dependent invertebrate and bird communities of conservation value.

4.5.3 Based on Natura 2000 Data Form, Sandlings SPA comprises six SSSIs, of which Sandlings Forest SSSI is the largest and dominated by commercial forestry. Within the forest, large areas of open ground suitable for woodlark and nightjar were created by storm damage in 1987. Maintenance of open areas in the future relies on clear felling as the main silvicultural practice and the maintenance of some areas earmarked for woodlark and nightjar habitat.

4.5.4 In terms of vulnerability, on the heathland SSSIs, lack of traditional management has resulted in the heathland being subjected to sucessional changes with the consequent spread of bracken, shrubs and trees. This is being addressed through habitat management work under the Countryside Stewardship Scheme and Tomorrows Heathland Heritage, and is resulting in the restoration of more typical heathland habitat favourable to both nightjar and woodlark.

4.5.5 The conservation objectives from The Sandlings SPA are:

4.5.6 “To maintain2, in favourable condition, the habitats for the populations of Woodlark Lullula arborra and Nightjar Caprimulgus europaeus. Specifically:

• No significant decrease in coniferous woodland; and

• No significant decrease in heathland”

4.6 Minsmere to Walberswick SPA (and Ramsar)

4.6.1 The site qualifies under Article 4.1 of the Birds Directive by supporting populations of European importance of the following species listed on Annex I of the Directive:


• Avocet, 47 pairs representing at least 10.4% of the breeding population in Great Britain (count, as at early 1990s);

2 maintenance implies restoration if the feature is not currently in favourable condition


• Bittern Botaurus stellaris, 7 individuals representing at least 35.0% of the breeding population in Great Britain (5 year mean, 1993-1997);

• Little tern, 28 pairs representing at least 1.2% of the breeding population in Great Britain (5 year mean, 1992-1996);

• Marsh harrier, 16 pairs representing at least 10.2% of the breeding population in Great Britain (5 year mean, 1993-1997); and

• Nightjar, 24 pairs representing at least 0.7% of the breeding population in Great Britain (count, as at 1990).

Over winter –

• Hen harrier Circus cyaneus, 15 individuals representing at least 2.0% of the wintering population in Great Britain (5 year mean, 1985/6-1989/90).

4.6.2 The site also qualifies under Article 4.2 of the Birds Directive by supporting populations of European importance of the following species:


• Shoveler, 23 individuals representing at least 2.3% of the breeding population in Great Britain (count, as at 1990);

• Gadwall Anas strepera, 93 individuals representing at least 3.1% of the breeding population in Great Britain (count, as at 1990); and

• Teal, 73 pairs representing at least 4.9% of the breeding population in Great Britain (count, as at 1990).

Over winter –

• Shoveler, 98 individuals representing at least 1.0% of the population in Great Britain (5 year mean 1991/92-1996/96);

• Gadwall, 93 individuals representing at least 1.1% of the population in Great Britain (5 year mean 1991/92-1995/96); and

• White-fronted goose, 67 individuals representing at least 1.1% of the population in Great Britain (5 year mean 1991/92-1995/96).

4.6.3 In terms of vulnerability (based on the Natura 2000 Data Form). The site is actively managed to prevent scrub and tree invasion of the heathlands grazing marshes and reedbeds. Much of the land is managed by conservation organisations and positively by private landowners through ESA and Countryside Stewardship schemes. Natural processes are pushing back the coastline which is being addressed in the Shoreline Management Plan.


Alternative sites for reed bed creation are being sought to help off set the possible future natural losses.

4.6.4 The conservation objectives from the Minsmere to Walberswick SPA are:

4.6.5 “Subject to natural change, maintain in favourable condition the habitats for populations of Annex I Species of European importance (namely avocet, little tern, marsh harrier, nightjar, woodland and hen harrier) in particular:

• Shingle;

• Swamp, marginal and inundation communities;

• Saltmarsh;

• Standing water;

• Grassland; and

• Heathland.

4.6.6 To maintain in favourable condition, the habitats for the populations of migratory bird species of European importance (namely gadwall, teal, shoveler, and European white-fronted goose) with particular reference to:

• Shingle;

• Marsh; and

• Standing water.

4.7 Outer Thames SPA

4.7.1 The Outer Thames Estuary has been submitted by the UK Government to the European Commission for inclusion in the Natura 2000 network. The SPA regularly supports Annex 1 wintering red-throated diver Gavia stellata in numbers of European importance (6,466 individuals – wintering 1989 – 2006/07) (NE/JNCC, 2010).

4.7.2 Key ‘supporting habitats’ for the conservation of the designated bird populations are covered by the SPA designation and include marine areas and sea inlets which provide important habitat and feeding grounds for the red-throated diver.

4.7.3 In relation to vulnerability (based on Natura 2000 Data Form), red-throated divers are highly sensitive to non-physical disturbance by noise and visual presence during the winter. Locally, significant disturbance and displacement effects are predicted to arise from noise and visual impacts from wind farm construction, maintenance traffic and visually from the turbines themselves. Disturbance and displacement effects may also arise from shipping (including recreational boating) and boat movements associated with marine aggregate and fishing activities. Marine aggregates


activities tend to be temporary and localised. Dredging and shipping activities are expected to be confined to existing shipping channels, which are already known to be avoided by divers. A number of operators discharge effluent into freshwater input sources upstream of the site and directly into coastal waters adjacent to the site. Direct discharges into the site include low levels of radionuclides and heavy metals. Deterioration of invertebrate and small fish populations as a result of large oil and chemical spills can have a significant impact on important food resources. Oil on the surface and in the water column would present a threat to diving and feeding seabirds. Removal of fish and larger molluscs can have a significant impact on the structure and functioning of benthic communities. Mechanisms for these activities to impact on red-throated divers may be an indirect effect through a reduction in food availability. Entanglement in static fishing nets is an important cause of death for red-throated divers in the UK waters.

4.7.4 The conservation objectives from the Outer Thames SPA are:

“Subject to natural change, maintain in favourable condition the internationally important populations of the regularly occurring Birds Directive Annex I species [red-throated diver] and its supporting habitats and prey species [shallow coastal waters and areas in the vicinity of sub-tidal sandbanks]. Specifically:

• Maintain population on the site subject to natural fluctuations. There should be no permanent decline, only non-significant fluctuation around the mean to account for natural change: where the limits of natural fluctuations are not known (as currently in this case), maintain the population above 50% of that at designation; loss of 50% or more unacceptable”

• Maintain the area of sandbanks in the site subject to natural change: No reduction in extent of sublittoral, shallow (<20m) sandbank habitat.

• Maintain the abundance and distribution of red-throated diver prey species subject to natural fluctuations”

4.8 Flamborough Head and Bempton Cliffs SPA

4.8.1 Flamborough Head and Bempton Cliffs were designated as a SPA in 1993. The site qualifies under Article 4.1 and 4.2 of the Birds Directive for supporting the largest colony of kittiwake Rissa tridactyla in the UK, with 2.6% of the breeding population. During the breeding season, the area regularly supports 305,784 individual seabirds including: puffin Fratercula arctica, razorbill Alca torda, guillemot Uria aalge, herring gull Larus argentatus, gannet Morus bassanus, kittiwake Rissa tridactyla.

4.8.2 As well as the distinctive white cliffs, the coastline also has numerous sea cave, sea stacks and reefs. The site is designated as an SAC (Flamborough


Head SAC) and a European Marine Site due to the presence of these important features.

4.8.3 The site, located approximately 250km from the GWF, has been included in the assessment due to the presence of gannet, which are known to have a foraging range in excess of 300km and therefore have the potential to forage within the GWF site. Given their nature and provenance, no further designated species at the site are likely to interact with the GWF development.

4.9 Margate and Long Sands cSAC

4.9.1 The Margate and Long Sands cSAC is a candidate SAC designated for the Annex I habitat – Sandbanks which are slightly covered by sea water all the time. Although this site is being put forward for designation on the basis of the presence of the Sandbank Annex I interest feature, there is a significant amount of the reef-forming ross worm (Sabellaria spinulosa) at this site, which when formed as a reef qualifies as an Annex I habitat (biogenic reef). However, the available data indicate that the distribution of S. spinulosa is patchy, or that the aggregations form crusts rather than reefs.

4.9.2 In relation to vulnerability (based on Natura 2000 Data Form), operations likely to affect the habitat are:

• Physical loss by removal or smothering;

• Physical damage by siltation, abrasion or selective extraction;

• Toxic contamination by introduction of synthetic or non-synthetic compounds;

• Non-toxic contamination from changes in nutrient loading, organic loading, changes in thermal regime or changes in turbidity;

• Changes in salinity; and

• Biological disturbance by the introduction of non-native species and translocation or selective extraction of species.

4.9.3 The conservation objectives from the Margate and Long Sands cSAC3 are:

“Subject to natural change, maintain the sandbanks slightly covered by seawater all the time in favourable condition, in particular:

• Dynamic sand communities

• Muddy sand and gravel communities”

3 The draft conservation objectives for the Margate and Long Sands cSAC interest features may be refined by

NE/JNCC in future as our understanding of the features improves.


