4 Environmental impacts and mitigation
43. While it is clear that a tidal barrage will have
a significant effect on the environment, the scale of specific
impacts is difficult to determine. This section will examine some
of the key environmental aspects of the Hafren Power proposal,
including: flood risk issues; loss of intertidal habitat; international
comparator sites; impact on fish and birds; compliance with EU
environmental legislation, and mitigation measures.
Flood impacts
44. Assessments regarding the impact of a barrage
on flood risk vary. Two types of flooding are relevant: fluvial
flooding risk (flooding from rivers) and tidal or coastal flood
risk. Hafren Power asserted that the barrage would offer protection
against coastal flooding and storm surges, offering protection
to 90,000 properties over an area of 500km2.[83]
Engineering the Future agreed that flood risk due to storm surges
would be reduced due to control of basin water level, while modelling
by Professor Falconer (Expert Panel, Hafren Power Ltd and Professor
of Water Management, University of Cardiff) suggested that the
area around Bridgwater would experience "a small reduction
of the water level" and that overall, "the mean water
level [...] will stay the same."[84]
The Natural Environment Research Council (NERC) noted that "In
general, it is anticipated that they [barrages] will mitigate
sea flood risk (particularly storm surges) by providing a physical
barrier that prevents seawater ingress"[85],
although Ed Mitchell (Environment Agency) pointed out that such
tidal surges are "very rare".[86]
45. There is evidence to suggest that a barrage would
offer some protection against flooding caused by sea level rise;
in addition, research undertaken by Professor Falconer (currently
unpublished) suggested that the "far-field effects"[87]
of a barrage would be negligible.[88]
However, fluvial flood risk is an area of concern for a number
of stakeholders.[89]
NERC outlined some of the potential complications of a barrage:
For example, flood risk may be increased as a
result of saltmarsh erosion, the restriction of river outfalls
by the longer high water stand, and the possible siltation of
outfalls as a result of hydrodynamic changes. Flood risk, freshwater
supplies and local land use patterns may also be affected by changes
to the water table and groundwater flow.[90]
According to Professor Falconer, under the Hafren
Power barrage scheme low tide would be raised by 3m.[91]
Dr Richard Creswell (Environment Agency) explained that this was
a "major concern" since it might restrict river outfalls
and water drainage and hence lead to increased flooding from rivers:
"It is the 3 metres at the lower end with
which we have the greatest concern because of the freeboard for
getting water out of rivers. Certainly, around the Severn Estuary
one of the biggest problems is land drainage."[92]
46. Overall, there is a lack of consensus regarding
how flooding might be affected by the Hafren Power scheme or indeed
any barrage. NERC highlighted the "apparent contradictions"
when discussing barrage impacts due to a "lack of empirical
evidence".[93] Regen
SW and South West Marine Energy Park claimed that the impacts
of an ebb-flood barrage on flooding are as yet unknown, stating
that "Much more modelling and research is required to fully
understand the hydrodynamic impacts of this technology."[94]
The impact on flood risk is likely to be mixed, as reflected in
Ed Mitchell's assessment (Environment Agency) that a barrage "has
potentially both positive and negative implications for flood
defence" and is therefore "probably cost neutral"
(i.e. it would neither increase nor reduce costs from flood defence
and damage).[95]
Loss of intertidal habitat
47. According to Professor Falconer, the Hafren Power
barrage scheme would reduce tidal range in the Severn from its
current range of 0m to 14m to one of 3m to 12m.[96]
Low tide would therefore be raised by 3m, as noted previously,
and high tide would be reduced by 2m. The overall reduction in
tidal range would lead to a reduction in intertidal habitats of
salt marsh and mudflats, with a resultant impact on bird populations
dependent on these areas for feeding grounds. Kate Jennings (RSPB)
suggested a barrage would have "significant adverse effects
on the populations of 30 species" with potential "serious
effects on a total of 96 European protected sites for birds".[97]
The Countryside Council for Wales illustrated how changes to the
estuary's morphology could further affect habitats by altering
conditions in the estuary:
"Decreased flows and flow speeds incurred
by a barrage would reduce the suspended sediment concentration
within the impounded area and downstream leading to further changes
in the estuary extent and composition of intertidal and subtidal
habitat features of the Severn Estuary"[98]
48. DECC's Severn Tidal Power Feasibility Study
estimated that a Cardiff-Weston barrage would cause loss of 40-50%
of intertidal habitat (baseline figure).[99]
Hafren Power stated that its new ebb-flood design would lead to
60% less habitat loss, which equates to 49km2 or 4900
hectares of lost habitat;[100]
our understanding is that this is equivalent to approximately
16% loss of overall intertidal habitat.[101]
Kate Jennings (RSPB) suggested that there were additional, ongoing
complications after the initial impact:
You would expect the estuary to evolve, to try
to change its shape in response to barrage construction over time,
which would result in on-going erosion and loss of intertidal
habitat. That is significant because of what it means in terms
of the intertidal habitat, the loss of that habitat and the features
it supports, like the internationally important populations of
birds.[102]
49. Many witnesses agreed that there was a lack of
up-to-date baseline data for the estuary from which to gauge potential
impacts.[103] HR Wallingford
noted that while expertise has advanced, there is an "absence
of robust and long-term basic data for the estuary" and recommended
"A comprehensive bathymetric survey of the entire estuary"[104].
