Monday, 30 March 2026

Planning and energy costs again

 An extraordinary blog on the costs of the planning system via conservative assessments of ecological damage. My italics. 


1. "The first example shared with me related to the questionable designation of a vast 25,898 hectare area of sea (from St Austell to Gribbin Head in Cornwall) as a Special Protection Area (SPA), at  Natural England's insistence. The basis of the designation was the presence of three types of seabird – all of which are widely dispersed around the UK in low concentrations. ...It was suggested to Natural England that the boundary of the SPA should begin at least 500m out to sea, to ensure that housing developments coming forward near the coast weren't unnecessarily required to assess risk of harm to the SPA's seabirds. This request was refused on the grounds that one of the three species was found within this inshore zone: the Slavonian Grebe. Natural England's estimate was that 15 such birds (1.4% of the total population in Great Britain) might use the 25,898 hectare SPA area. Yet as a result of this designation, whenever a new housing development is proposed along this stretch of coast, a habitats assessment must be prepared and considered by the local planning authority in order to assess the risk that people inhabiting the houses go out boating, encounter one of these protected birds and disturb them. The birds in question are only present in winter. The chances of a winter boat tripper encountering one of these 15 birds was said by the Ecologist to be "infinitesimal." 


2. "Sabellaria spinulosa is a worm that builds and lives in tubes on the seabed. When thousands of these tubes are formed together, a reef is formed. 

In recent advice to offshore wind developers, including Outer Dowsing offshore wind farm, Natural England has advised that compensation for impacts to Sabellaria reef is required for placing rock on seabed even in areas that Sabellaria reef isn't present (see paragraphs 11 and 12 [here]).

The consequence of this is that multiple wind farms are delayed while ecological compensation for Sabellaria reef is secured...Projects suffering from this issue include the trio of Norfolk offshore wind projects: Norfolk Vanguard East, Norfolk Vanguard West and Norfolk Boreas. These projects consented in 2021/2022 by Vattenfall and since sold to RWE have been delayed by approximately two years due to inability to satisfy seabed compensation requirements."

3. breeding Guillemot Dr Trinder's evidence at a recent Dogger Bank South windfarm DCO hearing. You can listen to Dr Trinder [here] at minutes 9 to 20; then his comments on the precautionary approach at minutes 41 to 49; and his thoughts on Natural England's questionable advice around minute 56. I summarise the upshot below.

To understand the potential impact of the wind farm on guillemot during the breeding season, Natural England looked at the maximum distances that six guillemots flew from the breeding site to forage for food during the study period. The distances travelled by each bird were, respectively: 7km, 9km, 27km, 44km, 65km and 338km. The British Trust for Ornithology (BTO) who undertook the study acknowledge ..the 338km figure to be an outlier, and excluded it when calculating the maximum mean foraging distance for these birds. Their expert view was that it was not a realistic data point for the purpose of assessment.

Natural England ignored this recommendation and (including this outlier) calculated the maximum foraging distance to be 153km (putting the wind farm within range in terms of its impact on foraging birds)....The Dogger Bank South project will likely be required to provide compensation for 719 breeding pairs of Guillemot to replace those the SNCBs believe will die as a result of the construction and operation of the project. This will likely be delivered in the form of a combination of predator eradication programmes, artificial nesting structures (bird hotels) and bycatch reduction measures. The estimated total cost of compensation quoted by Dogger Bank South is £173m, although to this includes compensation for other features of the habitat too.

4. The proposed scale of the East Anglia One North (EA1N) offshore wind farm was slashed by 40%, in order to minimise its impacts on Red Throated Diver (RTD) in the Outer Thames Special Protected Area (SPA). This was despite the fact that the developer’s ecological modelling suggested that there would be little or no impact on adult survival (at worst an undetectable 0.1% of the population) due to bird displacement (birds scared by construction)."