4.10 Alde, Ore and Butley Estuaries SAC

4.10.1 The Alde, Ore and Butley Estuaries SAC is designated for the Annex I habitats – Estuaries. The estuary, made up of three rivers (Alde, Butley and Ore), is the only bar-built estuary in the UK with a shingle bar. Other Annex I habitats present as a qualifying feature, but not the primary reason for the SAC designation are ‘mudflats and sandflats not covered by seawater at low tide’ and ‘Atlantic salt meadows (Glauco-Puccinellietalia maritimae)’.

4.10.2 In relation to vulnerability, past canalisation and erosion together with sea-level rise has resulted in saltmarsh loss.

4.10.3 The conservation objectives from the Alde, Ore and Butley Estuaries SAC are:

“Subject to natural change, maintain in favourable condition the Atlantic salt meadows, estuaries, and mudflats and sandflats not covered by seawater at low tide.”

4.11 Orfordness to Shingle Street SAC

4.11.1 The Orfordness to Shingle Street SAC includes both marine areas (i.e. land covered continuously or intermittently by tidal waters) and land which is not subject to tidal influence. The marine part of the SAC is termed a European Marine Site (Alde-Ore Estuary European Marine Site; refer to Section 4.3 above) and qualifies as an SAC for the Annex I habitat ‘annual vegetation of drift lines’. The SAC also qualifies for the Annex I habitats ‘perennial vegetation of stony banks and lagoons’ however they do not occur within the European Marine Site since they occur above the highest astronomical tide.

4.11.2 In relation to vulnerability, activities should be managed such that they do not result in deterioration or disturbance to habitats for which the site has been selected, through any of the following:

• Physical loss through removal;

• Physical damage resulting from abrasion; and

• Toxic contamination from the introduction of non-synthetic compounds.

4.11.3 The conservation objectives from the Orfordness to Shingle Street SAC are:

“Subject to natural change, maintain in favourable condition the saline lagoons, annual vegetation of drift lines and perennial vegetation of stony banks in favourable condition”.


4.12 Minsmere to Walberswick Heaths and Marshes SAC

4.12.1 The Minsmere to Walberswick Heaths and Marshes SAC is designated for the Annex I habitats – Annual vegetation of drift lines and European dry heaths. Other Annex I habitats present as a qualifying feature, but not the primary reason for selection of the site are ‘perennial vegetation of stony banks’ and ‘coastal lagoons’. The great-crested newt Triturus cristatus, an Annex II species, is also present on site.

4.12.2 Both the dry heath and annual vegetation of drift lines are noted for their vulnerability at this site.

4.12.3 The conservation objectives from the Minsmere to Walberswick Heaths and Marshes SAC are:

“Subject to natural change, maintain in favourable condition the annual vegetation of drift lines, European dry heaths, perennial vegetation of stony banks and coastal lagoons.”


5 CONSIDERATION OF POTENTIAL EFFECTS

5.1 Screening to determine potential for the GWF project to adversely effect designated features

Special Protected Areas and Ramsar sites

Supporting habitats

5.1.1 Potential impacts to the supporting habitats of protected sites during the construction, operation and decommissioning of the GWF are:

• Habitat loss;

• Disturbance; and

• Indirect effects through change to physical processes.

5.1.2 For SPAs with a terrestrial and marine component, potential effects could manifest as a result of the installation of offshore assets (including the Wind Turbine Generators (WTGs), Met Masts, offshore substations and cable corridor) and onshore infrastructure (including the substation and onshore cable corridor). The permanent removal of important foraging, resting or breeding habitat within the infrastructure footprint or as a result of localised changes in sediment dynamics or coastal processes is considered in relation to the distribution and foraging ecology of protected species which may rely on these habitats for growth, survivorship or reproduction.

5.1.3 Due to their significant distance from the GWF site and associated onshore substation, the supporting habitats of the following designated sites are not considered to exist within a potential impact pathway:

• Alde-Ore Estuary European Marine Site;

• Alde-Ore Estuary SPA / Ramsar; and

• Flamborough Head and Bempton Cliffs SPA

5.1.4 Furthermore, it should be noted that throughout the consultation process no concerns have been raised by the SNCBs in respect to the supporting habitats of these designated sites.

5.1.5 The supporting habitats of the Outer Thames SPA include marine areas and sea inlets which inshore foraging habitat for red-throated diver. Given that the export cable will pass through the site, there is potential for the small-scale temporary disturbance to habitats within the footprint of the cable route. Onshore, the impacts will be localised to the substation and cable works, direct habitat loss will not occur.


5.1.6 The close proximity of the onshore works to the Minsmere to Walberswick SPA/Ramsar and the Sandlings SPA, mean that there is potential for impacts to occur on the supporting habitats of these site.

Ornithological features

5.1.7 Potential impacts to the ornithological interests of the SPA and Ramsar sites during the construction, operation and decommissioning of the GWF comprise:

• Habitat loss;

• Disturbance;

• Displacement;

• Collision risk (during operation of the offshore WTGs); and

• Barrier effects (during operation of the offshore WTGs)

Offshore

5.1.8 The first stage in determining which, if any, of the SPA bird populations are at risk of the impacts identified is to determine which species of relevance to the designated sites, have been recorded, in significant numbers, in the offshore study areas. For the purposes of this screening assessment, population estimates within the GWF study area at or above the 1% threshold for the SPA were considered significant. For example, in the case of red-throated diver the 1% threshold is 64 individuals.

5.1.9 Over 70 avian species (including birds identified to genus or family level only) have been recorded during the GWF boat-based surveys, however, in the context of regional or national populations, many of these species have been recorded in very low numbers within the GWF study area, and / or are of low conservation value. In some cases, the total numbers affected will not approach the 1% significance threshold at regional or national levels. Therefore, it is considered inappropriate to include such species in this assessment. The analysis carried out for the GWF EIA has identified 12 species of principle concern, these species have been used to inform the HRA Screening process.

5.1.10 The screening assessment has been summarised in Table 5.1, which identifies the qualifying and assemblage species for each SPA and Ramsar site. The table also highlights where a qualifying or assemblage species has also been identified as a species of principle concern in relation to the GWF project.


Table 5.1 SPA species and their exposure to risk of any effect from the GWF project.

Key: Q = qualifying species, A = assemblage species (as detailed in Section 4)

SPA Wind Farm Use:

Species of principle concern* Species Outer

Thames Alde-Ore Estuary

The Sandlings

Minsmere to Walberswick

Flamborough Head and

Bempton Cliffs Conservation status

Significant numbers

recorded within GWF

Potential for significant

adverse interaction with

GWF

White-fronted Goose

-- A -- -- -- -- -- --

Shelduck -- A -- -- -- -- -- --

Teal -- A -- -- -- -- -- --

Wigeon -- A -- -- -- -- -- --

Nightjar -- -- Q Q -- -- -- --

Bittern -- -- -- Q -- -- -- --

Woodlark -- -- Q Q -- -- -- --

Shoveler -- A -- -- -- -- -- --

Red-throated Diver

Q -- -- -- -- ��

Hen Harrier -- -- -- Q -- -- -- --

Marsh Harrier -- Q -- Q -- -- -- --

Avocet -- Q/A -- Q -- -- -- --

Lapwing -- A -- -- -- -- -- --


SPA Wind Farm Use:



The Sandlings




Significant numbers

recorded within GWF



GWF

Dunlin -- A -- -- -- -- --

Black-tailed Godwit

-- A -- -- -- -- -- --

Redshank -- Q/A -- -- -- -- -- --

Herring gull

-- A -- -- A

��

(Alde-Ore Estuary

SPA only**)

X

(***) --

Little Tern -- Q/A -- Q -- -- -- --

Black headed gull

-- A -- -- -- -- -- --

Sandwich Tern -- Q/A -- -- -- -- -- --

Lesser black-backed gull

-- Q/A -- -- -- ��

Kittiwake -- -- -- -- Q/A ** -- --

Puffin -- -- -- -- A -- --

Razonbill -- -- -- -- A ** -- --

Guillimot -- -- -- -- A ** -- --


SPA Wind Farm Use:



The Sandlings




Significant numbers

recorded within GWF



GWF

Gannet -- -- -- -- A �� * Identified in the GWF EIA using conservation status and numbers recorded during GWF surveys ** Although identified as being species of principle concern, the Flamborough Head and Bempton Cliffs SPA is over 250km from the GWF and there is no likely impact pathway for birds associated with colonies at this site. Gannet associated with the Flamborough Head and Bempton Cliffs SPA are considered relevant due to the species wide foraging range (+300km). *** Sightings data from aerial and boat-based surveys suggest that the GWF survey area is relatively unimportant for the species in all months within the context of the South and East North Sea sector (Stone et al., 1995). Populations tend to reach a peak in December-January, likely coinciding with the influx of birds (both adults and juveniles) from more northerly breeding areas augmenting the existing populations of resident birds (Stone et al., 1995). This suggests that the species is relatively coastal throughout the year, and that the GWF is beyond regular foraging ranges of breeding or roost sites. Kubetzki and Garthe (2003) studied the foraging behaviour of herring gull in the breeding season in the south-eastern North Sea, and found that birds forage mainly in the intertidal zone. Small numbers were observed at sea, but very few were recorded more than 40km offshore.