The recent POST note on environmental impacts of barrages pointed
out that "studies of habitat response are limited to conceptual
models only", with available models diverging in their assessment
of long-term impacts to habitat.[105]
Dr Simon Pryor (Natural Environment Director, National Trust)
highlighted the risk of unintended consequences:
First principles, if you look at the Severn
estuary, it is a huge, very complex, very dynamic ecosystem and
the hydrology, the geomorphology, the ecology are all very much
interdependent, and if we intervene in a very major and quite
heavy-handed way, we can expect unintended consequences.[106]
50. We conclude that the environmental impacts
of the Hafren Power barrage, as currently presented to us, are
very considerable and that there is a high risk of unintended
and possibly damaging consequences. We also conclude that Hafren
Power has not presented sufficient credible evidence relating
to estuary morphology, impacts to habitats and upstream fluvial
flood risk. Further data, research and modelling will be required
before impacts in these areas can be assessed with any degree
of certainty.
International comparator sites
51. Suggested comparators for environmental impacts
include the following sites:
- EDF's tidal barrage facility
at La Rance;
- the Annapolis Royal Tidal Barrage in Canada,
an ebb-only scheme intended as a pilot for a proposed larger facility
in the Bay of Fundy, and
- the Eastern Scheldt Storm Surge Barrier in the
Netherlands.
52. While Hafren Power cited the La Rance scheme
as evidence of the potential for improved biodiversity with a
barrage in place,[107]
assessment of environmental impacts is hampered by a lack of any
baseline data prior to the construction of the barrage. In addition,
we have received evidence arguing that La Rance is not an appropriate
comparator for the Severn since it is "a rocky river valley"
unlike the sediment-rich Severn estuary.[108]
Problems experienced at the Annapolis Royal site in the Bay of
Fundy include "fish mortality, erosion problems downstream
and the health of the river upstream". Professor Graham Daborn
and Natasha Barker Bradshaw reported that tidal causeways across
tributaries in the area have led to "rapid, unpredictable
consequences and no foreseeable return to a state of dynamic equilibrium."[109]
However, Hafren Power has drawn attention to studies which illustrate
the complexity of the flows in the area which limit its comparability
with the Severn. [110]
Erosion issues have also been experienced at the Eastern Scheldt
site, as Kate Jennings (RSPB) explained:
Experience in the Eastern Scheldt, where they
built a storm surge barrier in the 1980s—this is the site
that the Severn Tidal Power Feasibility Study identified as the
best comparator for a Severn Barrage—is they have found
that 30-odd years after construction that estuary shows absolutely
no sign of reaching a new equilibrium, so it is still attempting
to change its shape and its morphology in response to the construction
of the barrier. It is still losing intertidal habitat. They think
it will go on losing habitat for at least a century, so the idea
that the Severn will reach any rapid equilibrium of any kind—clearer
water, muddier water or whatever—does not seem realistic
based on the evidence.[111]
53. However, once again comparisons with the Severn
are constrained due to differences in the type and source of the
sediment at each site. As NERC pointed out, "only limited
information is available from existing power plants [barrages],
and there appear to be no examples of coherent, comprehensive
monitoring."[112]
We therefore conclude that the usefulness of international
comparator sites is limited as a result of differences in estuary
characteristics and scheme designs.
