Temporary Jetty Habitats Regulations Assessment Information PDF

Temporary Jetty Development
Hinkley Point C - Proposed Nuclear Development
Habitats Regulations Assessment Information

June 2011
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Rightwell House
Bretton
Peterborough PE3 8DW
United Kingdom
+44 (0)1733 334455 Telephone
+44 (0)1733 262243 Fax
info@peterborough.royalhaskoning.com E-mail
www.royalhaskoning.com Internet
Document title Hinkley Point C Preliminary Works:

Temporary Jetty
Habitats Regulations Assessment Information
Document short title Hinkley Point C Preliminary Works
Status Final
Date June 2011
Project number 9S4862
Client EDF Energy
Reference Habitats Regulations Assessment
Drafted by Richard Cottle / Peter Thornton / Peter Brunner
Checked by Richard Cottle

Date/initials check 27/5/11 RC
Approved by Sian John
Date/initials approval 14/6/11 SAJ
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EXECUTIVE SUMMARY
Introduction and Approach
1.1.1 This report considers the likely implications of the proposed Hinkley Point C jetty development
for the European designated sites in the study area and provides information for a Habitats
Regulations Assessment (HRA) in relation to the proposed jetty development. It sits
alongside the Environmental Statement (ES) for the jetty development (submitted in
December 2010) which reports the findings of the EIA and the addendum to the ES
(published in June 2011). The HRA information has been produced from the data and
assessment provided in this ES and the ES addendum.
1.1.2 The HRA information was prepared based on a three stage process, which included
screening, test for likely significant effect (LSE) and appropriate assessment. Within this
process, mitigation measures have been identified where appropriate. The potentially
significant effects of the jetty development were assessed alone as well as in-combination
with other relevant plans or projects. The approach for dealing with in-combination effects
was to determine the environmental parameters where spatial and temporal overlap between
plans and projects could occur (i.e. scoping of potential interactions). Only two projects were
identified as having the potential for direct interaction with the jetty development (i.e. they
would overlap with its footprint). These are the site preparation works which, together with the
jetty development, form the Preliminary Works for the Hinkley Point C Project, and the Hinkley
Point C Project itself, which is the subject of a separate Development Consent Order (DCO)
application. While other projects are assessed where effects on the same receptor (or
designated feature) may combine to generate a cumulative impact, any interactions would be
of an indirect nature as, spatially, their footprints do not overlap.
1.1.3 As set out in the ES for the jetty development, it is apparent that certain aspects of the
proposed works have the potential to interact with and have an effect upon a range of
ecological interests that form part of the designated features of a number of European sites.
A summary of the impacts reported in the ES was used to screen for ‘LSE’.
1.1.4 The initial screening was based on the Government’s HRA of the Hinkley Point site and
incorporated all sites within a 20km radius, with two sites (the River Usk Special Area of
Conservation (SAC) and River Wye SAC) outside of this boundary being included on the
basis that they are intrinsically linked to the Severn Estuary designations (due to shared
migratory fish features). However, potential effects on the migratory fish features of the River
Usk SAC and the River Wye SAC have not been considered directly as part of the
assessment, as it was determined to first establish if effects would arise with regard to the
Severn Estuary SAC and Ramsar fish species and assemblage.
1.1.5 The European sites screened into the assessment for the jetty development are as follows:
• Severn Estuary SAC;

• Severn Estuary Special Protection Area (SPA);
• Severn Estuary Ramsar; and
• Exmoor and Quantocks Oakwoods SAC (5.8km from the development site).
Hinkley Point C Preliminary Works -i- Habitats Regulations Assessment

Temporary Jetty Development June 2011
1.1.6 A number of sites were screened out of the HRA based on their location outside the area of
any potential jetty development effects (direct or indirect) on Annex I habitats and Annex II
species, or where the foraging ranges of the species for which these sites are designated
were not identified as extending as far as the jetty development site (i.e. are less than 20km).
These are:
• The Mendip Grasslands SAC; and

• Hestercombe House SAC.
Likely Significant Effect
1.1.7 On the basis of the known presence and distribution of designated interests relevant to the
study area and the likely effects of the development (as set out in the ES and the ES
Addendum), a likely significant effect test was undertaken to determine the potential for the
project activities to influence the designated features of the relevant European sites. These
activities were identified as:
• the physical footprint of the construction of the jetty and its berthing pocket, and
associated landward activities;
• construction disturbance (noise, light, movement, dust) due to the rock extraction,
delivery of materials, and construction and workforce access onshore and along the jetty
bridge and jetty head;
• operational disturbance (noise, light, movement, dust) on the jetty bridge, jetty head and
onshore relating to the delivery and movement of materials;
• underwater noise and vibration from piling of the jetty bridge and jetty head, dredging and
maintenance dredging of the berth pocket, and operation of the conveyor;
• sediment re-suspension during berthing pocket dredging (capital and maintenance); and
• surface water discharge during soil stripping and rock extraction, and from stockpiles of
soil and rock, to the foreshore.
1.1.8 The result of the likely significant effect test identified those interest features where the
potential for interaction with the proposed project activities exists. Features for which there
are no potential for interaction were screened out from further assessment. The removal of
features from further consideration at this stage has largely been undertaken on the basis of
distance from the application site, the potential area of influence of the proposed works and
the lack of either direct or indirect impact pathways that could affect the designated features
of the sites in question. Once the interest features with the potential for interaction were
identified, the particular project activities with the potential to affect each of the features were
identified. These are summarised under the relevant sites and features (in brackets) below:
Severn Estuary SAC (Estuaries, Reef and Migratory Fish)
1.1.9 The following potential impacts were examined in relation to the Severn Estuary SAC:
• Disturbance (noise, light and dust / sediment) potentially affecting the estuaries, reef and
migratory fish features during construction (due to rock extraction, movement of
personnel / construction plant, piling and dredging), operation (operation of conveyer,
movement of materials and maintenance dredging) and dismantling/restoration or
removal/reinstatement (the latter if the DCO is not made).
Hinkley Point C Preliminary Works - ii - Habitats Regulations Assessment

• Surface water discharge to the foreshore potentially affecting the estuaries, reef and
migratory fish features during construction (soil stripping, rock extraction, and from
stockpiles of soil and rock), operation and dismantling/restoration or
removal/reinstatement.
• Physical disturbance potentially affecting the estuaries features as a result of
construction equipment, the footprint of the jetty and berthing pocket during operation
and due to dismantling/restoration or removal/reinstatement equipment and materials on
the foreshore.
• Alteration to hydrodynamic processes and physico-chemical quality, and potential effects
on the estuaries, reef and migratory fish features, due to the physical footprint of the jetty
and berth pocket, berthing operations and maintenance dredging.
1.1.10 Of the potential impacts identified none was determined to have a likely significant effect on
the Severn Estuary SAC estuaries, reef or migratory fish features, with the proposed
development mitigation measures in place. For the estuary features this was on account of
the negligible scale and low interest of the area affected by the physical footprint of
construction and operation, and the lack of sensitive flora and fauna present on the foreshore.
Furthermore, any disturbance to physico-chemical quality was considered to be of a low
magnitude relative to natural background levels (e.g. storm events).
1.1.11 For the migratory fish feature the disturbance associated with the elevated noise and vibration
levels would not affect large areas or the deeper waters of the estuary. Due to the
intermittent nature of the proposed piling activities any effects would be of a short duration,
limited to the length of the construction period. If drill and socket methodology is used it
would further minimise noise and vibration levels. Furthermore, no significant disturbance to
hydrodynamic processes is expected and, therefore, no obstruction to migratory fish would
arise.
1.1.12 In terms of the estuaries and reef SAC features and potential impacts associated with
discharges influencing intertidal and subtidal communities (including Sabellaria and
Corallina), discharge modelling (during a 1:30 year storm event) showed that neither of the
nearest areas of Sabellaria reef (approximately 200m and 300m away) or the nearest
Corallina turf (approximately 150m down shore of the proposed discharge location) would be
affected by the proposals. The modelling indicated that 99.5% of all high tides inundate all
areas of Corallina habitat, limiting the length of exposure to the fresh water discharge and
smothering from sediments due to piling.
1.1.13 The site preparation works and Hinkley Point C Project were identified as having no likely
significant effect in-combination, due to the limited interaction between the features affected
(albeit at a very low magnitude) by the jetty development and these projects. Where similar
features were predicted to be affected, there was no spatial overlap, and the additive scale of
impact remained negligible. In-combination with other projects, only the Steart Coastal
Management Project has the potential to affect similar features, however, it would result in an
overall habitat gain at the estuary level. Furthermore, the significant spatial separation
between the jetty development works and other projects indicates that the potential for
disturbance events to affect the same migratory fish populations would be extremely small.
Given this and the lack of any significant disturbance effect associated with the other projects,
the conclusion was reached that there would be no interaction and in combination impact.
Drainage across the upper foreshore from the jetty development is not predicted to interact
with the water quality effects of any other projects, including the site preparation works, and
cause an adverse effect on designated species or habitats.
Hinkley Point C Preliminary Works - iii - Habitats Regulations Assessment

Severn Estuary SPA (Internationally important populations, Assemblage of waterfowl, and
supporting habitats)
1.1.14 The following impacts were examined in relation to the Severn Estuary SPA:
• Disturbance (noise, light and movement) potentially affecting internationally important

waterbird populations and assemblages of waterfowl during construction (rock extraction,
delivery of materials, plant and machinery, workforce, piling and dredging), operation
(from activities on the jetty bridge, jetty head, conveyor, onshore, and maintenance
dredging) and dismantling or removal of the jetty structure,
• Physical disturbance potentially affecting designated features (including the
internationally important populations, assemblages of waterfowl and supporting habitat)
during construction (from equipment and materials on the foreshore), operation (physical
footprint of the jetty and onshore elements) and dismantling/restoration or
removal/reinstatement (equipment and materials on the foreshore).
• Alteration to hydrodynamic processes due to the physical footprint of the jetty and
berthing pocket and potential effects on the internationally important populations,
assemblages of waterfowl and supporting habitat features.
1.1.15 The potential impacts to the Severn Estuary SPA relate to the loss of habitat and changes in
prey availability (direct disturbance to the waterbirds is considered below). With respect to
these issues, a likely significant effect has not been predicted on account of the limited use of
the foreshore within the vicinity of the jetty development site by wintering and passage birds.
Furthermore, any habitat loss would be very small-scale and unlikely to lead to the loss of
invertebrate species that constitute key prey items for the SPA bird species.
1.1.16 The potential for disturbance to waterbirds from human activity during construction activity,
particularly noise and light was also examined. Data indicates that very limited use is made of
the foreshore or coastal fields within the vicinity of the jetty development site by wintering and
passage birds. Noise contour mapping also indicated that the predicted heightened noise
levels extend only a short distance from the source. Furthermore, in the event that birds are
displaced, similar quality habitat is available within a few hundred metres.
1.1.17 A potential in-combination effect, however, was identified in relation to the disturbance of
waterbirds in the vicinity of the foreshore during construction activity associated,
predominantly, with the jetty development and elements of Hinkley Point C. A combined
impact on the SPA designated bird populations could arise through disturbance generated by
overlapping activities, which could generate a larger potential zone of disturbance than that
for the jetty development alone. If the displacement of birds from the foreshore in the vicinity
of the works (to surrounding intertidal areas) occurs as a result of activities associated with
the jetty development, these birds could be further displaced as a result of activities
associated with the seawall construction. Whilst the number of birds that could be affected is
still likely to be very small, between them, the works would be likely to affect a greater number
of birds than the jetty alone; however, for all birds potentially displaced, they would not be
displaced from their home range. Consequently, in-combination, the jetty development’s
construction works and the Hinkley Point C works could potentially have a significant effect
upon SPA designated populations, albeit they would not be displaced outside their home
range. Information for ‘appropriate assessment’ was, therefore, provided in relation to this.
Hinkley Point C Preliminary Works - iv - Habitats Regulations Assessment

1.1.18 While other projects were also assessed, it was concluded that they would be unlikely to
generate disturbance effects that would spatially interact with the jetty development to the
degree that foraging or feeding of any displaced birds would be adversely affected. Similarly,
the predicted habitat loss as a result of the jetty development was considered to be negligible,
whilst the habitat losses as a result of the site preparation works and Hinkley Point C Project
would take place in areas unlikely to be used by either foraging or roosting birds (that is,
supporting SPA habitat would not be affected and an in-combination effect would not arise).
The Steart Coastal Management Project would also provide an overall habitat gain at the
estuary level and this project would not affect supporting habitat.
Exmoor and Quantocks Oakwoods SAC (Barbastelle bats)
1.1.19 The following impacts were examined in relation to the Exmoor and Quantocks Oakwoods
SAC and, in particular, the Barbastelle bats feature:
• Physical footprint of the land-based works; and

• Disturbance (light) from land and shore based construction, operation and
dismantling/restoration or removal/reinstatement.
1.1.20 It was concluded that land clearance during construction would not have a discernible effect
on the availability of foraging resource and, whilst connectivity across the site would be
reduced by the removal of hedgerows, the commuting corridor along the coast would only be
temporarily disturbed and overall access to foraging areas would be maintained. Hence no
effect on the barbastelle population would occur. During the operational phase no habitat
would be lost and there would be no obstruction to commuting along the coast. Lighting
mitigation would avoid or reduce any potential deterrence to foraging areas or commuting
corridors, which are located outside the site. Restoration or reinstatement would result in
enhanced or similar habitat within the site suitable for foraging or commuting barbastelles.
1.1.21 Based on the assessment, it was concluded that the various phases of jetty development,
alone, would not lead to a change in the habitats outside of the Exmoor and Quantocks
Oakwoods SAC, such that a significant detrimental affect to the designated barbastelle
population would occur. Hence it was concluded that no likely significant effect would arise
with respect to the SAC.
1.1.22 Because the jetty development is located within (i.e. overlaps with) the landward extent of the
site preparation works (and the Hinkley Point C site), the effect of the site preparation works
and Hinkley Point C on foraging or commuting habitat would comprise the maximum in-
combination effect on barbastelles (to which the jetty would provide no addition to scale or
duration). Although an increase in the extent of habitat affected within 9km would arise, this
would remain small (less than 0.8% of the overall habitat) and account needs to be taken of
the limited suitability of much of this habitat, the retention of the key commuting corridors,
mitigation to provide hop over points and lighting mitigation for the Hinkley Point C Project.
While other plans may result in the potential loss of or reduction of other habitat, the suitability
of this habitat is unknown and is generally greater than 4.5km from the SAC. It was,
therefore, concluded that a significant affect on the conservation status of the barbastelle
population would not occur.
Hinkley Point C Preliminary Works -v- Habitats Regulations Assessment

Ramsar
1.1.23 For the purposes of this HRA information and given the overlap of the interest features, the
designated Severn Estuary Ramsar interests have been considered together with the relevant
designated interests of the Severn Estuary SAC and / or Severn Estuary SPA. The features
and potential impacts would, therefore, be the same as those discussed above for the SAC
and SPA. Based on the assessment of the features under the SAC and SPA, no likely
significant effect on the Ramsar site would arise.
Appropriate Assessment
1.1.24 Given the above conclusions, the combined disturbance effect to the SPA that could result
from the jetty development’s construction works (encompassing the landward works that
overlap with site preparation) and the construction works on the seawall for the Hinkley Point
C Project was examined further.
1.1.25 The assessment undertaken determined that, in-combination, the works would not have an
adverse impact on the overall coherence of the ecological structure and function of the
Severn Estuary SPA, which enables it to sustain the populations of bird species for which the
site has been designated. The same conclusion applies to the Severn Estuary Ramsar site.
That is, a number of factors indicated that the extent of this disturbance would not be
detrimental at the population level. These factors include:
• the temporary nature of the activities likely to cause the greatest disturbance effects;
• the low numbers of birds likely to be affected within the vicinity of the jetty site;
• the capacity for the majority of species to either avoid or habituate to disturbance;
• the presence of extensive areas of suitable alternative habitat within their home range
should displacement occur; and
• appropriate mitigation (e.g. confining construction activities and personnel movements to
demarcated working areas; and erection of fencing along the northern boundary of the
site preparation works area to restrict access).
1.1.26 Overall, it is therefore concluded that there would be no adverse effect on the integrity of the
European Sites within the study area as a result of the jetty development alone or in
combination with other plans and project.
Hinkley Point C Preliminary Works - vi - Habitats Regulations Assessment

CONTENTS
Page
1 INTRODUCTION 1
1.1 The Application 1
1.2 Project Background 1
1.3 Consenting and EIA Requirements 2
1.4 Scope of this Report 4
2 THE HABITATS REGULATIONS ASSESSMENT PROCESS 6
3 PROJECT DESCRIPTION 10
3.1 The Application Site 10
3.2 Description of the Jetty Development 10
3.3 The Temporary Jetty 12
3.4 The Berthing Pocket 17
4 OVERVIEW OF PREDICTED EFFECTS ON THE NATURAL AND PHYSICAL

ENVIRONMENT 19
4.1 Introduction 19
4.2 Coastal Hydrodynamics and Geomorphology 19
4.3 Marine Ecology 20
4.4 Terrestrial Ecology and Ornithology 21
4.5 Water Quality 22
4.6 Geology and Land Contamination 23
4.7 Air Quality 24
5 SCREENING OF RELEVANT ACTIVITIES AND EUROPEAN SITES 25

5.1 Introduction 25
5.2 Information on European sites potentially affected by the temporary
jetty development 25
5.3 Screening to determine potential for the project to influence designated
features 34
6 ASSESSMENT OF ‘LIKELY SIGNIFICANT EFFECT’ 47

6.1 Assessment of screened project activities on designated features 47
6.2 Severn Estuary SAC 47
6.3 Severn Estuary SPA and Ramsar 92
6.4 Exmoor and Quantocks Oakwoods SAC 113
6.5 Summary of effects on receptors 120
7 IN COMBINATION EFFECTS 130

7.1 Introduction 130
7.2 Details of Other Plans and Projects 131
7.3 Findings of In-Combination Test for Likely Significant Effect 136
7.4 Severn Estuary SAC 142
7.5 Severn Estuary SPA 152
7.6 Exmoor and Quantocks Oakwoods SAC 154
7.7 Conclusion on In combination Screening for ‘Likely Significant Effect’156
Hinkley Point C Preliminary Works - vii - Habitats Regulations Assessment

8 INFORMATION FOR APPROPRIATE ASSESSMENT 160
8.1 Introduction 160
8.2 Baseline information 160
8.3 Project activities relevant to the assessment 160
8.4 Assessment of the likely impact of disturbance generated by the
combined works 161
8.5 Conclusion on adverse effect on integrity 165
9 REFERENCES 167
Hinkley Point C Preliminary Works - viii - Habitats Regulations Assessment

