Energy and Climate Change CommitteeWritten evidence submitted by the Marine Conservation Society (SEV87)

1. Background

1.1 The Marine Conservation Society (“MCS”) is the UK charity dedicated to the protection of the UK’s seas, shores and wildlife. MCS campaigns for clean seas and beaches, sustainable fisheries, protection of marine life and their habitats, and the sensitive use of our marine resources for future generations. MCS produces the annual Good Beach Guide, the Good Fish Guide on sustainable seafood, organises volunteer projects and surveys such as Beachwatch, the Beachwatch Big Weekend and Basking Shark Watch and works closely with the UK Government and devolved administrations on the development and implementation of marine laws and policies.

1.2 MCS is strongly supportive of renewable energy, in particular offshore wind, as it will lessen our dependence on fossil fuels, and make a significant contribution to meeting the UK Government’s legally binding target of at least an 80% cut in greenhouse gas emissions by 2050.

1.3 However, MCS is firmly of the opinion that the proposed Severn Barrage is the wrong option in the wrong place for generating electricity. Although the tidal range in the Severn estuary is considerable, building a 16km concrete barrier from South Wales to Somerset is not a credible option; the environmental risks simply far outweigh the commercial benefits. For example, fish and eel migratory routes will be severely inhibited, if not blocked completely; approximately 14,000 hectares of inter-tidal habitat of European importance will be lost upstream of the barrage; due to the high suspended sediment levels within the water, it is doubtful whether the lifetime of the barrage would be anywhere near as long as the projected 120 years; and the barrage could severely damage the viability of ports such as at Avonmouth.

1.4 At a projected cost of up to £34billion, the barrage will generate—at most—5% of the UK’s energy needs. MCS would far prefer to see a diverse approach taken to the generation of renewable energy, identifying the most suitable option that is fit for purpose in each location. The range of energy generation options includes on- and offshore wind turbines, tidal lagoons, and wave and tide turbines all of which need to be sensitively located and undergo full environmental impact assessments.

2. Introduction

2.1 Over the past few months there has been a lot of conjecture and opinion published in local, regional and national media regarding the revised design for a Severn barrage being promoted by both Hafren Power and Peter Hain MP; MCS therefore welcomes the Energy and Climate Change Select Committee’s (“the Committee”) inquiry into “A Severn Barrage?”. MCS feels this is timely and will help promote a reasoned, objective debate through the media and between the various stakeholders and interested parties about both the advantages and the disadvantages.

2.2 We would, however, raise the challenges faced in submitting evidence when Hafren Power still has not published a detailed proposal relating to this latest version for a Severn barrage. We have therefore based comments on the previous so-called Cardiff-Weston barrage (promoted by the then Severn Tidal Power Group) which was considered in detail by the Department of Energy and Climate Change’s (“DECC”) seminal report “Severn Tidal Power: Feasibility Study Conclusions and Summary Report” which was published in October 2010 (“the October 2010 report”).

2.3 Furthermore, we note Hafren Power’s website (www.hafrenpower.com) was not established in time for the Committee’s deadline for submission for written evidence, and still (as at January 2013) does not contain a detailed proposal that can be subjected to rigorous, external, objective scrutiny by third parties.

2.4 Although we are aware some research has been undertaken by Professor Roger Falconer of Cardiff University on Hafren Power’s behalf, this research has yet to be published in a peer-reviewed journal or released in detail by other means to the scientific community for external, objective scrutiny (although we do acknowledge that Professor Falconer has given numerous presentations throughout the UK and other countries on the proposal to extract energy from the Severn estuary, although we believe most of these presentations are based largely on the previous barrage proposal).

3. Questions Posed by the Select Committee

3.1 The inquiry has directed interested parties to address some or all of the following 10 questions:

(1)What contribution could the Cardiff-Weston Barrage make to UK energy security and climate change objectives?

(2)What risks and opportunities could it pose with regard to flooding in the Severn estuary, and how might any risks be mitigated?

(3)What risks and opportunities could it pose to wildlife and habitat in the Severn estuary, and how might any risks be mitigated?

(4)What lessons can be learned from the successful development of La Rance tidal barrage in France and other tidal power projects?

(5)What risks and opportunities could it pose to local employment and community, and how might any risks be mitigated? In particular, what are the consequences for current ports, fishing and aggregate extraction industries in the estuary?

(6)Would the project require support under the proposed new Contracts for Difference mechanism? If so, approximately what level of strike price would be required to make the project economically viable?

