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Dear Editor
Re: MP vows to continue fighting for nuclear power plant after Government dismisses Dungeness

The final Habitats Regulation Assessment (HRA) report for Dungeness confirms that adverse effects on the integrity of three European Sites cannot be ruled out (Dungeness Special Area of Conservation (SAC), Dungeness to Pett Level Special Protection Area (SPA) and the Dungeness, Romney Marsh and Rye Bay proposed Ramsar site) with regards to impacts on water resources and quality, air quality, habitat and species loss and fragmentation/coastal squeeze and disturbance (noise, light and visual).

Development at Dungeness would require direct land take from the SAC. It is still considered that adverse effects related to habitat loss (at the Dungeness SAC) could not be mitigated.

The final HRA for Dungeness confirms that there would be inherent difficulties in providing compensation for adverse effects such as compensation for habitat loss. This is because of there is a lack of suitable alternative shingle in the vicinity where it would be more likely that compensation could be successful, the active role that coastal processes play in maintaining shingle habitats and the time successional shingle vegetation communities take to establish. Natural England has advised that the risks around securing suitable mitigation and compensatory habitat for vegetated shingle habitats should not be underestimated, and that the habitat at Dungeness is unique and unlikely to be replicated elsewhere.

The nominator of the site, EDF Energy, submitted three environmental studies to support their response.

The environmental studies have not changed the conclusions of the HRA on Dungeness.

The Government is obliged by law to consider adverse effects on the integrity of European protected sites which might be caused by development and to consider alternative sites if these impacts cannot be mitigated. This is because European protected sites have been given the highest level of protection because of their importance to nature conservation.

The Dungeness SAC is the most important shingle site in the UK and Europe and is one of the largest shingle expanses in the world.

The nominated site would require direct land take from the European protected site which sits wholly within the Dungeness Romney Marsh and Rye Bay SSSI. The HRA report for Dungeness has noted that the nominated site does not include land for temporary construction works. Additional land outside the nominated site (not necessarily adjacent) may also be required for coastal protection measures, highway and rail improvements, and a construction-phase Marine Off-Loading Facility.

Therefore the actual land required for construction might be larger than the nominated area.

There is a strict regulatory regime governing internationally designated sites and a high threshold given the significance of the designations, and to the extent that the nationally designated sites are covered by international designations, criterion D6 should be referred to.

A developer is not precluded from applying for development consent to build a new nuclear power station at Dungeness even though it is not listed in the Nuclear NPS.

However, a developer would need to overcome the potential difficulties and concerns which the SSA has flagged around coastal erosion and adverse effects on internationally designated sites of nature conservation importance. A project level HRA would also be required and if the developer could not demonstrate that adverse effects on the integrity of European protected sites could be avoided or mitigated the IPC would need to consider whether there are better alternative sites.

Yours

Barrie Botley