1 INTRODUCTION
1.1 The Application
1.1.1 In order to facilitate the construction of a proposed new nuclear power station at Hinkley Point,
Somerset (Hinkley Point C), NNB Generation Company Limited (part of EDF Energy) is seeking
permission from the Marine Management Organisation (MMO) for the development of a
temporary jetty and associated onshore infrastructure at Hinkley Point (henceforth termed the
‘jetty development’). The application site is shown in Figure 1.
1.1.2 Consent is being sought by way of a Harbour Empowerment Order (HEO) under the Harbours Act
1964 (as amended) and licences under the Food and Environment Protection Act 1985 (i.e. FEPA
licences). The HEO application covers the construction and operation of the jetty. EDF Energy
has made clear that it is committed to dismantle / remove the jetty once the second reactor at
Hinkley Point C has been commissioned, or if a Development Consent Order (DCO) for the
Hinkley Point C project is not granted. The jetty will be a temporary structure and this
assessment covers the construction, operation, and subsequent dismantling and restoration of
the site (in due course).
1.1.3 In addition to the jetty development, EDF Energy is proposing site preparation works to clear and
level the proposed development site for Hinkley Point C and provide the necessary infrastructure
for the main construction activities. Key features of the site preparation works include site
clearance, earthworks and drainage, which together with the jetty development form ‘Preliminary
Works’ to the construction of Hinkley Point C. EDF Energy is seeking consent for the site
preparation works by way of grant of planning permission from West Somerset Council under the
Town & Country Planning Act 1990.
1.1.4 EDF Energy will be separately seeking a DCO from the Infrastructure Planning Commission (IPC)
to construct and operate Hinkley Point C.
1.2 Project Background
a) Site Enabling Works
1.2.1 A small package of enabling works is being initiated around the eastern end of the jetty
development site in order to facilitate the Preliminary Works. These enabling works include:
• remediation works to remove and reuse materials - including works to remove known areas
of asbestos contamination - within a spoil mound and other areas of made ground located
within the eastern part of the development site;
• construction of a bat barn to mitigate the impact of demolishing three existing barns (as part
of the site preparation works, see below); and
• continued use of two temporary trenches for vibration testing and removal of topsoil for three
temporary trial areas for compression testing within the site preparation works area.
b) Site Preparation Works
1.2.2 The proposed site preparation works would involve the following activities: site clearance
(including erection of fencing, vegetation removal, demolition of existing structures, and creation
of alternative footpaths); earthworks (including soil stripping and storage, site levelling, soil
screening / storage for subsequent re-use on site); provision of earth retaining structures; deep
excavations; provision and relocation of drainage infrastructure (including culverts, outfalls,
Hinkley Point C Preliminary Works Habitats Regulations Assessment

Temporary Jetty Development 1 June 2011
balancing ponds); the provision and operation of plant and machinery (including plant for concrete
batching); site establishment works (including the provision of construction compounds and
associated (including layover) facilities, car parks, haulage roads, site access points and
roundabouts, and laying, replacement and/or diversion of utilities); and other associated works.
c) Jetty Development
1.2.3 Preliminary Works to the Hinkley Point C Project are proposed in order to advance the
construction programme so that the new power station can be operational as soon as possible.
The jetty development is needed to provide a means for the delivery of bulk construction
materials (principally stone, sand, and cement) to the construction site at Hinkley Point. EDF
Energy’s programme is for the new power station to commence operation in 2018. This is in line
with Government policy that encourages early development of new nuclear build to assist in
meeting the UK’s carbon reduction targets (to help mitigate climate change) and improve the
diversity and security of our electricity supplies. Transporting the material by sea will avoid a
significant number of freight movements on the local road network, with attendant environmental
impacts.
1.2.4 Collectively these Preliminary Works (site preparation and the jetty development) are necessary
to enable the earliest possible completion of construction of Hinkley Point C following the grant of
the DCO.
d) Hinkley Point C
1.2.5 The Hinkley Point C site was nominated for new nuclear build by EDF Energy in 2009 and is
identified in the Government’s revised draft National Policy Statement (NPS) for Nuclear Power
Generation as one of eight sites in England and Wales that are potentially suitable for the
deployment of nuclear reactors by 2025 (Ref. 1). The NPS makes it clear that all eight sites are
needed, and that it is in the public interest to give priority to sites where new nuclear power
stations can be developed significantly earlier than 2025.
1.3 Consenting and EIA Requirements
1.3.1 As identified above, EDF Energy is seeking a HEO to authorise the jetty development and FEPA
licences to authorise discrete aspects of the jetty development’s construction. Both of the
consent application procedures include provisions for EIA in accordance with the requirements of
Council Directive 85/337/EEC (as amended) on the Assessment of the Effects of Certain Public
and Private Projects on the Environment (herein referred to as the ‘EIA Directive’). In relation to
the HEO, the EIA Directive is transposed into national law by the Harbour Works (Environmental
Impact Assessment) Regulations 1999 (as amended in 2000 and 2009) which amended the
Harbours Act 1964. In relation to FEPA licences, the EIA Directive is transposed into national law
by the Marine Works (Environmental Impact Assessment) Regulations 2007 (as amended in
2011). Through a ‘screening’ process, the MMO confirmed that the jetty development is subject
to EIA under the provisions of the EIA Directive and both of the aforementioned Regulations
because it, or elements of it, fall under Annex I of the EIA Directive and could be described as
falling under Annex I (2) or Annex I (8) (b) of the EIA Directive

Figure 1: Jetty Development Application Site

1.3.2 In addition, the jetty development includes a number of activities that would require separate legal
consents from a number of different regulatory bodies, potentially including land drainage
consents, discharge consents, waste management exemptions / licences, and protected species
licences. Prior to commencement of these activities, EDF Energy will ensure that it has secured
the necessary consents and that any relevant works are undertaken in full compliance with legal
requirements.
1.3.3 The application site is located adjacent to and partially within the Severn Estuary Special Area of
Conservation (SAC), Severn Estuary Special Protection Area (SPA) and Severn Estuary Ramsar
site (see Figure 2). Given the location, nature and scale of the proposed jetty development, it is
recognised that the proposals need to comply with the measures set out in Council Directive
(1992/43/EC) on the conservation of natural habitats and wild flora and fauna (herein referred to
as the ‘Habitats Directive’). The Habitats Directive is transposed into UK law through the
Conservation of Habitats and Species Regulations 2010 (the ‘Habitats Regulations’).
1.4 Scope of this Report
1.4.1 This report considers the likely implications of the jetty development (alone and in combination
with other relevant plans and projects) for the European designated sites in the study area and
provides Habitats Regulations Assessment (HRA) information in support of the MMO decision
making in this regard. It sits alongside the Environmental Statement (ES) for the jetty
development (submitted in December 2010) which reports the findings of the EIA and the
addendum to the ES published in June 2011.
1.4.2 The HRA process is set out in the first instance (Section 2), along with a summary of the
proposed project (Section 3) and of the findings of the EIA with respect to the key environmental
aspects of relevance to the HRA (Section 4) (full details are included within the ES and the ES
Addendum). Section 5 then screens in the relevant activities and European sites and Section 6
assesses ‘likely significant effect’. Section 7 considers in-combination effects with other plans
and projects and Section 8 provides information for ‘appropriate assessment’.

Figure 2: Designated Nature Conservation Areas in relation to the Jetty Development Application Site

2 THE HABITATS REGULATIONS ASSESSMENT PROCESS
2.1.1 The Habitats Directive protects habitats and species of European nature conservation
importance. Together with Council Directive (2009/147/EC) on the conservation of wild birds (the
‘Birds Directive’), the Habitats Directive establishes a network of internationally important sites
designated for their ecological status. Special Areas of Conservation (SACs) and Sites of
Community Importance (SCIs) are designated under the Habitats Directive and promote the
protection of flora, fauna, and habitats. Special Protection Areas (SPAs) are designated under
the Birds Directive in order to protect rare, vulnerable and migratory birds. These sites combine
to create a Europe-wide ‘Natura 2000’ network of designated sites, which are hereafter referred to
as ‘European sites’.
2.1.2 The Conservation of Habitats and Species Regulations 2010 incorporate all SPAs into the
definition of ‘European sites’ and, consequently, the protections afforded to European sites under
the Habitats Directive apply to SPAs designated under the Birds Directive.
2.1.3 In addition to sites designated under European nature conservation legislation, UK Government
policy (ODPM Circular 06/2005; Ref. 2) states that internationally important wetlands designated
under the Ramsar Convention 1971 (Ramsar sites) are afforded the same protection as SPAs
and SACs for the purpose of considering development proposals that may affect them.
2.1.4 As set out in the ES and ES Addendum for the jetty development, it is apparent that certain
aspects of the works have the potential to interact with and have an effect upon a range of
ecological interests that form part of the designated features of various European sites (see ES
Chapters 10 and 11).
2.1.5 Regulation 61 of the Habitats Regulations sets out the procedure for the assessment of the
implications of plans or projects on European sites. Under this Regulation, if the proposed
development is not directly connected with or necessary to the management of the site and is
likely to have a significant effect on the designated site (either alone or in combination with other
plans or projects), the competent authority must make an ‘appropriate assessment’ of the
implications for the site in view of the site’s conservation objectives (regulation 61(1)). In the light
of the conclusions of that assessment and subject to the considerations of overriding public
interest in regulation 62, the competent authority may agree to the plan or project only after
having ascertained that it will not adversely affect the integrity of the site (regulation 61(5)). The
person applying for consent is required by regulation 61(2) to provide such information as the
competent authority may reasonably require for the purposes of the assessment or to enable
them to determine whether an appropriate assessment is required. This Assessment is intended
to fulfil EDF’s obligations as applicant to provide the MMO as competent authority with the
necessary information to determine if appropriate assessment is required, if so what effects
should be considered, and with the information to undertake such assessment if required. It is
predicated on the basis that these questions have to be answered on a highly precautionary
basis.
2.1.6 The Department of Communities and Local Government (DCLG) (Ref. 3) guidance on ‘Planning
for the Protection of European Sites: Appropriate Assessment’ recommends a three stage
process:
1 Screening: Determining whether the plan or project ‘either alone or in combination with other
plans or projects’ is likely to have a significant effect on a European site (or sites).
2 Appropriate Assessment: Determining whether, in view of the European site’s conservation
objectives, the plan or project ‘either alone or in combination with other plans or projects’

would have an adverse effect (or risk of this) on the integrity of the site. If not, the plan can
proceed.
3 Mitigation and Alternatives: Where the plan or project is assessed as having an adverse
effect (or risk of this) on the integrity of a site, there should be an examination of mitigation
measures and alternative solutions. If it is not possible to identify mitigation and alternatives
it will be necessary to establish the “imperative reasons of overriding public interest” (IROPI).
This is not considered a standard part of the process and will only be carried out in
exceptional circumstances.
2.1.7 All three stages of the process are referred to cumulatively as the Habitats Regulations
Assessment, to clearly distinguish the whole process from the step within it referred to as the
‘Appropriate Assessment’.
2.1.8 In respect of step 3, the integrity of a site is defined as the coherence of the site’s ecological
structure and function, across its whole area, which enables it to sustain the habitat, complex of
habitats and/or populations of species for which the site has been designated (Ref. 4). An
adverse effect on integrity, therefore, is likely to be one which prevents the site from making the
same contribution to favourable conservation status for the relevant feature as it did at the time of
designation.
2.1.9 English Nature’s (now Natural England’s) Habitats Regulations Guidance Note 1 (HRGN1) (Ref.
5), describes how appropriate assessment (i.e. step 2 above) should be undertaken. This
guidance bases the assessment on a series of nine key steps. These steps include consultation,
data collection, impact identification and assessment, recommendation of project modification
and/or restriction, and reporting. Table 1 below sets out these steps.
Table 1: Key steps in Appropriate Assessment
Step Description of requirements
1 Defining the need for Appropriate Assessment.
2 Consultation with relevant nature conservation agency(ies).
3 Consultation with other organisations (e.g. Environment Agency etc.).
4 Definition of the designated status of the site, the qualifying interests and the site’s
conservation objectives.
5 Provision of further information – this information includes information already available,

new information from surveys and assessments of a technical nature.
6 Consideration of the potential effects.
7 Assessment of the influence of any potential impacts on the integrity of the site.
8 Avoiding adverse effects.
9 Conclusion regarding the potential for the scheme to adversely affect the integrity of the
designated site.

2.1.10 In the determination of likely significant effect (step 1), guidance has been provided in English
Nature’s Habitat Regulations Guidance Note 3 (HRGN3) (Ref. 6) ‘The Determination of Likely
Significant Effect under the Habitats Regulations’. This involves a preliminary consideration of
whether a qualifying feature is likely to be directly or indirectly affected (in which case there is a
presumption that a significant effect is likely). In such a case, a fuller consideration should then
be applied, using further analysis and information, to confirm and justify the presence or absence
of ‘likely significant effect’. Appropriate Assessment is needed in cases where a ‘likely significant
effect’ is identified. Figure 3, taken from HRGN3, sets out the recommended steps in the
process.
Figure 3: Step-by-step approach to determining whether a significant effect is likely on a

European site (HRGN3)

2.1.11 A likely significant effect is, in this context, any effect that may be reasonably predicted as a
consequence of a plan or project that may affect the conservation objectives of the features for
which the site was designated, but excluding trivial or inconsequential effects.
2.1.12 The undertaking of the appropriate assessment is the responsibility of the ‘competent authority’
(in this case, the MMO with respect to the HEO application). This HRA aims to provide the
information required by the MMO in order to enable it to undertake an appropriate assessment, if
required, of the project in accordance with Article 6(3) of the Habitat Directive.

3 PROJECT DESCRIPTION
3.1 The Application Site
3.1.1 This section describes the jetty development and the characteristics of the application site and
surrounding area that it could affect. The application site (see Figure 1) is located on the
northern coastline of West Somerset, 25km to the east of Minehead and 12km to the north-west
of Bridgwater, and falls within the parish of Stogursey. The onshore component of the application
site is located adjacent to the west of the existing Hinkley Point Power Station Complex. The
offshore component of the application site extends into Bridgwater Bay, part of the Severn
Estuary, as shown on Figure 2.
3.1.2 Immediately to the east of the application site are the Hinkley Point A and Hinkley Point B nuclear
power stations (i.e. the Hinkley Point Power Station Complex). Hinkley Point A operated between
1965 and 2000 and is currently undergoing decommissioning by the Nuclear Decommissioning
Authority (NDA). Hinkley Point B, owned by EDF Energy, has operated since 1976 and is
scheduled to continue generating until at least 2016.
3.1.3 The topography of the application site and the surrounding land is typical of that in the wider
locality, comprising mostly open, gently rolling, mixed lowland farmland with a series of east-west
trending ridges. Ground elevations range from approximately 10m to 35m Above Ordnance
Datum (AOD). The main access road serving Hinkley Point is the C182, which is an unclassified
road that runs south from Hinkley Point through the village of Cannington and then joins the A39
to the south of the village.
3.2 Description of the Jetty Development
3.2.1 The jetty development would be constructed and, assuming a DCO is granted for the Hinkley
Point C Project, operated during the construction of Hinkley Point C. It would then be dismantled
and the site restored outside of the area of permanent works associated with Hinkley Point C.
However, if a DCO is not granted for the Hinkley Point C Project, the constructed jetty would not
be operated, but would be removed and the land reinstated back to its current form.
3.2.2 The proposed jetty development comprises the following offshore infrastructure, as shown in
Figures 4 and 5:
• a jetty bridge constructed from vertical tubular piles supporting the deck;
• a jetty head constructed from vertical tubular piles supporting horizontal cross-heads and a
deck, and incorporating mooring infrastructure (e.g. dolphins);
• a berthing pocket dredged alongside the jetty head to accommodate vessels at various
states of the tide;
• materials handling and conveyance equipment on the jetty head and along the jetty bridge;
• a roadway along the jetty bridge; and
• aids to navigation.
3.2.3 An indicative photomontage of the proposed jetty development is provided in Figure 6.

Figure 4: Plan of Jetty Bridge and Jetty Head
Figure 5: Detailed Plan of Jetty Head

Figure 6: Photomontages of the Jetty - Looking West (top) and Looking East (bottom)
3.2.4 The jetty development comprises the following onshore infrastructure, as shown in Figure 7:
• an aggregates storage area comprising stockpile areas for stone and sand, and silos for
cement and/or cement replacement products, and including a surface water drainage system
with a water management zone for the treatment and regulation of discharges;
• a rock extraction area and two soil storage areas to facilitate construction of the onshore
components;
• a service road providing access to the aggregates storage area, the rock extraction area and,
temporarily for the purposes of construction, to the foreshore; and
• materials handling and conveyance equipment from the jetty bridge to the aggregates
storage area.
3.3 The Temporary Jetty
3.3.1 The jetty bridge would extend landwards from the jetty head to the aggregates storage area (see
Figure 7). It would be approximately 490m long and 11.5m wide. Based on a review of
maximum wave heights and a 5m wave on mean high water springs (MHWS), the bridge’s deck
level is positioned so as to provide a minimum 1m air gap between the wave crest and the
underside of deck beams. The deck level at its seaward end would be +16.5mCD (i.e. 16.5
metres above Chart Datum), which equates to 10.6mAOD (i.e. 10.6 metres above Ordnance
Datum) (see Figure 6). From this point, the bridge would rise on a constant grade to meet the
ground level on land which would be at +25.9m CD (i.e. 20m AOD) (see Figure 6).
3.3.2 The bridge comprises a steel box truss structure supported on concrete cross-heads, which in
turn are supported on raking steel tubular piles driven into the bedrock (see Figure 4). The box
truss structure is of consistent form along the whole bridge up to the last span to the jetty head,
where two smaller trusses accommodate the aggregates conveyor and cement pipeline. A typical
crosshead would have two raking piles but at main bridge joints there would be four raking piles.
A special cross head would be required at the location of the transfer hopper which would be
larger than the other cross heads. The box truss structure provides stability to the bridge and the

opportunity for large spans between the supporting cross heads of between 25m and 35m,
thereby reducing the number of piles and the construction programme. The number of bridge
piles in the arrangement is between 45 and 55 depending on the final detailed design of the
maximum possible span. The pile diameter would be in the order of 860mm, giving each pile a
surface area of 0.58m2 and a circumference of 2.70m, and a total footprint for all the piles of
between 26m2 and 32m2 depending on the number of piles.
3.3.3 The jetty head would comprise a concrete head sized to accommodate 5000 dead weight
tonnage (dwt) self-discharging aggregates vessels (e.g. barges) and 2500 to 5000 dwt cement
carriers (see Figure 5). The size of the main jetty head is expected to be in the order of 60m by
15m. It is anticipated that the jetty deck would be a 1.5m thick reinforced concrete slab supported
by a combination of both vertical and raking piles (70 to 90 in total). Some piles would need to be
anchored to withstand the berthing loads. The pile diameter would be in the order of 910mm,
giving each pile a surface area of 0.65m2 and a circumference of 2.86m. The jetty head would
also accommodate a mobile crane in order to offload various construction materials and allow for
their transportation to the aggregates storage area (see Figure 5). The jetty head would be sized
to allow vehicles to turn on the deck (and return along the jetty bridge’s roadway) and to facilitate
the anticipated movement of a mobile crane at this location. It is anticipated that 25 to 35 steel
tubular piles in the order of 910mm diameter would be required, giving each pile a surface area of
0.65m2 and a circumference of 2.86m. The total footprint of all the piles for the jetty head would
be between 62m2 and 82m2 depending on the number of piles.
3.3.4 It is anticipated that the jetty head would have a mooring dolphin at its eastern and western ends.
The dolphins would consist of a concrete cap supported by raking steel piles (although, at
detailed design stage, consideration could be given to using monopole construction for the
dolphins).
3.3.5 The berthing face of the jetty head would be parallel to the prevailing dominant east-west tidal
current direction and generally parallel to the prevailing west through to south-west winds. This
approach to the berth’s design should assist vessel manoeuvring because, for example, berthing
with the ship heading into the prevailing conditions is preferable as it allows greater control of the
vessel.
3.3.6 A roadway would be built along the jetty bridge as an independent structure adjacent to the truss
bridge already in place, but supported by the existing concrete cross heads and raking piles (see
Figure 5). The road’s deck arrangement would comprise pre-cast concrete deck units on steel
beams and provide a road that would be 5m wide.
a) Construction
3.3.7 In constructing the jetty bridge, the piles would be installed 4m to 5m into the bedrock layer
depending on the ground investigation data, which to date suggests that there might be a
weathered layer or weaker layer within the rock mass which may necessitate additional
penetration. It might not be feasible to drive the piles directly into the rock mass; hence the
installation method is anticipated to be either by drilling and driving or by pre-drilling and
concreting the pile into the socket, subject to further ground investigation data.
3.3.8 With the drill and drive method, the pile is seated onto the rock head, a drill is inserted down the
pile shaft and a hole drilled into the rock mass; the pile is then driven into the hole, the hole is
extended and the pile is driven further into the hole until the required penetration is achieved.
This technique would generate a degree of piling noise but is not anticipated to create much in
the way of bed disturbance.