5.1.11 Table 5.1 shows that there is potential for impacts upon the following species

and sites:

• Red throated diver – Outer Thames Estuary SPA;

• Lesser black backed gull – Alde-Ore Estuary SPA; and

• Gannet – Flamborough Head SPA.

As a result, these will be assessed in more detail within subsequent sections of this HRA Screening Report

5.1.12 It is considered that there are no pathways for impacts upon the remainder of the offshore ornithological features of any of the European sites assessed as part of this screening exercise.

Onshore

5.1.13 Breeding bird surveys recorded over 60 species, although no species associated with European designated sites were recorded within or close to the proposed onshore footprint. The overall the works area is not considered of local importance for breeding birds.

5.1.14 Nonwithstanding this, the proximity of both the Sandlings SPA, and the Minsmere to Walberswick SPA/Ramsar (which lay within 2km of the onshore site) require that these SPAs must be considered further as part of the HRA Screening exercise. Those designated species considered comprise:

• Avocet;

• Bittern;

• Little tern;

• Marsh harrier;

• Nightjar;

• Hen harrier;

• Shoveler;

• Gadwall;

• Teal;

• Whitefronted goose; and

• Woodlark.


SAC

5.1.15 Potential impacts on SAC designated features as a result of the GWF development comprise habitat loss (during construction and decommissioning) and disturbance.

5.1.16 At this point of the assessment, all four SACs cannot be excluded in relation to potential impacts on interest features and are considered in subsequent sections of the HRA Screening exercise.

High level screening

5.1.17 On the basis of the known presence and distribution of the designated interests relevant to the GWF Project and the likely effects of the development (as detailed in the previous sections), an initial high-level screening has been undertaken to determine the potential for the project activities to influence the designated features of the selected European sites.

5.1.18 The main activities and effects of the GWF Project that have the potential to influence the designated international sites are identified below for the construction, operation and decommissioning stages. The previous sections provide an explanation of those sites / features which have not been considered further.

Potential impacts on the Alde-Ore SPA lesser black-backed gull population:

• Construction & Decommissioning

o Habitat loss; and

o Disturbance.

• Operation

o Displacement;

o Collision risk; and

o Barrier effects.

Potential impacts on The Sandlings SPA nightjar and woodlark population.

Potential impacts also include effects on those habitats which support the aforementioned species:


o Disturbance.

• Operation

o None.

Potential impacts on the Outer Thames SPA red-throated diver population:



o Habitat loss; and

o Disturbance.

• Operation

o Displacement;

o Collision risk; and

o Barrier effects.

Potential impacts on the Flamborough Head to Bempton Cliffs SPA gannet population:


o None.

• Operation

o Collision risk.

Potential impacts on the Minsmere to Walberswick SPA breeding populations of avocet, bittern, little tern, marsh harrier, shoveler, gadwall, teal and nightjar; along with wintering populations of shoveler, hen harrier, gadwall and white-fronted goose. Potential impacts also include effects on those habitats which support the aforementioned species:


o Habitat loss; and

o Disturbance.

• Operation

o Disturbance.

Potential impacts on the Orfordness to Shingle Street SAC ‘annual vegetation of drift lines’ and ‘perennial vegetation of stony banks’ and ‘saline lagoons’ features:


o Habitat loss; and

o Disturbance.

• Operation

o Disturbance.

Potential impacts on the Alde, Ore and Butley Estuaries SAC ‘estuaries’, ‘Atlantic salt meadows (Glauco-Puccinellietalia maritimae)’, and ‘mudflats and sandflats not covered by seawater at low tide’ features:



o Habitat loss; and

o Disturbance.

• Operation

o Disturbance.

Potential impacts on the Minsmere to Walberswick Heaths and Marshes SAC ‘annual vegetation of drift lines’, ‘European dry heaths’, ‘perennial vegetation of stony banks’ and ‘coastal lagoon’ features:


o Habitat loss; and

o Disturbance.

• Operation

o Disturbance.

Potential impacts on the Margate and Long Sands cSAC ‘sandbank’ features:


o Habitat loss; and

o Disturbance.

• Operation

o Habitat loss; and

o Disturbance.

5.1.19 Table 5.2 presents the results of the initial screening assessment in relation

to the above activities / effects. The table identifies those interest features where the potential for interaction with the proposed project activities exists. Supporting information regarding Technical Notes are provided in Appendices B to C.

5.1.20 An initial view is provided as to whether the project is likely to have a significant effect with regard to the identified sites and features. Three categories have been utilised, as follows:

• No likely significant effect – based on available information on project activities and their potential effects it is considered that there would be no likely significant effect with respect to the identified feature and site. This determination is based on a number of factors, but mainly, distance between the GWF Project site(s) and the designated areas and the lack of either direct or indirect impact pathways that could affect the designated features of the sites in question;


• Potential for a likely significant effect – the possibility of a likely significant effect cannot be ruled out; and

• Likely significant effect – based on available information it is apparent that project activities would have an impact upon designated features and could lead to significant adverse temporary or long term change.

5.2 Plans and Projects for Assessment of In-combination Effects

5.2.1 Regulation 61 of the Habitats Regulations requires the competent authority to make an Appropriate Assessment of any plan or project which is likely to have a significant effect on a European site, either alone or in-combination with other plans or projects. In-combination effects are considered within the screening assessment presented in Table 5.2.

5.2.2 The Regulations limit the scope of the in-combination test to “other plans or projects” where these should include:

• Approved but as yet uncompleted plans or projects;

• Permitted ongoing activities (e.g. discharge consents or abstraction licences);

• Plans and projects for which an application has been made and which are currently under consideration but not yet approved by the competent authorities; and

• Plans or projects which are being planned but an application is yet to be submitted to the Competent Authority.

5.2.3 In light of the outcome of the initial assessment work undertaken in Section 5, it is considered that the following wind farm projects and ongoing permitted activities plans may have the potential for in-combination effects with the GWF Project, in terms of potential impacts on the Alde-Ore SPA lesser black-backed gull population:

• Additional renewable development projects from Rounds 1, 2, 2.5 and 3;

o GGOWF;

o Gunfleet Sands III;

o Kentish Flats Extension;

o London Array (Phases I and II); and

o East Anglia Offshore Wind Farm project ONE (East Anglia ONE).

• Aggregation extraction areas and active dumping grounds.


5.2.4 There are a number of aggregate extraction areas and active dumping grounds within the vicinity of GWF, the most relevant being the application / prospecting areas in close proximity to the export cable route, in particular Shipwash 507/5 (Cemex UK Marine Ltd) which is located within the cable corridor route. Consultation with Cemex UK Marine Ltd in regard to their activities at this site is ongoing.

5.2.5 In respect to onshore plans and projects the proposed Sizewell B Dry Fuel Store has a construction phase expected to take place during 2012/2013, and therefore will be in operation upon commencement of construction at GWF in 2014. The new dry fuel store building is proposed to sit within the existing Sizewell B Nuclear Site Licence area. The non-technical summary for this development (EDF, 2010) indicates that there will be no significant impacts on habitats at the site given that it is on an existing car park. In addition the replacement parking area will result in the permanent loss of 0.5ha of semi-natural habitats, however these are of low ecological value, and not within any European designated sites.

5.2.6 EDF Energy also has expansion plans for Sizewell C. This project has been nominated with the IPC but to date no formal scoping exercise has been undertaken. This development would lie to the north of the existing Sizewell infrastructure and construction is not expected to begin until approximately 2017 with no further information available at the time of writing.

5.2.7 No additional onshore plans or projects are considered relevant to the onshore development of GWF as potential impacts are anticipated to be localised and contained within the site or within close proximity of the substation and cable works.


Table 5.2 European sites screened for the GWF Project

Project component and stage Feature and potential impact

Construction & decommissioning Operation In-combination

Alde-Ore Estuary SPA - 28km from the GWF site; 5km from onshore substation.

The proposed wind farm area is not within the SPA boundary. Lesser black-backed gulls are wide-ranging within the Greater Thames area, and the amount of sea directly lost to turbine construction outside of the SPA and therefore main foraging areas is therefore negligible. Lesser black-backed gull is rated as being of “Very Low” sensitivity to habitat loss by Maclean et al. (2009).

N/A GWF alone, or in-combination with other wind farms, will not contribute to any habitat loss as they lie outside of the SPA boundary. The opportunistic, wide-ranging nature of the species means that habitat loss for SPA-associated birds will be negligible within the context of overall foraging range of up to at least 80km..

Lesser black-backed gull: habitat loss

No likely significant effect No likely significant effect No likely significant effect

Lesser black-backed gull is rated as being of “Low” sensitivity to disturbance by Maclean et al. (2009).

GWF survey evidence suggests the species is not affected by the presence of human-related activities, often being actively attracted to fishing vessels in search of food. Any disturbance effects will be temporary and will have no observable impact on any individual’s fitness or breeding success, due to alternative habitat availability.

N/A GWF construction will not overlap with that of GGOWF. Other wind farms (with the possible exception of the London Array Phase II and East Anglia ONE) will not coincide with the GWF construction phase, as such, disturbance within the context of the SPA population not considered likely. Cumulative disturbance due to maintenance activities is considered very unlikely due to the species’ tolerance for human-related activity.