(7)How does the company plan to engage and consult the community in the development of the project?

(8)Are the proposals in breach of EU legislation, and if so how will this be addressed?

(9)Are any other proposals for tidal power projects in the Severn estuary currently under consideration?

(10)What could be the wider international implications of the scheme for UK engineering and UK low-carbon industry?

3.2 Of these 10 questions, three fall wholly or mainly within MCS’s remit, and these have been highlighted for ease of reference.

4. Response to Question 2

4.1 Because a detailed proposal still has yet to be published by Hafren Power, and the research it has commissioned to date still hasn’t been released to the scientific community for rigorous, external, objective scrutiny, MCS can only respectfully direct the Committee to the findings of the October 2010 report.

5. Response to Question 3

5.1 To reiterate a quote from the October 2010 report, “the evidence base [which was published with the report] is extensive, particularly the Strategic Environmental Assessment of Severn tidal power”. To date, MCS has not had sight of any credible evidence that would challenge any of the key conclusions of the feasibility study; we therefore accept, support and commend the findings of the report.

5.2 A number of the key conclusions on page 5 of the October 2010 report are of direct interest to MCS. For ease of reference, the relevant key objectives are reproduced below:

(1)The scale and impact of a scheme would be unprecedented in an environmentally designated area, and there is significant uncertainty on how the regulatory framework would apply to it. The study has considered ways in which to reduce impacts on the natural environment and also how to provide compensation for remaining impacts on designated features. It is clear that the compensation requirement would be very challenging, however defined, and require land change within the Severn estuary and probably outside it also;

(2)A scheme would produce clearer, calmer waters but the extreme tidal nature of the Severn estuary would be fundamentally altered. This means that some habitats including saltmarsh and mudflat would be reduced in area, potentially reducing bird populations of up to 30 species;

(3)Fish are likely to be severely affected with local extinctions and population collapses predicted for designated fish, including Atlantic salmon and twaite shad. This could mean the loss of twaite shad as a breeding species in the UK as three of the four rivers where it breeds run out into the Severn estuary; and

(4)Water levels would also be affected and in order to maintain current flood protection levels in the Severn estuary additional flood defences would be required; these costs are included in the cost estimates for each scheme.

5.3 The October 2010 report also clearly states the environmental and nature conservation value and status of the Severn estuary, which is of international, European and national nature conservation significance. On page 28 the report states that it is:

(1)A Special Protection Area under the Birds Directive for the number of water birds that use the Severn estuary;

(2)A Special Area of Conservation (“SAC”) under the Habitats Directive for the unique and highly dynamic conditions and the special range of habitats and species this supports, including sandflats, mudflats, saltmarsh and rare marine life; and

(3)A Ramsar Wetland of International Importance.

5.4 On page 29 the report also states that the Rivers Wye and Usk, which flow into the Severn estuary, are also designated as SACs. Together, they represent around 1.3% of all the UK’s designated SAC habitat. These rivers provide important spawning habitats for species of migratory fish, including five species protected under the Habitats Directive (allis and twaite shad, sea and river lamprey and Atlantic salmon) which travel up the Severn estuary on the way to these spawning grounds.

5.5 Elsewhere on page 29 the report also states that the area also contains Sites of Special Scientific Interest (“SSSI”), Scheduled Ancient Monuments and Areas of Outstanding Natural Beauty. A Severn tidal power scheme would impact significantly on natural and historic conservation sites both upstream and downstream of any scheme. The landscape and seascape of the Severn estuary would be significantly altered with the addition of a scheme.

6. Response to Question 8

6.1 MCS is extremely concerned that Government continues to support proposals by private companies to develop a Severn barrage as well as barrages in numerous other estuaries, rather than opposing such proposals as being unsustainable and likely to be in contravention to at least three EU Directives (the Habitats Directive, the Marine Strategy Framework Directive and the Strategic Environmental Assessment Directive), as well as the Government’s commitments to halt biodiversity decline.

6.2 MCS supports the generation of electricity from sustainable renewable sources such as offshore wind, wave and tidal currents as essential components of reducing greenhouse gas emissions provided they are sited and developed sensitively with appropriate mitigation to minimise impacts. However, a barrage in the Severn would not be sustainable and would adversely affect this internationally important ecosystem, at a time when we ought to be making ecosystems more resilient in the face of climate change, not decimating them.