Figure 7: Temporary Jetty Development – Onshore Development

3.3.9 The alternative pile installation method is for the pile to be placed into a concrete filled rock
socket. The pile is firstly driven to rock head, a drill is inserted down the pile and the rock socket
is drilled and then enlarged using the under-reaming blades to a diameter greater than the pile.
Concrete is placed into the rock socket and the pile is driven into the wet concrete. Shear rings
on the pile provide a degree of tension capacity.
3.3.10 Once the piles are driven, concrete cross heads would be placed over the pile bents. It is
anticipated that the cross head units would be pre-cast with in situ stitching to the pile, thus
minimising over water concrete works.
3.3.11 The steel box truss structure units would be prefabricated in lengths that span between cross
head supports. The prefabricated units would incorporate the steel longitudinal and transverse
deck beams. It is also anticipated that the cement pipeline, aggregate conveyor and open mesh
flooring would be installed within the units whilst on-shore.
3.3.12 The inshore end of the jetty bridge, including the first few spans across the upper foreshore,
would be installed using land based plant. For the drilling and placing of the tubular piles it is
anticipated that various plant would be required for the installation of approximately one pile per
day, including a 120t crawler crane, 30t excavator with drill attachment, piling hammer, 20t
excavator to load spoil and 25t dump truck to remove spoil (4-6 loads per day). It is envisaged
that this would result in approximately 10 vehicles per day, including 3-4 concrete deliveries. In
addition, piles would be brought to site by barge and tug, at a rate of one delivery per week.
3.3.13 To place the concrete cross heads and deck steelwork it is anticipated that various plant would be
required on a daily basis, including a 120t crawler crane and a 25t excavator. Crossheads and
truss units would be brought to site by barge and tug at an expected delivery rate of one delivery
per week.
3.3.14 In addition to the above, there would be support plant and equipment such as tractor and trailer,
small dumper trucks, lighting towers, welding sets, etc. required on an ad-hoc basis. There would
also be miscellaneous deliveries each day; these items would be transported on the tractor and
trailer.
3.3.15 All plant would be required to drive on the foreshore via the temporary service road and move out
of the tidal zone at the end of each shift. The typical speed of tracked plant is 5mph over this type
of terrain.
3.3.16 The piles beyond the upper foreshore and the jetty head would be installed from sea-based plant
in the form of piling equipment operated from jack-up barges. These complete units would then
be lifted by crane provided off a jack-up barge and installed over the cross heads.
3.3.17 It is envisaged that the roadway would be constructed from cross-head to cross-head using a
crane on a jack-up barge or land based plant to lift the materials into place. The pair of steel
beams would be placed on bearings and then the pre-cast deck units would be placed on the
steel beams. Pockets within the deck units would be positioned over shear connectors on the
steel beams and the pockets subsequently concreted in situ. The lighting columns would be
supported on the concrete cross heads and installed from the completed roadway.
3.3.18 The jetty head is expected to comprise in situ cast reinforced concrete, with construction activities
being undertaken from a jack-up barge. The use of pre-cast concrete elements could be
considered during detail design.

3.3.19 It is anticipated that the offshore construction works (e.g. piling and dredging) for the jetty would
require working hours of 24 hours a day and seven days a week, albeit that works would be tide
dependent, with normal working hours for onshore works (0700 – 1800 Mondays to Fridays and
0700 – 1300 on Saturdays, no working on Sundays or public holidays). Construction offshore
would take place with one or two shifts a day with variable start and finish times as dictated by the
state of the tide. These extended hours are needed to expedite the jetty’s construction in relation
to the restrictions imposed on working due to tidal conditions.
3.3.20 The jetty construction would take up to 15 months, with works in the intertidal zone (piling and
construction of jetty structure) from mobile plant would extend for around 2 months of the jetty
construction, and the remainder from sea-based plant (i.e. barges) would take approximately 4
months, with an overall duration of piling of around 6 months. Following completion of the jetty
structure, the roadway would be built which will take around 3 months, with elements of this work
entailing the presence of land-based plant within the intertidal zone.
b) Operation
3.3.21 The jetty would provide a route for bringing construction aggregates (cement, sand, and stone)
into the site during construction of Hinkley Point C. However, no additional extension to the
footprint or physical disturbance from new structures would occur, other than potential unforeseen
work resulting in maintenance of the infrastructure. However, it is considered that the main area
of maintenance would be mechanical and electrical maintenance associated with the receiving
aggregates hopper and articulated conveyor and the cement booster pumps and pipeline.
Maintenance and minor replacement of items would be undertaken locally unless significant
replacement of equipment is required. Maintenance walkways are to be provided along the jetty
bridge on either side of the aggregates conveyor and cement pipeline via the 1.5m wide central
walkway.
3.3.22 Should it be necessary to replace significant pieces of equipment, which would be very unlikely,
delivery could be achieved by a vessel berthing at the jetty and using its onboard unloading
equipment to unload items. Delivery could be achieved either by a vessel berthing at the jetty
and using the crane on the jetty head, or by a truck driving along the jetty’s roadway with items
being off-loaded and craned into position.
c) Removal / Dismantling
3.3.23 The temporary jetty would be dismantled at the end of its operational life. It is anticipated that
reuse of materials handling equipment would be feasible along with reuse and/or recycling of
some of the jetty’s structural items.
3.3.24 The materials unloading and handling equipment at the jetty head (e.g. articulated conveyor, silo,
booster, hoppers and crane) would be dismantled and shipped away from the jetty. It is
anticipated that following some local dismantling work the steel truss inclusive of the cement
pipeline and aggregate conveyor would be removed in units in a similar manner to that in which it
was installed. This would require a crane barge to transport the units. The roadway deck would
be systematically dismantled in a linear manner. Firstly, the pre-cast concrete deck sections
would be removed from the steel beams. This would involve local breaking out of the in situ
concrete surrounding the shear studs; hydro-demolition could be used in order to minimise
damage to reinforcement. The steel beams would then be disconnected from the cross heads
and removed. It should be feasible to re-use the steel beams and pre-cast concrete deck
sections at another location. The concrete cross heads for the jetty bridge and jetty head would
be dismantled from the piles by cutting of the piles immediately below the cross head. The
concrete could be recycled, subject to the degree of reinforcement.

3.3.25 It is not considered feasible to pull out the steel tubular piles, hence cutting of the piles at rock
head / seabed level would be used to remove the main section of pile shaft. On the foreshore,
where the pile locations could pose a risk to people walking and falling into holes, the remaining
section of pile and internal void would be in-filled with grout. At locations on the foreshore where
the holes / restoration are visible, a natural stone slab would be placed into the concrete plug.
The voids left within the seabed beyond the foreshore would not be plugged with concrete but
allowed to infill naturally with seabed deposits.
3.3.26 It is anticipated that dismantling of the jetty would be undertaken during normal working hours
(0700 to 1800 on weekdays, and 0700 to 1300 on Saturdays, with no working on Sundays or
bank holidays). The dismantling works would take between 1 and 2 years.
3.4 The Berthing Pocket
3.4.1 It is considered necessary for the berth to operate with vessels afloat rather than on the seabed
(i.e. not a Not Always Afloat But Safely Aground (NAABSA) berth) due to the exposed nature of
the berth. Aggregates vessels would operate within tidal access windows which are estimated to
be 7 hours on spring tides (giving 5.5 hours for off-loading) and 7.5 hours on neap tides (giving 6
hours for off-loading). Cement carriers would need some 15 hours to 30 hours to off-load and
would have to remain at the berth during low water; hence there would be a preference to deliver
cement on neap tides, when there is least difference between high and low water levels.
3.4.2 In order to increase the tidal window available for off-loading the cement carriers without going
aground, a berthing pocket would be dredged seaward of the jetty head’s berthing face (see
Figure 4). The berthing pocket’s dimensions would be approximately 160m long by 27m wide by
up to 3m deep. The sides of the berthing pocket would have slopes of 1 in 5. An additional depth
allowance of up to 0.5m could be dredged, making a total depth of up to 3.5m. This is because it
is assumed that the appointed dredging contractor would over-dredge by up to 0.5m to ensure
that the required 3m depth is provided across the berthing pocket.
3.4.3 Given the berthing pocket’s dimensions and side slopes, approximately 22,725m3 of dredged
material is expected to arise from the berthing pocket. The maximum potential for over-dredging
(i.e. by 0.5m) would add up to 2,160m3 dredged material. Therefore, the total volume of dredged
material that would arise from the berthing pocket would be approximately 24,885m3.
a) Construction
3.4.4 Existing ground investigation information indicates 4m of superficial deposits over rock head at
the proposed position of the berthing pocket. It is proposed to dredge up to 3.5m of this material
to create a berth pocket (including up to 0.5m of over-dredge). The actual dredging method
would depend on the dredging equipment available to the contractor appointed to undertake the
works. However, it is expected that dredging would take place using one of the two dredging
methods described below.
3.4.5 One method would be to use a small trailing suction hopper dredger (i.e. hopper capacity in the
range of 2,000m3 to 5,000m3). This type of dredger is a self-propelled vessel, with a draghead
that extends to the seabed and agitates the sediment as it moves forward. The agitated sediment
along with some of the surrounding water is sucked into the draghead and up a suction pipe by a
centrifugal pump. The mix of sediment and water is discharged into the dredger’s onboard
hopper. The hopper filling process may entail over-flowing (and/or diverting) excess water and
some of the finer-grained sediment overboard. Once the hopper is full, the draghead is retracted
and the dredger sails to the disposal ground, releases the dredged material through the hopper’s
bottom doors, and returns to the dredging location.

3.4.6 An alternative method would be to use a mechanical dredger, such as a backhoe dredger. This
type of dredger typically works from a jack-up pontoon (i.e. it is a static piece of equipment) and is
supported by a self-propelled transport barge with a built in hopper (hopper capacity in the range
of 1,000m3). This type of dredger is, in essence, a hydraulic excavator that uses a bucket on the
end of a boom and dipper crane arm to remove the seabed sediment and then bring it above the
water surface and place it into a barge moored alongside. Once the barge is full, it sails to the
disposal ground, releases the dredged material through its bottom doors, and returns to the
dredging location.
3.4.7 Dredging of the berth pocket would require working at high tide, at any point during the day or
night, seven days of the week.
3.4.8 The berth pocket dredge would commence approximately 12 months after commencement of the
jetty construction. The dredging would take approximately 1 month.
b) Operation
3.4.9 It is anticipated that a degree of sediment infilling would occur over time and, hence, maintenance
dredging of the berthing pocket might be required to ensure sufficient water depth for vessel
berthing and unloading operations. A maintenance dredging regime has not been determined for
the berthing pocket, but it is anticipated that the method for maintenance dredging and the
dredged material disposal site would be similar to capital dredging. The berth pocket would be
maintained for up to 8 years. Once maintenance stops, the berthing pocket would be expected to
accrete.

4 OVERVIEW OF PREDICTED EFFECTS ON THE NATURAL AND PHYSICAL
ENVIRONMENT
4.1 Introduction
4.1.1 The following sections provide a summary of the predicted effects of the jetty development, during
construction, operation and dismantling, on the key environmental aspects that are of relevance
to the HRA, as reported in the jetty development ES and ES Addendum. These are:
• coastal hydrodynamics and geomorphology (ES Chapter 9);

• marine ecology (ES Chapter 10);
• terrestrial ecology and ornithology (ES Chapter 11);
• water quality (ES Chapter 12);
• geology and land contamination (ES Chapter 16); and
• air quality (ES Chapter 19).
4.1.2 The following sub-sections provide a brief summary of the key predicted effects and any
mitigation measures proposed to deal with any adverse impacts of the project, as reported on in
the ES and ES Addendum. Where appropriate, reference is made to the relevant sections of the
ES and ES Addendum where further baseline information is provided. It should be noted that
predicted impacts to ecological receptors associated with noise and vibration, are discussed in
ES Chapters 10 and 11 (Marine Ecology, and Terrestrial Ecology and Ornithology). The
information provided below has been used for screening Likely Significant Effect, as described in
the following chapter (Section 5).
4.2 Coastal Hydrodynamics and Geomorphology
a) Main Predicted Effects
4.2.1 There is the potential for the jetty supports located in the upper part of the foreshore to partially
impede any longshore wave driven sediment transport to the east. However, the jetty structure
has been designed to be as transparent as possible to such wave trains. In addition, historical
data indicates that very little shingle from the western side of Hinkley Point is transported
eastwards. Hence, the presence of the jetty supports on the upper shore platform is predicted to
have a negligible effect on sediment transport to the east of Hinkley Point.
4.2.2 The piles would cause local hydraulic changes in the tidal flow around each support, but these
are predicted to be of negligible significance and would not require specific mitigation.
4.2.3 The dredged berthing pocket could be subject to increased sediment deposition due to the
alteration of current flows. However, the proposed design of the berthing pocket (i.e. its specific
alignment relative to the tidal flows) has been chosen so that the existing hydrodynamic
conditions promote self-scouring of this dredged area and, therefore, reduce the requirement for
frequent maintenance dredging during the jetty development’s operational phase.
b) Mitigation Measures
4.2.4 The overall design of the jetty structure and other design elements (e.g. the exact positioning of
the jetty, the orientation of the berthing pocket and the number of piles and uprights) have been
specified to minimise environmental impacts.

4.2.5 Where possible, the piling technique to be employed (specific methodologies would be confirmed
by contractors) should minimise the degree of sediment disturbance, through the choice of
access method and type of piling.
4.3 Marine Ecology
4.3.1 The following potential impacts on marine ecological receptors could arise during the jetty
development’s construction phase:
• temporary and permanent loss of sensitive marine receptors;

• physical disturbance of marine receptors due to piling activities at each jetty upright and
access to the foreshore for vehicle and plant, the delivery of materials and the workforce;
• changes in cross-shore and longshore intertidal drainage patterns and associated effects on
Corallina;
• physical disturbance due to dredging around the seaward end of the jetty (including impacts
associated with the re-suspension within the water column of bottom sediments such as
smothering etc.);
• other water quality impacts due to run-off during construction and potentially associated with
other accidents and incidents (particularly spillage and leaks of fuels and oils and possibly
other chemicals, including cement and concrete if it is used in the jetty construction);
• noise and vibration; and
• artificial light disturbance during 24 hour construction works.
4.3.2 During the construction phase, piling, dredging and the use of plant and materials could disturb
the physical environment (and its species and habitats) and drainage characteristics of the
intertidal habitats present. While most species of invertebrates, fish and marine mammals would
not be significantly affected, the red alga species Corallina could be affected by physical
disturbance (i.e. interruption) to the intertidal cross-shore drainage channels where it is present
(see Figure 8); although the jetty’s location has been chosen such that it avoids key areas of
foreshore that support Corallina habitat, that occur more regularly to the east.
4.3.3 During the jetty development’s operational phase, impacts on marine ecology could arise as a
result of maintenance dredging (if required), noise and vibration and artificial lighting.
4.3.4 During the jetty development’s dismantling / restoration, or removal / reinstatement phase (if
required), impacts on marine ecology could arise from loss of and disturbance to intertidal and
subtidal habitat (e.g. due to removal of each jetty upright, access for construction vehicles and
plant) and water quality effects.
4.3.5 Specific mitigation measures are proposed to protect Corallina habitat and the species associated
with it from physical disturbance during the construction and dismantling / restoration phases, or
the removal / reinstatement phase (if required). These include establishment of a narrow working
corridor across the intertidal area to avoid areas of Corallina, where possible, and measures to
ensure that the drainage environment of Corallina is not compromised by piling and other
construction activities.

4.3.6 In recognition of the importance and protected status of the marine environment, a number of
good practice and precautionary measures are proposed to provide additional safeguards. These
include the designation of “no-go” areas and associated buffer zones around all identified
sensitive locations; buffer zones around construction and access sites in foreshore areas;
provision of training for the construction workforce; specific accident and incident response and
cleanup procedures; and the implementation of a monitoring programme.
4.4 Terrestrial Ecology and Ornithology
4.4.1 Drawing upon the results of the surveys and other data gathering, and informed by consultation
with Natural England, the RSPB, Somerset County Council, Somerset Wildlife Trust and West
Somerset Council, the jetty development’s design has been progressively refined to minimise the
adverse impacts on wildlife and, where possible, to deliver benefits. The changes to the scheme
that have arisen as a consequence include:
• avoidance of mature woodland and use of existing field accesses to avoid impacts on
hedgerows;
• implementation of best practice measures to minimise emissions and dust deposition; and
• a simple jetty design that is likely to reduce the potential for bird collisions.
4.4.2 The following potential impacts on ornithology could arise during the jetty’s construction phase:
• adverse effects on intertidal birds resulting from noise generated by the jetty development,
small-scale habitat loss and changes in intertidal plant / animal communities, visual
disturbance due to the presence of the workforce and their machinery, and lighting;
• loss of habitat for and disturbance of breeding birds adjacent to the application site; and
• displacement of passage and wintering birds adjacent to the application site.
4.4.3 Fewer potential impacts would arise during the jetty development’s operation and dismantling and
restoration or, if required, its removal and reinstatement phase, namely:
• adverse impacts on intertidal birds resulting from disturbance caused by ships docking to
unload cargo and from human activity (including dismantling activities), light and noise along
and on route to the jetty; and
• restoration (or, if required, reinstatement) of the site resulting in the creation of habitats,
which subsequently would be available for colonisation by wildlife.
4.4.4 The following potential impacts on barbastelle bats could arise during the jetty’s construction
phase:
• disturbance to foraging or commuting barbastelles due to lighting;

• loss of habitat for foraging, and loss of commuting corridors.
restoration or, if required, its removal and reinstatement phase, namely disturbance to foraging or
commuting barbastelles due to lighting.

