Energy and Climate Change CommitteeSupplementary evidence submitted by The Bristol Port Company

Preliminary

1. This Supplementary Submission represents The Bristol Port Company’s (“Bristol Port”) response to the evidence lodged by Hafren Power (“HP”), and others, in two ways.

First, it summarises—as best it can given the paucity of available detail about the barrage proposal—the likely adverse impacts the proposed barrage would have upon Bristol Port and thus on the regional and national economies and interests.

Second, it responds to important errors and omissions in HP’s submission to the Select Committee.

Part I: Summary of the Adverse Impacts of the Barrage on Bristol Port

2. Bristol Port, in its first submission to this Select Committee, has already indicated that, whilst it … “supports the exploitation of the Estuary’s extraordinary power to generate energy … a fixed barrage across the Estuary offers the worst possible solution” and that … “any proposal to build a fixed barrage … should be rejected as it would cause exceptional environmental damage and have severe economic consequences which could include closure of Bristol Port”. The elements of adverse impact on the Port itself include:

2.1The barrage is apparently to include two permanently available locks. Even assuming these were built sufficiently large, queuing for all traffic to and from upstream ports to use the locks plus the time spent approaching and transiting the locks would add a material time-penalty and delay for both existing and proposed traffic. In terms of trade for the existing Port this additional delay would be a seriously adverse factor. Put simply ships will seek other ports rather than face delay to use Bristol Port.

2.2Additional time would be required for many vessels that would require tugs and pilotage; in adverse weather conditions, particularly downstream of the barrage, entry to and egress from the locks would be progressively more time consuming to the point of such manoeuvres becoming simply too hazardous in certain sea states.

2.3In terms of the consented but yet to be built Bristol Deep Sea Container Terminal (“DSCT”), access for container vessels to the Port is intended to be free of any requirement to lock-in or out since such vessels would simply lie alongside in dredge pockets without need of locks. Construction of the barrage—with lock-controlled access to and egress from the upper part of the Estuary—would introduce a substantial additional passage time and delay for these very large, Post-Panamax vessels using the DSCT, removing one of the key reasons for constructing this facility of strategic importance to the UK.

2.4Point 2.1 above assumes that at least two locks would be built, available at all times and of sufficient size (in terms of beam, length overall, draught and air draught). Whilst HP have given vague indications that any locks would be sufficient to accommodate current vessels using the Port, Bristol Port is not aware of any precise proposed dimensions. Any such locks would have to be “future-proofed” in order that any increases in size of vessels plying their trade could also be accommodated. No such enforceable guarantees have been forthcoming. Significant questions about constructability and maintenance have likewise yet to be answered satisfactorily.

2.5Similarly, there is the question of charges for any vessels using the barrage locks. In the absence of an enforceable guarantee in perpetuity that no such charges would be levied, the adverse impact is patent.

2.6HP have as yet provided no adequate indication of how maintenance of the barrage as a whole, and of the locks (including permanent availability) in particular, is to be guaranteed. Nor of how the maintenance of new shipping channels is to be achieved.1

2.7Crucially, HP have not explained how they will guarantee in perpetuity the operation and maintenance of the locks and their approaches; the provision of pilotage and vessel traffic services; and the management of commercial priorities for access to the locks by multiple vessels all requiring passage through the locks on the same tide.

2.8The preceding impacts would be exacerbated by the barrage’s reduction of upstream water-depth by up to 2m with lower high-water and increased siltation. This would make it impossible for deep-draught vessels to enter or leave the Port on 80% of tides and would impact on the viability for handling vessels over 70,000dwt unless there were substantial works, including dredging and replacement of existing locks; such works would not only require further and substantial capital expenditure, they would also themselves potentially have adverse environmental impacts.

2.9Increased siltation upstream of and referable to the barrage would materially increase the requirement for maintenance dredging adding further environmental and financial cost.2

2.10The reduced water level upstream of the barrage would produce a requirement to deepen Bristol Port’s existing locks; this would involve a fundamental rebuild of those locks with significant disruption and at substantial cost. The business displaced by closure of the Port to carry out this work may never return.

2.11Downstream of the barrage, the structure is highly likely to exacerbate local sea conditions. All the sea energy, currently dissipated along the full length of the Estuary, will hit the concrete barrage wall causing considerable turbulence immediately downstream. This would cause delays and significant extra costs for shipping and therefore further harm Bristol Port’s competitive position. It would also require the designation of a number of new, safe deep water anchorages to house delayed vessels for up to several days.