Impact on fish
54. The Severn estuary is an important habitat for
many species of fish. Martin Salter (Angling Trust) described
the species composition of the estuary:
In terms of fish, there are 83 species of fish
recorded in the Severn estuary. It is an incredibly dynamic habitat,
both for migratory fish and freshwater fish upstream of the intertidal
zone and obviously as a nursery area for bass and many other important
sea fish. There are five Annex II species. These are the highly
protected species under the Habitats Directive. They are the twait
shads, the lamprey and the salmon. There are 11 BAP protected
species. That is the UK Biodiversity Action Plan. That includes
high-value species like sea trout as well as a whole range of
sea species.[113]
55. The presence of turbines across the estuary poses
a number of concerns, in particular to migratory fish. Consequences
include: death or injury when passing through turbines as a result
of blade strikes; disorientation caused by pressure changes and
noise, and delayed or terminated migration due to physical barriers.[114]
For the Cardiff-Weston barrage studied under the Severn Tidal
Power Feasibility Study, local extinctions and population collapses
were predicted for designated fish including Atlantic salmon and
twaite shad, with the possible loss of the latter as a breeding
species in the UK.[115]
"FISH-FRIENDLY" TURBINES?
56. Hafren Power's stated aim is to "accomplish
zero mortality for fish passage through its turbines" through
the use of a new, bi-directional Very-Low-Head (VLH) turbine design.
The Hafren turbine would operate at a tip speed of 9m/s, which
is below the "limit of negligible fish mortality" suggested
by Oak Ridge National Laboratory research, as published by Idaho
National Laboratory.[116]
However, most trials of turbine related fish mortality have
been carried out using small-sized salmon, a notoriously robust
species.[117] These
trials do not encompass the diversity of fish, invertebrates and
crustaceans found in estuaries. In addition, estimates of fish
mortality are based on fish making a single pass through a turbine:
fish living in an estuary may make multiple passes in a day, increasing
their risk of mortality.[118]
Hafren Power also drew attention to the "fully operational
VLH turbine" developed to prototype by French company MJ2
Technologies on which "full-scale field tests using live
European eels" have been carried out which indicate a 100%
survival rate.[119]
While such initial results are encouraging, further research will
need to be carried out with different fish species and sizes,
in addition to upstream studies, before firm conclusions can be
drawn. As yet, no prototype of the Hafren turbine has been built
and tested. "Indirect impacts", such as sub-lethal injuries
and predation, may constitute a significant source of overall
mortality but there has been little research in this area.[120]
57. Regarding Hafren Power's proposed VLH turbine,
Ed Mitchell (Environment Agency) stated that "it is difficult
to envisage how that could be fish friendly"[121].
We note that the Environment Agency claims that it is "not
aware of any turbine designs which would allow the safe, repeated
passage of fish through a barrage at the scale proposed."[122]
While claims that a barrage would lead to very extensive fish
mortality may be exaggerated, existing figures of low level fish
mortality tend to derive from a single species and do not encompass
the diversity of species found in estuaries. Studies have largely
focused on only direct mortality. However initial studies on indirect
mortality suggest it may constitute a significant source of overall
mortality. Field testing a prototype in an estuary on a
range of fish species and sizes will need to be carried out before
the claimed "fish-friendliness" of Hafren Power's proposed
turbine can be determined.
