Page 376 - Alderney Regional Environmental Assessment of Renewable Energy: Environmental Report

Alderney Regional Environmental Assessment of Renewable Energy:
Environmental Report
Stakeholder Comment Action (Including Clarification
Sought/Received, if Applicable)
Section(s) in
REA
Regarding water quality, there is a French
WFD water body (FRHC04), which extends
from Cap de Carteret to Cap de la Hague,
which may provide additional baseline
information.
Any baseline information that is available for this
water body may be useful at the project level,
particularly with regards to the interconnector
cable route between Alderney and France.
Reference to this information has been included
in the Limitations and Data Gaps sub-section of
the Water Quality section.
4.3.1.2
Alderney Licensed Vessel
Owners Organization, Raymond
Gaudion,
Chairman
(received 21-11-13)
The report fails to take into account the points
made in my response to the scoping report
particularly the dynamic nature of the Alderney
fleet.
To make the point again the wet fish efforts
feed the potting efforts for each boat providing
bait as a by catch. The potting efforts supply
an income when wet fish are scarce. The
reduction of any one of these methods of
fishing will result in economic failure for the
fleet.
Please refer to Table A2 in Appendix A which
includes your scoping response and provides an
action/response to each comment, cross-
referencing to the relevant section of the REA
where the issue is considered in more detail.
Following a meeting with you on 18 February
2014, we appreciate the dynamic nature of the
fleet and your concerns with the Draft Plan for
renewable energy in Alderney. The Commission
will therefore continue to engage with your
organisation to ensure that the Draft Plan is
implemented in such a way as to avoid and/or
minimise any significant adverse impact.
Table A2 in
Appendix A
7.2.2.1 Paragraph 3 ‘Permanent displacement
may ultimately lead to a reduction in fishing
opportunities to the extent that the commercial
fleet may be permanently reduced’. This is an
understatement.
The Draft REA has concluded that the long term
displacement of fishing activities will result in a
moderate to major adverse impact and therefore
we feel that the importance of this issue has been
recognised. Mitigation measures for this
significant adverse impact have been proposed
for consideration by developers at the project
level. In order for mitigation measures to be most
effective they will need to be discussed and
agreed with local fishermen at the project level by
individual developers when further details and
information on specific development is known.
The Commission welcome continued dialogue
with your organisation to facilitate this process.
7.2.2.1 and
7.2.2.6.
There are other issues with this report however
the demise of the Alderney fishing fleet is
inevitable even if only a small proportion of the
total potential area is developed.
In addition to the mitigation measures that have
been highlighted for developers to consider at the
project level, the Commission is committed to
adopting an iterative plan review process. This
process will involve collecting and analysing data
from initial deployments under the Draft Plan and
seeking similar information from other regulators
to inform the implementation of the Draft and
ensure it is carried out in a manner that avoids
significant adverse effects.
9
I do not see in this report any other business
that will be forced to close by this project.
See comment above. N/A
Ultimately the decisions will be made by
Alderney politicians who are already trying to
‘handcuff’ the Alderney commercial fleet with
the Fisheries Management White Paper.
The Commission is not involved in the Fisheries
Management White Paper and would therefore
recommend that any comments to this Paper be
directed to the States of Alderney.
N/A
Alderney Renewable Energy,
Declan Gaudion
(received 22-11-13)
In summary, this report presents a clear
representation of the current stage of
assessment in the context of ARE’s Draft Plan
and as such we have no amendments.
The report clearly:
x Acknowledges where we are in the
development cycle;
x Assumes worst case scenario – currently
assuming 1MW per turbine up to 4GW of
installed capacity = 4000 turbines;
x Notes the proposed development is 2GW @
2 MW per unit = 1000 turbines;
x Has not identified any significant impacts
across the 17 receptors (once mitigation
has assumed to have been implemented);
Points noted. N/A
R/4001/7 A.12 R.2129