4.4.6 Movement of personnel outside of the footprint of works would be restricted and screening of the
jetty approach bridge to reduce the sky lining / disturbance effect from the movement of people on
birds would be implemented. In addition, the construction works on the intertidal area would be
constantly rather than intermittently lit each night through the use of directional lighting so that
light spill is limited and birds can habituate to the light. There is a presumption against blasting
during the earthworks and, in addition, the use of soft start for piling would be used to habituate
birds within the study area to piling noise and prevent a startling / flight effect.
4.5 Water Quality
4.5.1 There is the potential for water quality status to be adversely affected as a result of a range of
activities associated with the jetty development. The impacts that have been identified during the
construction of the jetty may be broadly divided into:
• disturbance of marine sediment and mobilisation of associated contaminants into the Severn
Estuary (e.g. due to dredging of the berthing pocket or scouring around the jetty’s piles);
• discharge of water containing sediment, hydrocarbons and/or concrete leachates into the
Hinkley Point C Drainage Ditch and then into the Severn Estuary (e.g. surface water run-off
from the onshore storage area); and
• discharge of freshwater onto the foreshore where Corallina is present in drainage channels.
4.5.2 During the jetty development’s construction, piling and berthing pocket dredging could disturb
sediment, resulting in increased levels of suspended sediment and potential contaminants in the
water column, followed by subsequent deposition within or over subtidal habitats. However, the
techniques to be employed (specific methodologies would be confirmed by contractors) would be
appropriate to the conditions and have due regard to the avoidance of unnecessary sediment
disturbance (i.e. keeping the dredging footprint to a minimum).
4.5.3 In addition, with respect to freshwater inputs during construction of the jetty, no significant impacts
are predicted to arise in relation to water quality due to measures that would be put in place to
control the quality and volume of discharges into the surface drainage (i.e. the Hinkley Point C
Drainage Ditch) and onto the foreshore and the waters of the Severn Estuary. In addition, the
sensitivity of the local marine water quality conditions to increases in suspended solids is low,
given the existing high background concentrations.
4.5.4 The impacts associated with the operation of the jetty are likely to arise from maintenance
dredging of the berthing pocket, scouring of sediment from the seabed around the jetty’s
infrastructure (e.g. piles and berthing pocket) and freshwater discharges into the marine
environment from the onshore storage area. However, the impacts are predicted to be of
negligible or minor significance. Because of the proposed limited use of vehicles along the jetty
and on the jetty head, and hence the limited risk of potential discharge or run-off of polluting
substances, no drainage measures e.g. separators have been included within the jetty design.
4.5.5 Impacts associated with dismantling and restoration phase and, if required, the removal /
reinstatement phase would be similar to those described for the construction phase, with no
significant impact predicted.

4.5.6 Due in part to the design measures associated with the jetty development (e.g. oil / water
separator and a water management zone for the aggregates storage area), all of the identified
potential impacts on water quality were found to be not significant (i.e. minor and negligible
impacts) prior to implementation of mitigation measures. Nevertheless, mitigation measures
would be adopted on the basis of a precautionary approach to the protection of the environment.
4.5.7 Measures proposed include:
• the adoption of best practice guidance for works in and adjacent to watercourses, as
provided in the Environment Agency’s Pollution Prevention Guidelines (PPGs);
• the implementation of a surface drainage strategy for the onshore areas, including measures
to minimise generation of sediment-laden surface drainage water and potential impacts on
the Hinkley Point C Drainage Ditch (e.g. settlement ponds to reduce suspended solids and oil
interceptors to recover hydrocarbons);
• the provision of Water Management Zones (WMZ) where attenuation and any required
treatment of water quality would be undertaken:
• the development and implementation of a Water and Sediment Management Plan (WSMP);
• the implementation of measures to avoid or reduce sediment and surface water run-off from
land based works;
• ensuring that pile installation plant present a minimal obstruction to tidal flows, thereby
reducing scouring and sediment re-suspension;
• ensuring that the footprint for piles and the berth pocket are a minimum size to reduce the
degree and extent of sediment disturbance; and
• monitoring as detailed in the WSMP, which would form part of the overall Environmental
Management and Monitoring Plan (EMMP).
4.6 Geology and Land Contamination
4.6.1 The following potential impacts on geology could arise and sources of contamination could be
affected during the jetty development’s construction phase:
• loss of exposed rock pavement features / habitats;

• impacts on controlled waters (i.e. on-site groundwater and surface water) could occur
through physical mobilisation (e.g. run-off); and
• risk to the on-site and off-site environment (including the Severn Estuary) could occur in the
event that contamination migrates off-site via uncontrolled dust and wind transport (i.e.
aeolian processes).
restoration phases and, if required, its removal and reinstatement phase, namely:
• spillage or leakages of contaminating liquids such as diesel and hydraulic oil to contaminate
the estuary.

4.6.3 As the foreshore is of geological / palaeontological interest a pre-construction survey to identify

any paleontological finds of scientific importance would be undertaken on the intertidal rock
platform within the footprint of the jetty access road and the area to be impacted by pilling works.
4.6.4 Mitigation measures with respect to water quality are summarised in Section 4.5, whilst mitigation
measures related to dust (air quality) are summarised in Section 4.7 below. Formal mitigation
associated with land contamination would not be required as (stated in ES Chapter 16) there is
no radiological contamination present within the site, nor is there any significant sustained source
of ground gas contamination; soil contamination is considered unlikely and any possible
contamination would be of low risk to the environment.
4.7 Air Quality
4.7.1 The primary air pollution sources during construction (non vehicular) would be those typical of an
industrial construction-site that may cause fugitive dust and particulate matter. Key potential
impacts include:
• airborne dust/PM10 generated by the jetty construction works, which a range of prevailing
wind directions might carry to marine and terrestrial ecological receptors;
• meteorological conditions that may lead to the transport air pollutants generated by on-site
Non-Road Mobile Machinery (NRMM) to both marine and terrestrial ecological receptors
would occur for 60% of the time; and
• atmospheric emissions and subsequent deposition of NOx and SO2 into statutory ecological
designated sites, including the Seven Estuary Ramsar, SPA and SAC.
restoration phases and, if required, its removal and reinstatement phase, namely:
• limited generation of airborne dust/PM10 to marine and terrestrial ecological receptors.
4.7.3 A Dust Management Plan (DMP) would be implemented for the duration of the jetty development
works to minimise the generation of dust. The DMP would fall within the EMMP, and a skeleton
Air Quality Management Plan is provided in the ES Addendum (Appendix 7) that provides details
of fugitive dust management measures. In addition, a Dust Monitoring Scheme (DMS) would be
prepared to detail any associated monitoring responsibilities that would be implemented in order
to ensure that the DMP is being implemented successfully. Best practise guidance measures
would also be carried forward to control on-site exhaust emissions and marine vessel emissions,
while a comprehensive travel plan would be implemented to minimise off-site vehicular
movements during works.

5 SCREENING OF RELEVANT ACTIVITIES AND EUROPEAN SITES
5.1 Introduction
5.1.1 According to Department of Communities and Local Government (DCLG) guidance (Ref. 3), Step
1 of the HRA process is concerned with determining the need for appropriate assessment; that is,
whether the proposed development has the potential to have a significant effect on a European
site.
5.1.2 The MMO Scoping Opinion for the jetty development (Ref. 7) does not explicitly state that the
proposed works have the potential to have a likely significant effect on any of the designated
features of the Severn Estuary European sites. However, the responses of a number of the
consultees to the scoping request (see ES Appendix 5-1, Volume 4) make clear statements
about the potential for the works to impact upon features which form part of the designated
interests of the European sites; these are summarised in Table 2.
5.1.3 EDF Energy’s Environmental Scoping Report for the Hinkley Point C jetty development (Ref. 8)
explained that the location and nature of the works could give rise to potential impacts on the
designated features of the adjacent European sites, and that information to determine the need
for and/or to undertake appropriate assessment would be provided as part of the application for
the works. The jetty development ES and ES Addendum, therefore, provides the information
required to meet this need; which is summarised and cross-referenced in this assessment.
5.2 Information on European sites potentially affected by the temporary jetty development
5.2.1 The Department of Energy and Climate Change (DECC) Habitats Regulations Assessment for
Hinkley Point (EN-6, 2010; Ref. 7) scoped into the screening process all of those European Sites
within a 20km radius of the proposed site for the Hinkley Point C nuclear power station
development. The approach for this strategic assessment was determined on the basis that a
20km radius reflected guidance recommendations, but also took into account that distance is in
itself not a definitive guide to the likelihood or severity of impacts known to arise from
developments. For example, inaccessibility / remoteness is typically more relevant and factors
such as the prevailing wind directions, river and groundwater flow direction all have a bearing on
the relative distance at which an impact can occur. On this basis, two sites (the River Usk SAC
and River Wye SAC) which fell outside of the 20km search area, but which have hydrological
connections to the Severn Estuary designations, were also included in the screening assessment.
5.2.2 In the case of the jetty development, although the application site forms part of the Hinkley Point
C project site, a significant amount of additional information (e.g. survey data, reports) is available
through the EIA process that has enabled detailed consideration of the scale and nature of the
proposed activities in relation to relevant designated areas. The area of search for the HRA has,
therefore, been informed by the outputs from the EIA process.
5.2.3 On this basis, the European sites listed in Table 3 and shown in Figure 2 have been scoped into
the screening process for the jetty development.

Table 2: Key consultee scoping responses related to the designated interests of the European sites
Consultees Points Raised
Marine Management Note: The MMO consulted with Natural England (NE), Environment Agency (EA) and Countryside Council of Wales (CCW) to
Organisation (MMO) form their Scoping Opinion, with their key comments mirroring those provided below in the responses of these organisations,
and thus only additional comments directly expressed by the MMO are provided here.
As various consultees pointed out to the MMO, the site is within and adjacent to areas designated by virtue of their
environmental significance. In order to properly determine the impact on these sites, the EIA will need to look at the effects of
the scheme in combination with other projects in the area. The consultees have suggested other works that should be
considered in this regard and the MMO would expect to see the impacts of these projects and any other relevant works in the
vicinity addressed fully in the environmental statement. Furthermore, given the intention to submit, ahead of the Development
Consent Order application, a separate environmental statement for the temporary jetty, it is vital that the issue of any
cumulative and in-combination effects stemming from the proposed Associated Developments is also properly addressed.
Countryside Council The proposals have the potential to affect Severn Estuary SPA, SAC and Wetland of international importance (Ramsar Site).
for Wales (CCW) The proposals also have the potential to affect the River Usk SAC and River Wye SAC.
The effects of pile driving (or any increase in vibration) on the fish features of the Severn Estuary SAC should be assessed.
Impacts on the fish features of the Severn Estuary SAC from any decommissioning activities producing vibration should be
addressed.
Whilst drilling and pile-driving is not expected to cause much physical disturbance to the seabed, the impacts of increased
vibration on fish species and fish assemblage features of the SAC will need to be considered in detail.

Consultees Points Raised
Environment Agency If dredging and maintenance of the resulting berthing pocket is required. The potential impact of these activities should be
(EA) taken into consideration.
The potential impact of the jetty on the Sabellaria reef and Corallina turf during construction and the operational phase is of
major concern. Assessments must define in detail how this impact has been minimised by the positioning of the jetty, and
construction methods. The management of the delivered cargo, when the jetty is in operation should also be considered.
The cumulative/in combination impacts of the multiple applications, which include the Main Site and the Associated
Development, should be assessed. The assessment must include for example temporal cumulative effect of dredging of the
jetty’s berthing pocket and the thermal plume. The effect on benthic populations that are resettling after dredging and new
pressures felt from repeated discharges.
Awareness of other proposals for example, further development at Oldbury power station site, should be assessed. If a
development consent order is granted this may overlap with the construction phase of Hinkley point. The cumulative impact of
these developments should be included in the assessment. A example of such effects is the potential impact on bottom
dwelling fish, firstly from construction of Hinkley Point, secondly from the thermal plume when operational, followed by the
potential impacts of further development at Oldbury.
Natural England (NE) While the scoping study identifies a possible impact on the SAC/SPA from vibration and noise during the construction and
demolition of the structure there may be a problem associated with its use. Thus, vibrations associated with the running of the
conveyor may be transmitted to the water column and disturb fish populations in the near vicinity. This issue should be taken
into consideration.
It is unclear if the dredged material from the berthing pocket is to be disposed within the SPA/SAC or outside it.
There is a potential for the works to impact on Sabellaria reef or Corallina turfs on the foreshore. Defining how any impact on
these features has been minimised / avoided through location, construction methods and management of the cargoes delivered
should be clearly stated.

Table 3: European sites scoped into the temporary jetty development HRA process
Site Designation Distance from the project area
Severn Estuary SAC Partially within
Severn Estuary SPA Partially within
Severn Estuary Ramsar Partially within
Exmoor and Quantocks Oakwoods SAC 5.8km from the site
5.2.4 The following European sites that are located within 20km of the jetty site have been screened
out of the HRA information:
• The Mendip Grasslands SAC: No potential development influence on Annex I habitats, as the
SAC is located outside the area of any potential effects (direct or indirect), including
emissions (NOx or PM10) to air. Greater horseshoe bats (Annex II species) have been
recorded from the jetty site but are highly unlikely to have ventured from roost sites in the
Mendip Limestone Grassland SAC as this species generally forages within 6km of its roost
sites with maximum foraging distances recorded of up to 8km, and the jetty site is in excess
of 20km from the roost sites within the SAC.
• Hestercombe House SAC: Lesser horseshoe bats for which the SAC has been designated,
have been recorded in the jetty site; however, these individuals are highly unlikely to have
ventured from the roost at Hestercombe House SAC, where a radio-tracking study found the
average foraging radius from the roost was up to almost 2km, with foraging being recorded
up to 4km away, and the jetty site is over 16km away from the SAC boundary.
5.2.5 The point is made in the West Somerset Council Scoping Opinion for the Hinkley Point C site
preparation works (Ref. 8) that the designated features of the River Usk SAC and River Wye SAC
are intrinsically linked to those of the Severn Estuary SAC and that the proposed works could also
have a significant effect with respect to these sites. In this instance the shared features are
species of migratory fish. However, if it can be demonstrated that an adverse effect on the
integrity of the relevant designated features of the Severn Estuary SAC, Severn Estuary SPA and
Severn Estuary Ramsar site would not arise due to the works, then it can also be implicitly
demonstrated that a significant effect would not arise with respect to the designated features of
the other linked European sites; as any effects would be on the same or similar designated
features (i.e. species such as migratory fish or the waterfowl assemblage). Potential effects on
the River Usk SAC and the River Wye SAC are not, therefore, considered directly as part of the
assessment described below, but will be considered if effects arise with regard to the Severn
Estuary that are determined to also have implications for migratory fish (see below and ES
Chapter 10).
a) The Severn Estuary SAC
5.2.6 The Severn Estuary is a SAC designated for its unique and diverse range of estuarine habitats
and migratory fish populations. The SAC designation includes an overarching estuaries feature
as well as subtidal sandbanks, intertidal mudflats and sandflats, Atlantic salt meadow and reef (of
Sabellaria alveolata) and three species of migratory fish (river lamprey Lampetra fluviatilis, sea
lamprey Petromyzon marinus and twaite shad Alosa fallax); which are all defined as both features
in their own right and as sub-features of the estuaries feature.

5.2.7 The conservation objective for the estuaries feature of the Severn Estuary SAC is ‘to maintain the
feature in favourable condition’. The feature will be considered to be in ‘favourable condition’
when, subject to natural processes, each of the following conditions is met:
• The total extent of the estuary is maintained.

• The characteristic physical form (tidal prism/cross sectional area) and flow (tidal regime) of
the estuary is maintained.
• The characteristic range and relative proportions of sediment sizes and sediment budget
within the site is maintained.
• The extent, variety and spatial distribution of estuarine habitat communities within the site
is maintained.
• The extent, variety, spatial distribution and community composition of notable communities
is maintained.
• The abundance of the notable estuarine species assemblages is maintained or increased.
• The physico-chemical characteristics of the water column support the ecological objectives
described above.
• Toxic contaminants in water column and sediment are below levels which would pose a
risk to the ecological objectives described above.
• Airborne nutrient and contaminant loads are below levels which would pose a risk to the
ecological objectives described above.
5.2.8 The conservation objective for the reef feature of the Severn Estuary SAC is ‘to maintain the
feature in a favourable condition’. The feature will be considered to be in favourable condition
when, subject to natural processes, each of the following conditions is met:
• The total extent and distribution of Sabellaria reef is maintained.

• The community composition of the Sabellaria reef is maintained.
• The full range of different age structures of Sabellaria reef are present.
• The physical and ecological processes necessary to support Sabellaria reef are
maintained.
5.2.9 The conservation objective for the three Annex II fish species for which the SAC is designated
(river lamprey, sea lamprey and twaite shad) is ‘to maintain the feature in a favourable condition’.
The feature will be considered to be in favourable condition when, subject to natural processes,
each of the following conditions is met:
• The migratory passage of both adult and juvenile fish through the Severn Estuary between
the Bristol Channel and any of their spawning rivers is not obstructed or impeded by
physical barriers, changes in flows, or poor water quality.
• The size of the population in the Severn Estuary and the rivers which drain into it is at least
maintained and is at a level that is sustainable in the long term.
• The abundance of prey species forming the food resource within the estuary is maintained.
• Toxic contaminants in the water column and sediment are below levels which would pose
a risk to the ecological objectives described above.

5.2.10 In addition, hard substrate habitats (including eel grass beds), the estuary-wide assemblage of
fish species and the assemblage of waterfowl species (for which the Severn Estuary SPA and
Ramsar site are specifically designated) are identified as notable estuarine assemblages which
are an intrinsic part of the estuary ecosystem – these are therefore also covered by the estuaries
feature.
5.2.11 The estuary and its associated biological communities are moderately to highly vulnerable to:
substratum loss; smothering; changes in suspended sediment, water flow rate, wave exposure;
abrasion and physical disturbance; toxic contamination; changes in nutrient loading, thermal
regime, salinity, oxygenation (Ref. 30). Similar vulnerabilities are associated with the other
interest features of the Severn Estuary SAC.
b) The Severn Estuary SPA
5.2.12 The Severn Estuary SPA designation provides protection to the designated bird populations that
are present within the estuary and the habitats that support them.
5.2.13 The Severn Estuary qualifies as a SPA under Article 4.1 of the Birds Directive by supporting the
following internationally important population of a regularly occurring Annex 1 species (i.e.
regularly supports numbers of birds over 1% of the national population):
• Bewick’s swan (Cygnus columbianus).
5.2.14 In addition, the SPA supports internationally important populations of regularly occurring
migratory species (i.e. the SPA is used regularly by 1% or more of the bio-geographical
population of the following migratory species), as follows:
• shelduck (Tadorna tadorna);

• dunlin (Calidris alpina);
• redshank (Tringa totanus); and
• European White-fronted goose (Anser albifrons).
5.2.15 The SPA further qualifies as it is used regularly by over 20,000 waterbirds or 20,000 seabirds in
any one season. The Severn Estuary supported 68,026 individual birds over the period 1998/89
to 1992/93. In addition to the above, the SPA supports national important populations of a
number of waterbirds as listed below:
• wigeon (Anas penelope);

• teal (Anas crecca);
• pintail (Anas acuta);
• pochard (Aythya farina);
• tufted duck (Aythya fuligula);
• ringed plover (Charadrius hiaticula);
• grey plover (Pluvialis squatarola);
• curlew (Numenius arquata);
• whimbrel (Numenius phaeopus); and
• spotted redshank (Tringa erythropus).