2.12Bristol Port has excellent rail and road connections to its hinterland and the country as a whole. Through the recent granting of consent, without a public inquiry, for the DSCT, the national strategic importance of Bristol Port has very recently been recognised. The impact of the barrage on Bristol Port is a direct detriment to the UK’s strategic and economic interests. The suggestion which has apparently been made in parallel with the barrage proposal—namely of a new port in South Wales—perhaps reflects an implicit recognition of these adverse effects. Any port at Port Talbot would suffer from inadequate and materially inferior transport links, particularly rail, compared to those enjoyed by Bristol Port. Again, the UK’s interest would be harmed.

2.13The adverse impacts of any job losses at Bristol Port are obvious, in terms of both direct and induced employment. As Bristol Port is an anchor company with a catalytic effect on a wide geographically area, the adverse impacts would be significant at regional and national level, in terms of both strategic and economic consequences.

Part II: Errors and Omissions in Hafren Power’s Written Submission to the Energy and Climate Change Select Committee (SEV70)

3. Bristol Port summarises below some of the more significant errors and omissions it has found in HP’s written submission to the Energy and Climate Change Select Committee’s Inquiry into the Severn Barrage. Bristol Port’s silence on a particular point should not be taken as agreement with it.

4. HP’s proposal is in places unrealistic and frequently presents only part of the full picture. In order for HP to be credible with a wide range of stakeholders, including Members of Parliament, it must present a complete, impartial assessment of the positive and negative impacts of its proposal; this it has failed to do.

5. The analysis below is divided into four sections:

(A)Economic impacts.

(B)Alternative technologies.

(C)Environmental impacts.

(D)Timescales.

6. The numbered quotation at the start of each sub-section (in bold) is taken directly from Hafren Power’s submission to the Energy and Climate Change Select Committee’s Inquiry into the Severn Barrage.

A Economic Impacts

7. “Construction of the barrage will employ at least 20,000 workers. The barrage project will induce or indirectly create another 30,000 jobs.”

7.1 The asserted economic benefit to the local area from constructing the barrage is central to HP’s case for the barrage. These claims however fail under scrutiny. The 2012 report “Severn Tidal Power: Cardiff-Weston Socio-Economic Impact” (Bristol Port evidence Appendix D) summarises the output of the sound methodology used by the Welsh Assembly Government 2010 report Regional Economic Impacts Study, namely that around 76% of the economic benefit of the project would leak outside Wales and the South West. HP have presented no evidence to show how their scheme differs in this respect from the Cardiff-Weston barrage studied in the 2010 report or why such leakage would be any different for their proposal.

7.2 HP’s submission is unrealistic in suggesting a benefit for Wales of 50,000 jobs. For example, HP have produced no evidence to support their claim that manufacturers would build turbine factories in Wales or the South West. Without confirmation of the intention of companies such as Rolls-Royce, often cited in presentations on the HP’s scheme as a likely investor in these facilities, this claim is without foundation.

7.3 Furthermore HP have failed to take account of the impact on existing jobs. This omission can be contrasted with the methodology of the credible 2010 Economic Impacts Study which showed there would be considerable negative impacts amounting to a net loss of 80 jobs per annum once the barrage was operational.

7.4 As the DECC submission to this Committee noted:

“The STP study concluded that a barrage could benefit the regional economy with net value added to the economy and jobs created but that these would come at the expense of potential negative impacts on the current ports, fishing and aggregate extraction industries in the estuary.”3 (DECC)

8. “There should be minimum delay to shipping…The estuary will be dredged to ensure shipping lanes are kept open with minimal inconvenience to navigation. Hafren Power intends to minimise any impact on current business at ports upstream.”

8.1 The HP submission contains no understanding of the impact on shipping of the changes in water levels, navigation channels, dredging and associated disposal that the barrage would create. The 2010 study acknowledged these issues without being able to find solutions to them. As stated in Bristol Port’s earlier evidence, there would be a substantial adverse impact on the Port caused by the barrage; as an example, the changes to water levels and siltation in navigation channels would result in vessels over 70,000dwt being unable to access the port on 80% of tides making the port effectively unviable. The prospect of temporary work during construction of the barrage and some role in maintenance once the barrage is operational and in the leisure sector in no way compensates for this loss of business.

8.2 HP merely asserts an intention to minimise impact on current business at ports upstream. This is wholly inadequate and reveals a lack of concern about the future of such nationally important infrastructure, which, in Bristol, includes one of the UK’s most important ports. HP cannot simply ignore future port requirements. Shipping, vital to bringing in 95% of all imports to this island nation, has changed dramatically over the past 100 years and continues to change constantly to reflect global and local needs. As a 100+ year project, the barrage must take account of the changes likely to occur in shipping over at least that timescale.

