HC 1624 Energy and Climate Change CommitteeMemorandum submitted by RSPB


1.1 The RSPB strongly supports continued expansion of the tidal stream and wave industries because of the significant role they could play in delivering low carbon energy and positioning the UK as a global leader in green growth. Significantly increased efforts are needed, however, to understand and mitigate the potential impacts this will have on marine biodiversity. Failure to do so will result in adverse environmental impacts, and public concern over these impacts, becoming a major barrier to further deployment. We recommend:

(i)Support for tidal stream and wave power is increased to the same level as currently received in Scotland (5/ROCs/MWh) in England, Wales and Northern Ireland. Ideally this should not be capped, but if a 2017 cap is introduced it should not be less than 300MW.

(ii)Tidal range may be capable of delivering significant amounts of energy. However, the evidence shows that existing commercial technologies are not capable of harnessing this without causing major environmental impacts. Support should therefore focus on the research, development and demonstration of low-impact tidal range technologies.

(iii)Urgent action is taken to designate an ecologically coherent network of marine protected areas, ensuring proper protection of marine wildlife from energy development and other offshore activities, and reducing uncertainty for the marine renewables industry.

(iv)DECC, Defra and the marine energy industry collaborate to develop a coherent and comprehensive survey programme for marine wildlife.

(v)Public R&D investment focuses on technological innovation to reduce the environmental impacts of tidal and wave power, and a collaborative industry-stakeholder-government partnership is established to monitor the impact of marine renewables on the environment and share data.

(vi)National-level infrastructure assessments are made in each UK country to assess port infrastructure requirements and to develop a strategic approach that will minimise overall requirement and the overall impact on the natural environment.

The RSPB and Marine Renewables

2.1 Climate change is already affecting birds and wildlife in the UK and globally, and it threatens to drive future biodiversity loss unless urgent action is taken to reduce emissions and keep the world within “safe” levels of climate change. One study published in Nature indicates that climate change could cause up to 35% of species to be committed to extinction by 2050. The RSPB therefore strongly supports the UK’s greenhouse gas reduction targets and recognises the critical role that renewable energy, including tidal stream and wave power, will play in delivering them as part of a wider package that prioritises energy savings.

2.2 The huge amount of new infrastructure needed to decarbonise our energy supply can, however, have a detrimental impact on wildlife in the UK if poorly located and/or designed, whether at sea or on land. The Government has committed to reversing biodiversity decline by 2020. We believe, therefore, that Government has a duty to ensure these targets are met with minimal environmental impact.

2.3 The RSPB engages with individual applications for renewable and other energy infrastructure across the UK, advising developers how they can minimise the impact of their developments. Where the environmental impacts of a proposed scheme are likely to be unacceptable, we will object, but our preference is to work with renewable energy developers to address and mitigate any impact. This has meant that since 1990 we have placed sustained objections on only 5.9% of wind farm applications that we have engaged with.

Tidal Stream and Wave Power

2.4 The RSPB works closely with the tidal power industry across the UK. The industry is at an important stage as preferred designs and approaches have yet to emerge, and there is therefore an opportunity to ensure that minimising impacts is a priority for the industry from the outset. For example, we worked with Marine Current Turbines on their tidal stream installation on Strangford Lough, advising on the monitoring regime required to evaluate its impact on wildlife, and we recently welcomed Scottish Power Renewables’ announcement that they will build a 10 turbine array in the Sound of Islay and will implement a comprehensive monitoring programme.

2.5 Our key concern is the potential impacts on the UK’s internationally important breeding seabird populations, notably Manx shearwater, northern gannet, great skua and lesser black-backed gull, for which the UK has particular responsibility given the high proportion of their breeding populations that we host. We have therefore conducted a review of potential impacts of wave and tidal stream energy on seabirds, which will be published in due course. Given the paucity of literature in this area, the review is based on an ecological approach, making inferences about likely impacts based on what we know about seabird ecology. A short summary of potential impacts based on this review is available on request.