Compliance with EU legislation
58. Hafren Power acknowledges in its evidence that
the barrage project would need to comply with the following legislation:[123]
- Water Framework Directive[124]
- The Floods Directive[125]
- The Habitats Directive[126]
- The Birds Directive[127]
- The Environmental Impact Assessment Directive[128]
59. The Habitats and Birds Directives are likely
to be the most challenging legislative requirements for the Hafren
Power project to meet, due to the significant impact a barrage
would have on a number of Annex I and II species of wild flora
and fauna, protected by law under the Directives. The Severn estuary
is designated as a UK Site of Special Scientific Interest (SSSI)
and a Special Area of Conservation (SAC) under the EU Habitats
Directive, recognising its extensive intertidal mud flats and
importance for migrating birds.[129]
Its international importance for wildlife is also recognised through
its designation as a Special Protection Area (SPA) under the Birds
Directive and a Ramsar site.[130]
Under the Habitats Directive, the Severn region forms part of
"Natura 2000", an EU-wide network of SACs and SPAs established
to assure the long-term survival of Europe's most valuable and
threatened species and habitats.[131]
60. Representatives of the RSPB and the Angling Trust
stated they would support the Hafren Power barrage project if
it were able to comply with European Directives.[132]
The Sustainable Development Commission's 2007 report "Turning
the Tide: Tidal Power in the UK" recommended that "any
proposal for a Severn barrage must fully comply with the Directives
and adhere rigorously to the process they set out."[133]
EU process under the Habitats
Directive
61. As a project affecting a Natura 2000 site, the
barrage would trigger an "appropriate assessment" under
EU law to determine whether there were adverse environmental impacts.
Alan Seatter (European Commission) indicated that "a base
line of data in relation to the objectives for conserving that
site" would be used in order to "inform public authorities
as to what kind of impacts might happen and what you would need
to do to address those".[134]
If the barrage were found to have an adverse effect on the integrity
of the site, the project could only go ahead via the derogation
process under Article 6(4) of the Habitats Directive. That process
requires that the following three sequential tests are met:
- There must be no feasible alternative
solutions to the plan or project which are less damaging to the
affected European site(s);
- There must be "imperative reasons of overriding
public interest" (IROPI) for the plan or project to proceed,
and
- All necessary compensatory measures must be secured
to ensure that the overall coherence of the network of European
sites is protected.[135]
FEASIBLE ALTERNATIVE SOLUTIONS?
62. Chapter 7 examines alternatives to a fixed barrage
in more detail. In terms of the legislative requirements of the
Directive, alternatives must be "financially, legally and
technically feasible" to be acceptable, and must "deliver
the overall objective of the original proposal."[136]
It is clear that alternatives to the barrage do not deliver energy
on the same scale as the barrage (16.5 TWh/year), although the
Minister has suggested that alternatives do exist:
If there were no alternative to the barrage that
would enable us to meet our 2050 target, then I think the question
that you pose would be at its most acute, i.e. unless we went
down the road of the barrage Britain would miss its 2050 target,
but I am not aware that anyone is seriously saying that is the
case.[137]
63. Guidance from the Department for Environment,
Food and Rural Affairs (Defra) states that the relevant competent
authority would need to "use its judgment to decide what
is reasonable in each case" when considering alternatives.[138]
In oral evidence, Mr Seatter drew attention to how discussions
about alternatives could lead to a change in the project's design
in order to mitigate impacts: "It is difficult to find an
example where there isn't a discussion involving project design
that then changes during the course of a process."[139]
IMPERATIVE REASONS OF OVERRIDING
PUBLIC INTEREST (IROPI)
64. Alan Seatter (European Commission) indicated
that a barrage scheme could pass the IROPI test as a renewable
infrastructure project. Mr Seatter stated that the "elected
people" - as opposed to the European Commission - would be
responsible for balancing climate change and environmental considerations:
"You cannot say in one case it is more important than another,
but clearly the fight against climate change in a major project
is a question of great public interest."[140]
The Minister indicated that such considerations would be weighed
in the context of "our 2050 commitments", noting that
the barrage "is not deemed as yet to be an essential element
of a successful 2050 package".[141]
Clarity
in application of the EU Habitats Directive
65. Alan Seatter confirmed in evidence that a project
on this scale was "completely unprecedented" in the
Commission's experience of projects subject to the Habitats Directive.[142]
This underlines the uncertainty identified by DECC during the
Severn Tidal Power Feasibility Study as to how the regulatory
framework of EU Directives might apply to a large-scale barrage.[143]
Mr Seatter also characterised the Habitats Directive as "a
directive that is implemented by member states in the way that
they feel best meets their own requirements and the requirements