9. “The barrage may help regenerate fishing in the area as has happened in La Rance. The increased photosynthesis and nutrients in the waters upstream of the barrage could stimulate to the creation of new mollusc and fish farming industries.”

9.1 HP hypothesizes about regenerating fishing but in the case of La Rance, the waters surrounding the barrage were devoid of fish for 10 years after construction.4 (EDF) When fish returned most of the indigenous fish species such as conger eels, flat fish and sand eels had disappeared. Jonathan White sums up the position at La Rance admirably in the concluding paragraph of his submission.

“The obvious difference between the Rance and the Severn is the scale of the rivers concerned and range of species affected. The Rance is a small river, which prior to the barrage did not have significant populations of migratory anadromous fish (salmon, sea trout, shad), with a comparatively small estuary. The rivers that flow into the Severn estuary, by contrast, cover a massive watershed, and are home, inter alia, to important populations of migratory salmonids, shad and eels.”5

9.2 The Angling Trust dramatically describes the acute risks to the fishing population through any interference with their habitat and they make it clear that:

“Estuaries are probably the most important habitats for fish and many of the species are already threatened by a host of other environmental challenges.”6

9.3 As DECC stated:

“The STP assessment noted that reductions in fish abundance would have adverse effects on commercial and recreational fisheries contributing to local economies. The assessment calculated commercial fisheries for salmon and juvenile and adult eel in the Severn catchment to be valued at £96,200, £299,000 and £36,000pa respectively in 2010, with recreational fisheries, particularly for salmon, valued at £28m. Sea angling is a major recreational activity in the Severn Estuary/Bristol channel: charter boat annual turnover was valued at c. £1m. These fisheries and related economic activity (eg local hospitality industry, fishing tackle retail) would be adversely affected by a barrage and likely to seek compensation.”7 (DECC)

10. “It will not require public money for construction… Since Hafren Power will fund the construction privately, the barrage will be highly affordable for the nation.”

10.1 It is incorrect to portray this project as having no cost to the public. HP must reveal how much their project will cost energy consumers each year as the costs will be considerable in the first 30–40 years. As DECC’s submission to this Committee states:

“Although the capital for the Hafren Power proposal would be provided by private investors, the consortium has informed us that it would require revenue support via CfD in order to provide a suitable return for investors. Government would need to take a view as to whether the level requested represented value for money such that offering a CfD would be in line with the principle of decarbonisation whilst minimising the cost to consumers.”8 (DECC)

“Any CfD funding would need to be value for money and considered against support for other low carbon technologies in the context of the Levy Control Framework.”9 (DECC)

10.2 The RWE Npower Renewables Ltd submission states:

“The direct and indirect impacts of the Cardiff Weston Barrage on existing power generation and transmission require careful consideration. A scheme of this size would have requirements for major changes to grid and other infrastructure…. through the Levy Control Framework, the substantial size of this one scheme and its requirement for Government support mechanisms could significantly offset the development of other established renewable generation technologies. Therefore the direct investment benefit from this scheme is not as attractive as first presented. A spread of investment in a number of proven technologies, projects and development companies presents a lower risk profile and a cheaper option to the UK.”10

11. “The barrage will defend 90,000 properties and 500km2 of flood plains from flooding. Government forecasts of coastal and tidal flood damage and defence costs in the Severn estuary over the next century range from £2bn to £15bn on a net present value basis. From 2023, when the barrage structure is complete, taxpayers would therefore save many hundreds of millions of pounds a year in flooding costs.”

11.1 This is a spurious, partial calculation. HP have apparently included only the aspects of flooding that are favourable to their proposal. They have omitted fluvial and pluvial flooding impacts (which have been experienced widely across the area in recent years and months) as well as downstream flooding impacts and the potential for the contamination of freshwater, all of which will be made worse by the barrage. Whilst the potential for a storm surge to cause damage needs to be taken into account, this cannot be to the exclusion of other highly significant, and very regular, flood events.

11.2 HP have also apparently not taken account of the negative impacts on existing flood defences upstream as a result of long-term erosion as evidenced in the Eastern Scheldt.

11.3 The Environment Agency’s submission concludes:

“Our initial assessment is that over 100 years the overall impact on flood risk management costs may be neutral, although further work is required to understand the effects on coastal regions far from the Severn. We believe additional flood mitigation measures should be included in the scheme.”11 (Environment Agency)

11.4 Rather than the £2 billion–15 billion flood defence cost savings in the Severn Estuary over the next 100 years claimed by HP, the EA submission estimates total increased costs for the next century of £600 million, with a Present Value cost of £156 million. Claims that taxpayers would save many hundreds of millions of pounds a year in flooding costs would appear to be greatly exaggerated.

