The Prime Minister
Rt Hon Boris Johnson MP
10 Downing Street
London W1 2AA
CC Rt Hon Alok Sharma MP, Secretary of State for Business, Energy and Industrial Strategy
CC Rebecca Pow MP, Parliamentary Under Secretary of State for Environment, Food and Rural Affairs
13 November 2020
Dear Prime Minister
We support your ambition for large-scale expansion of offshore renewable energy generation but— in the context of a climate and nature emergency—it is vital this does not happen at the expense of our marine environment. Climate and nature must be prioritised in the future uses and planning of the North Sea and our marine habitats.
The current planning and consenting regime for offshore wind and other marine activities is not fit for purpose. It fails to take a strategic view of how energy infrastructure, fisheries and other marine activities can be accommodated in a way that enables fragile and degraded ecosystems to recover.
As our seas become more crowded with turbines, fishing activities and other development, this approach will become completely unsustainable. Without reform, the seabed will be razed, food webs will be destroyed, blue carbon stores will be squandered, foraging and flightpaths will be disrupted. Species extinction is a real risk if we do not adopt an approach to planning, consenting and grid development that prioritises zero carbon power and nature recovery over other uses of the sea.
To meet carbon budgets and support healthy and wildlife-rich seas, the marine planning system must be overhauled to operate at a strategic level, rather than on a project by project basis. Offshore wind infrastructure can be designed sensitively for nature and blue carbon if a transparent system of strategic and spatial planning of future offshore wind and associated grid infrastructure is put in place. Each new development must be planned in the light of better mapping and data about the habitats affected and the cumulative effects of multiple activities.
Alongside energy development, a more strategic approach is needed for mitigation, compensation and nature’s recovery, so that where damage to the natural environment does take place, the right measures are designed to support ecosystem restoration. This should include making space for nature-based solutions that focus on tackling both the climate and the nature crises. Habitats such as seagrass, saltmarsh and deep-sea mud are important long-term stores of blue carbon and protecting and restoring these habitats prevents carbon from entering the atmosphere.
We will not pretend that trade-offs can be avoided; more places will need to be allocated where damaging activities like seabed trawling and other fishing pressures are curtailed. Fully or highly protected marine protected areas across at least 30% of the sea will be needed to help set our seas on a path to recovery, and must be accompanied by better monitoring, regulation and enforcement of the rules for fishing and other marine activities.
These changes could support a triple win of a world-leading marine renewables industry, increased blue carbon storage and recovery of marine species and habitats. This is an issue that countries are grappling with across Europe and around the world and—to be a genuine leader in offshore wind and marine management—the UK must prove that we can have clean power and thriving marine ecosystems.
As organisations dedicated to beating climate change and restoring nature, we urge you to take swift action to ensure that climate change mitigation and marine restoration go hand in hand.
Craig Bennett, CEO, The Wildlife Trusts
Beccy Speight, CEO, RSPB
John Sauven, CEO, Greenpeace UK
Sandy Luk, CEO, Marine Conservation Society
Dr James Robinson, Director of Conservation, WWT
Chris Butler-Stroud, CEO, Whale and Dolphin Conservation Ian Dunn, CEO, Plantlife
Nick Measham, CEO, Salmon and Trout Conservation
Mike Childs, Head of Science, Policy and Research, Friends of the Earth Dr Tony Gent, CEO, Amphibian and Reptile Conservation Trust
David Bunt, Chairman, Institute of Fisheries Management
Julie Williams, CEO, Butterfly Conservation
Andy Knott MBE, CEO, League Against Cruel Sports
Crispin Truman, CEO, CPRE The Countryside Charity
Kit Stoner, CEO, Bat Conservation Trust
Jill Nelson, CEO, People’s Trust for Endangered Species
Hugo Tagholm, CEO, Surfers Against Sewage
Dr Richard Benwell, CEO, Wildlife and Countryside Link
The Secretary of State has granted a three month extension to the Examination.
During the recent development consent order hearings (DCO), the Suffolk Energy Action Solutions group (SEAS) brought to the attention of the inspectors the fact that Scottish Power Renewables (SPR) are using “gagging” clauses in their agreements with landowners involved in the planning process for their offshore wind farms, EA1N and EA2. These clauses offer financial incentives to individuals and groups to withdraw objections and/or desist from objecting to their plans. There can be no justification for making payments or imposing conditions which undermine a statutory planning inquiry conducted in accordance with public law principles.