Lesser black-backed gull: Disturbance


Lesser black-backed gull:

N/A Aerial surveys in the Greater Thames showed that lesser black-backed gulls are likely to be

Data from aerial surveys indicate that the lesser black-backed gull is




Displacement more common in inshore areas than offshore (DTI, 2006a; BERR, 2007). This screening assess the likelihood that lesser black-backed gull from the Alde-Ore SPA would suffer significant long-term displacement from important foraging or loafing areas in the vicinity of physical infrastructure associated with the GWF wind farm. Which would equate to, at most, the entire turbine area plus a buffer zone of up to 4km (as per Maclean et al. 2009). The species has a ‘negligible’ sensitivity to habitat limitations (Maclean et al. (2009). Within the GWF survey area, lesser black-backed gull distribution was often concentrated in ephemeral large aggregations, most likely in response to increased prey resources, e.g. discards from trawlers working in and passing through the survey area. There was no apparent pattern to the location of these aggregations based on the Kernel analysis undertaken as part of the GWF EIA (GWFL, 2011). Monitoring results from operational Dutch wind farms by Leopold et al. (2010) found that lesser black-backed gull were often seen within the perimeters of the operational wind farm, sometimes resting on the water or on

relatively evenly distributed throughout the Thames Strategic Area, although gulls in general were more common nearer to the coast (DTI, 2006a; BERR, 2007). Results of radio-tagged birds from both Orfordness within the SPA, and Texel, The Netherlands have shown that lesser black-backed gulls forage extensively and employ a variety of feeding strategies, which enables them to utilise different areas. The SPA Conservation Objectives highlight the variety of habitats and food resources available to lesser black-backed gulls. The core foraging range within the breeding season is 40km, which would take in GWF, GGOWF, London Array Wind Farm, Gunfleet Sands and East Anglia ONE Wind Farms. Given the evidence in relation to micro-avoidance from other operational wind farm sites, and the adaptive foraging strategies employed by this wide-ranging species, any localised displacement effects at these sites are unlikely to result in loses to the




the monopole structures, or feeding in the tidal wakes of the monopiles. These observations were also supported by the findings of Krijgsveld et al. (2010), where lesser black-backed gulls appeared to show no avoidance of the OWEZ wind farm (macro avoidance), and were commonly recorded foraging within the footprint. Of the birds that did enter the wind farm, all species showed very strong avoidance close to individual turbines (micro-avoidance). This also corresponds with observations of gulls at Horns Rev (Petersen et al. 2006). Monitoring surveys of operational offshore turbines in UK waters (including North Hoyle and Kentish Flatshave also shown that lesser black-backed gulls show no obvious displacement effects. It is therefore unlikely that displacement will take place out to the recommended precautionary 4km buffer and would realistically be confined, at worst, to the GWF turbine areas alone. The peak breeding season population estimate for the GWF site was 1,001 birds in June 2009, which represents one third of the current Alde-Ore Estuary SPA breeding population. Given the empirical evidence from other operational wind farm sites in relation to

Alde-Ore population. With alternative habitat available, no in-combination displacement effects are predicted.




micro-avoidance, this predicted level of impact is considered unlikely: lesser black-backed gulls forage widely and through analysis of ship-based surveys, Schwemmer and Garthe (2005) and Camphuysen et al. (2008) found a significant association between offshore distribution and commercial fisheries. Post-construction, lesser black-backed gulls are likely to follow fishing vessels, whether close to the wind farm or not, thereby minimising any displacement effects. This is supported by the findings of the GGOWF Appropriate Assessment (DTI, 2006a).


Lesser black-backed gull: Collision risk

N/A The lesser black-backed gull have a high sensitivity to collision risk (Maclean et al., 2009). Nationally important numbers have been recorded within the GWF study area. The species activity within the entire GWF survey area is relatively high during the breeding season, with a peak density estimate of 2.8 birds per km2 recorded in June 2008. Numbers in 2009-10 were lower, with a peak density of 2.0 birds per km2 in July 2009. During boat-based surveys within the GWF study area in 2008-10, between 14.2% and 20.0% of all lesser black-backed gulls in flight were recorded at potential collision risk height

Lesser black-backed gulls are known to occur throughout the Thames Estuary, where other Round 1, 2 and 2.5 wind farms are built, under construction or in consenting. Estimates of lesser black-backed gull mortality at other offshore wind farm sites within the upper 80km foraging range of the species ranged from 0.5 at Thanet, to approximately 12 at GGOWF (converted to 99.9% avoidance rate). Preliminary CRM for the East Anglia ONE estimated 3.3




(>20m). Although gulls are more manoeuvrable than divers, they are more likely to forage within or close to offshore wind farms, especially if vessels are present.

The collision risk modelling predicted that 23-33 birds would be lost each year (at 99.9% avoidance rate), which reduces to 16 during the 2009 breeding season (April to August). This would result in an increase in baseline mortality of 5.1% on the current SPA population. The highest mortality was predicted to occur in the late breeding season and subsequent migration period, and is likely to include adults from breeding pairs within the Alde-Ore SPA and other colonies in southeast England within the upper 80km foraging range for the species. Radio-tagged birds from Texel also show that birds that use the GWF site for feeding are also likely to come from a variety of colonies throughout northwest Europe. The assumption that all birds that collide with turbines are from SPA would almost certainly not be the case, and it is reasonable to assume that many birds recorded in the GWF site do not breed in the SPA, and may come from the other breeding colonies cited above.

Lower fishing activity levels, not directly due to

collisions per annum (converted to 99.9% avoidance) when turbines are 90% operational. It is not known where these birds have originated from, although it is possible that birds may have flown from a number of colonies in Essex, Greater London or Kent, as well as the Netherlands, Denmark and Germany.




turbine presence, would therefore reduce future collision risks by moving foraging activity to outside of the wind farm. It is therefore considered that collision risk in the future could pose a lower impact on the SPA population than predicted through modelling. The confidence level of these predictions is however low, and therefore, the effects on the ‘Disturbance’ component of the Conservation Objectives would likely require investigation in an AA.

No likely significant effect Likely significant effect Likely significant effect

Lesser black-backed gull: Barrier effects

N/A Observations of onshore turbines at the East Dam (Zeebrugge) and Maasvlakte (Rotterdam) indicate that lesser black–backed gulls fly between turbines to and from their breeding colonies and marine feeding areas (Everaert et al., 2002). Gulls were rated as being of ‘Low’ sensitivity to barrier effects by Maclean et al. (2009), and are considered among the most manoeuvrable of species by Garthe and Hüppop (2004). There is no evidence to suggest that there is a regular foraging route between breeding colonies and particular foraging areas via the wind farm area, and it is therefore concluded that there will be no barrier effects in the context of the SPA.

Only the GGOWF reported a possible barrier effect on lesser black-backed gull, which is expected since the site lies within foraging range of the breeding colonies in the SPA. Although the species is highly manoeuvrable and likely to pass between turbines, it is a possibility that due to the large number of flights during the breeding season, small incremental reductions in a breeding pair’s and therefore juvenile gulls’ fitness may build up. Based on the relative turbine layouts of the two sites however, the adjacent GWF would likely account for a negligible increase in flight length, since birds




heading to and from the colony would already take evasive action due to the presence of GGOWF turbines. There is however no evidence that GWF and GGOWF combined will create a significant barrier to movement. Other offshore wind farms in the Thames Strategic Area are each separated by several kilometres of open sea and there is no continuous barrier in the context of the SPA. No barrier effects are predicted.


The Sandlings SPA - 32.5km from the GWF site; 300m from onshore substation.

The SPA is 300m from the proposed works. Given that the works will not require piling, there is not expected to be any significant noise or vibration disturbance. It should also be noted, that the SSSI Unit closest to the development is currently in unfavourable condition and unlikely to be supporting nightjar and woodlark.

No disturbance to the Nightjar and Woodlark once the substation is in operation (i.e. low noise, potentially buffered). Low foraging range of Annex I species predominately woodland and heath (not intertidal or offshore).

Similar to construction phase. Nightjar and Woodlark (and associated supporting habitats), disturbance


Outer Thames Estuary SPA - 8km from the GWF site; 0km from offshore cable route, 0.8km from onshore substation.

Red-throated diver: Habitat loss

Subsea transmission cable installation may result in temporary loss of SPA habitats associated with red-throated diver prey species. However, the

N/A The Environmental Statements for other wind farms in the Outer Thames area all predict non-significant




species is wide-ranging within the Thames Strategic area, and the proportion of habitat directly lost to turbine construction outside of the SPA and, therefore, main foraging areas, is negligible. No SPA sublittoral, shallow (<20m) sandbank habitat will be lost, which is the priority habitat for red-throated diver referred to in the Conservation Objectives.

The loss in extent of suitable SPA habitat for divers from transmission cable installation will be both temporary, and negligible in magnitude. Any effects on SPA seabed habitat are likely to be less extensive than the dredging activity that currently takes place in the Thames area. DTI (2006b) report that there is considerable evidence in the southern North Sea that demonstrates that the highly dynamic, sediment-rich waters, together with largely opportunistic benthic species, lead to rapid re-establishment of the fauna, e.g. within months or by the following year, in response to seabed disturbance from dredging, dumping and aggregates extraction (e.g. Newell et al, 2004 and MMS, 1999).

impacts on red-throated diver. Only small areas of habitat would be lost, amounting to a total of less than 0.5% of the SPA (DTI, 2006a). GWF alone, or in-combination with other wind farms, will therefore not contribute to any significant habitat loss as it lies outside of the SPA boundary. The transmission cable will be installed below water and habitat loss would be short-term only, during installation and re-colonisation of benthic fauna.