11.5 DECC’s submission confirms that the “change in tidal regimes is likely to cause extensive foreshore erosion within the impounded areas of the Estuary, undermining the integrity of existing flood defences”.12 Hafren Power have not taken account of the very significant additional costs of addressing erosion problems and reinforcing and repairing existing flood defences over the long-term, as evidenced in the Eastern Scheldt where worse case estimates for additional investment in failing flood defences are up to €260 million over the next 50 years13 (RSPB). This is an expensive problem for Government and tax payers to address post construction of a barrage.

11.6 The evidence from Parsons Brinckerhoff states:

“The change in the tidal regime in the impounded estuary has an adverse effect on evacuation of flood water and drainage systems during ‘tide lock’ conditions. For the Cardiff-Weston Barrage, specialists at Black & Veatch concluded that there would be an increased flood risk and/or impeded drainage affecting up to 372 km² of land, over 50,000 properties and 28 critical infrastructure assets. Whilst most of those adversely affected in this way would also benefit from the reduction in flood risk from extreme tide levels, the impeded drainage issue would occur many times a year, whereas the additional protection against extreme high tides would be beneficial on rare occasions.”14

11.7 Further evidence on the impacts and costs of increased flood risks from the barrage has been presented to the Committee by, amongst others, the Severn Rivers Trust, Countryside Council for Wales, DECC, The Wildlife Trusts, Country Land and Business Association and the Natural Environment Research Council.

12. “After construction, Hafren Power will consider converting the caisson casting basins into a port for ultra-large container ships.”

12.1 HP is correct that the UK will need increased container handling facilities with fast access to major markets, particularly the Midlands and South East. However they have omitted to carry out an assessment of demand which would have revealed that there is no demand for a ULC port at Port Talbot.

12.2 Cargo owners and shipping businesses are in a highly competitive market where the requirement to drive down the costs of inland transportation, avoid congestion, reduce CO₂ emissions and move to more sustainable modes of transport are highly significant. Put simply, Port Talbot is too far from the end destinations for inbound UK containers. If it was a suitable location it would already be under consideration by global investors. By contrast the fully consented Deep Sea Container Terminal at Bristol Port with its excellent road and rail links is ideally placed to reduce CO₂ and costs with its easy access to customers in the Midlands, Wales and much of Southern England.

13. “The UK would be able to export its expertise in turbine technology and barrage construction from here to many sites around the world.”

13.1 HP have omitted to include any evidence of demand for barrage construction around the world. The submission by DECC states:

“The export potential from a tidal barrage may be more limited as there are only relatively few sites around the world with the combination of features…to make a tidal barrage viable.”15

13.2. Similarly, RWE Npower Renewables Ltd see very limited opportunities for exporting engineering skills. They point out that:

“the number of suitable international sites for tidal barrages are limited and all would require significant government funding. It is considered that export opportunities could be limited.”16

14. “The calmer estuary waters upstream of the barrage will encourage tourism and water sports.”

14.1 HP’s evidence is contradictory. On the one hand it claims that the tides will not be very different from the current conditions (hence their claim for minimised impact on the environment and shipping) but on the other hand they seemingly claim lake-like conditions upstream of the barrage for leisure users. These statements cannot both be correct.

14.2 There will be a 10m difference between high and low water upstream of the barrage. With this 10m rise and fall happening twice a day, plus currents which have not been assessed, this will be far from a placid lake for leisure users. Take sailing for example. How will a small yacht return to its marina after a few hours sailing when the marina is behind locks up to 10 metres above the level of the Estuary? Comparisons to Lake Garda or the impounded area of Cardiff Bay are wholly misleading.

B. Alternative technologies

15. “To Hafren Power’s knowledge, there are no viable alternatives of a similar scale to the barrage proposal.”

15.1 To comply with the Habitats Directive, alternatives do not need to be on a similar scale; the Directive instead identifies a need to show an absence of alternative solutions. Indeed with HP’s proposals it is the very scale of the project that is the problem and results in such unacceptable levels of environmental and economic damage. HP’s evidence expressly accepts that the barrage would be likely to have an impact on a number of European sites; yet it not only fails to demonstrate that any appropriate assessment would not be negative but also contains no tenable basis upon which to conclude an absence of alternative solutions or the existence of imperative reasons of overriding public importance. It further fails to provide any robust basis upon which a decision-maker might be satisfied that all necessary compensatory measures can be achieved. The onus is on HP to prove these matters and, had such robust evidence existed, it is to be assumed HP would have adduced it.

16. As Energy and Climate Change Minister Greg Barker said in December 201217 in response to the European Commission’s announcement of EU funding for two UK tidal projects:

“European funding for Scottish Power Renewables and Marine Current Turbines’ tidal projects is great news for the UK’s marine energy sector and further underpins the UK’s position as a world leader in this source of clean green power.”