of the directive", which clearly indicates that the onus
is on the UK Government to judge compliance with European legislation,
and indeed suggests some leeway in the way it is applied.[144]
Several further points of uncertainty regarding the Habitats Directive
were also explored in questioning:
- the distinction between "like-for-like"
and "equal value" compensatory habitat;[145]
- the possibility of providing compensatory habitat
outside the member state, currently unprecedented,[146]
(see also next section) and
- if the Commission is called upon to review a
decision, what considerations inform the Commission's view on
whether the benefits of a particular project outweigh environmental
harm caused.[147]
66. Research from Bournemouth University drew
attention to the "legal paradox" underpinning the Severn
barrage and other large-scale renewable energy infrastructure
projects where there is "a damaging impact to the environment
caused by development designed to mitigate the damaging impact
to the environment".[148]
This research suggested that the principle of IROPI ('Imperative
Reasons of Overriding Public Interest') could be applied to all
climate change mitigation development, potentially opening the
door to all manner of environmentally damaging projects and overriding
the statutory protections of Habitats Directive. In response to
our enquiries on this issue, Alan Seatter (European Commission)
confirmed that IROPI could potentially be applied to all developments
which involve climate change mitigation, but assured us that "such
projects could not be given the green light regardless of their
impacts." The question of public interest would need to be
considered:
What is expected here is that the importance
of the public interest is weighed against the severity of the
impact on the site. Is the public interest truly overriding? If
so, the Member State must then show that it has taken all compensatory
measures necessary to ensure that the overall coherence of Natura
2000 is protected and inform the Commission of these measures.[149]
67. Before giving further consideration to the
project, the Government should establish greater clarity in the
terms and application of the Habitats Directive to major renewable
infrastructure projects, in particular regarding the derogation
process and principle of 'Imperative Reasons of Overriding Public
Interest' (IROPI).
COMPENSATORY MEASURES AND MITIGATION
68. Hafren Power proposed a number of mitigation
measures to offset adverse environmental impacts, based on "the
operation of the barrage and the optimisation of the turbine design."
The company suggested that the use of a "fish-friendly"
VLH turbine together with an ebb-flood mode of generation which
"more closely emulate[s] the natural tidal flows" would
reduce environmental impacts. The Consortium also stated that
"screening technologies" based on fish behaviour, use
of fish ladders and fish passes could help prevent or reduce the
passage of fish through turbines.[150]
However, the overall efficacy of such measures has not been determined,
with potentially "contradictory effects on different species"
and "limited research on marine species."[151]
As noted previously, the environmental impacts of a new bi-directional
VLH turbine have yet to be fully modelled.
69. The EU Habitats Directive requires provision
of compensatory habitat to replace that which is lost. European
Commission guidance states that any compensation must "fully
offset any loss or damage to the site" and must be "feasible
and operational" within a specified timescale. The guidance
also states that ratios for compensatory habitat "should
be generally well above 1:1" unless habitat is known to be
100% effective. [152]
Alan Seatter (European Commission) confirmed that compensation
"should be in place before the project is completed"
and that Member States are responsible for deciding on the adequacy
of compensation provided.[153]
Hafren Power suggested that marine construction techniques such
as topographic raising could be used to "increase foraging
space for wading birds" and provide additional mudflat and
saltmarsh habitat.[154]
Engineering the Future explained:
To mitigate the loss of inter-tidal habitat,
material dredged from beneath the caissons and from the shipping
channels could be used to raise the bed of the estuary in selected
places replacing some of the bird feeding habitat that would become
submerged.[155]
70. However, extensive areas of compensatory habitat
would need to be created. Hafren Power estimated that 49 km2
(4900 hectares) of habitat would be lost as a result of the barrage,
which at a 2:1 ratio would require the implementation of 9800
hectares of compensatory habitat. Even with the "up to £1
bn [billion]" [156]
that Hafren Power is prepared to invest in the creation of alternative
habitats, provision of compensation on this scale remains a great
challenge and could prove a lengthy process. As part of the Severn
estuary flood risk management strategy, Environment Agency proposals
to create 400 hectares of compensatory intertidal habitat were
reported to have taken "eight years in the negotiations."[157]
71. Creating fish habitat, as opposed to intertidal
habitat, could present particular difficulties. Mike Evans (Environment
Agency) outlined some of the challenges:
Of course the other difficulty then is that with
salmon they are loyal to their natal rivers. They do return to
the same river to spawn, so there is a particular challenge there.