5.2.16 With respect to the internationally important populations of waterbirds for which the SPA has been
designated, the specific conservation objective for dunlin, redshank, shelduck, and gadwall is ‘to
maintain their populations and supporting habitats in favourable condition’. Dunlin, redshank,
shelduck and gadwall populations will be considered to be in favourable condition when, subject
to natural processes, each of the following conditions is met:
Conditions of individual SPA interest feature:

• the 5 year peak mean population size for the wintering dunlin population is no less than
41, 683 individuals (i.e. the 5 year peak mean between 1988/9 - 1992/3);
• the 5 year peak mean population size for the wintering redshank population is no less than
2,013 individuals (i.e. the 5 year peak mean between 1988/9 - 1992/3);
• the 5 year peak mean population size for the wintering shelduck population is no less than
• the 5 year peak mean population size for the wintering gadwall population is no less than
330 individuals (i.e. the 5 year peak mean between 1988/9 - 1992/3);
Conditions common to all SPA interest features, unless otherwise stated:

• the extent of saltmarsh is maintained (exception gadwall);
• the extent of intertidal mudflats and sandflats is maintained;
• the extent of hard substrate habitats is maintained (exception gadwall):
• the extent of vegetation with a sward height of <10cm is maintained throughout the
saltmarsh (exception shelduck, gadwall);
• the abundance and macro-distribution of suitable invertebrates in intertidal mudflats and
sandflats is maintained (exception gadwall);
• unrestricted bird sightlines of >200m at feeding and roosting sites are maintained; and
• aggregations of individual SPA bird species at feeding or roosting sites, are not subject to
significant disturbance.
5.2.17 There is no quantitative definition that describes when disturbance of waterfowl within the Severn
Estuary SPA would become significant with regard to the relevant conservation objective. Within
this assessment disturbance is assessed as being potentially significant if it is predicted that it
may result in a detectable decline in the population of any of the birds that are listed as
designated features. The size of the predicted decline is then used, as appropriate, to determine
whether the level of effect is determined to be a significant adverse effect with regard to the
conservation objective.
5.2.18 Before this assessment can be made it is important to understand that the terms ‘disturbance’
and ‘displacement’ cover a number of real world scenarios that have different potential effects on
the body condition, breeding success and/or survival of individual birds.
5.2.19 Disturbance of birds using intertidal habitats results in detectable changes in behaviour. These
are most commonly observed as (from minor to major disturbance) cessation of normal behaviour
(e.g. foraging/loafing/roosting) to stand in a ‘head up’ alert posture, through short distance
movements (on foot or by air) to other areas within an individuals’ usual home range, to larger
distance flights in to areas that are outside of an individuals’ usual home range. The effects of
these reactions on individual birds, and latterly to the population, will differ and will also be

modified by the duration and frequency of the disturbance event and the quality of the habitat
from which they have been displaced.
5.2.20 Birds that are disturbed and react by taking up an alert posture may have their body condition
reduced due to a reduction in the time available to forage or rest. However, it is highly likely that
if the level of disturbance was such that the time spent on alert was to have a detectable effect on
body condition the individual in question is more likely to vacate the disturbed area and would,
therefore, be displaced. Therefore this type of disturbance is not considered to be significant
within this assessment.
5.2.21 Small-scale displacement within an existing home range will lead to a small increase in energy
expenditure due to the walk or flight that is undertaken. However, detectable effects on body
condition due to temporary exclusion from areas of a home range are only likely if the places
being disturbed are considered to be core foraging or roosting sites (i.e. prey rich feeding areas or
secure roosting sites). Temporary exclusion from areas of a home range that are used
infrequently or by small numbers of birds are highly unlikely to result in a detectable population
effect. If core areas are disturbed, the level of effect will be determined by the duration and
frequency of disturbance events; long duration and frequent disturbance could result in the
abandonment of home ranges.
5.2.22 Displacement of birds outside of their usual home range is likely to have greater detrimental
effects on body condition, and hence survival rates, as the ability of individuals to utilise new
areas effectively will be reduced and the level of competition is likely to be greater. In addition the
quality of the alternative areas (with regard to foraging resources, availability of secure roost sites
etc.) may be lower than the original home range. The potential effects due to displacement
outside of home ranges will be moderated by the frequency and duration of the disturbance
event. For example, infrequent disturbance events of short duration are unlikely to have an
effect, whereas frequent yet short duration events could result in a detectable increase in energy
expenditure and a reduction in energy intake.
5.2.23 In this assessment individual disturbance events have not been outlined in detail. This is
because it is not possible to compile a list of all the potential disturbance events associated with
such a construction project (hence broad disturbance categories are identified). In line with the
precautionary principle it has been assumed that for all disturbance events within 250m of the
relevant intertidal areas, all waterfowl will be displaced from Count Sectors 1 – 3 (see Figure 8).
5.2.24 Key ‘supporting habitats’ for the conservation of the designated bird populations are covered by
the SPA designation and include saltmarsh, the adjacent extensive areas of intertidal mud and
sand and rocky shores. All these habitats provide essential food and resting places for the wide
range of wintering and migratory waterfowl.
5.2.25 In relation to vulnerability, the wildfowl assemblage of the Severn Estuary SPA is moderately to
highly vulnerable to: substratum loss and smothering; changes in suspended sediment,
desiccation and changes in emergence regime; changes in water flow rate, wave exposure,
grazing management; noise and visual presence; changes in nutrient loading, salinity,
oxygenation, and Introduction of microbial pathogens.
5.2.26 In relation to the SPA, the list of species set out above reflects the Natura 2000 Standard Data
Form. The following changes have been suggested by the SPA Review (Ref. 9): removal of
European white-fronted goose and gadwall (which no longer meet qualifying levels) and the
addition of passage ringed plover and wintering curlew and pintail. The SPA Review has yet to
be formally adopted although, in practice, recommended additions are treated as SPA species.

c) The Severn Estuary Ramsar Site
5.2.27 The Severn Estuary is also a designated Wetland of International Importance under the Ramsar
Convention. This designation applies to the physical habitats of the estuary and the species that
these habitats support, in particular waterbird populations.
5.2.28 The qualifying interest features of the Severn Estuary Ramsar site are as set out below:
• Criterion 1: qualifies due to immense tidal range (second-largest in world), this affects both
the physical environment and biological communities.
• Criterion 3: qualifies due to its unusual estuarine communities, reduced diversity and high
productivity.
• Criterion 4: qualifies as it is important for the run of migratory fish between sea and river via
estuary. Species include Salmon Salmo salar, sea trout S. trutta, sea lamprey Petromyzon
marinus, river lamprey Lampetra fluviatilis, allis shad Alosa alosa, twaite shad A. fallax, and
eel Anguilla anguilla.
• Criterion 5: qualifies as it supports a waterfowl assemblage of international importance
(1998/99-2002/2003 5 year peak mean was 70,919 waterfowl).
• Criterion 6: qualifies as it regularly supports 1% of the individuals in a population of one
species or subspecies of waterbird:
Species with peak counts in winter - at designation:
o Tundra/Bewick’s swan
o Greater /European white-fronted goose
o Dunlin
o Common redshank
o Common shelduck
o Gadwall
Populations identified subsequent to designation:
o Ringed plover (spring/autumn)
o Eurasian teal (winter)
o Northern pintail (winter)
o Lesser black-backed gull (breeding)
• Criterion 8: qualifies as the fish assemblage of the whole estuarine and river system is one of
the most diverse in Britain, with over 110 species recorded.
d) The Exmoor and Quantocks Oakwoods SAC
5.2.29 The Exmoor and Quantocks Oakwood is a SAC designated for various habitats under Annex I of
the Habitats Directive, including: old sessile oak woods with Ilex and Blechnum in the British Isles
and Alluvial forests with Alnus glutinosa and Fraxinus excelsior. Annex II species associated with
the site include Barbastelle bats (Barbastella barbastellus); Bechstein’s bats (Myotis bechsteinii);
and otter (Lutra lutra).

5.2.30 The relevant conservation objective for the Exmoor and Quantocks Oakwoods SAC is ‘to
maintain, subject to natural change, in favourable condition, the Barbastelle and Bechstein’s
Bats’. The barbastelles population will be considered to be in favourable condition when, subject
• No loss of ancient semi-natural stands;

• Current area of semi-natural woodland to be retained;
• At least the current level of structural diversity maintained;
• Canopy cover present over 50-90% of area;
• A minimum of 4 trees per ha allowed to die standing;
• Signs of seedlings growing through at sufficient density to maintain required canopy cover
over a 10-year period;
• Current length and extent of woodland / moorland scrub edge to be retained;
• No overall loss of open water; and
• Human access to roost area controlled and limited; no significant increase since previous
visit.
5.2.31 The SAC supports extensive tracts of old sessile oak woods in conjunction with heath vegetation.
The woodlands are rich in bryophytes, ferns and epiphytic lichens, the latter often associated with
old pollards, since parts are former wood-pasture rather than the oak coppice that is more
common with this type. In the Barle Valley the woods also occur in mosaic with glades and small
fields and the combination results in good populations of fritillary butterflies and bats.
5.3 Screening to determine potential for the project to influence designated features
5.3.1 On the basis of the known presence and distribution of the designated interests relevant to the
study area and the likely effects of the development (as set out in the ES and ES Addendum and
summarised in Section 4 above), an initial high-level screening exercise has been undertaken to
determine the potential for the project activities to influence the designated features of the
relevant European sites.
5.3.2 Based on the information contained in the ES and ES Addendum, specifically that presented in
ES Chapter 10 (Marine Ecology) and ES Chapter 11 (Terrestrial Ecology and Ornithology) the
activities that have the potential to influence the designated features of the Severn Estuary SAC,
SPA and Ramsar site, and Exmoor and Quantock Oakwoods SAC are:
• the physical footprint of the construction of the jetty and berthing pocket;
• construction disturbance (noise, light, activity, dust) due to the rock extraction, delivery of
materials, and construction and workforce access onshore and along the jetty bridge and
jetty head;
• operational disturbance (noise, light, activity, dust) on the jetty bridge, jetty head and onshore
relating to the delivery and movement of materials;
• underwater noise and vibration from piling of the jetty bridge and jetty head;
• underwater noise and vibration from operation of the conveyor;
• sediment re-suspension during berthing pocket dredging; and
• surface water discharge during soil stripping and rock extraction, and from stockpiles of soil
and rock, to the foreshore.

5.3.3 Tables 4, 5, 6 and 7 present the results of the screening assessment. Table 4 identifies those
interest features where the potential for interaction with the proposed project activities exists.
Features for which there is no potential for interaction are screened out from further assessment.
The removal of features from further consideration at this stage has largely been undertaken on
the basis of distance from the application site, the potential area of influence of the proposed
works and the lack of either direct or indirect impact pathways that could affect the designated
features of the sites in question.
5.3.4 Tables 5, 6 and 7 identify the particular project activities with the potential to affect each of the
features identified in the first stage of the screening process, and how these activities may affect
the identified features, applying the required precautionary test.

Table 4: Designated features with potential for interaction with the jetty development
Interest Feature Site/s Potential For Comment ES Chapter

Interaction with Reference
Project
Estuaries Severn Feature present within the application site; Corallina. 10.4
Estuary
SAC,
Ramsar
Subtidal sandbanks Severn The nearest subtidal sandbank habitat is in excess of 2km to the north of the jetty 10.4
Estuary development and the potential for interaction to occur via identified impact
SAC pathways (direct or indirect) is considered either to be negligible or non existent.
Intertidal mudflats Severn The nearest intertidal mudflats and sandflats habitat is in excess of 1.5km to the 10.4
and sandflats Estuary east of the jetty development and the potential for interaction to occur via identified
SAC impact pathways (direct or indirect) is considered either to be negligible or non
existent.
Atlantic salt Severn The nearest Atlantic saltmeadows habitat is in excess of 3km to the east of the 10.4
meadow Estuary jetty and the potential for interaction to occur via identified impact pathways (direct
SAC or indirect) is considered either to be negligible or non existent.
Reef Severn Area of known Sabellaria reef 500m from application site. 10.4
Estuary
SAC
River lamprey, Sea Severn Migratory fish may be present in waters within the application site and area of 10.4
lamprey, Twaite Estuary potential influence.
shad SAC,
Ramsar

Project
Allis shad, Salmon, Severn Migratory fish may be present in waters within the application site and area of 10.4
Sea trout, Eel Estuary potential influence.
Ramsar
Annex I bird Severn Bewick’s swan only found in the upper Severn Estuary. 10.4
species Estuary
SPA,
Ramsar
Internationally Severn Other than shelduck, all other species are recorded infrequently and/or in small 11.4
important waterbird Estuary numbers (less than 1% of the SPA population) from the frontage within and
populations SPA, adjacent to the application site.
Ramsar
Waterbird Severn Regularly occurring species recorded from the frontage within and adjacent to the 11.4
assemblage and Estuary site include ringed plover and small numbers of curlew and wigeon.
nationally important SPA,
populations Ramsar
Old sessile Exmoor and No potential influence as SAC located outside of the influence any potential site 11.4
oakwoods Quantock construction effects (direct or indirect), including emissions to air, as the increases
Oakwood in these emissions due to the project would be negligible as a result of
SAC atmospheric dispersion over the 5km between the site and feature.
Alluvial forest Exmoor and As above for old sessile oakwoods. 11.4
Quantock
Oakwood
SAC

Project
Barbastelle bats Exmoor and Barbastelles that roost in the SAC could constitute some or all of the Barbastelles 11.4
and Bechstein’s Quantock recorded on the site and surrounding area. Vegetation / habitat loss within the site
bats Oakwood could reduce available foraging habitat for Barbastelles, and lighting could also
SAC disturb their foraging behaviour.
Otter River Wye No potential influence (either directly or indirectly) on otter and their supporting 11.4
SAC and habitat due to the distance from the site, being in excess of 5km.
River USK
SAC

Table 5: Jetty Development - Potential impacts on designated features of the Severn Estuary SAC and Ramsar
Activity Designated features potentially Comment

affected
Estuaries Reef Migratory fish
Construction Phase
Construction The re-suspension and subsequent deposition of sediment during jetty piling and berthing
disturbance (noise, pocket dredging could result in elevated suspended sediment levels that could affect the
light and dust / estuaries feature and potentially any migratory fish species present; whilst deposition of re-
sediment) due to rock suspended sediment has the potential to affect Sabellaria reef habitat.
extraction, delivery of
materials, construction Noise and vibration during construction is not an activity that would affect the reef or
plant and workforce estuaries features and is, therefore, screened out from further assessment in relation to this
?
access onshore and activity.
along the jetty and on
the foreshore, piling of Noise and vibration during piling of the jetty structure and berth pocket dredging could
the jetty bridge and disturb migratory fish species.
jetty head, and
dredging of the Increased light levels in the water column could affect the behaviour of any migratory fish
berthing pocket species present.
The Cardiff Grounds is a licensed disposal site within the Severn Estuary and is not
identified as a location supporting reef habitat; therefore this feature would not be affected.
Disposal of dredged
sediments at Cardiff
Disposal of dredged material at the licensed disposal ground would be undertaken in line
Grounds
with the requirements of the licence and, as such, would not affect the estuaries and
migratory fish features.

affected
Surface water
Surface water run-off during the land-based construction activities, such as soil stripping and
discharge to the
rock extraction, as well as run-off from the stockpiles of soil and rock, would discharge into
foreshore during soil
the estuary, potentially resulting in an increase in sediment and other potential contaminants.
stripping and rock
The increase in suspended sediment or potential contaminant levels could affect the
extraction, and from
estuaries feature and migratory fish species present, whilst deposition of re-suspended
stockpiles of soil and
sediment could result in smothering of the reef feature.
rock
Movement of construction plant and machinery on the foreshore and storage of materials on
Physical disturbance
the foreshore during the construction phase could result in physical disturbance to the
from construction
estuaries feature, notably Corallina habitat (either directly or indirectly, i.e. through
equipment and
obstruction to or alteration of the natural drainage channels). Due to the distance of the reef
materials on the
habitat no impact is expected, and given the nature of the works (when the tide is out)
foreshore
migratory fish species would not be affected.
Operational Phase
The physical footprint Habitat loss or modification resulting from the presence of the jetty and berthing pocket
of the jetty and ? could directly impact on the estuaries and reef interest features, and indirectly on migratory
berthing pocket fish due to the potential impact on the estuaries and reef features.
Alteration to Increased scour or deposition could arise within the estuary as a result of the presence of
hydrodynamic the jetty and berthing pocket, as well as during vessel berthing operations, which could
processes due to the affect the estuaries feature. Potentially the alterations could extend to reef habitat and thus
physical footprint of the could affect the reef feature.
jetty and berth pocket,
berthing operations, No direct effect would arise for migratory fish; however, a secondary effect resulting from the
and maintenance change in hydrodynamic processes could cause an alteration to the benthic food resource
dredging for migratory fish species.

affected
The re-suspension and subsequent deposition of sediment during berthing pocket

Operational maintenance dredging could result in elevated suspended sediment levels that could affect
disturbance (noise, the estuaries feature and potentially any migratory fish species present; whilst deposition of
light, and dust / re-suspended sediment has the potential to affect Sabellaria reef habitat.
sediment) from
activities on the jetty Noise and human activity would not impact on the estuaries or reef features.
bridge, jetty head,
onshore relating to the Noise and vibration during berth pocket maintenance dredging could disturb migratory fish
delivery and movement species.
of materials, and
maintenance dredging Increased light levels in the water column could affect the behaviour of any migratory fish
species present.
Noise and vibration during operation is not an activity that would affect the reef or estuaries
Noise and vibration features and it is, therefore, screened out from further assessment in relation to this activity.
from operation of the
conveyor Noise and vibration during operation of the jetty and conveyor could disturb migratory fish
species.
Surface water run-off from the land-based storage and roads would discharge into the
Surface water
estuary, potentially resulting in an increase in sediment and other potential contaminants.
discharge to the
The increase in suspended sediment or potential contaminant levels could affect the
foreshore during
estuaries feature and migratory fish species present, whilst deposition of re-suspended
operation
sediment could result in smothering of the reef feature.

affected
Dismantling / Restoration (Removal / Reinstatement)
The re-suspension and subsequent deposition of sediment during dismantling / restoration

(removal / reinstatement) of the jetty structure could result in elevated suspended sediment
levels that could affect the reef and estuaries features.
Disturbance (noise,
Noise and vibration during dismantling / restoration (removal / reinstatement) is not an
light, and dust /
activity that would affect the reef or estuaries features and is, therefore, screened out from
sediment) due to
further assessment in relation to this activity.
removal of jetty
structure
Noise and vibration during any activity could disturb migratory fish species.
Increased light levels in the water column could affect the behaviour of any migratory fish
species present.
Surface water run-off during the land-based dismantling and restoration (removal /
Surface water reinstatement) activities, such as soil stripping and rock extraction for removal, as well as
discharge to the run-off from the stockpiles of soil and rock, would discharge into the estuary, potentially
foreshore during resulting in an increase in sediment and other potential contaminants. The increase in
dismantling and suspended sediment or potential contaminant levels could affect the estuaries feature and
restoration works migratory fish species present, whilst deposition of re-suspended sediment could result in
smothering of the reef feature.
Physical disturbance Movement of plant on the foreshore and storage of materials on the foreshore during the
from removal / dismantling / restoration (removal / reinstatement) phase could result in physical disturbance
reinstatement to the estuaries feature, notably Corallina habitat (either directly or indirectly, i.e. through
equipment and obstruction or alteration to the natural drainage channels). Due to the distance of reef
materials on the habitat no impact is expected, though works to remove the piles could result in noise which
foreshore disturbs migratory fish species.