16.1 As Regen SW and the Marine Energy Park stated in their submission:

“There is a growing tidal industry focused around the Bristol Channel, who have devices applicable to the global market already at the full-scale prototype stage. We are aware of a number of project proposals for tidal stream and tidal lagoon projects which are under development.”18

16.2 Bradshaw and Daborn note:

“The Canadians are forging ahead to test and refine tidal in-stream energy devices to create a commercially viable technology appropriate to the Fundy environment. They have partnered with Marine Current Turbines Ltd. (MCT)—based in Bristol, UK—to test its technology in the Bay of Fundy. This has the potential to provide economic impacts in the Atlantic region and position Canada as a world leader in marine renewable energy.”19 (Bradshaw and Daborn)

17. “Under the EU Habitats Directives and application of IROPI, the question has to be asked: ‘Are there other better or more viable marine energy technologies which would be preferable to the Hafren Power barrage and which would provide the same energy at less environmental cost?’”

17.1 HP have misinterpreted relevant guidance on the requirements of the Habitats Directive which indicates that the alternatives do not have to be “more viable” or necessarily “provide the same energy” as the barrage. The pertinent question is whether there are viable alternatives that are less damaging to the European protected sites.

17.2 There are undeniably a number of feasible options (at least as feasible as a barrage of this scale) which generate tidal energy without building a concrete wall across the mouth of the estuary and with significantly less environmental impacts, alone or in combination.

17.3 The effect of HP’s failure to make out its case in respect of impact on European sites is fatal.

17.4 The Angling Trust illustrates the sheer enormity of the compensatory task facing the developer:

“The Habitats Directive would require compensatory habitat to be created elsewhere to replace that which is damaged in the Severn. This could involve the creation or restoration of thousands of hectares of intertidal habitat and/or hundreds of miles of salmon and shad river habitat. If the damage to habitats is on the scale that we believe it might be, this would be even more unfeasible than stocking salmon to the Wadis of the Yemen, and considerably more expensive. What’s more, this habitat would have to be in place and functional before work could begin on the proposed barrage.”20

C. Environmental Impacts

18. “This proposal focuses above all on mitigating the environmental impact on the Severn estuary.”

18.1 The proposal pays lip service to mitigating the environmental impact but provides no adequate evidence whatsoever of how this will be done; it is an aspiration without foundation in reality.

18.2 There has been no testing of many of the proposed mitigation measures including the low-head turbines and evidence suggests that much of the proposed mitigation cannot be achieved.

18.3 The RSPB’s evidence reflects the serious doubts apparently felt by many stakeholders on reading HP’s claims for mitigation:

“Impacts should be mitigated and where possible avoided through good design, and any unavoidable residual impacts must, as a minimum, be brought within the realms of the realistically compensatable and therefore potentially acceptable (subject to rigorous application of the tests set out in Article 6(4) of the Habitats Directive ‘alternative solutions’, ‘imperative reasons of overriding public interest’ and compensation secured). We remain deeply sceptical that any shore-to-shore barrage could achieve this.”21 (RSPB)

18.4 The serious expressions of doubt by stakeholders are both predictable and to be viewed with the utmost gravity. HP’s failure to adduce cogent evidence to deal with these doubts is fatal to its case.

18.5 It should give major pause for thought to realise that in the only other estuary in the world to have a tidal range higher than the Severn, the Bay of Fundy in Canada, the environmental consequences of barricading the estuary were regarded as completely unacceptable by the Canadian Government.

18.6 HP have failed to demonstrate an understanding of how siltation will impact on their proposals. With over 30 million tonnes of suspended sediment moving on spring tides, the silt in the Severn is a force to be reckoned with. As Bradshaw and Daborn point out in their submission:

“Experience from the Bay of Fundy on the response of estuaries to the construction of causeways and dams has raised awareness of the unpredictable consequences where there are high silt concentrations.”22

18.7 To demonstrate how unrealistic the Hafren Power claims are, it is worth drawing attention to the comprehensive and compelling evidence submitted by Natasha Barker Bradshaw and Professor Graham Daborn (SEV 67) in respect of the long term evaluation and research conducted by the National Canadian and State governments into the energy potential from the massive tidal range in the Bay of Fundy. Many years of study based on smaller barrages and causeways resulted in the Canadian Government abandoning any plans for a major power generating barrage. The primary reason was the evidence from the smaller schemes which suggested that:

“Predicted impacts of a larger tidal barrage in Fundy were shown to substantially change the tidal regime with largely unpredictable consequences…”

