Last chance to save the fish in the Severn as the Environment Agency, planning Inspectorate and Marine Management Organisation deliberates a landmark decision.
This crucial decision could see thousands of fish, including cod, sprat, salmon, and whiting, drawn to their deaths each day as they are sucked into double-decker sized water-cooling systems of the new Hinkley Point C nuclear power station.
The Secretary of State’s Development Consent Order (DCO), an Environment Agency Permit and a Marine Management Organisation License currently require an acoustic fish deterrent (AFD) to be installed at Hinkley Point C as a protection measure, but there has been an application for the removal of the AFD from the permit by EDF Energy.
The Environment Agency are currently considering this amendment to the Environmental Permit. EDF have also made a pre-application to make an unprecedented ‘Material’ change to the DCO. They will also request a change to their license with the Marine Management Organisation.
Environmentalists believe that the removal of this vital piece of environmental protection would threaten the biodiverse ecosystem of the estuary over the sixty-year lifetime of the power station. It is also dangerous due to the risk of fish clogging up the water-cooling system.
David Attenborough in Extinction the Facts shown on the BBC on 13 September showed us that maintaining biodiversity is essential to sustaining food production and that trawler-caught fish have declined to 5% from the turn of the 20th Century. Acoustic deterrent devices are already being used on all size of fishing vessels to deter dolphins and porpoises from their nets.
EDF arguments are as follows: they say that ‘The impact of HPC on fish will be negligible’ however, work by local environmental groups shows impacts have been badly underestimated and not assessed on a precautionary basis by EDF.
‘Removal of AFD won’t make much difference, there’s good fish protection without it’ According to EDF’s own proposal, an AFD is needed for the low velocity intake to protect fish. The Devon and Severn IFCA response states: ‘The scaling of fish mortality from HPB to HPC appears to include some major errors in its approach (e.g. mesh size of drum screens). There are also large uncertainties in the scaling, partly due to a very limited evidence base.’
‘The AFD is impractical’ UK AFD developers Fish Guidance Systems Ltd state “As with all innovative companies, we are constantly developing and improving – in the last 12 months alone we have developed power units, and pressure compensation systems that solve the issues raised by EDF. We would be ready to install a system as soon as the Environment Agency comes to its decision”
Important fish in the estuary that are at risk from the cooling water systems include protected Atlantic salmon, sea trout and twaite shad but they could be saved if the required Acoustic Fish Deterrent (AFD) system is installed to protect these migratory species as well as fragile and young fish that use the Severn Estuary as a nursery. Atlantic salmon numbers are in decline and a byelaw is in place currently that protects them from fishing.
Another concern is that a ‘material change’ to a Development Consent Order has never been granted by the government and doing so could set a precedent for future infrastructure projects in the UK and lead to the erosion of environmental protections.
EDF have also removed the AFD from their 3rd consultation for Sizewell C in Suffolk.
What the experts say:
Dr Andy Turnpenny, Fisheries Scientist, said: “The Severn Estuary is a Special Area of Conservation important for its role as afish nursery and migratory corridor. There is uncertainty over the exact impact Hinkley Point C will have on the fish assemblage that supports the complexity of bird species and commercial fish stocks. The Hinkley Point C cooling system will be 3 to 4 kilometres offshore and the number of fish it will draw in will take away the ability of the stocks to withstand normal environmental pressures and natural setbacks. With climate change, we will see significant changes to fish stocks over the 60-year life span of the station and the assessments made by Cefas, therefore, carry a high degree of uncertainty. The acoustic fish deterrent is a keystone in the design to minimise harm to fish”
Natasha Bradshaw, an independent researcher in coastal governance with extensive knowledge of the Severn Estuary, says: “I have lost sleep over the danger to the fish and the risk of devastating the ecosystem of the Severn Estuary. There is little proof that fish will survive the journey through 3km of tunnels or what impact returning them (dead or alive) into the estuary will have on the ecosystem. The decision made about the fish deterrent for the cooling water system for Hinkley Point C will last decades and set a precedent for other new nuclear and industrial projects across the UK.”