Red-throated diver: Disturbance

Garthe and Hüppop (2004) rated red-throated diver as being a species of the highest sensitivity to boat-based disturbance, and the general sensitivity of the species to disturbance was considered by Maclean et al. (2009) to be Very

By the time that GWF will reach its construction phase, GGOWF, will be fully operational and so disturbance caused by maintenance activities in




High. High volumes of boat traffic are already present in the Thames Strategic Area. Despite this, the area is nationally important for the species, and numbers have remained stable, at least in recent years. It is, therefore, likely that any displacement effect would be temporary and that red-throated diver would return if the area was of sufficient quality for food resources.

Within the GWF survey area, numbers were low during this period (peak of 11 birds). Construction activity associated with the transmission route within the SPA would only potentially affect divers during winter months, when birds are present within the area. Nevertheless, it is considered unlikely that there will be a significant disturbance effect even if localised cable-laying activities were to take place during this period. Any effects would be temporary and unlikely to affect individuals’ fitness to a significant extent over a whole winter, as birds are likely to naturally forage widely in response to prey movements. No potential LSE was highlighted in the GGOWF AA (DTI, 2006b) as a result of cable-laying activities, which were similar in nature and location to the proposed GWF route.

the latter site will be less frequent and of low magnitude (assuming that birds continue to use the wind farm area post construction). As such, the in-combination disturbance effects of GWF and Greater Gabbard are unlikely to be significant within the context of the SPA population. As construction effects are likely to be restricted to the short-term, any cumulative impacts will only occur if the construction phases of the wind farm projects are coincidental. It is evident that most OWFs in the Thames area will be operational by the time that GWF is in construction. The only possibility of overlapping construction activity is with the planned London Array Phase II and East Anglia ONE. It is considered unlikely that any significant effects will result, due to the distance between sites and the localised and temporary nature of the works. Red-throated divers are likely to be habituated to some extent to boat traffic in the Greater Thames area already.


Red-throated The GWF site is around 27km from the shore at Evidence suggests that divers do generally The proportion of the Outer Thames




diver: Displacement

its closest point, which is outside the main distribution area of red-throated divers recorded during aerial surveys in southeast England, established as being mainly 10-20km from the shore (e.g. DTI, 2006a; DECC, 2009; Webb et al. 2009). This suggests that the GWF site, whilst frequented, supports sub-optimal habitat for the species. Evidence from the aerial surveys above confirms that the GWF and GGOWF sites are relatively unimportant to the species, compared with areas further inshore in the Thames Estuary. Thames Strategic Area Aerial Surveys 2004/05, 2005/06, 2007/08 (DTI, 2006a, BERR 2007, DECC 2009), indicated that highest densities of divers were in mid channel in the outer part of the Thames Estuary and inshore areas. Although birds were consistently encountered over 40km from shore, albeit in low densities, very few divers were recorded in and around the GWF study area. Distance-based density estimates of sightings between January-February, from all years, were lower within the ‘TH3’ survey block (which overlaps with the GWF) that the inshore ‘TH1’, ‘TH2’ and ‘TH4’ areas. For example, in 2004/05 TH3 was estimated to hold 1.5% of the SPA population (TH1: 18% and TH4: 34%) and in 2005/06 TH3 had a peak population estimate which equated to 11.2% of the SPA population (TH1 and TH2: 64%), in 2007/08 the GG1 and GG2 study area held and estimated 2.4% of the

avoid wind farms, although may still be found near and within turbine areas if the habitat is of sufficient quality. Furthermore, it has suggested (Percival, 2009) that the magnitude of this displacement may be decreasing through time, potentially due to habituation, although this was not statistically tested.

When GWF plus 4km buffer alone is considered, the proportion of the SPA population potentially affected is 1.7%.

The main concentrations of red-throated diver in the Greater Thames areas are well inshore to the south and west of GWF, and this is likely due to the area being sub-optimal habitat for the species, being in deeper water than preferred. It is unlikely that surrounding areas are at carrying capacity for the species, and therefore the relatively small numbers that might be displaced from the proposed wind farm site will be able to settle elsewhere. If this is the case, then any increases in mortality to the SPA population as a result of displacement will be insignificant, particularly as it would only be expected to affect any individuals during the short-term.

SPA population recorded within OWFs in the Greater Thames was very high and cumulatively exceeded the citation figure. The high value was mainly due to the February 2004 survey results at London Array which recorded a single flock of 4,000 birds seen flying through the area (RPS, 2005). This unusual observation was likely to reflect bird aggregating more closely in larger flocks before their spring migration, and so likely included birds that would have been present across the Greater Thames area during winter months. This would likely lead to a larger over-estimation in numbers. Excluding this figure, numbers only reached 8.4% of the SPA population. Within two Appropriate Assessments for London Array and Gunfleet Sands 2, the buffer zone for red-throated diver was considered to be 1km. This was assumed to be sufficient to capture the significant proportion of the population of red-throated divers that would be displaced from the wind farm and the surrounding area (London Array Ltd Scoping Response to Galloper Wind Farm, July 2011).




population.

Population estimates from boat-based surveys in 2008-10 suggest that for the majority of the winter the GWF survey area holds smallish numbers of divers (<1% of the SPA population), except during the main spring migratory period in February and March when birds are more widespread. It is therefore more likely that at least some of these birds do not overwinter in the Outer Thames SPA, but in areas further south. Behaviour of observed birds was recorded during boat-based surveys, and although this category may be less of a priority for surveyors than count and species identification for example, it was evident that no birds were observed feeding in either 2008/09 or 2009/10. Although it is acknowledged that recording red-throated diver feeding behaviour may be difficult since birds dive beneath the surface to capture prey, or they may be disturbed by the boat’s presence, it is still unlikely that the study area is an important foraging site for the species in comparison to inshore waters- within the context of the wider southern and eastern North Sea. Therefore, it is probable that any temporary displacement at the wind farm site is unlikely to significantly affect the integrity of the SPA population- in the context of optimal habitat and foraging areas found in the wider Thames Estuary.

Although it is likely that red-throated diver would be relatively sensitive to the presence of the wind farm as a whole, the displacement of up to 112 birds, or 1.7% of the SPA population from the GWF study area (out to 4km) is likely to be an overestimate of the likely magnitude of impacts as (i) displacement is likely to be less than 4km and therefore many birds would be able to make use of the GWF buffer zone outside of the SPA; and (ii) the GWF population is likely to consist of many overwintering non-SPA birds from outside of the region passing through on migration to breeding areas in northern Europe. Aerial survey results suggest the GWF site is sub-optimal for the species, sector TH3 always held lowest diver densities in winter 2004/05. Only in February-March 2005/06 were numbers relatively high, during the migration It is unlikely that all birds displaced would be associated with the SPA, thereby reducing the likelihood of significant effects on its population to below 1%. Any displacement of low numbers of red-throated divers could




be absorbed by a number of adjacent areas of apparently better habitat Due to the long-term dredging activity in the area and the wide-ranging nature of red-throated diver, it is likely that the current population is already adapted to such operations, and that effects would be short-term and temporary. It is expected that any increase in displacement effects would only be potentially significant when there was a concentration of activity in a single year within the main foraging areas for the species. It is therefore concluded that combining the wind farms with the ongoing effects of dumping and extraction will not create in-combination effects that are significant.


Red-throated diver: Collision risk

N/A Evidence suggests that divers generally avoid wind farms (e.g. Christensen et al., 2004) and the species has a high predicted avoidance rate of 99.0% (Maclean et al. 2009). Boat-based surveys within the GWF in 2008-10, observed that between 1.1% and 4.9% of all red-throated divers in flight were recorded at potential collision risk height (>20m). As

A review of collision risk estimates for all wind farms within the Thames Strategic Area (where data were available – GGOWF, Kentish Flats and Thanet) resulted in a cumulative mortality of 5.8-6.1 birds per year (<1% increase in SPA baseline mortality), which includes the GWF




part of the Collision Risk Modelling (CRM) to inform the GWF EIA, the Band model assumed that an average 2% of birds were recorded flying at potential collision height. Assuming that the survival rate of the SPA population is close to that recorded elsewhere (0.85: Garthe and Huppop, 2004), to reach a 1% rise in mortality rate, at least 9 birds would have to collide with turbines each year, assuming all are from the SPA. When using a precautionary 95% avoidance rate, an average of only 2.9 collisions will occur each year at the GWF, which results in an increase in baseline mortality of 0.3%. With the population in apparent favourable condition, the mortality rates presented above would not in any case affect the integrity of the SPA and its conservation objectives.

total, using a 99.0% avoidance rate. The low levels of predicted mortality due to collisions at other sites, reported above reflect the fact that the vast majority of flights in the Thames Strategic Area were recorded below collision height