Table 6: Jetty Development - Potential impacts on designated features of the Severn Estuary SPA and Ramsar
Activity Designated features potentially affected Comment
Internationally Assemblage Supporting

important of waterfowl habitat
populations
Construction
Construction disturbance Human activity generated during construction, particularly along the shoreline
(noise, light and movement) and jetty, may cause disturbance to waterfowl and wintering bird species
due to rock extraction, present in the immediate and surrounding area, which could affect SPA
delivery of materials, plant interest features (notably shelduck, wigeon, pintail, curlew, whimbrel, and
and machinery, and ringed plover).
workforce access onshore,
along the jetty and on the Noise generated by plant, machinery, and piling operations during
foreshore, piling of the jetty construction may cause disturbance to waterfowl and wintering bird species
bridge and jetty head, and present in the immediate and surrounding area, which could affect SPA
dredging of the berthing interest features (notably shelduck, wigeon, pintail, curlew, whimbrel, and
pocket ringed plover).
Movement of construction plant and machinery on the foreshore and storage

of materials on the foreshore during the construction phase could result in
Physical disturbance from
physical disturbance to supporting habitat (notably hard substrate), which may
construction equipment and
impact upon the availability of prey items for foraging birds or result in the loss
materials on the foreshore
of area used for roosting; this could affect the SPA interest features (notably
shelduck, wigeon, pintail, curlew, whimbrel, and ringed plover).


populations
Operation
Small scale loss of supporting habitat (notably hard substrate) may impact
The physical footprint of the
upon the availability of prey items for foraging birds or result in the loss of
construction of the jetty and
area used for roosting; this could affect the SPA interest features (notably
onshore elements
Increased erosion or accretion as a result of alteration of hydrodynamic

processes caused by the jetty structure and berth pocket could result in the
Alteration to hydrodynamic
alteration of supporting habitat (notably intertidal mudflats and sandflats, and
processes due to the
hard substrate), which may impact upon the availability of prey items for
physical footprint of the jetty
foraging birds or result in the loss of area used for roosting; this could affect
and berthing pocket
the SPA interest features (notably shelduck, wigeon, pintail, curlew, whimbrel,
and ringed plover).
Human activity along the shoreline and jetty during operation of the jetty and
Operational disturbance conveyor may cause disturbance to waterfowl and wintering bird species
(noise, light and movement) present in the immediate and surrounding area, which could affect SPA
from activities on the jetty interest features (notably shelduck, wigeon, pintail, curlew, whimbrel, and
bridge, jetty head, ringed plover).
conveyor, onshore relating
to the delivery and Noise generated during operation of the jetty and conveyor may cause
movement of materials, and disturbance to waterfowl and wintering bird species present in the immediate
maintenance dredging and surrounding area, which could affect SPA interest features (notably


populations
Human activity generated during dismantling / restoration (removal /

reinstatement) works, particularly along the shoreline and jetty, may cause
disturbance to waterfowl and wintering bird species present in the immediate
and surrounding area, which could affect SPA interest features (notably
Disturbance (noise, light, shelduck, wigeon, pintail, curlew, whimbrel, and ringed plover).
and movement) due to
removal of jetty structure Noise generated by plant and machinery during dismantling / restoration
(removal / reinstatement) works may cause disturbance to waterfowl and
wintering bird species present in the immediate and surrounding area, which
could affect SPA interest features (notably shelduck, wigeon, pintail, curlew,
whimbrel, and ringed plover).
Movement of plant and machinery on the foreshore and storage of materials

on the foreshore during the dismantling / restoration (removal / reinstatement)
Physical disturbance from
could result in physical disturbance to supporting habitat (notably hard
removal / reinstatement
substrate), which may impact upon the availability of prey items for foraging
equipment and materials on
birds or result in the loss of area used for roosting; this could affect the SPA
the foreshore
interest features (notably shelduck, wigeon, pintail, curlew, whimbrel, and
ringed plover).

Table 7: Jetty Development - Potential impacts on designated features of the Exmoor and Quantocks Oakwoods SAC
Activity Designated features Comment

potentially affected
Barbastelle bats
Construction
Physical footprint of the Removal of terrestrial habitats during construction may reduce the foraging habitat available to
land-based works Barbastelles and could affect the Barbastelles population associated with the SAC roost.
Disturbance (light) from

Increased lighting during construction may disturb the foraging and commuting behaviour of
land and shore based
Barbastelles and could affect the Barbastelles population associated with the SAC roost.
construction works
Operation
Disturbance (light) due

Increased lighting during operation may disturb the foraging and commuting behaviour of
land and shore based
Barbastelles and could affect the Barbastelles population associated with the SAC roost.
operations
Disturbance (light) due Increased lighting during dismantling / restoration (removal / reinstatement) works may disturb the
land and shore based foraging and commuting behaviour of Barbastelles and could affect the Barbastelles population
works associated with the SAC roost.

6 ASSESSMENT OF ‘LIKELY SIGNIFICANT EFFECT’
6.1 Assessment of screened project activities on designated features
6.1.1 Where the potential for the project activities to influence the designated features is identified (see
Tables 5, 6 and 7), then further analysis and assessment to determine whether this influence is
likely to constitute a significant effect on the European site, so as to require appropriate
assessment, has been undertaken, again applying the required precautionary approach. This is
presented below in relation to each of the designated sites and defined interest features. Unless
specifically described, for the purposes of the assessment, the designated Severn Estuary
Ramsar interests have been considered together with the relevant designated interests of the
Severn Estuary SAC and / or Severn Estuary SPA. The assessment is presented separately for
the effects of the construction and operational phases of the jetty development and, where
specific effects are identified, also for dismantling or removal of the jetty. The features and
activities covered are those identified through the initial screening process, as presented in Table
5, 6 and 7.
6.1.2 The assessment as to whether project activities could have a ‘likely significant effect’ is
undertaken with reference to the defined conservation objectives for the designated features (see
below). It also takes into account the manner in which the relevant activities are proposed to be
carried out, the mitigating measures proposed, and any conditions or restrictions to which it is
proposed that consent will be given
6.2 Severn Estuary SAC
a) Estuaries Feature (and Ramsar Criterion 1 and 3)
Baseline Environment
Physical Characteristics
6.2.1 The extent of the Estuary feature is 73,678 ha. At Hinkley Point, the MHWS tide elevation is
11.5mCD and MLWS tide elevation is 0.8mCD, giving a tidal range of 10.7m, though the tidal
range reaches 13m at Avonmouth. This macrotidal environment is partly due to the estuary’s
funnel shape which concentrates the tidal wave as it moves up the Bristol Channel and,
consequently, tidal currents reach a maximum of 2.4m/s near Avonmouth. BEEMS (Ref. 10) data
collected in late summer 2008, during an intensive fieldwork campaign directly offshore of Hinkley
Point, found tidal currents to be generally orientated along the main axis of the estuary (i.e. shore-
parallel) (Ref. 10). Offshore current meter moorings (installed in the subtidal region and covering
4 spring-neap cycles) showed that currents reach a maximum velocity of 1.7m/s on springs and
1.4m/s on neaps tides at an offshore monitoring location. The inshore monitoring site showed
peak currents to attain only 1.5m/s on spring tides and 1.0m/s on neap tides. At all locations a
pronounced asymmetry on spring tides was seen, such that ebb currents were stronger than flood
currents with the degree of asymmetry decreasing as neap tides were approached. Residual
currents show a distinct response to meteorological forcing. Winds were seen to reduce and at
times even reverse the non-tidal current component. BEEMS (Ref. 10) reported on the wave
record collected by a Waverider buoy deployed in December 2008. An initial interpretation of the
wave data regarding sediment transport is that, in the region offshore of Hinkley Point, waves will
tend to enhance the tidally-driven transport by increasing bed shear stresses. They are thus
likely to enhance the magnitude of transport rather than greatly influence its direction (Ref. 10). In
contrast, at the coast, waves are likely to drive dominant sediment transport to the east. Wave
action on the intertidal platform would thus enhance along-shore transport of materials primarily to
the east.

6.2.2 The area to the east of the existing Hinkley Point Power Station Complex between Stolford and
Steart Point Beach is characterised by a substantive shingle beach extending for approximately
3.5km, and erosion of this beach has been a chronic problem for many years. It has been
reported (Ref. 11 and Ref. 12) that the natural supply of shingle, generated during the last glacial
retreat, has since been exhausted and that this may be a reason for reduced supply of shingle to
the east.
6.2.3 The wave cut platform at Hinkley Point comprises the cliff units that extend from the cliffs south of
the intertidal zone. A study in 1986 (Ref. 13) reported that shoreline retreat to the west of Hinkley
Point resulting from coastal erosion was at a rate of 0.1 to 0.5m/yr. However, this was based
upon a limited study period of 30 months during which the results could have been sensitive to
short term environmental fluctuations. Moreover, the report did not allow for anticipated rise in
sea level and other climatic changes. Another more recent study covering the location of the
proposed jetty development contained evidence to indicate that the interbedded limestones and
shales of the Blue Lias cliff top have retreated at around 0.13m/yr since 1888, and mean high
water mark by around 0.04m/yr (Ref. 14). Various sources (Ref. 11, Ref. 15 and Ref. 16) indicate
that there has been an increase in the susceptibility of the coastline to wave action and erosion
that is likely to be exacerbated with predicted increases in sea level.
6.2.4 Sediment transport within the intertidal area comprises mud moving as suspended sediment,
sand moving in suspension and as bed load, and gravel and coarser particles moving on the
upper part of the rock platform as bedload. In general, large amounts of mud travel in suspension
past Hinkley Point. These suspended sediments are, however, not expected to accumulate due
to the highly active hydrodynamic conditions. Therefore, mud fraction sediments are unlikely to
interact with the coastal defences to any noticeable degree.
6.2.5 The most obvious evidence of coastal sediment transport at Hinkley Point (coarse grained
sediment) is shown by the ridge of shingle and coarser particles at the crest of the beach
immediately west of the existing seawall protecting the current Hinkley Point Power Station
Complex. The seawall projects out approximately 10m to 20m from the cliff line to the west and it
is likely that, due to the longshore drift of this coarse beach sediment, the accumulation of a wider
shingle beach has occurred. It is assumed that shingle deposits observed along the front of the
existing seawalls at Hinkley Point and to the east of the seawalls was derived from the west and
is being progressively transported east. Over time shingle is transported along the West
Somerset coastline by high energy wave action in an easterly direction driven primarily by
westerly and south-westerly swells resulting from the open fetch of the Bristol Channel to the
North Atlantic (Ref. 17). This transport system is most active in the upper intertidal zone, and
therefore has the potential to be impacted by the structures on the upper intertidal zone.
However, studies undertaken (Ref. 13 and Ref. 17) do not consider the existing seawalls at
Hinkley Point to be acting as barriers to hinder shingle transport around Hinkley Point.
6.2.6 The sediment cover within Bridgwater Bay is dominated by the presence of intertidal mudflats and
sandflats. These Bridgwater Bay sediments are mobile, both in terms of movements within the
bay and changes to the height of these flats over short time scales. Bridgwater Bay is heavily
influenced by the presence of the River Parrett. The channel of the River Parrett turns to an east-
west orientation below the low water mark and meets the Bridgwater Bar offshore of Hinkley
Point. This low water channel disrupts the pattern of muddy sediments within Bridgwater Bay and
the route of the low water channel traverses an area of sand, which overlays the mudflats. Other
features within Bridgwater Bay include Chisel Rocks and Steart Island. The figure presented in
ES Appendix 9-4, Volume 4 shows a conceptual model of the ‘Bridgwater Bay mud patch’ (i.e.
the area of settled mud), showing areas of erosion, stability and sediment accumulation based on
analysis of acoustic records and sediment samples (Ref. 18) reproduced from BEEMS (Ref. 10).

The cliffs at Brean Down to the north of Bridgwater Bay may offer a degree of protection from
erosive tidal currents (Ref. 19) although there are many influencing factors at work.
6.2.7 ABPmer (Ref. 20) report a long residence time for suspended solids material in the Severn
Estuary and upper Bristol Channel area, with little gain or loss from the system. The intertidal
zones are composed largely of relict sediments (Ref. 19), although short term deposits will occur
during calm conditions and as such intertidal mudflats will act as localised, small capacity sinks.
The subtidal zone is the most important sediment sink (Ref. 19) and probably receives as much
as two million tonnes annually, although large discrepancies are to be found in budget estimates
throughout the literature. Table 8 taken from ABPmer (Ref. 20) suggest that the intertidal zone
(saltmarsh and mudflat) forms the largest sediment sink, on an annual basis. Conversely, erosion
of tidal flats represents a major source of sediment to the Bristol Channel. For context purposes,
according to Langston et al. (Ref. 19) the combined total mass of fine sediment present in the
subtidal mudflats, wetlands and in the waterbody amounts to 1.16 x 1010 tonnes.
Table 8: Summary of Sediment Budget Component Estimates (source: ABPmer, 2007; Ref.
20)
Dynamic Element Description Rate of Sediment Load Total

Status
Sources Rivers Fluvial Sediment 1M tonnes/yr From 4.16M

Supply to 5.4M
tonnes/yr
Cliff Erosion 0.06M to 1.3M tonnes/yr
Saltmarsh Erosion 0.1M tonnes/yr

(horizontal)
Mudflat Erosion 2.5M tonnes/yr
Subtidal Erosion 0.5M tonnes/yr
Sinks Saltmarsh (around Accretion 1 to 2M tonnes/yr* 1.05 to 2.06M

Bridgwater Bay) (vertical) tonnes/yr*
Mudflat (Bridgwater Bay, Accretion 1 to 2M tonnes/yr*

Petertone Flat and
Newport Deep)
Transfers Water Body Suspended Estimation varies from 9 30M tonnes

Sediment – 13M tonnes (SP-NP)
and 30M tonnes/yr (SP)
Anthropogenic Aggregate 1.5M tonnes/yr 1.5M

Intervention Extraction tonnes/yr
* Sinks estimate refers to localised areas, rate of accretion in some areas has not been identified.
Note: These figures relate to the Severn Estuary; however the CHaMP boundary extends as far south
as Hinkley Point. There are large differences in budget estimates throughout the literature.

Water Quality
6.2.8 Data for water quality has been based on the Summary of Marine Surface Water Quality Non-
Radiochemical Analysis Results (Campaigns 1-4 including WFD) (Ref. 7) (Volume 4, Section 12,
Part B of the application) and in-situ monitoring carried out in January 2009. The results of the
marine water quality monitoring programme are presented in Appendices 12-1, 12-2, 12-3 and
12-4 (Volume 4). The key findings from the marine water quality monitoring results are
presented in the following paragraphs. All chemicals for which there are assigned WFD EQSs
had average values below the threshold values (see ES Appendix 12-1, Volume 4).
Suspended Solids
6.2.9 The marine waters off Hinkley Point are characterised by high concentrations of suspended solids
with a mean value of 264mg/l and show increasing concentrations with depth. The maximum
recorded value was 1,795mg/l. The high suspended solids concentrations arise from sediment
mobilisation under bed scouring flows associated with the high tidal range and associated tidal
currents. There is correspondingly low water transparency.
6.2.10 There is a significant difference in suspended solid concentrations during neap and spring tide
periods with respective mean concentrations of 185 mg/l and 351mg/l. The higher suspended
solids concentrations under spring tide conditions are associated with higher tidal flow velocities
causing greater mobilisation of bed sediment deposits.
Total Metal Concentration
6.2.11 There was a general trend of increasing mean total metals concentrations (i.e. inclusive of
dissolved and particulate fractions on unfiltered samples) with depth, such that the highest values
were recorded for samples collected from the lower water column. This is likely to result from
metal adsorption to sediment particles which display a corresponding increased concentration
with water depth.
6.2.12 Exceedance of the EQS threshold level for dissolved copper, of 5µg/l, was recorded at numerous
sites across the sampling area on each of the sampling campaigns. Comparison with the
dissolved copper EQS has been made using an annual averaged value. The mean value
calculated from the combined data for all campaigns and at all sampling locations for dissolved
copper was 3.95µg/l and was below the EQS threshold value.
6.2.13 Exceedance of the Maximum Acceptable Concentration (MAC) EQS for dissolved mercury of
0.07µg/l was recorded at a limited number of sites during the sampling campaign. The mean
value calculated from the combined data for all campaigns and at all sampling locations for
dissolved mercury was 0.02µg/l which is below the Annual Average EQS threshold value of
0.05µg/l.
6.2.14 Statistical analysis undertaken for metals (ES Section 12.4) identified that there was spatial
(inshore and offshore) and depth variability for the range of total and dissolved metals that were
analysed. However, statistical analysis of the overall mean values showed that the only
significant difference detected was for total lead for which higher concentrations were recorded
within the inshore sampling area. Overall the data indicate that the water quality conditions, in
terms of dissolved and total metal concentrations, are relatively homogenous in the marine waters
off Hinkley Point.

pH
6.2.15 pH values were typical of seawater with a mean overall value of 7.83 and a range of 7.04 to 8.05
pH units.
Salinity
6.2.16 Salinity varied between the sampling campaigns according to tidal state and the level of
freshwater run-off. The overall mean value was 30.4ppt, thus less than the full strength sea water
of 32 to 34ppt. The range of salinity values recorded during the sampling campaigns was 23.3 to
33.3ppt. The results of the first in-situ sampling campaign (January 2009) indicated relatively low
salinity conditions (in the range of 23 to 25ppt) in the sampling area in comparison to subsequent
campaigns (ES Section 12.4).
6.2.17 There was no evidence of saline stratification from in-situ measurements throughout the depth of
the water column at each sampling location (ES Section 12.4). These data are indicative of a
system that is well mixed by high tidal velocities. Stratification may potentially occur under some
conditions, for example under heat wave conditions or certain tidal states. Such stratification was
not detected within the four sampling campaigns which were conducted across a range of tidal
flood and ebb states.
Dissolved Oxygen
6.2.18 The WFD EQS now includes threshold values for dissolved oxygen for transitional and coastal
waters. For marine waters with salinity lower than 35ppt the ‘high’ category threshold is defined
by a calculated oxygen concentration of (7mg/l – (0.037 x salinity)). The most stringent (and
therefore most precautionary) EQS threshold applicable to this High Status waterbody unit is
calculated by selecting the lowest monitored salinity of 23.5ppt, which produces a threshold value
of 6.13mg/l. Comparison is made to this threshold value using a 5th percentile calculated for the
entire monitoring data set which is 6.40mg/l. Therefore, the dissolved oxygen levels within the
sampling area have a High Status which accords with the current status indicated in the
Bridgwater Bay waterbody description.
6.2.19 As with salinity, there was no evidence of stratification of dissolved oxygen from in-situ
measurements throughout the depth of the water column at each sampling location (ES Section
12.4).
Nitrogen
6.2.20 Under the WFD, the assessment of dissolved inorganic nitrogen status requires a mean winter
concentration in micromoles per litre to be calculated for samples collected between 1 November
and 28 March. Within the present campaign only one sample was collected during this period in
campaign 1 (27 and 28 January 2009). As this result has only been obtained from one monitoring
visit it needs to be viewed with caution when comparing to the WFD EQS for winter dissolved
inorganic nitrogen. The WFD EQS for dissolved inorganic nitrogen in transitional and coastal
waters varies with both salinity and turbidity. Under the WFD criteria the sampling areas included
in the monitoring campaign would be classed as high turbidity (i.e. a mean value greater than
300mg/l) based on the mean suspended solids concentration for the January 2009 sampling
campaign being 494mg/l. The EQS threshold values for ‘high’ and ‘good’ dissolved inorganic
nitrogen status in very turbid waters are 18 and 270µM/l respectively to which comparison of a
99th percentile results value is made. This calculated percentile value for dissolved inorganic
nitrogen in the January 2009 campaign was 130.1µM/l which is between the ‘high’ and ‘good’
status standards.

