DOGGER BANK TEESSIDE A & B August 2014 Statement of Common Ground Correspondance with Scottish Natural Heritage F-EXL-CG-054 OF SNH Page 1 © 2014 Forewind DOGGER BANK TEESSIDE A & B Document Title Dogger Bank Teesside A & B Statement of Common Ground Correspondance Scottish Natural Heritage Forewind Document Reference Date F-EXL-CG-054 OF SNH F-EXL-CG-054 OF SNH August 2014 Page 2 © 2014 Forewind DOGGER BANK TEESSIDE A & B 1. Introduction 1.1. Reason for this document 1.1.1. This document has been prepared to demonstrate that Forewind has engaged with Scottish Natural Heritage (SNH) regarding the Dogger Bank Teesside A & B application. 1.1.2. The following appendices are included in this document: Appendix 1 – Consultation between Forewind and SNH regarding the Dogger Bank Teesside A & B application F-EXL-CG-054 OF SNH Page 3 © 2014 Forewind DOGGER BANK TEESSIDE A & B Appendix 1 Appendix 1 – Consultation between Forewind and SNH regarding the Dogger Bank Teesside A & B application. From: Michael Stephenson Sent: 13 August 2014 16:37 To: John Uttley Cc: Martin Goff Subject: RE: Dogger Bank Creyke Beck John, I hope this finds you well. You may be aware that the Dogger Bank Creyke Beck examination is coming to a close on Monday, but in the meantime Dogger Bank Teesside A & B have now just entered the examination phase. Much like Creyke Beck we are being requested by the Examining Authority to seek assurances from yourselves regarding LSE on European designated sites in Scotland with respect to Teesside A&B – please see the attached Rule 8 letter and first examiner’s questions (2.4 – 2.6 are directed at SNH). I was wondering whether you may be able to provide a similar email to that below which was very useful during the Dogger Bank Creyke Beck examination. It would be much appreciated and save us a lot of time during the course of the coming months. The deadline for responses to questions is on 3rd September and as such if you are able to provide a response by that date that would be great. I can of course provide any further documentation you may need with regard to Dogger Bank Teesside A &B, or point you in the right direction of any documents available on the PINS website here. Many thanks Michael From: John Uttley [mailto:[email protected]] Sent: 15 April 2014 09:53 To: Michael Stephenson Subject: RE: Dogger Bank Creyke Beck Dear Michael I have reviewed previous correspondence with your project and also between SNH and JNCC. I have also quickly reviewed the consolidated ornithological addendum. SNH agreed the following with JNCC on 6 November 2013. F-EXL-CG-054 OF SNH Page 4 © 2014 Forewind DOGGER BANK TEESSIDE A & B 1. Apportioning breeding season impacts to individual non-English SPAs. With the exception of Northern gannet at Bass Rock there is no published tracking data (and Forewind have provided no empirical site-based evidence) of seabird connectivity with Scottish SPA’s with the Dogger Bank Creyke Beck projects. While the recently published paper from Wakefield et al (2013), shows a single record of one bird entering the north-west corner of Dogger Bank, the overall results of the study indicate that gannets spatially partition themselves during the breeding season. Tracking data continues to expand our knowledge of the foraging behaviour of seabirds but until such time as a review of the published mean-max foraging ranges Thaxter et al (2012) has been undertaken, in the case of Scottish SPA’s SNH and JNCC will continue to provide our advice based on the existing data. We look forward to the publication of the FAME data to enable this review process to start. SNH and JNCC therefore conclude no Likely Significant Effect with regards to northern gannet, common guillemot and razorbill associated with any Scottish SPA. We are content that JNCC's advice has covered potential breeding season effects on seabirds from Scottish SPAs adequately. I note Natural England's written representation of 17 March 2014 and in particular: 2. 