Red-throated diver: Barrier effects

N/A Barrier effects are determined by considering (i) the number of birds likely to be flying through the wind farm; and (ii) the extent to which the wind farm will act as a barrier. This is based on biological characteristics (e.g. wing loading) as well as the sensitivity of species to turbines. Red-throated diver was rated as being of “high” sensitivity to barrier effects by Maclean et al. (2009). Overall, 71-86% at Horns Rev, and 78% at

Offshore wind farms have the potential to pose a barrier to migratory movements of divers (e.g. Horns Rev 1). Drewitt and Langston (2006) summarised data on barrier effects of offshore developments, and concluded that none of the barrier effects identified had significant impacts on populations. They identified example scenarios where a




Nysted, of all bird flocks, including divers, scoters and eider, heading for the wind farm at 1.5-2.0km distance avoided entering into the wind farm between the turbine rows (Petersen et al. 2006). There was considerable movement of birds along the periphery of both wind farms, as birds preferentially flew around rather than between the turbines. Changes in flight direction tended to occur closer to the wind farm by night than day at both sites, but avoidance rates remained high in darkness, when it was also shown birds tend to fly higher. Such avoidance was calculated to add an additional period of flight equivalent to an extra 0.5-0.7% on normal migration costs of eiders migrating through Nysted. Although red-throated diver are likely to range widely within the Thames Strategic Area throughout the winter, there is no evidence from any of the surveys undertaken that there are clear patterns of movement. It is acknowledged that information on preferred foraging areas is incomplete, but there is no evidence to suggest that birds must commute in the vicinity of the GWF or GGOWF to reach important feeding areas. No such behaviour has been recorded at any of the other offshore wind farm locations in the Thames area, according to DTI (2006b). Winkelman (1992) reported on large-scale autumn migrations at

population level impact might be seen, including where several wind farms interact cumulatively to create an extensive barrier which could lead to diversions. These scenarios would not appear to be present in this case, and even if such an effect was present for migratory birds, it is unlikely that the majority would be from the SPA. Resting and foraging areas are both marine so resting/foraging journeys are unlikely to be comparable to a land-roosting bird.




a wind farm in Oosterbierum in the Netherlands, and noted that larger species (likely to include divers) reacted at the greatest distances compared to smaller passerines during daylight hours. . A peak monthly snapshot count of five birds was recorded within the two GWF turbine areas, which equates to less than 1% of the SPA population. Using this figure (as per Maclean et al. 2009), it is evident that no significant barrier effects are likely.


Flamborough Head and Bempton Cliffs SPA - over 250km from GWF site and onshore substation.

Gannet: Collision risk

N/A Garthe and Hüppop (2004) suggest that gannets predominantly fly between 10 and 20m. Observations of gannet flight behaviour at operational wind farms suggest that birds do strongly avoid wind farms as a whole (demonstrating a combination of macro avoidance, micro avoidance (Krijgsveld et al. 2010) and low flight altitudes,. Collision rates are likely to be very low, and realistically avoidance would be at least 99.5% as recommended by Maclean et al. (2009). The GWF site is just under 300km from the SPA and barely within the mean maximum foraging range (Langston, 2010). Birds found within the GWF site during the breeding

Gannet has been included following consultation with the JNCC and Natural England. Whilst the species do not breed within the Greater Thames area, was not recorded in nationally-important numbers within the GWF survey area, birds may pass through the site that originate from SPAs further north. Empirical data for patterns of gannet usage within the North Sea suggest that in summer months, breeding birds from SPA colonies are likely to be mainly confined within 100km of the colony. Birds present within the




season are likely to be mainly wandering non-breeders and sub-adults not attached to this SPA. Breeding birds found in the GWF that originate from the SPA are only likely to pass through once or twice per season on migration, particularly during autumn, and therefore are at negligible risk from collision.

GWF site are likely to originate from across most of northern Europe, even on occasion those from colonies in western and southern Britain, as well as Norway and France. With such high numbers, few collisions will be birds from the Flamborough Head and Bempton Cliffs SPA, which will likely be present on migration only, and so the GWF will not contribute significantly to cumulative mortality on gannets.


Minsmere to Walberswick SPA (and Ramsar) – 35.5km from GWF site; 2km from onshore substation.

The proposed wind farm area is not within the SPA (and Ramsar) boundary.

No potential influence on physical conditions affecting habitats supporting populations of Annex I species of European importance of populations of migratory bird species of European importance identified during the construction phase.

Evidence from hydrodynamic modelling for GGOWF predicted effects would be contained to the near field. Given the similar scales of the GGOWF and GWF developments and the greater distance of GWF from the designated site similar conclusions on far field impacts on coastal habitats are anticipated.

Given that all the effects on the hydrodynamic regime during operation will be local to GWF, no potential pathway exists for in-combination impacts.

Shingle, swamp, marginal and inundation communities, saltmarsh, standing water, grassland and heathland: habitat loss No likely significant effect No likely significant effect No likely significant effect

Avocet, little tern, marsh harrier, nightjar, woodland and

The proposed wind farm area is not within the SPA (and Ramsar) boundary. Given the distance from the works, there is not expected to be any significant noise or vibration disturbance.

The proposed wind farm area is not within the SPA (and Ramsar) boundary. Given the distance from the works, there is not expected to be any significant noise or vibration

N/A




disturbance.

hen harrier, gadwall, teal, shoveler and European white-fronted goose: Disturbance. No likely significant effect No likely significant effect No likely significant effect

Orfordness to Shingle Street SAC – 28km from the GWF site; 7km from onshore substation 35.5km.

The proposed wind farm area is not within the SAC.

Construction impacts associated with increases in suspended sediments during cable laying and foundation installation will be localised and temporary in nature. No effects have been identified that could result in changes to coastal features or habitats further afield than within the immediate footprint of the works (see evidence provided in Appendix C).

Evidence from hydrodynamic modelling for GGOWF predicted effects would be contained to the near field. Given the similar scales of The GGOWF and GWF developments and the greater distance of GWF from the designated site similar conclusions on far field impacts on coastal habitats are anticipated (refer to evidence provided in Appendix C)

Given that all the effects on the hydrodynamic regime during operation will be local to GWF, no Potential pathway exists for in-combination impacts.

Annual vegetation of drift lines, perennial vegetation of stony banks, and lagoons.


Alde, Ore and Butley Estuaries SAC - 29km from the GWF site; 5km from onshore substation.

Estuaries, Atlantic salt meadows and mudflats and sandflats not covered by seawater at low tide.

The proposed wind farm area is not within the SAC.

Construction impacts associated with increases in suspended sediments during cable laying and foundation installation will be localised and temporary in nature. No effects have been identified that could result in changes to coastal

Evidence from hydrodynamic modelling for GGOWF predicted effects would be contained to the near field (see evidence provided in Appendix C). Given the similar scales of the GGOWF and GWF developments and the greater distance of GWF from the designated site similar conclusions on far field impacts on coastal habitats are anticipated.

Given that all the effects on the hydrodynamic regime during operation will be local to GWF, no potential pathway exists for in-combination impacts.




features or habitats further afield than within the immediate footprint of the works (see evidence provided in Appendix C).


Minsmere to Walberswick Heaths and Marshes SAC - 35.5km from the GWF site; 2 km from onshore substation.

GGOWF and GWF share similar project characteristics, studies carried out by APBmer(2011) in support of the Preliminary Environmental Report produced by GWFL showed that conclusions made in the GGOWF ES could be use to provide reasonable indication of the impacts on physical processes from GWF.

No potential influence on physical conditions affecting designated habitats identified during the construction phase.

In regard to the cable landfall and potential impacts on annual vegetation of drift lines, the effects on physical processes and level of disturbance are anticipated to be small scale and localised as a result of the method of cable installation to be employed (HDD). Therefore there are no impacts anticipated on this coastal feature.

Evidence from hydrodynamic modelling for GGOWF (GGWLF, 2006) predicted effects would be contained to the near field, within the immediate vicinity of the wind farm. Given the similar scales of the GGOWF and GWF developments and the greater distance of GWF from the designated site similar conclusions on far field impacts on coastal habitats are anticipated (see evidence provided in Appendix C).

Given that all the effects on the hydrodynamic regime during operation will be local to GWF (see evidence provided in Appendix C), no potential pathway exists for in-combination impacts.

Annual vegetation of drift lines, European dry heaths, perennial vegetation of stony banks and coastal lagoons


Margate and Long Sands cSAC - 16km from the GWF site.

Sandbanks No potential influence on hydrodynamics, wave Evidence from hydrodynamic modelling for Given that all the effects on the




and sediment regime, essential for the maintenance of the sandbanks, is identified during the construction phase (see evidence provided in Appendix C).

GGOWF predicted no far field effects on the hydrodynamics and hence geomorphological regime of the cSAC (see evidence provided in Appendix C). Given the similar scales of the GGOWF and GWF developments and the greater distance of GWF from the designated site similar conclusions on far field impacts on the sandbanks of the SAC can be drawn.

No operation effects are predicted to the hydrodynamics and sediment dynamics that are essential to the integrity of the sandbanks.

hydrodynamic regime during operation will be local to GWF, no potential pathway exists for in-combination impacts (see evidence provided in Appendix C).