“Rapid accumulation of mudflats seaward of the causeway grew to 6–8 metres above the original sand bar, with nothing growing on them for over two decades after the causeway was constructed. Ecosystem responses to modifications of these macro tidal estuaries take decades to develop, so the environmental effects are prolonged. These changes are continuing (albeit at a slower rate) some 40 years after the construction. In both the Avon and Petitcodiac causeway cases, new large mudflats developed progressively for many years at rates so great that they did not consolidate. They remained so fluid that the typical fauna of bivalves, amphipods and polychaetes was established only decades later.”23

19. “Hafren Power’s innovative turbines spin slowly, so fish can swim unharmed through the turbines or bespoke fish passes…Our turbines are also bi-directional and do not hold back high heads of water, so the tides are more natural. This means we preserve 60% more intertidal habitat than previous schemes proposed, saving the feeding and roosting grounds of wading birds.”

19.1 These claims are without foundation. Rolls-Royce/Atkins developed a concept design for Very-Low Head Turbines funded under the Severn Embryonic Technologies Scheme (SETS). The summary report24 suggested that one of the two concept designs would have “no detriment to fish survivability” however these turbines have not been developed even to prototype stage let alone tested as to their effects on fish, energy production, tides or any other aspect.

19.2 HP’s claim to preserve 60% more habitat is theoretical and cannot be relied on unless evidence is provided that is fully tested and peer reviewed. In making such claims, Hafren Power have failed to address the potentially greater scale of longer-term loss, and reduced quality, of intertidal habitats in the estuary likely as a result of ongoing foreshore erosion.

19.3 The DECC evidence states:

“The Hafren Power proposal is aiming to use a Very Low Head turbine concept which is being developed with lower environmental and flooding impact in mind. However the turbine hasn’t as yet been developed beyond concept stage and we have not seen any evidence confirming its potential.”25 (DECC)

19.4 The Environment Agency evidence states:

“We are not aware of any turbine designs which would allow the safe, repeated passage of fish through a barrage at the scale proposed.”26

19.5 The Salmon and Trout Association state:

“The proposed Severn Barrage would have a serious impact on fish populations within the Severn estuary, especially as it would create a barrier to migratory species such as Atlantic salmon, sea trout, shad, lampreys and eels, all of which are protected by European legislation. Salmon in particular could become non-viable in important rivers, such as Severn, Wye and Usk. As well as upward migrating adult fish being impeded, the turbines could also potentially kill high numbers of outward migrating juvenile fish.”27 (Salmon and Trout Association)

19.6 It is unclear how the claim that tides are “more natural” fits with other claims that the barrage will provide a placid lake upstream. As stated previously, such statements cannot both be correct.

19.7 HP’s asserted intention to create mudflats in compensation needs full explanation. Creating habitat is difficult and expensive and it is not possible to create sufficient mudflats to compensate fully for the impacts of the barrage in accordance with EU law.

19.8 The STPG studies undertook initial modelling to investigate the possible scale of this long term erosion, concluding that a barrage could result in 39–66% of total intertidal habitat to be lost over 120 years. RSPB’s submission points out that:

“experience from the Eastern Scheldt suggests that erosion could continue far beyond the modelled 120 year period, and could in the worst case scenario eventually result in the loss of all such habitat”.28

19.9 The RSPB also state:

“it is reasonable to assume that a low head barrage would result in less habitat loss than a high head barrage at the point of construction, because a lesser area would become permanently inundated behind the barrage. However, it should be noted that this would still constitute habitat loss on an unprecedented scale from a site protected under national and EU legislation, that the STPFS predicted ongoing erosive effects resulting in further intertidal habitat loss post-construction, and that experience on the Eastern Scheldt suggests that intertidal loss at the point of construction may represent only a small proportion of that which could subsequently occur as a result of changes to the structure and function of the estuary.”29

19.10 Failure to mention and address the risks to wildlife and flooding as a result of such long-term erosion and the mitigation and compensation costs in addressing these impacts is a major omission by HP.

20. “Hafren Power is exploring the opportunity to use the barrage for pumped storage.”

20.1 Much more detail is needed on this aspiration which could have a major impact on habitat, erosion and many other key environmental issues.

21. “Around 49km² of intertidal habitat will be lost. This is almost the same amount as would be lost anyway due to rising sea levels, according to Defra projections.”

21.1 HP have omitted to include the loss of habitat due to ongoing erosion after the barrage is built. For the scheme in the Eastern Scheldt, 85% of total intertidal habitat is predicted to be lost by 2100, far exceeding loss due to sea level rise.