3.3.27. It is acknowledged that there are on-going differences in methodological approaches to apportioning between different SNCBs. Scottish Natural Heritage (SNH) continue to advise that in Scottish waters there is no requirement for impacts to be assessed under HRA to SPAs out with the breeding season. Instead, the assessment of impact at larger populations scales (e.g. national, biogeographic), and for the appropriate season, should be presented as part of the EIA process. Consequently the Applicant should obtain advice from SNH to adequately capture their assessment. We are content for you to follow Natural England’s recommendations in relation to impact assessment in the non-breeding season, and we confirm that SNH will place no additional or separate requirements upon you in this regard. SNH is represented on the steering group for the Natural England project to establish the scale at which non-breeding populations of seabirds should be defined, and thus derive relevant reference population figures for the assessment of wind farm impacts during the non-breeding season. This work is on-going and therefore the appropriate scale for any cumulative impact assessment in the non-breeding season has yet to be established. Additionally, we would note that there are no robust estimates of the seabird collision mortalities that may arise from consented / constructed Rounds 1 & 2 wind farms, with this matter currently under review by DECC. Regards John John Uttley| Principal Adviser| Planning & Renewables Unit| Scottish Natural Heritage| www.snh.gov.uk| 01595 693345| 07876447403 From: Michael Stephenson [mailto:[email protected]] Sent: 14 April 2014 09:39 To: John Uttley Subject: RE: Dogger Bank Creyke Beck F-EXL-CG-054 OF SNH Page 5 © 2014 Forewind DOGGER BANK TEESSIDE A & B John, 3.3.27 (p120) of the attached. Many thanks Michael From: John Uttley [mailto:[email protected]] Sent: 14 April 2014 09:37 To: Michael Stephenson Subject: RE: Dogger Bank Creyke Beck Michael You refer to ' a written representation from Natural England that proposed further interaction with SNH'. Can I see this? Thanks John John Uttley| Principal Adviser| Planning & Renewables Unit| Scottish Natural Heritage| www.snh.gov.uk| 01595 693345| 07876447403 From: Michael Stephenson [mailto:[email protected]] Sent: 10 April 2014 14:21 To: John Uttley Cc: Sophie Barrell; Gareth Lewis Subject: RE: Dogger Bank Creyke Beck Dear John, Have you been able to make any further progress in relation to my request below? Many thanks Michael From: Michael Stephenson Sent: 25 March 2014 16:18 To: '[email protected]' Cc: Sophie Barrell ([email protected]); Gareth Lewis ([email protected]) Subject: Dogger Bank Creyke Beck Dear John, I am emailing to follow up on Gareth’s call earlier regarding SNH advice on Dogger Bank Creyke Beck offshore wind farm. After receiving a request from the Planning Inspectorate to agree a Statement of Common Ground with SNH, we sought to confirm that advice regarding matters of nature conservation is delegated to JNCC/NE as appropriate. After some discussion with Erica, we didn’t manage to work up a final document as Erica was seeking further advice from Marine Scotland. We therefore submitted a log of correspondence to the Planning Inspectorate which can be found here: F-EXL-CG-054 OF SNH Page 6 © 2014 Forewind DOGGER BANK TEESSIDE A & B http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/EN010021/2.%20PostSubmission/Representations/LIR%20and%20SoCG/Forewind%20%20SoCG%20correspondence%20with%20SNH.pdf We have also recently received a written representation from Natural England that proposed further interaction with SNH, which follows on from our recent submission in February of a consolidated ornithological addendum that added in certain Scottish projects into our cumulative and in-combination ornithology assessment. This document can be found here (Part 1 is the key document): http://infrastructure.planningportal.gov.uk/projects/yorkshire-and-the-humber/dogger-bank-creykebeck/?ipcsection=docs&stage=3 We are therefore seeking any further clarity on this. If you have any further questions or require any more information please do get in touch. Many thanks Michael ____________________________________________________________________________ Michael Stephenson Offshore Project Developer Forewind Ltd | Davidson House | Forbury Square | Reading | RG1 3EU | United Kingdom t: +44 (0)118 955 6468 | m: +44 (0)7715 069 068 e: [email protected] | w: forewind.co.uk ____________________________________________________________________________ F-EXL-CG-054 OF SNH Page 7 © 2014 Forewind
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