All potential impacts will be localised and therefore, there is no potential pathway for impact on features of the SAC.

All potential impacts will be localised. Therefore there is no potential pathway for impact on features of the SAC.

All potential impacts will be localised and therefore, there is no potential pathway for in-combination effects to occur.

Reef-forming ross worm (Sabellaria spinulosa)



5.2.8 The HRA Screening Assessment did not identify any likely significant effects on the Flamborough Head and Bempton Cliffs SPA as a result of impacts that may arise from the development of GWF, in particular relating to additional mortality due to collisions with turbines.

5.2.9 The HRA Screening Assessment did not identify any likely significant effects on the Outer Thames SPA as a result of impacts to red-throated diver, in particular relating to disturbance, displacement and additional mortality due to collisions with operational turbines.

5.2.10 On the basis of the screening information presented in Table 5.2, it is therefore considered that the GWF Project could have a likely significant effect on the following sites of international nature conservation importance:

• Alde-Ore Estuary SPA

5.2.11 The lesser black-backed gull breeding colonies within the Alde-Ore Estuary

SPA are around 25km from the proposed GWF development. As the species is opportunistic and ranges widely to forage, it is not anticipated that factors such as direct habitat loss, disturbance-displacement and barrier effects would be significant. It is possible that a significant increase in mortality over the baseline rate due to collisions with turbines may occur, particularly when assessed against the background of a declining SPA population.

5.2.12 A precautionary approach suggests that at this screening stage, the potential adverse effects on the integrity of the Alde-Ore SPA lesser black-backed gull population as a result of increased collision mortality cannot be ruled out

5.2.13 In line with IPC tenth advice note on ‘Habitat Regulations Assessment relevant to nationally significant infrastructure projects’ (IPC, 2011), it is the intention of GWFL to submit a ‘No Likely Significant Effects Report’ with the DCO application providing information on the following eight European sites that have been screened out:

• Outer Thames Estuary SPA;

• The Sandlings SPA;

• Minismere to Walberswick SPA and Ramsar;

• Flamborough Head and Bempton Cliffs SPA;

• Orfordness to Shingle Street SAC;

• Alde, Ore and Butley Estuaries SAC;

• Minsmere to Walberswick Heaths and Marshes SAC; and

• Margate and Long Sands cSAC.


6 CONCLUSIONS

6.1.1 Under the requirements set out under the Council Directive 92/43/EEC on the conservation of natural habitats and of wild flora and fauna (the ‘Habitats Directive’) and in line with IPC tenth advice note on ‘Habitat Regulations Assessment relevant to nationally significant infrastructure projects’ (IPC, 2011), this report outlines the methods used and the findings arising from the screening stage of the Habitats Regulations Assessment undertaken for the onshore and offshore assets of the GWF.

The screening assessment and conclusions were informed by:

• The ornithological consultation meeting minutes (Appendix A); • The ornithological technical report for HRA screening (Appendix B); • The technical note on physical processes with regard to Margate and

Long Sands cSAC (Appendix C); • Information gathered on European sites (Section 4); • The summary analysis of potential environmental impacts generated

by the development activities arising from the GWF Project (Section 5); and

• Consideration of the other plans and projects that have spatial/ contextual relevance (Section 5).

6.1.2 The HRA considered nine European sites adjacent to, or potentially affected

by, the proposed GWF development area. The nine sites were assessed by considering the key impacts identified as arising from the construction, operation and decommissioning of the onshore and offshore assets of the wind farm. These impacts were assessed against the factors required to maintain European site integrity including the conservation objectives of the individual designated sites. The findings are summarised in Table 6.1 below.


Table 6.1 Summary of potential significant effect screening

Impact Habitat loss Disturbance Displacement Collision risk Barrier effect

Phase

Con

stru

ctio

n &

Dec

omm

issi

on

Ope

ratio

n

In-c

ombi

natio

n

Con

stru

ctio

n &

Dec

omm

issi

on

Ope

ratio

n

In-c

ombi

natio

n

Con

stru

ctio

n &

Dec

omm

issi

on

Ope

ratio

n

In-c

ombi

natio

n

Con

stru

ctio

n &

Dec

omm

issi

on

Ope

ratio

n

In-c

ombi

natio

n

Con

stru

ctio

n &

Dec

omm

issi

on

Ope

ratio

n

In-c

ombi

natio

n

Outer Thames SPA � � � � � � � � � � � � � � �

Alde-Ore SPA, Ramsar and Marine Site

� � � � � � � � � � � � � � �

Sandlings SPA � � � � � � -- -- -- -- -- -- -- -- --

Minsmere to Walberswick SPA and Ramsar

� � � � � � � � � � � � � � �

Flamborough Head and Bempton Cliffs SPA

-- -- -- -- -- -- -- -- -- � � � -- -- --

Orfordness to Shingle Street SAC

� � � � � � -- -- -- -- -- -- -- -- --

Alde, Ore and Butley Estuaries SAC

� � � � � � -- -- -- -- -- -- -- -- --

Minsmere to Walberswick Heaths and Marshes SAC

� � � � � � -- -- -- -- -- -- -- -- --

Margate and Long Sands cSAC

� � � � � � -- -- -- -- -- -- -- -- --

Key: � Likely significant effect, � No likely significant effect, -- Not relevant


6.1.3 The screening assessment showed that, during operation, the GWF may have a likely significant effect on site integrity of the Alde-Ore SPA, both alone and in-combination with other neighbouring windfarm sites. These significant effects on site integrity arise from the potential collision risk posed to the breeding population of lesser black-backed gulls. As a likely significant effect cannot, at this stage, be ruled out, further assessment and information will be provided within the GWF HRA Report (currently in preparation) which will be submitted as part of the DCO application, alongside the GWF Environmental Statement (ES). The Information to Inform the Appropriate Assessment within the HRA Report will enable the competent authority to make an Appropriate Assessment as laid down in Article 6(3)) of the 2010 Habitat Regulations (as amended).

6.1.4 Should it be determined that an Appropriate Assessment will be necessary, it is recommended that this should be limited to a consideration of the effects of collision risk mortality on the integrity of the SPA population and the ‘disturbance’ component of the conservation objective. This will primarily involve (i) establishing whether or not a significant portion of lesser black-backed gull originate from the Alde-Ore Estuary SPA breeding population, and (ii) ascertaining whether the additional mortality of SPA birds caused by collisions will prevent favourable status of the SPA population being maintained/attained. GWFL would seek to continue their close consultation with the SNCBs in relation to the optimisation of survey data, analysis and impact assessment methodologies in order to inform a robust and

6.1.5 It is felt that there is sufficient evidence presented within this report to recommend that the requirement for HRA on the following European sites can be screened out, and therefore, would not require an Appropriate Assessment:

• Outer Thames Estuary SPA;

• The Sandlings SPA;

• Minsmere to Walberswick SPA;

• Flamborough Head and Bempton Cliffs SPA;

• Orfordness to Shingle Street SAC;

• Alde, Ore and Butley Estuaries SAC;

• Minsmere to Walberswick Heaths and Marshes SAC; and

• Margate and Long Sands cSAC.

6.1.6 In line with IPC tenth advice note on ‘Habitat Regulations Assessment

relevant to nationally significant infrastructure projects’ (IPC, 2011), it is the intention of GWFL to submit a ‘No Likely Significant Effects Report’ with the DCO application on the eight European sites that have been screened out. The No Likely Significant Effects Report will form part of the HRA Report (in preparation) and will contain information as stipulated in Table 2 of the tenth IPC advice note (IPC, 2011).


7 REFERENCES

BERR (2007). Aerial Surveys of Waterbirds in Strategic Wind Farm Areas: 2005/06 Final Report. Department of Business, Environment and Regulatory Reform, London. BirdLife International (2010). BirdLife Seabird Wikispace. Available online: http://seabird.wikispaces.com/ Accessed 04/04/11. Christensen, T.K., Hounisen, J.P., Clausager, I. & Petersen, I.K. (2004). Visual and radar observations of birds in relation to the collision risk at the Horns Rev offshore wind farm – annual status report 2003. NERI Report, 53pp Cook, A.S.C.P., Wright, L.J. and Burton, N.H.K. (in prep.). A review of methods to estimate the risk of bird collisions with offshore windfarms. Draft report of work carried out by the British Trust for Ornithology on behalf of the Crown Estate. DCLG (2006). Planning for the Protection of European Sites: Appropriate Assessment - Guidance For Regional Spatial Strategies and Local Development Documents. DECC (2009). Aerial Surveys of Waterbirds in the UK: 2007/08, Final Report. Department of Energy and Climate Change, London. Dierschke, V. and Garthe, S. (2006): Literature review of offshore wind farms with regard to seabirds. In: Zucco, C., W. Wende, T. Merck, I. Köchling & J. Köppel (eds.): Ecological Research on Offshore Wind Farms: International Exchange of Experiences. Part B: Literature Review of Ecological Impacts: 131-198. BfN-Skripten 186, Bundesamt für Naturschutz, Bonn. Drewitt A.L. and Langston RHW (2006). Assessing impacts of windfarms on birds. British Ornithologists union, Ibis, 148: 29-42 DTI (2006a). Aerial Surveys of Waterbirds in Strategic Wind Farm Areas: 2005/05. Final Report. Department of Trade and Industry, London. DTI (2006b). Appropriate Assessment with regard to Greater Gabbard Wind Farm. Department of Trade and Industry Energy Development Unit. EDF (2010) Sizewell B Dry Fuel Store Environmental Statement Non Technical Summary Available at http://www.british-energy.com/documents/NTS.pdf