Tidal Range

2.6 The RSPB has been closely engaged with the Severn Tidal Power Feasibility Study (STPFS), and was on the Steering Group for the SEA. Whilst we objected to the barrage proposals, which would have had an irreversible and detrimental impact on the geomorphology of the estuary with consequential effects on the unique and internationally important biodiversity in the estuary and on flood risk, we were open to innovative means of sustainably exploiting the energy resource in the Severn. We consistently called for greater resources and effort to be put behind developing these options, and asked that acceptable environmental impact be considered a priority for the feasibility study. Whilst we welcomed the Severn Embryonic Technologies stream of the study, it was under-resourced and formed only a small part of the overall study (£0.5 million). As a result, the £20 million STPFS ultimately delivered recommendations that were unworkable because of their excessive costs, due in part to their enormous environmental impacts.

2.7 We note that the Mersey barrage proposal by Peel Holdings followed a similar trajectory to that of the STPFS, with plans now shelved because of costs and opposition on the grounds of environmental impact. Whilst the RSPB supports the sustainable exploitation of tidal range power in principle, we conclude from these experiences that:

It is extremely difficult if not impossible for a conventional shore-to-shore high head barrage to be built without detrimental impacts on biodiversity and on the hydrology and geomorphology of an estuary, and therefore to comply with environmental legislation.

Innovative technologies may allow tidal range to be exploited sustainably, but further R&D is required to develop and commercialise them. We believe this should be the focus of the industry and any future Government intervention.

3. What are the potential benefits that marine renewables could bring to the UK and should Government be supporting the development of these particular technologies?

3.1 The UK’s tidal stream and wave resources offer a significant source of low carbon, renewable energy. If deployed with care and sited correctly, we believe this resource can be exploited without unacceptable impact on the marine environment, and therefore strongly support public intervention to research, develop and deploy these technologies sustainably. In the absence of proactive measures to mitigate impacts, however, marine renewables risk having significant detrimental impact on seabirds and marine mammals in particular, and that this would result in significant public concern and opposition to further deployment.

3.2 Provided measures to achieve sustainable solutions are in place, we believe that Government should increase support for tidal stream and tidal power in England, Wales and Northern Ireland to the level of support received in Scotland. (5ROC/MWh). The higher support available in Scotland, along with clear political commitment and initiatives such as the Saltire prize, has led to Scotland becoming a global leader in this new industry. Furthermore, the 2017 cap should be set at no less than 300MW to ensure growth is sustained and investor confidence.

3.3 The UK’s tidal range resource is considerably more difficult to exploit without causing major alterations to estuarine geomorphology, resulting in unacceptable damage to wildlife and flood risk, and at an acceptable financial cost. We believe that future support should be smarter, and targeted at low impact technologies, and consideration should be given to what combination of R&D investment and ROC support is needed to develop and commercialise lower-impact tidal range technologies. This should be coupled with a removal of ROC support for shore-to-shore high head barrage schemes, which would send a clear signal to potential developers that impacts of such magnitude are unacceptable, and that rewards will be reaped by those who innovate lower impact approaches.

4. What lessons can be learnt from experiences within the UK and from other countries to date in supporting the development and deployment of marine renewables?

4.1 There are a number of examples of good spatial planning at sea as a means of facilitating deployment of marine renewables and reducing conflict with the natural environment from which England could learn.

4.2 The Scottish Government has introduced spatial planning for wave and tidal power through the Strategic Environmental Assessment process, which was carried out for wave and tidal development off the north and west coasts in 2007, and also identified and supported the European Marine Energy Centre (EMEC) site in Orkney for testing new technologies. This process established a clear direction of travel for the industry and ensured environmental impacts were considered and mitigated from the outset. The Scottish Government has commenced a new strategic planning exercise for wave and tidal development in all Scottish waters out to 200nm in consultation with the industry and stakeholders, including the RSPB. We believe that a similar approach would be extremely useful in other countries, and note that the parallel SEA (OESEA2) in England and Wales was not spatial for these technologies and therefore failed to deliver such clarity.