6.3 The Severn estuary is a conservation site of international importance as its vast dynamic estuarine complex is unusual at the European level as well as national, and its various environmental designations have already been mentioned in Section 5 of this submission. In addition, it supports a large mosaic of habitats including mudflats, sandbanks, biogenic reefs, rocky platforms and saltmarsh and internationally important populations of wildfowl and migratory fish.1 Its demise would hence be a disastrous loss to European conservation as well as national conservation. While limited compensation of some parts of its habitats may be possible the complexities of the Severn’s ecosystem are not just due to the sum of its parts but due to the unique interactions between them.

6.4 The Severn barrage would have an adverse affect on the integrity of the Severn estuary as it will radically alter the estuary’s natural physical processes. The proposed inner Severn barrage would have the effect of reducing the tidal range in the inner Severn estuary by approximately 50% of the existing range.2 The tidal prism, sedimentation, tidal inundations, the size of the intertidal zone, subtidal zone will all be irreversibly altered.

6.5 The Marine Strategy Framework Directive: The Severn barrage could compromise the UK’s ability to meet our Marine Strategy Framework Directive (MSFD) requirements of Good Environmental Status, especially under Descriptor 7 (hydrographical conditions) since even DECC’s Energy SEA 2 acknowledged that barrages would cause effects potentially detectable over the whole continental shelf. We are concerned that the Department of Environment, Food and Rural Affairs has not made either DECC or the developers aware of the legal environmental requirements under the MSFD and the fact a Severn barrage would likely cause infraction. In a meeting with DECC (held on 15 May 2012) we raised this issue and they have suggested such environmental impacts would be considered as a requirement of the EIA process, but they seem to believe that an EIA will actually address such an issue, whereas we believe that the MSFD is insurmountable.

6.6 The Habitats Directive: A barrage would have an “adverse affect on site integrity” under the terms of the Habitats Directive and hence cannot be consented unless there are not more suitable “alternatives”, it is a project of “over-riding public interest” and “compensation” can be provided. MCS does not believe it will be possible to meet all these criteria. There are a number of alternatives, most notably nuclear power and offshore wind. Ecosystem health is as much of public interest as is electricity supply. It would be completely impossible to compensate for all the lost intertidal and sub-tidal habitats as a result of a barrage, due firstly to the scale and nature of the habitat creation necessary and secondly, because it is not possible to replicate the Severn and the loss of the rare twaite and allis shad and this important Salmon river, the sabellaria reefs, and the intricate and unique biodiversity of such an estuary.

6.7 The Strategic Environmental Assessment Directive: Article 1 of the SEA Directive states the aim is “to provide for a high level of protection of the environment” is met. DECC’s Energy SEA 2 makes clear that tidal range developments (generally tidal barrages) lead to the destruction and modification of whole estuaries, bays and inlets permanently.

7. Stepping Stones Tidal Lagoon

7.1 As an alternative option for the Severn estuary, we would like to bring to the Committee’s attention the Stepping Stones tidal lagoon proposal that has been developed by Parsons Brinckerhoff in association with Black and Veatch.

7.2 However, in doing so, we must emphasize it is still MCS’s view that any proposed marine renewable energy option must be sensitively located and undergo full environmental impact assessments. Even though the proposed tidal lagoon is significantly reduced in scale when compared to the proposed Severn barrage it would still be the largest tidal plant in the world, which we can only infer means there will still be a significant impact on the marine environment. For example, it impact on the East Aberthaw SSSI.

7.3 It is encouraging that, according to Parsons Brinckerhoff, the objectives of the proposal are:

(1)To demonstrate that tidal power can be generated from the Severn estuary with acceptable cost, environmental and social impacts and build UK confidence in ocean energy;

(2)To be informed by the October 2010 report research and add to that research base through full scale demonstration; and

(3)To be financeable in the private sector but developed in partnership with the public sector.

7.4 MCS does not have a view on the Stepping Stones tidal lagoon until we see a full environmental impact assessment but we respectfully suggest the Committee views the Stepping Stones tidal lagoon as an example of a smaller, tidal renewable energy option.

8. Conclusions

8.1 Because only high-level statements and information have been released by Hafren Power to date, we urge them to release a detailed proposal supported by robust scientific research which can then be subjected to rigorous, external, objective scrutiny by third parties. Until this is done, MCS can only respond on the basis of information contained within the October 2010 report published by DECC, the key conclusions of which we accept, support and commend to all relevant stakeholders and other interested parties.

January 2013