European Commission (2001). Assessment of plans and projects significantly affecting Natura 2000 sites – Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC. EC November 2001. English Nature (EN) (1997). Habitats Regulations Guidance Note 1. The Appropriate Assessment (Regulation 48): The Conservation (Natural Habitats &c) Regulations 1994. HRGN No.1. English Nature (EN) (1999). Habitats Regulations Guidance Note 3. The Determination of Likely Significant Effect under The Conservation (Natural Habitats &c) Regulations 1994. HRGN No.3. English Nature (EN) (2001). Alde-Ore Estuary European marine site. English Nature’s advice given under Regulation 33(2) of the Conservation (Natural Habitats &c.) Regulations 1994. 25 May 2001. Everaert, J., Devos, K. and Kuijen, E. (2002). Wind turbines and birds in the Flanders. Rapport van het Instituut voor Natuurbehoud 2002.3. Garthe, S. & Hüppop, O. (2004) Scaling possible adverse effects of marine wind farms on seabirds: developing and applying a vulnerability index. Journal of Applied Ecology 41: 724-734. GWFL (2011). Chapter 12: Ornithology. Galloper Wind Farm Preliminary Environmental Report. Galloper Wind Farm Limited. June 2011. Infrastructure Planning Commission (IPC) (2010). Scoping Opinion for Proposed Galloper Wind Farm Project. Infrastructure Planning Commission (IPC) (2011). Habitat Regulations Assessment. Advice Note Ten: Habitat Regulations Assessment relevant to nationally significant infrastructure projects. Joint Nature Conservation Committee (JNCC) (2009a). Natura 2000 Standard Data Form. Orfordness – Shingle Street. Available at URL: http://www.jncc.gov.uk/ProtectedSites/SACselection/n2kforms/UK0014780.pdf Accessed - 15/07/2009. JNCC Marine SPA Team. (2009b). Defining draft SPA boundaries for common scoter and red-throated divers using optimum density thresholds. Unpublished paper to UK Conservation Agency Chief Scientists Group, April 2009. Langston, R. (2010). Offshore wind farms and birds: Round 3 zones, extensions to Round 1 & Round 2 sites & Scottish Territorial Waters. RSPB Research Report No. 39.


Maclean, I.M.D, Wright, L.J., Showler, D.A. and Rehfisch, M.M. (2009) A Review of Assessment Methodologies for Offshore Wind farms. British Trust for Ornithology Report Commissioned by COWRIE Ltd. Natural England (NE) and Joint Nature Conservation Committee (JNCC) (2010). Departmental brief: Outer Thames Estuary Special Protection Area. ODPM (2005). Circular 06/05: Biodiversity and Geological Conservation - Statutory Obligations and Their Impact Within the Planning System. Percival (2009). Kentish Flats Offshore Wind Farm: A Review of Monitoring of Red-throated Divers 2008-09. Ecology Consulting, on behalf of Vattenfall Wind Power. SSER and RWE NRL (2010). Galloper Wind Farm Project Scoping Study.


APPENDIX A – ORNITHOLOGICAL CONSULTATION MEETING MINUTES


APPENDIX B – ORNITHOLOGICAL TECHNICAL REPORT: HRA SCREENING


APPENDIX C – TECHNICAL NOTE: PHYSICAL PROCESSES WITH REGARD TO MARGATE AND LONG SANDS CSAC


Margate and Long Sands cSAC: Considerations for HRA screening with regard to Galloper Wind Farm. Introduction The JNCC and Natural England, through the Scoping Opinion, have highlighted the potential for impacts to occur upon the Margate and Long Sands cSAC, 16km to the west of the GWF site. Specifically, concerns have been raised about the potential in-combination impacts on the site as a result of changing hydrodynamic and sedimentary processes arising from the GWF and adjacent projects. The JNCC highlight the possibility that in combination with proposed developments in the vicinity of this site there could be disruption of, or changes to physical processes and sediment transport which may lead to significant effects on the coastal and marine habitats of the Margate and Long Sands cSAC. This desk-based review summarises the current evidence base on potential impacts on the existing hydrodynamic regime from the Galloper Wind Farm (GWF) project. The following documents were reviewed:

• GGOWF Environmental Statement (GGOWL, 2006); • Review of Round 1 sediment process monitoring data – lessons

learnt. A report for the Research Advisory Group (DECC 2008); and • APBmer. Ltd et al (2010) A further Review of Sediment Monitoring

Data. Commissioned by COWRIE Ltd (project reference ScourSed-09).

Evidence from GGOWF Results from modelling studies at GGOWF provide information about the scale of the expected effects of the turbine array and the potential for in combination impacts on the cSAC which have been highlighted by the JNCC. Hydrodynamic and sediment modeling for the GGOWF EIA was carried out using a worse case scenario of 140 turbines, with a 36m foundation base width. The effects of changes to the hydrodynamics and sediment dynamics from the modeling outputs are summarised as follows:

• Changes to tidal current velocities only occur within the development site and are typically concentrated within the wind farm array;

• In the water depths designated for development, the structures will not affect the wave transmission;

• There is no change to the existing wave conditions further afield than the immediate vicinity of the wind farm (thus there are no effects expected along any of the surrounding coastlines);

• During construction suspended sediment concentrations (SSC) associated with sediment spill from foundation installation are low and within background concentrations; and


• No operational effects on existing sediment transport pathways are predicted over the regional domain with operational effects expected to be limited to localised scour around the turbines and cables (in the absence of scour protection).

No effects were predicted on the hydrodynamic regime from the cabling works during either the construction or operation phase. The results of the modelling efforts for GGOWF provide strong evidence that the hydrodynamic and sediment dynamic effects of the wind turbine field are local to the wind farm and their will be no effects away from the wind farm. This evidence shows that because the GGOWF will have no effect on hydrodynamic processes across the Margate and Long Sands cSAC, it follows that the geomorphological functioning of the cSAC will be unaffected and hence there will be no impact on its integrity. Given the similar sizes of GGOWF and GWF, and the greater distance of GWF from the cSAC, the conclusion is drawn that GWF will also have no impacts on the sandbanks. Given that the hydrodynamic effects of the GWF in isolation will be local to the array, then there are no potential pathways for in-combination effects on the cSAC. Evidence from Round 1 developments Supporting generic evidence related specifically to suspended sediment concentrations is provided by monitoring campaigns implemented during Round 1 offshore wind farm developments including Barrow, Blyth, Kentish Flats and Scroby Sands (DECC, 2008). A review of existing data and reports, carried out by DECC (2008), concluded that construction activities which disturb the seabed, in particular cable laying and foundation installation (drilling), lead to short-term localised changes to suspended sediment concentrations. In addition, the effects of different cable laying methods appears to indicate that jetting is not a major concern, with sediment plumes tending to remain close to the seabed (up to 2m displacement above the seabed). The conclusions of DECC (2008) were supported by a more recent review of monitoring undertaken by ABPmer (2010). Relative changes in turbidity concentrations above background levels fall within natural variations due to waves and tides for the shallow water sites, concluding that there is unlikely to have been any significant impact due to offshore wind farm construction (DECC, 2008). This outcome is consistent with the predictions of the Environmental Statements for each project (Table B1).


Table B1 Round 1 Environmental Statement predictions and observed impacts

Site ES Prediction Observed Impacts

North Hoyle <10% increase to SSCs <5% detectable increase in SSCs as a

result of construction works

Kentish Flats SSC levels could increase to

double that of background levels

Final deposition site unknown

Installation of the first cable saw no

significant alterations to SSCs

Installation of the second and third

indicated a 9% increase on

background levels

Scroby Sands Impacts unlikely due to dynamic

nature of the site

SSC seen to increase 9 to 11% during

construction works (may have been

due to period of increased wave

heights)

Barrow No significant impact predicted as

naturally high levels of SSCs at

site

Increases found to be small and

relatively localised, whilst remaining

between 1 to 2m above the seabed

Nysted

Small increases predicted Small increases observed but both

temporary and localised

Horns Rev No significant impact due to

naturally high SSC levels

Impacts minimal

Source: DECC, 2008 Summary The evidence suggests that as a worse case scenario any construction effects originating from the GGOWF development are localised and short term. Operational effects will be restricted to the immediate wind farm vicinity with no potential for indirect effects on the geomorphological regime. It is concluded that there is no pathway for the GGOWF project to impact on the integrity of the designated sandbanks of the Margate and Long Sands cSAC or their associated features either alone or in-combination with other developments. References GGOWL, (2006). Greater Gabbard Offshore Wind Farm: Environmental Statement DECC, (2008). Review of Round 1 sediment process monitoring data – lessons learnt. A report for the Research Advisory Group


APBmer. Ltd, Cefas and HR Wallingford, (2010) A further Review of Sediment Monitoring Data. Commissioned by COWRIE Ltd (project reference ScourSed-09).APBmer. Ltd et al (2010)