Organic Compounds
6.2.21 For expected organic discharge chemicals, no results above laboratory minimum reporting values
were recorded for these chemicals at any of the sampling sites across all four sampling
campaigns.
Summary
6.2.22 Comparison of the water quality data for inshore and offshore sampling areas indicates a high
degree of homogeneity when considered as a whole across all sampling sites and campaigns.
Some local spatial and depth variations are evident within data collected for each campaign. The
high degree of homogeneity is likely to be associated with the high tidal flow velocities creating
well mixed water quality conditions in the marine waters off Hinkley Point. The high degree of
water mixing resulting from the strong tidal currents is reflected in the in-situ profiling data, with
readings for dissolved oxygen, salinity and temperature being consistent throughout the depth of
the water column at each monitoring location on each campaign visit (ES Section 12.4 and ES
Appendix 12-4, Volume 4).
6.2.23 Marine water quality parameters exhibited greater significant variability between neap and spring
tide periods than between inshore and offshore sampling areas. This suggests that tidal
conditions may have a greater influence on local marine water quality off Hinkley Point than
spatial variations between inshore and offshore areas. Consequently, the water quality status of
the estuaries feature that potentially could be affected by impacts associated with scheme
activities is the suspended sediment concentrations and levels of contaminants.
Marine Sediment Quality
6.2.24 Sediment type and distribution within the estuarine system are considered to heavily influence the
distribution of contaminants and therefore water quality. A variety of sea bed sediments are
found in the Bristol Channel ranging from clays (or fine grained sediment that is <0.002mm
particle diameter) to pebbles (of greater than 100mm diameter). The high tidal range and
existence of strong tidal currents in particular ensures that the sea bed sediment deposits are
subject to much reworking. Contaminants entering the Severn Estuary and Bristol Channel from
anthropogenic sources may become associated with particulates (in particular the fine fractions)
through adsorption and complexation. For these reasons, the spatial distribution of contaminants
is often associated with the complex sediment processes and sediment distribution patterns
within the Severn Estuary and Bristol Channel.
6.2.25 The distribution and movement of sediment (of all fractions) across the Bristol Channel is highly
complex and the subject of much discussion and debate in the literature. Exposed bedrock
covers extensive sections of the channel’s bed, particularly across the central Bristol Channel.
The tidal flow velocity is an important factor influencing the distribution of sea bed sediment and
respective grain size within the Bristol Channel and large areas of the Bristol Channel are
characterised by thin veneers of sand and gravel that are mobile on the bed. Of particular note
with respect to this assessment is the very high concentration of suspended sediments that are a
characteristic of the Bristol Channel.
6.2.26 Results from Environment Agency surveys undertaken in 2004 indicated a strong linear
relationship between total metal concentrations and total suspended solids concentrations for
copper, iron, mercury, lead, zinc, chromium and nickel. The total metals concentrations in the
water column may therefore be assumed to show variability relating to the tidal cycle with higher
concentrations expected during spring tide periods when suspended solid concentrations are
higher due to mobilisation of bed sediments and reduced settlement under higher flow velocities.

For dissolved metals the relationship with suspended sediments is less clear although elevated
concentrations of dissolved cadmium and iron in the lower water column of Bridgwater Bay have
been reported and associated with re-suspension of particulates (Ref. 21). Similar effects were
suggested in the results of the Environment Agency assessment in 2004 for dissolved iron, zinc
and chromium.
6.2.27 It should be noted that no significant correlation between total metal concentrations and
suspended solids concentrations for any of the metals discussed above was found during the
2009 marine surveys, conducted in the area directly off Hinkley Point. The following provides a
summary of the findings of the chemical analysis of sediments off Hinkley Point, and details are
presented in ES Section 12.4.
Metals
6.2.28 Comparison of data with Cefas Action Levels and Canadian ISQGs found elevated metal
concentrations to be widespread but very few of the metal concentrations recorded would be
considered to be highly contaminated. Metal concentrations were routinely found that were
above Cefas Action Level 1 and the Canadian TEL. None of the average concentrations for any
of the sediment cores were found to exceed either the Cefas Action Level 2 or the Canadian PEL.
6.2.29 At least seven of the sample locations around Hinkley Point (VCJ10, VCJ17, VCJ18, VJC21,
VC33, VCJ6 and VCJ7) were found to show generally decreasing contamination with depth. At
these locations, highest contaminant concentrations were found within the top metre of sediment.
This upper portion of the sediment is known to be highly mobile and constantly reworked by
strong currents within the channel. It may be postulated, therefore, that the level of contamination
that is present in these upper sediment layers may:
• be representative of wider baseline concentrations;

• be the result of contaminant redistribution from elsewhere in the Bristol Channel; and
• if disturbed (via dredging etc.), not be any different to contaminant concentrations that are
mobilised on an almost constant basis within the Bristol Channel.
Polycyclic Aromatic Hydrocarbons (PAHs)
6.2.30 PAH concentrations in the Severn Estuary often exceed ISQG TEL and occasionally PEL criteria
(Ref. 22). The primary source for PAHs in the Severn Estuary is considered to be anthropogenic
(Ref. 22), and large contributions offshore of Hinkley Point are thought to derive from coal dust,
as recently confirmed by BEEMS (Ref. 23).
6.2.31 Elevated concentrations, relative to the Cefas Action Level 1, of all selected PAHs were found in
the surface sediments in the Hinkley Point area but no elevated concentrations were found below
approximately one metre, supporting further the suggestion that surface contamination:
• is representative of wider baseline concentrations;

• is the result of contaminant redistribution from elsewhere in the Bristol Channel; and
• if disturbed (via dredging etc.), would be no different to the contaminant concentrations that
are mobilised during every tidal cycle within the Bristol Channel.

Organotins
6.2.32 Analysis of sediments in dredge disposal sites around the Severn Estuary suggest that there may
be localised reservoirs of elevated TBT concentrations to be found near major conurbations, such
as Newport and Cardiff (Ref. 22). All sediment chemistry results from offshore of Hinkley Point
showed organotin concentrations below Cefas Action Level 1.
Polychlorinated Biphenyls (PCBs)
6.2.33 Comparing average core data from the Hinkley Point area with the sum of 25 congeners Cefas
thresholds, no sampling location was found to contain elevated PCB concentrations. Comparison
with the ICES 7 threshold did find six cores with PCB concentrations above the Cefas Action
Level 1 threshold. Analysis of individual spot sediment samples, which as discussed above is
less appropriate in the context of the silt disturbances anticipated during this project, found
multiple samples in excess of the Cefas Action Level 1. All spot samples with elevated
concentrations were found in the top metre of each core. A single spot sample (1 of 57) was to
have a PCB concentration in excess of the Cefas Action Level 2, this being sampling location
VCJ9. Spot sample VCJ9-1.0m depth (located in the area of the jetty berthing pocket) also
showed relatively high metals, total hydrocarbons (THC) and PAH concentrations and is
considered to be an isolated pocket of relatively high contamination. The levels of contamination
that have been identified at this one spot sample are not considered to be at concentrations that
would merit a difference in management approach. Given that the main contamination by PCBs
was identified to be present in the top 1m of sediment, any mobilisation from surface sediments
as a result of dredging is not expected to have a greater magnitude than the natural mobilisation
under baseline conditions.
Organochlorine Pesticides (OCP)
6.2.34 Generally concentrations were found to be low across all samples. Three individual spot
sediment samples were found to be above the Cefas Action Level 1 and the Canadian ISQG/TEL
for DDT. Further analysis of these individual samples shows that an average concentration
across the same sediment cores exhibits a concentration below the guideline value. No individual
spot samples exceeded the Canadian PEL threshold.
Radiochemicals
6.2.35 The sediment quality survey included radiochemicals. The calculated mean values are presented
in ES Table 12.13 (ES Chapter 12) alongside adopted background data for radionuclides derived
from RIFE reports 9 to 13 (Refs 24 to 28) and fall within the background levels.
Summary
6.2.36 The sediment quality in the estuaries feature that potentially could be affected by impacts
associated with scheme activities contains concentrations of contaminants within the silty
sediments throughout the estuary. The sediment quality within the jetty, berthing pocket and
Hinkley Point area is similar in nature to that elsewhere within the estuary. In addition, the
concentrations of contaminants within the study area, and jetty and berthing pocket, tend to be
present in the upper sediment layers, which are subject to regular mobilisation under tidal flows.

Seabed and Estuary Habitats
6.2.37 There are several major rivers, including the Taff, Usk, Wye, Severn, Avon and Parrett which feed
into the estuary, and influence the salinity regime. Together these rivers tend to produce a
marked east-west salinity gradient and a range of conditions varying from brackish to fully saline,
depending on the season and rainfall, which in turn influences the occurrence and distribution of
habitats and species throughout the estuary and its fringes.
6.2.38 The suspended sediment concentrations in the Severn Estuary are generally exceptionally high.
The turbid environment is a result of strong tidal currents. A survey by Ravensrodd Consultants
(Ref. 29) found suspended sediment concentrations within the Bristol Channel within the range of
less than 100mg/l to approaching 200,000mg/l (fluid mud). Measurements at Hinkley Point (site
H6) indicate a range of suspended sediment of 30mg/l to 900mg/l depending on the tide state.
The combined total mass of fine sediment present in the subtidal mudflats, wetlands, and in the
waterbody amounts to 1.16 x 1010 tonnes (Ref. 19). The suspended sediment load within the
Severn Estuary is estimated at 30 Million tonnes (Ref. 20). However, it should be noted that there
are large discrepancies in budget estimates throughout the literature.
6.2.39 The seabed sediments on the intertidal and subtidal at Hinkley Point are shown on Figure 10-2,
Volume 4 of the ES. The approximate area of the more permanent subtidal sandbanks is
1,300ha and there are approximately 10,440ha of associated ephemeral sandbank. These
subtidal areas play an important role in holding and supplying sediment for other habitats notably
the intertidal mud and sandflats, saltmarshes and reef features and it is likely that subtidal
invertebrate communities play a role as a food resource for some species of the fish assemblage
feature of the SAC and Ramsar Site. The nearest sediments associated with subtidal sandbank
habitat is located several kilometres to the north of the site, whilst the nearest permanent subtidal
sandbank habitat is located slightly further to the northeast (Ref. 30).
6.2.40 The intertidal mudflats and sandflats within the Severn Estuary cover an area of approximately
20,300ha, and are representative of estuarine mudflats and sandflats influenced by strong tidal
streams and extreme silt loading. The nearest intertidal mudflats and sandflats are located to the
east of Hinkley Point A station (Ref. 30).
6.2.41 The saltmarsh habitat within the Severn Estuary covers approximately 1,400ha, and there is a
complicated present day pattern of erosion and accretion of the saltmarshes throughout the
estuary; with some parts appearing to exhibit the effects of coastal squeeze. The nearest
saltmarsh habitat is located to the east of Hinkley Point A station (Ref. 30).
6.2.42 There are patches of intertidal Sabellaria alveolata reef throughout the Estuary; however, the
exact distribution of subtidal reef in the Severn Estuary is unknown. Figure 10-4, Volume 3 of
the application presents the location of known and potential Sabellaria reef features in relation to
the jetty.
6.2.43 There is approximately 1,500ha of hard substrate habitat within the Severn Estuary, consisting of
boulders, rock, mussel/cobble scars, rocky pools and shingle; however, this is located to the east
of Hinkley Point A station (Ref. 30).
6.2.44 The intertidal area at Hinkley Point and fronting the jetty development application site comprises
intertidal rocky ledges with occasional pockets of sediment to the west. This forms part of the
‘estuarine rocky shores’ sub-feature of the Estuaries SAC feature. To the east lie the intertidal
mudflats of Bridgwater Bay and the saltmarsh areas lining the River Parrett Estuary. Notable
features of the intertidal ecology at Hinkley Point include:

• Corallina turf habitats occur on the littoral rock platforms, particularly between the mid to low
foreshore to the west of Hinkley Point (Ref. 31). Cross-shore run-off channels are in cases
heavily colonised by Corallina and are seen as an important contributor to foreshore
biodiversity in the area. Corallina distribution on the foreshore, within the application site, is
shown in Figure 8 (from Volume 3 Figure 10-5 in the ES).
• Intertidal and shallow subtidal aglommerations of the tube-building worm Sabellaria alveolata
occur at Hinkley, notably in front of the existing Hinkley Point A power station.
• The macroalgal assemblage in the rocky shore areas is associated with changes in tidal
height rather than changes associated with a longitudinal gradient (Ref. 32). A reduced
seaweed flora, i.e. low in species richness, is present on both sides of Hinkley Point. The
intertidal seaweed community contains no rare or designated species (with the exception of
Corallina sp. turfs), although the intertidal fucoids and red algae.
• Presence of the mussel Mytilus edulis. Surveys indicate a stable community with low faunal
and floral diversity (Ref. 33 and Ref. 34).
• The dominant macrofaunal species reported from core sampling of the littoral fine mud
substrate to the east of Hinkley Point (Ref. 35) was the bivalve M. balthica and the
polychaete worm Nepthys hombergii. Juvenile gastropods and small spionid polychaetes
were also frequently found within samples.
• Total macrofaunal biomass reported from recent surveys of the intertidal mudflats and
sandflats just to the east of Hinkley Point (Ref. 31) is disproportionately dominated by
relatively few taxa i.e. Macoma balthica 63%, Hediste diversicolor 15%, Hydrobia ulvae 8%.
The most widely distributed taxa were Hydrobia ulvae and M. balthica (each observed at 36
stations).
Assessment of Effects
Construction Phase
IMPACT: The effect on construction plant on physical processes
6.2.45 The construction works would extend to around 15 months duration, with many of the offshore
works occurring in 12 months or less, and would therefore have very limited capacity to influence
the physical characteristics (e.g. tidal prism, hydrodynamics and sediment transport) of the
estuary. The use of a jack-up rig to install the piles for the main jetty structure would have a very
small scale and localised effect on hydrodynamic conditions in the vicinity of the rig. However,
given the small cross-section of the rig legs and the very limited time it would spend in any one
location, it is not expected that it would have any discernible influence upon physical processes.
IMPACT: The re-suspension and subsequent deposition of sediment during jetty construction
6.2.46 The potential impact upon water quality during the construction of the jetty would be associated
with marine sediment disturbance (in the intertidal and subtidal) resulting from the following
activities:
• capital dredging;
• piling activities and other works in the subtidal area, including the movement of associated
construction plant (e.g. jack-up barges); and
• piling activities (drill and drive piling or direct rock driven piling) and other works in the
intertidal area, including the movement of associated construction plant (e.g. piling rigs).

Figure 8: Temporary Jetty Development – Location of the Jetty in relation to Corallina on the foreshore

6.2.47 The majority of sediment disturbance would result from dredging the berthing pocket in the
subtidal area, because this activity has the most potential to increase suspended solids
concentrations during the works and lead to localised mobilisation of sediment contaminants.
Sediment disturbance would, to a lesser extent, result from piling and other works in the subtidal.
In the case of activities in the intertidal, the potential for disturbance would be very limited
because the large majority of the intertidal area comprises exposed wave-cut platforms (i.e. rock
rather than sediment) and working would preferentially occur when the tide is out.
6.2.48 Such potential impacts need to be assessed in the context of the existing baseline conditions of
the Bristol Channel, which are characterised by high concentrations of suspended solids and
highly mobile sediments under strong tidal currents.
6.2.49 Given that the capital dredging needed to create the jetty’s berthing pocket is likely to cause the
greatest disturbance of sediment into the water column, dredging (rather than piling) is the focus
of this assessment. The approximate increase in suspended sediment concentration that would
occur will be dependent upon the exact nature of the dredged silts (e.g. the specific grain size),
the dredging techniques employed, and the current conditions at the time of dredging. The
dredging technique to be used is not known in detail at present because this will be dependent
upon establishing detailed arrangements upon appointment of the dredging contractor.
6.2.50 The following approach has been taken to investigate the potential effect of contaminant
mobilisation on water quality:
• estimate the maximum increase in suspended solids concentration as a result of dredging

activities;
• multiply the maximum contaminant value recorded in sediment cores with the estimated
suspended solids concentration increase to give a total concentration of contaminant
released into the water column;
• use partition coefficients to estimate the proportion of the total concentration of contaminant
that is likely to become dissolved in the receiving water; and
• compare the estimated maximum values of dissolved contaminant in the receiving water with
marine water EQSs.
6.2.51 Information on the effects of dredging from the Environmental Statement for the Bristol Deep Sea
Container Terminal (BDSCT) (Ref. 36) shows that the type of sediment present at the dredging
sites was found to be varied, containing sands through to mud sediment fractions. Focus upon
the fine sediment fractions is appropriate in the context of the jetty development at Hinkley Point
because the smaller grain sizes are those that can have the most potential to accumulate
contaminants at high concentrations. Numerical modelling studies undertaken for the BDSCT
simulated the release of fines into the Severn Estuary from the anticipated capital dredging works.
The maximum predicted, depth averaged suspended sediment concentration above background
levels was found to be between 100-500mg/l.
6.2.52 It is proposed that the upper value of the BDSCT’s (Ref. 36) studies’ predicted maximum range
for suspended solids (i.e. 500mg/l, which is greater than background concentrations) is used as a
proxy value within estimates made for the jetty development. As an upper value, this proxy value
is conservative in nature and should be viewed as such during the consideration of results based
upon it. It should also be compared with the naturally occurring high levels of suspended solids
which are a feature of the Bristol Channel. The mean suspended solids concentration across the
entire 2009 marine water quality sampling programme, in the area offshore of Hinkley Point, was
found to be 264mg/l and the maximum concentration to be 1,795mg/l.