4.3 In Northern Ireland, the Department of Enterprise, Trade and Investment (DETI) commissioned a strategic action plan for the development of offshore wind and marine renewable energy, with an accompanying Strategic Environmental Assessment. This spatially identified areas within Northern Irish waters that may be suitable for marine renewable energy, although there was a limit on the amount of environmental data available.

4.4 The Welsh Government commissioned a Marine Renewable Energy Strategic Framework (completed 2011), which was a spatial exercise aimed at mapping the available tidal stream and wave resource in Welsh territorial waters. This work incorporated marine conservation features, and recommended methodologies for impacts on mobile species, including seabirds

4.5 The Netherlands has developed a marine spatial plan to facilitate the deployment of renewables and other economic activities at sea. This has involved a strategic approach to the identification of Marine Protected Areas alongside other uses (including offshore wind and aggregates extraction) through the development of the Spatial Plan for the Dutch North Sea. In addition, a single Appropriate Assessment methodology has been agreed, which is now required to be used in all offshore windfarm cases, and to be delivered by a single contractor across all proposed sites to ensure quality of assessment and proper consideration of in-combination impacts. This approach – when compared to that in England – has the potential to better protect marine biodiversity and to reduce risk and uncertainty for developers.

5. Is publicly provided innovation funding necessary for the development of marine technologies and if so, why?

5.1 We believe that public funding for the development of marine technologies is essential given the early stage of development of this industry, and its potential to deliver low carbon, renewable energy. Public funding should, however, be aimed at reducing impacts on wildlife and the environment. Private funding for innovation tends to focus on economic considerations, such as efficiency, reliability, and costs, whereas the benefits of reducing impacts on wildlife are less tangible to the developer. This is in spite of the fact that costs of impact have a significant bearing on the economics of individual projects. As an example, the STPFS found that a Cardiff-Weston barrage would significantly heighten flood risk to local homes, businesses and industry, with mitigation costs of £672 million to £2,015 million.

6. What non-financial barriers are there to the development of marine renewables?

6.1 The environment and the need to protect marine wildlife have been considered by some parts of the renewable energy industry as a barrier to deployment. The RSPB believes that marine renewables can be delivered at scale and pace in harmony with the environment, provided that the right policy framework is in place. Critical to this is reducing uncertainty for developers in the marine environment by fully designating marine protected areas including the marine Natura 2000 network, and introducing a comprehensive and transparent marine biodiversity survey in UK waters. The absence of such measures has been seen to be a major source of uncertainty and risk in the deployment of, and investment in, offshore wind.

6.2 It has been suggested by some that the Habitats Directive may present a barrier to large-scale renewables deployment, particularly in relation to tidal range technologies. The RSPB strongly rejects this assertion. The EU Birds and Habitats Directives provide a clear and robust legal framework for achieving sustainable development – a conclusion shared by the Sustainable Development Commission (SDC) in their authoritative report, Turning the Tide. In the vast majority of cases, consideration of environmental impacts at the earliest stages in marine renewable technology design and site selection should ensure that effects on Natura 2000 sites can be avoided and/or mitigated. This is with the caveat, however, that the failure to identify and deliver a complete Natura 2000 network at sea has made this more difficult for both developers and regulators. Where avoidance and mitigation is not possible, the Habitats Directive does not preclude development. Instead, it requires that this development only be permitted where there are no less-damaging alternative means of delivering the public interest, where there are reasons of imperative overriding public interest why the development should proceed, and where adequate compensation has been secured.

6.3 For tidal range, we acknowledge that even the least damaging alternative may have adverse effects on the integrity of one of more Natura 2000 sites. However, we believe that it should be possible to limit any damage, such that it can be addressed through mitigation and/or (where appropriate) compensation.

Designation of a coherent marine protected area network

6.4 Defra’s recent report, Charting Progress 2, shows the UK’s seas are increasingly coming under pressure and suffering damage. Seabirds and other marine wildlife are in continued decline. The offshore renewable energy industry can either exacerbate the situation or be a catalyst for the solution: an ecologically coherent marine protected area network that includes sites for seabirds. As well as being an environmental imperative, designation is a legal requirement under national and European legislation. Furthermore, rapid designation accompanied by the surveying required to identify new protected areas is key to giving developers the information they need to avoid impacts and any associated costs and delays. This means developers face uncertainty over whether a site to which they have acquired development rights may be designated in the future, either because of known biodiversity interest or because of findings from pre-construction monitoring.

