ENVIRONMENT
Environmental perspective
Walberswick is surrounded by a rich mosaic of natural habitats due to a mix of geography, geology, and cultural history, making it internationally important for wildlife. This is recognised by the Minsmere to Walberswick Marshes and Heaths suite of protected wildlife sites, which comprise shingle, dune, marsh, intertidal and heathland habitats. They are variously designated a Site of Special Scientific Interest (SSSI) under national legislation, a Special Protection Area (SPA) and Special Area of Conservation (SAC) under the European Habitats Directive, and a Ramsar Site under international treaty. The area is also recognised as being of outstanding landscape value, located within the Suffolk Coast and Heaths AONB. Walberswick is a key location for hundreds of thousands of people annually accessing and connecting with nature, and benefitting from the mental and physical wellbeing this imparts.
To date, NGV (National Grid Ventures) have provided scant details of the landfall works and terrestrial cable routes, but to reach either of the proposed landfall alternatives at G or G2, will involve crossing or tunnelling under fragile coastal and marshland habitat. Both landfall sites are located immediately adjacent to the designated sites. Inland, the cabling route has to cross internationally protected heathland and woodland habitats. In short, it seems highly unlikely that the work could be undertaken without having a significant effect on the integrity of the internationally designated sites.
Through collaboration with local naturalists, WALL already has a wealth of information on local biodiversity. By collating existing records and commissioning ecological surveys, we will focus on building the evidence base we hold on the following key habitats and species:
Qualifying Annex 1 habitats and their characteristic flora protected within the SAC, specifically annual vegetation of drift lines, perennial vegetation of stony banks and European dry heaths.
Qualifying Annex 1 bird species protected within the SPA, specifically bittern, marsh harrier, avocet, little tern, nightjar and other breeding and wintering waterbirds.
Other protected species known or suspected to occur, namely, otters, water voles, reptiles, bats, wainscot moths and other key invertebrates, woodlarks and Dartford warblers.
Other priority habitats and species that are a material consideration under the planning process.
We are particularly concerned by the impact the proposal will have on the Annex 1 habitats and species, through direct and indirect disturbance, coastal erosion and hydrological disruption, causing changes to the coastal habitats, salinity and water levels, which are known to affect key protected features 1 . We will focus on the Competent Authority’s assessment under Test 1 of the derogation stage of the Habitats Regulations, that there is no alternative solution that would be less damaging to this or other European Sites; there appear to be such solutions that have so far not been acknowledged or explored by NGV.
WALL have already engaged a specialist ecological consultancy to ensure we gather the appropriate ecological information to robustly challenge NGV in their assessment of effects under both the Habitats and Environmental Impact Assessment Regulations.
We have also engaged a separate environmental legal team. We will work closely with the Walberswick Common Lands Charity and Natural England, who own and/or manage the protected site areas surrounding Walberswick, and will engage with key stakeholders, such as the RSPB, the SWT (Suffolk Wildlife Trust) and SEAS (Suffolk Energy Action Solutions).