21.2 Even at La Rance, where suspended sediment levels were always much lower than in the Severn, Jonathan White suggests that currently 30,000m³ of silt are being added each year to the marine basin and that, for example, the level of silt at Mondreuc is now 8 metres above sea level and:

“Intertidal habitat has been reduced from 70% to 50% of the area of the basin.”30

22. “To create new habitats for birds and to fund other mitigation measures, Hafren Power will invest up to £1 billion.”

22.1 Based on the direct experience of Bristol Port, HP will need over £1bn for the creation of compensation habitat for birds alone (around £115k/ha for an estimated 9,800ha [98km²] of intertidal habitat at a 2:1 compensation ratio).

22.2 There will be considerable additional costs for the extensive environmental mitigation, compensation and monitoring programme required for a barrage to meet the requirements of the Habitats Directive, The environmental mitigation measures and the compensation schemes required for a barrage (eg managed realignment schemes to create saltmarsh) are in themselves major engineering projects, requiring full assessment of the impacts in order to understand the very significant additional mitigation and compensation measures required to offset the impacts that they will cause in both the Severn Estuary and other designated UK estuaries.

22.3 The full scale of mitigation and compensation costs must be accurately identified by the promoters of the scheme, not only for the immediate impacts of a barrage but also importantly for the likely long term impacts as a result of foreshore erosion, subtidal deposition and gradual declines in the quality of habitats and the bird and fish populations that depend on them. These costs appear to have been considerably underestimated at present.

22.4 Compensation must be secured prior to consent for the scheme. It is entirely unclear how HP expects to obtain funding for that purpose ahead of consent being granted.

23. “Hafren Power is already engaging with all stakeholders to minimise this impact to a level that is as low as reasonable possible.”

23.1 This claim overstates the situation considerably. HP have published neither a business plan nor any evidence on any issues which can be peer reviewed. HP have only given overview presentations based on untested hypotheses; this is not consultation.

24. “Bridgwater Bay bund: As part of its mitigation strategy, Hafren Power is studying the option of building a bund around the entrance to the Parrett River.”

24.1 The proposed mitigation strategy of building a bund in Bridgwater Bay is a major infrastructure project in its own right, with significant adverse environmental and economic impacts likely on the River Parrett and surrounding area, requiring further mitigation and compensation measures that have yet to be considered. The assessment and consenting process for this engineering scheme alone would take many years.

24.2 HP should be aware that such a structure is highly likely to be in direct conflict with the habitat creation schemes at the Steart Peninsula by the Environment Agency and Bristol Port and jeopardises the millions of pounds already invested in them.

24.3 It is not clear if the cost of the Bridgwater Bay bund and its associated compensation are included in HP’s suggested capital costs.

25. “The barrage will create a number of opportunities… Reduced turbidity will increase light penetration and photosynthesis and result in an increase in biological productivity…higher invertebrate densities, greater fish populations and better opportunities for birds to feed”

25.1 HP cite the “great conservation opportunities” offered by the barrage. The reality is that it would require more than three times the total inter-tidal habitat created across the UK to date. This is totally without precedent, greater than anything attempted elsewhere in Europe and hugely risky.

25.2 HP’s claim about reduced turbidity is entirely unproven. As discussed in detail in Appendix E of Bristol Port’s submission to the Committee, although reduced turbidity would increase primary productivity, this will not solve the problem of damage to designated wildlife assets. The law requires the existing attributes of the Severn Estuary to be protected. It is not acceptable to change the particular characteristics of the existing dynamic, extreme and unusual ecosystem with a loss to its designated features and claim that it is a benefit that other non-designated habitats or species may develop, making the Severn Estuary more typical of other estuaries.

25.3 There is no certainty that improved primary productivity would improve mudflat productivity or carrying capacity of SPA birds. Evidence from the Eastern Scheldt, where similar increases in light penetration have arisen, indicates the opposite; mudflat productivity and bird populations have decreased as a result of widespread ongoing foreshore erosion and loss of intertidal habitats.

25.4 This view is supported by Bradshaw and Daborn’s submission based on evidence from case studies in the Bay of Fundy which states:

“Claims from La Rance that biodiversity may increase (eg Kirby, 2006) are probably only valid because habitat diversity has increased (and not necessarily productivity). By comparison, the very high productivity of the Upper Bay of Fundy is related to the highly dynamic behaviour of the sediments and the low biodiversity that is found there. Changes to the Severn Estuary could cause loss of species that are particularly well adapted to the special environmental conditions: the fact that other species may establish themselves doesn’t compensate for that loss.”31 (Bradshaw and Daborn)

25.5 Bradshaw and Daborn explain that new mudflats in some sites in the Bay of Fundy took many decades before they functioned as habitats:

“In both the Avon and Petitcodiac causeway cases, new large mudflats developed progressively for many years at rates so great that they did not consolidate. They remained so fluid that the typical fauna of bivalves, amphipods and polychaetes was established only decades later.”32 (Bradshaw and Daborn)

26. “There are other examples of tidal barrage projects around the world.”