We have poor understanding of shad, which only spawn in four rivers
in the United Kingdom at present, three of which would potentially
be upstream of the Severn barrage. We don't quite know what makes
a shad prefer those three rivers to similar adjacent rivers, which
they do run into but don't successfully spawn in.[158]
This will be particularly challenging if a barrage
necessitates "creation or restoration of 25% of the salmon
habitat in England and Wales" as was suggested by Kate Jennings
(RSPB).[159]
72. Anthony Pryor (Hafren Power) suggested that
a barrage project could follow a similar process to HS2 [the High
Speed Two rail network]:
If I may just mention the parallel example of
HS2. The Minister for Transport stood up at least 12 months ago
and said, "We will have a hybrid Bill approach to this project".
They put a project team in place. I do not think they had even
settled the line of the railway track when she said that. So there
was not much data out at that time. It is exactly the same process
for major projects of this nature.[160]
However, a barrage project is unprecedented in the
UK and, as we have highlighted, the environmental impacts are
uncertain. In the case of HS2 Phase 1,[161]
an Appraisal of Sustainability (AoS), including a Habitats Regulation
Assessment, was prepared as a "starting point" for the
full Environmental Impact Assessment (EIA); the resultant Environmental
Statement will be presented alongside the Hybrid Bill when it
is introduced to Parliament.[162]
The objective of the AoS was to "determine the extent to
which HS2 reflects and promotes sustainable development through
the integration of environmental, social and economic considerations."
[163] The AoS
consultation process concluded prior to the announcement of Government
support for the project.[164]
Tidal Lagoon Power Ltd have submitted an Environmental Impact
Assessment scoping report to the Planning Inspectorate in relation
to their proposed tidal lagoon in Swansea Bay; this is to help
identify the scope of a formal EIA.[165]
An EIA scoping report for the barrage would help to provide greater
certainty regarding potential environmental impacts and compensatory
habitat requirement.
73. Serious questions remain about the effectiveness
and feasibility of providing compensatory habitat on the scale
required for the proposed Hafren Power barrage scheme. While optimisation
of barrage design and operation offer possibilities for mitigation,
the requirements of the EU Habitats Directive are a significant
challenge. We note that smaller scale projects may face fewer
obstacles in achieving compliance with European legislation.
74. We appreciate the financial outlay implied
in, for example, developing a full Environmental Impact Assessment
of the proposed project. But it is clear that such a large-scale,
high risk and high cost project cannot go ahead in a designated
area without supporting evidence and assessments in place. Without
such evidence the project will not achieve political and public
acceptability.
83 Ev 153 Back
84
Ev 107; Qq 148, 156 Back
85
Ev w103 Back
86
Q 281 Back
87
In this context, "far-field effects" refer to effects
on water levels beyond the Bristol channel. Back
88
Ev w5, Ev w61, Ev w66, Ev 107, Ev w103, Ev w134, Ev w158; Zhou,
J., Pan, S. And Falconer, R.A., 2013, Effects of Open Boundary
Location on the Far-Field Hydrodynamic Impact of a Severn barrage
(in draft), Cardiff University Back
89
Ev w26, Ev w43, Ev 143, Ev 115, Ev w103 Back
90
Ev w103 Back
91
Q 147 Back
92
Q 284 Back
93
Ev w103 Back
94
Ev 91 Back
95
Q 280 Back
96
Q 147 Back
97
Q 57 Back
98
Ev w70 Back
99
DECC, Error! Bookmark not defined., October 2010 Back
100
Ev 153; Ev 153a describes how the "60% less" figure
was arrived at; Back
101
[49km2)/total intertidal habitat (310km2)]*100 = 16% habitat loss
rounded to nearest percent. Figure for total intertidal habitat
rounded to nearest km2 and taken from DECC, Severn
Tidal Power Sea Environmental Report, May 2010 Back
102
Q 52 Back
103
Ev w32, Ev w61, Ev w64, Ev w70, Ev w103, Ev 143, Ev 189 Back
104
Ev w32 Back
105
Environmental Impact of Tidal Barrages, Draft provisional
POSTnote 435, Parliamentary Office of Science and Technology,
June 2013 Back
106
Q52 Back
107
Ev 153 Back
108
Ev w41, Ev w48, Ev w70, Ev 91, Ev w78, Ev 107, SEV 54, Ev 115,
Ev 122, Ev w114, Ev w134; Q 60 Back
109
Ev w114 Back
110
See Ev 175, reference to Aretxabaleta et al., Model Simulations
of the Bay of Funday Gyre Back
111
Q 60 Back
112
Ev w103 Back
113
Q 57 Back
114
Environmental Impact of Tidal Barrages, Draft provisional
POSTnote 435, Parliamentary Office of Science and Technology,
June 2013 Back
115
DECC, Error! Bookmark not defined., October 2010 Back
116
Ev 153a Back
117
Environmental Impact of Tidal Barrages, Draft provisional
POSTnote 435, Parliamentary Office of Science and Technology,
June 2013 Back
118
Environmental Impact of Tidal Barrages, Draft provisional
POSTnote 435, Parliamentary Office of Science and Technology,
June 2013 Back
119
Ev 153a, See also MJ2 Technologies website: Error! Bookmark not defined.