6.5 As well as a protected area network, better marine spatial planning could further facilitate and accelerate renewable energy deployment. This involves identification of suitable areas for marine developments and activities, allowing possible conflicts to be identified and addressed at the earliest possible stage, and effectively front-loading the process through which developers must go.

A systematic marine wildlife survey

6.6 Impacts on seabirds and the marine environment caused by renewables and other economic activities at sea can be minimised by financing a comprehensive and systematic survey of marine wildlife. The data collected will have the added value of supporting being useful for wind leasing assessments, and allowing shorter pre-construction monitoring following site allocation. It would also reduce risk, as the locations of important sites for internationally important species will be known, avoiding scenarios where they are found during baseline monitoring, which significantly delayed the London Array offshore windfarm.

6.7 We believe that DECC, Defra and the offshore energy industry to should collaborate in the delivery of such a programme, which would aim to deliver a Geographic Information System atlas of bird and marine mammal distribution and abundance, significantly reducing risk and uncertainty for the industry, and providing an extremely useful component of a constraints assessment for offshore energy. The programme needs to include:

(i)Comprehensive baseline seabird data collection in potential development zones, using a combination of aerial and ship-based surveys, as best suits local conditions, using recommended methods.

(ii)A systematic survey to plug gaps in spatial and temporal coverage of existing data and provide updated contextual information for UK Continental Shelf waters.

(iii)Further research into foraging ranges and areas used by priority species relevant to each development zone for marine renewables, making use of developing technology such as GPS data loggers and habitat suitability modelling.

7. What approach should Government take to supporting marine renewables in the future?

7.1 The RSPB believes that Government needs to take a strategic approach to marine renewables, spatially planning for future deployment in order to minimise the industry’s impact on wildlife by avoiding the most sensitive and vulnerable sites. This needs to be informed by a systematic survey of marine wildlife, funded by Defra, DECC, the Scottish Executive, and the marine energy industry (6.6, 6.7). In addition, R&D investment into marine renewables should be targeted at innovation that will yield lower environmental impact technologies.

7.2 Support for tidal and wave power should be increased in England, Wales and Northern Ireland, whilst support for tidal range should be aimed at bringing innovative, low-impact technologies forward (3.2, 3.3)

7.3 In addition to surveys and spatial planning, considerable research effort and data sharing will be required as the wave and tidal sectors develop. This requires collaboration between government, industry and NGOs. COWRIE, which was established by the Crown Estate to carry out research into the impacts of offshore wind, provides a good model for such a partnership that could be emulated for wave and tidal stream power.

8. Are there any other issues relating to the future of marine renewables in the UK that you think the Committee should be aware of?

8.1 Marine renewables need considerable infrastructure in and around port sites to manufacture, supply and service installations. This demand for port facilities is in addition to rapidly growing demand from the offshore wind industry. It is important to recognise, however, that this could put pressure on the UK’s coasts and estuaries, which are extremely valuable areas for birds and other wildlife. DECC has identified 27 port locations in the UK that may be suitable for development to service the offshore wind industry, and presumably these sites will also be candidates for servicing the wider marine renewables industry. We estimate that 21 of these are in or adjacent to Natura 2000 sites.

8.2 Strategic consideration of supply chain needs is critical to ensure construction, assembly and maintenance capability is in place, and environmental impacts are minimised. The Scottish Government’s national Renewables Infrastructure Plan has been useful in identifying the capabilities of existing sites in Scotland—although it would have been much improved if it had also more fully considered environmental constraints and identified which sites should be priorities for development to assist the sustainable development of the industry. The RSPB believes that UK countries should positively plan for onshore infrastructure for the marine renewables industry through developing spatial infrastructure plans, similar to that developed by the Scottish Government.

September 2011

Prepared 15th February 2012