26.1 As previously discussed, the rocky nature of La Rance is fundamentally different from the Severn. It is not appropriate to use La Rance as a comparator.

26.2 The Sihwa Tidal barrage Scheme in South Korea is a small fraction of the scale of the Severn with little to no information available. Again is not an appropriate comparator. It is understood that other tidal power schemes proposed in South Korea are all currently on hold at various stages of the assessment and consent process pending further consideration by the Government.

26.3 Cardiff Bay is not a comparator although the action of the law of unintended consequences is worth noting; the barraged Cardiff Bay has so far suffered from lack of dissolved oxygen (requiring extensive piped oxygen), invasive zebra mussels and toxic algae.

26.4 HP should provide analysis and commentary on the schemes at the Eastern Scheldt and the studies carried out on smaller barrages and causeways in the Bay of Fundy, at the same time as making clear the scale of these projects is a fraction of that of the Severn Barrage. The experience of the Canadian and Dutch Governments will reveal the considerable problems experienced as a result of smaller scale tidal barrages and barriers. Producing evidence on this is necessary to understand why the Canadians no longer consider further or larger tidal barrages in the Bay of Fundy as viable and have instead moved on to more benign and reversible technologies.

27. “There are precedents of EU developments where similar large scale projects reconcile the three conditions of the Habitats Directive (paragraph 53). See Appendix item 2 for a Case Study of the new port in Granadilla, Tenerife illustrating the approach to compliance adopted in one instance.”

27.1 There are no similar scale projects in the EU.

27.2 The port development cited in Tenerife is largely irrelevant to HP’s proposal as it is very small scale compared to the Severn Barrage, relates to compensation for subtidal sandbanks and turtles and fails to reflect the accepted approach for the loss and damage to intertidal habitats and SPA bird species in the UK.

27.3 By contrast, Bristol Port’s Deep Sea Container Terminal in the Severn Estuary (also small scale compared to the barrage) is a good example of how the Habitats Regulations should be applied in the Severn Estuary for intertidal habitats and SPA birds, including the need to provide compensation for damage to intertidal habitats caused by deposition or erosion of the type which has been ignored by HP to date. The approach to providing appropriate compensation for these habitats is clear, tried and tested in the UK and should be the focus for HP’s attention.

D. Timescales

28. “We will need two years for design, turbine testing and development, an Environmental Impact Assessment (EIA) and further detailed fish and bird studies, seven years to build the barrage and two years to reach full installation. The barrage could be partially operational by the end of 2020 and at full capacity by the start of 2025.”

28.1 This timetable is a gross underestimation of the period of time required for planning, EIA, mitigation, consultation and compensation: it is not based in reality. For example EU law requires compensation to be secured, delivered and functioning in advance of impacts. As a minimum 10 years would be required for this before construction could substantially begin; realistically for a project of this unprecedented scale, complexity and controversy it is likely to take longer.

28.2 The submission from the British Marine Aggregate Producers Association makes it clear that at least three years would be required to achieve new Marine Licences. In addition, each of the compensation schemes would require planning permissions and a number of other terrestrial and marine consents, opposition to which in the Severn Estuary is likely to be considerable, and, as indicated by the Environment Agency,

“may in itself be as controversial as building a Barrage”.

28.3 It is therefore unrealistic to offer the barrage as a means to achieving any part of the 2020 targets even if it were possible to compress construction.

28.4 Other smaller scale tidal schemes may be able to be permitted and constructed sooner, although timescales are still ambitious.

28.5 Statutory consultee, the Countryside Council for Wales, places the likely timescale for a barrage in context in their submission:

“The STPFS [Severn Tidal Power Feasibility Study] concluded that many years of further detailed work would be needed to plan, finance, and assess the impacts of such a large structure as a Severn power scheme before a case could be put forward for planning consent. Even over a period of two years the study was only able to consider feasibility and impact at a strategic level. If consented, the construction times would be between four and nine years depending on the scheme. In addition, any of the schemes would first require new habitats to be created, or species re-introduced, to replace those that would be displaced; these habitats and measures require time to be effective.”

“These investigations would take a number of years and given the significant lead in time we believe it is crucial that this requirement is promoted early. Addressing these data gaps would allow greater certainty in any future assessment, in the design process, understanding of environmental impact and effectiveness of mitigation measures. These significant uncertainties and data gaps are not development specific but are fundamental gaps in our knowledge of the estuary functions.”33

December 2012