Back
120
Environmental Impact of Tidal Barrages, Draft provisional
POSTnote 435, Parliamentary Office of Science and Technology,
May 2013 Back
121
Q 291 Back
122
Ev 115 Back
123
Ev 153 Back
124
Directive 2000/60/EC Back
125
Directive 2007/60/EC Back
126
Directive 92/43/EEC Back
127
Directive 2009/147/EC Back
128
Directive 2011/92/EU Back
129
Directive 92/43/EEC Back
130
Ramsar sites are wetlands of international importance, designated
under the Ramsar Convention. Back
131
For more information see 'Natura 2000' section: Error! Bookmark not defined. Back
132
Q 81 Back
133
Sustainable Development Commission, Turning the Tide: Tidal Power
in the UK, October 2007 Back
134
Q 307 Back
135
Error! Bookmark not defined. Back
136
Error! Bookmark not defined. Back
137
Ev 153; Q 377 Back
138
Error! Bookmark not defined. Back
139
Q 324 Back
140
Qq 327-328 Back
141
Q 377 Back
142
Q 311 Back
143
DECC, Error! Bookmark not defined., October 2010 Back
144
Q 314, 28 February Back
145
Qq 330,333 Back
146
Q 315 Back
147
Qq 337-339 Back
148
Ginige TA, Thornton A, Ball F, The Severn Tidal Barrage Project:
A Legal Paradox?, Journal of Water Law 21:66-77 Article
number 2 2011 Back
149
Ev 192 Back
150
Ev 153 Back
151
Environmental Impact of Tidal Barrages, Draft provisional
POSTnote 435, Parliamentary Office of Science and Technology,
May 2013 Back
152
Error! Bookmark not defined. Back
153
Q 331-332 Back
154
See Ev 153: "Marine construction works: These can provide
additional or improved intertidal mudflats and saltmarsh habitat
for wintering birds upstream of the barrage. For example, topographic
raising to increase foraging space for wading birds which, in
combination with habitat enhancement, can improve quality of feeding,
ameliorating the loss of habitat. Salt marsh creation is also
beneficial to support wildlife and offset habitat loss." Back
155
Ev 107 Back
156
Ev 153 Back
157
Q 302 Back
158
Q 299 Back
159
Q 59 Back
160
Q 195 Back
161
Phase 1 refers to the proposed London to West Midlands route;
Back
162
Booz& Co. (UK) Ltd and Temple Group Ltd, HS2 London to the
West Midlands Appraisal of Sustainability, Main Report Volume
1, February 2011 and Appendix 4 - Associated Assessment Reports Back
163
Booz& Co. (UK) Ltd and Temple Group Ltd, HS2 London to the
West Midlands Appraisal of Sustainability, Main Report Volume
1, February 2011 Back
164
HC Deb, 10 January 2012, col 23 Back
165
Infrastructure planning portal, Proposed Tidal Lagoon Development
in Swansea Bay, South Wales, Environmental Impact Scoping Report,
October 2012, http://infrastructure.planningportal.gov.uk Back
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