What you can do:
Share your concerns and campaign online using #SaveSevernsFish
Encourage all your friends, followers, family, networks on social media, email contacts to engage and petition as follows:
Tweet the Environment Agency@EnvAgency @CefasGovUK @The_MMO and tell them that you are concerned that not using the Acoustic Fish Deterrents seriously risks the ecosystem of the Severn Estuary
Sample tweets:
Thousands of fish will die in the double-decker sized cooling tunnels at Hinkley Point C. @EnvAgency @CefasGovUK @The_MMO please make the right decision and make sure an AFD is installed, as the DCO states. #SaveSevernsFish
It’s imperative that an Acoustic Fish Deterrent is installed at Hinkley Point C as the Development Consent Order states. @EnvAgency @CefasGovUK @The_MMO Millions of fish will die and the ecology of the area is at risk please #SaveSevernsFish now & don’t change the permit & DCO
Write to:
Planning Inspectorate, Sarah Richards, Chief Executive, Planning Inspectorate, Room 3 O/P, Temple Quay House, 2 The Square, Temple Quay, Bristol, BS1 6PN [email protected] @PINSgov
The Water Quality Team, Environment Agency, Horizon House, Deanery Road, Bristol, BS1 5AH. 03708 506 506. [email protected]
Tom McCormack, Chief Executive Officer, Marine Management Organisation (MMO), Lancaster House, Hampshire Court, Newcastle upon Tyne, NE4 7YH, [email protected]
EDF: Stuart Crooks, Hinkley Point C Managing Director, The best way to contact us is by completing our online enquiry form.
Write to your MP to inform them about this issue. Find my MP
Further Information:
There are a number of international and national environmental designated sites close to Hinkley Point. Those that are relevant to HPC are: Severn Estuary Special Area of Conservation (SAC), Severn Estuary Ramsar site.
Other sites that could be affected by changes to the fish protection measures through effects on mobile interest features (migratory fish and marine mammals or birds that prey on fish) include: River Wye/Afon Gwy SAC, River Usk/Afon Wysg SAC, Afon Tywi SAC, vern Estuary SPA, Grassholm SPA, Skomer, Skokholm and Seas off Pembrokeshire SPA, Aberdaron Coast and Bardsey Island SPA, Saltee Islands SPA, Lambay Island SPA, Copeland Islands SPA, Cliffs of Moher SPA, Beara Peninsula SPA, Kerry Head SPA, Deenish Island and Scariff Island SPA, Puffin Island SPA, Iveragh Peninsula SPA, Skelligs SPA, Dingle Peninsula SPA, West Donegal Coast SPA, High Island, Inishshark and Davillaun SPA, Tory Island SPA, Duvillaun Islands SPA, Clare Island SPA, Blasket Islands SPA, Horn Head to Fanad Head SPA, Bristol Channel Approaches / Dynesfeydd Môr Hafren SCI, Lundy SAC, West Wales Marine / Gorllewin Cymru Forol SCI, Cardigan Bay SAC, North Anglesey Marine / Gogledd Môn Forol SCI, Isles of Scilly Complex SAC, Pen Llyn a’r Sarnau / Lleyn Peninsula and the Sarnau SAC, North Channel SCI, Rockabill to Dalkey Island SAC, Roaring Bay and Islands SAC, Blasket Islands SAC, Carmarthen Bay and Estuaries/ Bae Caerfyrddin ac Aberoedd and Pembrokeshire Marine/Sir Benfro Forol SAC.
Links to articles and further reading:
The effect of not fitting an AFD by CEFAS Read here
Read the Devon & Severn IFCA consultation response here.
Requested changes to the Development Consent Order Read More
Millions of fish could be destroyed during the 60-year lifetime of Hinkley Point C power station. A joint release from Angling Trust, Blue Marine Foundation, Bristol Channel Federation of Sea Anglers, Severn Rivers Trust, Somerset Wildlife Trust and Wildfowl & Wetlands Trust (WWT) Read More.
Ecology of the Allis and Twaite Shad Read More
Environment Agency Byelaw to protect Severn salmon stocks extended news release
Fish of the Severn Estuary Marine Site Read More
Hinkley Point C is situated next to WWT Steart Marshes, a £20 Million wetland which acts as a fish nursery for the Severn Estuary. https://www.wwt.org.uk/wetland-centres/steart-marshes
Read the Devon and Severn Inshore Fisheries and Conservation Authority report: Zooming out: A wider perspective of the Severn Estuary fish assemblage and implications for renewable energy developments
Google link for this information as a word document: https://drive.google.com/file/d/118kUFgEwvR52gZKYDS9di6-8YOnTfFaO/view?usp=sharing
What is an Acoustic Fish Deterrent (AFD)?
Developed in the United Kingdom by scientists, a Sound Projector Array is a fish deterrent system that uses specially synthesized sound and bubble screens that deter fish from entering underwater cooling tunnels. The acoustic deterrent incorporates underwater speakers that produce a repellent sound, blocking the fish from entering the cooling tunnels as they suck in large quantities seawater.
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I think EDF are talking to the wrong people. Maybe they should apply to Natural England for a license to kill the fish on conservation grounds. I am sure they could point out that cod eat some other fish species and therefore need to be ‘controlled’. They’d be sorted in a flash! NE might even throw in the option to cull a few monk parakeets while they are at it.