6.2.53 Under normal circumstances, very small proportions of the contaminants associated with
sediment partition into the surrounding water to enter the dissolved phase. This is because many
of these contaminants are ‘hydrophobic’ and remain adhered to the sediment particles that have
been released into the surrounding water. Partition coefficients may be applied to estimate the
proportion of the contaminant that can enter the dissolved phase and, therefore, to estimate the
change in contaminant concentration in the receiving water. The partition coefficients used in
calculations for this assessment are the same as those used in a marine dredging assessment
undertaken by ABPmer (Ref. 37), which are based upon information drawn from WFD EQS data
sheets and from reviews undertaken by WRc in relation to Specified Pollutants (Ref. 38). The
concentrations of metals entering the dissolved phase are generally four or five orders of
magnitude lower than the concentrations associated with suspended sediment (see Table 9).
PAH and PCB compounds have not been subject to partition analysis as these chemicals show a
very high affinity to the sediment particles and, therefore, are unlikely to be mobilised into the
water column on disturbance of sediments.
Table 9: Estimated Maximum Metal Concentrations entering the Water Column and the
Dissolved Phase due to Dredging Induced Sediment Disturbance
Determinand Max Overall Total Conc. in Partition Conc. Entering Background WFD
Conc. Suspension Coefficient Dissolved Mean Conc Marine
(mg/Kg) (µg/l) Phase (µg/l) (µg/l) EQS (µg/l)
Chromium 67 0.0335 191000 1.75E-07 0.02 0.6 AD*
Nickel 59 0.0295 80000 3.69E-07 0.19 20 AD
Copper 51 0.0255 61000 4.18E-07 3.95 5 AD
Zinc 307 0.1535 4860 3.16E-05 39.27 T 40 AD
Arsenic 30 0.015 10000 1.50E-06 2.3 25 AD
Cadmium 1.5 0.00075 130000 5.77E-09 0.00 0.2AD
Lead 141 0.0705 882000 7.99E-08 0.02 N/A
Mercury 0.67 0.000335 100000 3.35E-09 0.02 0.07 AD
Notes: A = Average; D = Dissolved; T = Total; * = chromium VI
6.2.54 After application of partition coefficients, the values of metal contaminants are orders of
magnitude below the annual marine EQSs set by the WFD and the Dangerous Substances
Directive. Again, it should be noted that the total concentrations in suspension as calculated
above are based upon a worst-case scenario for which the assumptions are extremely
conservative. In particular, it is not realistic that all the sediment disturbed in one dredging
episode would be contaminated to the maximum concentration value that has been used in the
calculations.
6.2.55 As set out above, the magnitude of impact associated with capital dredging would be dependent
on the dredging technique adopted by the appointed contractor. However, given that dredging
would only be undertaken in a localised area of 160m in length by 27m in width and to a shallow
depth of 3.5m, the magnitude of the impact has been assessed as low. Collected arisings from
piling activities would be appropriately disposed off-site at the Cardiff Grounds licensed dumping
ground. The magnitude of impact associated with other construction activities, such as piling,
would be much smaller than dredging.

6.2.56 Sediment disturbance would occur over a local scale, and would be temporary in duration.
6.2.57 Although dredging could occur in relatively close proximity to the low water mark and the
Corallina turf areas of the lower shore (see Figure 8), given the naturally high suspended
sediment concentrations in the water column and the tidal regime, any increase in suspended
sediment concentrations would be slight and likely to be advected by the tides. Overall, therefore,
the magnitude of any sediment settlement on Corallina associated with dredging and deposition
of re-suspended sediment is predicted to be very low (i.e. it is expected that the receptor would
experience little or no degradation and sediment deposition is likely to be within the range of
currently experienced in the study area).
IMPACT: Surface water run-off and subsequent increase in suspended sediment, alteration to
salinity, or discharge of contaminants during the land-based construction activities
6.2.58 The volumes and lateral extent of freshwater that would be discharged to the upper shore could
impact upon the intertidal ecology during low tide periods by causing an influx of water of a
different quality and salinity (see Figures 3, 4 and 5, in ES Appendix 10-1, Volume 4).
Inundation by increased levels of freshwater (due to increased run-off due to land use change)
has the potential to cause an adverse impact upon local intertidal communities through, for
example, osmotic stress. Furthermore, a high concentration of suspended sediment in the
discharge water (which would arise due to land clearance) also has the potential to smother
intertidal Corallina turf and other organisms sensitive to such effects.
6.2.59 With regard to the intertidal rocky shore community as a whole at Hinkley Point, the adaptation
and tolerance of the species present to rapid and significant changes in salinity (e.g. as
associated with rainfall) during daily tidal exposure should be noted. It is not predicted, therefore,
that the discharge, which would also quickly infiltrate into the upper shore sediments, would be
likely to significantly influence the composition of the existing foreshore communities. It should
also be borne in mind that the discharge would effectively replace the existing discharge to the
foreshore from the unnamed watercourse / drainage ditch that currently provides some drainage
to the northern part of the application site (see ES Chapter 13). However, given that there is
potential that the land clearance could result in potentially significant increases in suspended
sediment and freshwater volumes, this could affect the estuarine communities in the intertidal
zone and to a much lesser extent the estuarine communities in the subtidal zone. Because the
volume increase of potential freshwater discharge and the likely suspended sediment of the
discharge water compared to present cannot be quantified, a significant impact on estuarine
communities, particularly Corallina, cannot be ruled out without mitigation.
6.2.60 Land contamination in the vast majority of the jetty development site is considered unlikely.
Chemical testing identified that concentrations of contaminants found did not pose a significant
risk to human health or other receptors, with the exception of asbestos identified in one sample,
which is currently being remediated as part of the (consented) Hinkley Point C enabling works. A
summary of the results and risk assessment relating to the chemical testing are included in ES
Section 16.4. Where testing was not undertaken, desk-based assessment identified that the
area has remained as undeveloped agricultural land and, therefore, the potential for significant
contamination to be present is considered to be very low (see ES Section 16.4). Testing
identified that developed land at the eastern end of the jetty site could contain contaminants such
as asbestos. Hence this area is currently being remediated and asbestos and any other
contaminants removed as part of the Enabling Works; this work will be completed prior to the
commencement of the jetty development. Therefore, the magnitude of the presence of
contamination with the potential to impact controlled waters via leaching in the proposed rock
extraction area is very low; and any impact to controlled waters is considered to be unlikely.

6.2.61 Given this, the dispersal of contaminants into the estuary from surface waters is considered
unlikely during construction. However, there is a potential for contaminants to be associated with
run-off from construction materials or accidents and incidents, including spillages and leaks of
fuels, oils and other chemicals. Because these are accidental or incidental events the volume
and concentrations and types cannot be quantified and, therefore, a significant impact on
estuarine communities, particularly Corallina, cannot be ruled out without mitigation.
6.2.62 Consequently a number of mitigation measures have been identified in relation to avoiding,
wherever possible, potential pollution from surface water or as a result of accidents or incidents.
This includes measures that minimise the potential volume of discharge and contaminants and
measures to prevent them being discharged into the estuary. A summary of measures proposed
is presented later on in this section. Furthermore, it is assumed that, where relevant, discharges
to the water environment would be subject to the agreement of a discharge consent with the
Environment Agency and that potential impacts would be avoided or reduced such that
discharges to the Hinkley Point C Drainage Ditch and into the estuary would be managed at
attenuated run-off rates (including suspended sediment, and with any potential contaminants
removed), which would result in no change from the existing situation and that the mitigation
measures proposed would be able to meet that requirement. The measures that would be
implemented to avoid any potential impact are summarised in paragraphs 4.5.7 and 6.2.97 and
ES Section 12.6, and include the use of Water Management Zones, a Water and Sediment
Management Plan (as part of the EMMP), an Incident Response Plan, and other site measures.
Consequently, as no increase in freshwater discharge volumes, suspended sediment and
contaminant levels would occur, no effect would be expected on estuary features (including
Corallina) within the intertidal and subtidal zones from surface water derived sources.
IMPACT: Movement of construction plant and machinery on the foreshore and storage of
materials on the foreshore during the construction phase
6.2.63 Piling and works in the upper foreshore would result in plant movement above mean high water,
on the rocky wave cut platform (hard substrate habitat), over a length of approximately 400m and
working width of 20m (i.e. a total area of 8,000m2). These works would not take place when the
rocky shore is submerged and, therefore, no temporary reduction in estuary habitat area would
occur during the works in the intertidal zone.
6.2.64 The intertidal habitats which would be affected by construction activities consist predominantly of
a rocky wave cut platform (with Corallina described below), and the rocky shore itself is not
considered to contribute substantially to the maintenance of the qualifying features of the Severn
Estuary SAC and Ramsar site. The biotopes potentially affected by jetty construction activities
contain no known protected species of intertidal invertebrates. Given that the overall area of
estuary habitat within the Severn Estuary is approximately 736,780,000m2, and that the potential
disturbance of a maximum area of approximately 8,000m2 of rocky shore intertidal habitat within
the estuaries feature, this negligible effect (i.e. less than 0.001% of the estuaries feature) would
not alter the extent, variety and spatial distribution of estuarine habitat communities. The hard
substrate habitats within the SAC cover an area of 15,000,000m2 and, therefore, in relation to this
intertidal habitat feature, the maximum disturbance would constitute 0.05% of this feature. While
the hard substrate habitats are not considered to substantially contribute to the maintenance of
the estuary qualifying feature, the presence of Corallina is of interest and the impacts on it are
described below.

6.2.65 The movement and operation of plant and personnel along the foreshore for the pile driving
during the jetty construction is likely to disturb the Corallina channels. That is, the channels
supporting Corallina swards may become blocked during construction due to the presence of
piles or disturbed due to construction plant, the deposition of construction materials or
modifications to allow the passage of personnel, plant and vehicles. Any blockage of such
channels could disrupt the natural longshore and cross-shore drainage patterns of the foreshore.
In turn, this could influence the locations in which Corallina swards can develop or continue to
flourish; therefore, a reduction in longshore and cross-shore drainage could reduce Corallina
biomass on the foreshore. However, this effect would be short-term or even temporary and, once
the activity is completed, it is expected that Corallina would recover.
6.2.66 The jetty is located at the far western end of the extent of the known distribution of Corallina (see
Figure 8) and, as indicated above, although it does cross over the channels supporting Corallina
its footprint has been designed to fall between, rather than over, mapped areas of the cross-
channel features. Overall, an area of less than 4% (4,500m2) of the total Corallina biotope area
(c.118,800m2) within the vicinity of Hinkley Point would be present within the footprint of the
works. This represents a relatively small area that avoids the more interesting cross-shore
features and leads to the conclusion that, even if all of the Corallina biotope within this area were
disturbed (which is highly unlikely), this change would be of very low magnitude.
Operational Phase
IMPACT: Loss of or alteration to estuary feature and habitats
6.2.67 The installed piles, given their proposed width and number, would result in the reduction in
estuary seabed habitat area of no more than 320m2 (within the intertidal and subtidal zones).
Given the extremely large extent of the estuaries feature (c. 736,780,000m2), and given the
natural variation in extent of the habitat due to erosion and accretion and changes in the tidal
regime, this amount of estuary seabed habitat loss (equating to around 0.00004%) would be
negligible. Furthermore, the subtidal fauna in the area does not comprise any notable species,
with low species diversity and high dynamic activity in this area.
6.2.68 In the intertidal zone, the presence of jetty piles would result in the reduction of also significantly
less than 320m2 of intertidal rocky shore habitat. Given that the hard substrate habitats within the
SAC cover an area of 15,000,000m2, this would constitute a loss of no more than 0.002% of this
feature (as a worst case). The hard rocky substrate habitat is not considered to contribute
substantially to the maintenance of the qualifying features of the SAC. However, the potential
effect on Corallina could be more significant.
6.2.69 Corallina is sensitive to changes to drainage patterns and because the presence of Corallina is
associated with extensive longitudinal and cross-shore drainage pathways across the shore, the
potential exists for a more widespread impact as a result of any interruption to the drainage
features. However, the jetty has been positioned to avoid the more significant cross-shore
drainage features that maintain Corallina turf, and so wider scale impacts to the longshore
features are unlikely to arise. Consequently, any medium-term loss of Corallina due to footprint of
the jetty would be less than the maximum footprint of 320m2, or less than 0.3% of the extent of
Corallina within the estuary.
6.2.70 The berthing pocket would not result in a loss or reduction in the estuaries tidal prism, as it would
only result in a local change in the bed level of the estuaries feature, and the dredged material
would be deposited within the estuary at the licensed disposal site at Cardiff Grounds. The
presence of the jetty piles would not result in any measurable alteration to the tidal prism or the
tide levels within the estuary, given the insignificant volume loss in relation to the estuary.

6.2.71 The biotopes potentially affected by the berthing pocket contain no protected species and cover
an area of 736,780,000m2 within the Severn Estuary, so disturbance to subtidal habitat due to
dredging over an area of circa 8,000m2 (160m x 27m and including a 1 in 5 slope) is predicted to
cause an effect of very low magnitude, affecting less than 0.001% of the estuarine habitat. As
described in ES Section 10.5, subtidal invertebrates are assessed as being of low value in this
environment.
6.2.72 Given the very small cross-sectional influence of the berthing pocket and the jetty structure in
relation to the estuary at this location, there would no identifiable change in the rates of tidal flow
within the estuary. Any change would be local in scale and within the existing range of flow within
the estuary; therefore no change to the tidal regime is predicted.
6.2.73 Sediment size and the sediment budget potentially could be affected by the removal of sediment
from the berth pocket (expected to be in the region of 24,885m3). However, the dredge arisings
are to be deposited elsewhere within the Severn Estuary (at a licensed site at Cardiff Grounds)
and, therefore, the sediment budget would remain unchanged.
IMPACT: Increased scour or deposition as a result of the presence of the jetty and berth pocket
6.2.74 The jetty piles would provide a potential impediment to flow and thereby sediment transport, but
would be small in scale given that the jetty has been aligned across the direction of tidal flow and
an open piled jetty structure (i.e. as opposed to a mass structure) is proposed. The pile
diameters and spacings represent less than a 4% obstruction of the cross-section across the tide.
While there probably would be small-scale local eddies shed off the piles, these would tend to be
of the order of three to four times the width of the piles and would usually extend for only a few
radii downstream. Any impacts are therefore expected to be highly localised around each
obstruction. Greater changes to hydrodynamics may be anticipated around the jetty head where a
greater density of piles would be present and interference patterns between deflected flows may
develop. The spatial extent of scour associated with the jetty structure may be calculated from
the scour depth calculated by BEEMS (Ref. 39) (i.e. 1.3m for a paired pile) and the angle of
repose for different sediment types (Ref. 40). Based on the calculations reported in ES Section
9.5 and assuming the worst-case repose angle of 26 degrees for loose non-cohesive fine sand,
this equates to a radial scour extent of 2.7m for each paired pile. The predicted number of piles
required for the jetty components (jetty bridge, jetty head etc.) are estimated in ES Chapter 6, but
calculations assumed that a maximum number of 180 piles would be installed for the entire jetty.
By adopting a conservative approach (i.e. assuming loose non-cohesive fine sand, paired jetty
piles and no overlap of spatial scour between piles), the total spatial area affected by marine
sediment scour from the presence of the jetty is estimated to be 2,061m2. Consideration of this
area, relative to the spatial scale of subtidal sediment deposits in the area off Hinkley Point is
taken into account in the determining the magnitude of the potential scour impact. Calculations of
the spatial area of scour do not take account of time and it is, therefore, assumed that the
predicted scour area is constant throughout the lifetime of the jetty structure.
6.2.75 The true extent of scour would depend on the exact sediment type (which will not be
characterised as fine sand), the area of scour overlap between piles and the localised distribution
of sediment (i.e. if there are areas of exposed rock such as in the significant majority of the
intertidal area, then there would be no scour in these areas).
6.2.76 Given the extremely large extent of the estuaries feature (c. 736,780,000m2), and given the
natural variation in extent of the habitat due to erosion and accretion and changes in the tidal
regime, this amount of estuary seabed habitat alteration (equating to around 0.0003%) would be
negligible. Furthermore, the subtidal fauna in the area does not comprise any notable species
due to the low species diversity and high dynamic activity in this area.

6.2.77 In the intertidal zone, there is limited sediment and it is highly mobile during the tidal cycle;
consequently, no effect would be expected to arise.
6.2.78 The vessel berthing pocket may lead to relatively small scale hydrodynamic changes due to
localised changes in seabed bathymetry that may alter patterns of sediment scour and deposition,
exerting an influence over a wider area on tidal and near-bed wave-induced currents than the
piles. However, it would be located in the subtidal region where a highly dynamic sediment
movement regime is present and, therefore, a tolerance to change exists. On this basis the
magnitude of the effect related to the construction of the berthing pocket and the resulting
changes to the hydrodynamic regime is assessed as low (ES Section 9.5).
6.2.79 Moreover, given the extremely large extent of the estuaries feature (c. 736,780,000m2) and the
natural variation in extent of the habitat, the effect on the feature would be negligible.
IMPACT: The re-suspension and subsequent deposition of sediment during jetty operation
(maintenance dredging)
6.2.80 A potential impact upon water quality within the estuary during the operation of the jetty is
associated with marine sediment disturbance resulting from the following activities:
• Maintenance dredging; and

• Scouring of sediment from the seabed around the jetty’s infrastructure (e.g. piles and
berthing pocket).
6.2.81 The majority of sediment disturbance would result from maintenance dredging of the berthing
pocket because this activity has the most potential to increase suspended solids concentrations
and lead to localised mobilisation of sediment contaminants.
6.2.82 The potential impact on water quality can be determined with reference to the assessment of
sediment disturbance and contaminant mobilisation during construction (i.e. capital dredging and
piling works). This assessment, as described above, concluded that the likely values of metal
contaminants mobilised into the marine environment due to sediment disturbance by dredging
would be orders of magnitude below the annual marine EQSs set by the WFD and the Dangerous
Substances Directive. Accordingly, sediment disturbance and contaminant mobilisation due to
maintenance dredging and scouring around the jetty piles would also result in a change to water
quality that would be orders of magnitude below the annual marine EQSs set by the WFD and the
Dangerous Substances Directive (i.e. highly unlikely to lead to any adverse impact on water
quality), even in the event of a sustained requirement for maintenance dredging (should this
arise). A change to the water quality status of the estuary would not, therefore, occur.
6.2.83 Given the highly mobile nature of the seabed sediments during the tide states, no smothering
effect would be expected that would result in a noticeable adverse effect on the subtidal habitats
and fauna.
salinity, or discharge of contaminants during the land-based operational activities
6.2.84 Freshwater (i.e. surface water run-off) would drain from the onshore storage area and be
discharged into the Hinkley Point C Drainage Ditch and, ultimately, to the foreshore. There is a
potential that the volumes of freshwater and suspended sediments discharged into the estuary
could increase above the current discharges. Further drainage of freshwater may also be
expected from the foreshore service road which has no developed drainage system. Surface
drainage will be dispersed through lateral soakaway although the volumes from this source are

expected to be very low. Given that potentially significant increases in suspended sediment and
freshwater volumes could arise, these could affect the estuarine communities in the intertidal
zone and to a much lesser extent the estuarine communities in the subtidal zone. If there were
inundation of freshwater over parts of the mid-lower foreshore where Corallina and salinity
sensitive communities are present, then some loss of population might be expected. The extent
of any potential loss is difficult to quantify. However, it is considered that the nature of the
discharge and the extent and distribution of communities over the foreshore suggest that any
such loss would not be of significance.
6.2.85 There is also a potential for run-off waters to contain elevated concentrations of petroleum
hydrocarbons derived from mechanised plant used in the operation of the jetty development.
Run-off of hydrocarbons, particularly from road drainage, may have a deleterious effect on the
water quality status of receiving waters. There is also a potential for contaminants to be
associated with run-off from stored materials or derived from accidents and incidents, including
spillages and leaks of fuels, oils and other chemicals. Because these are accidental or incidental
events the volume and concentrations and types cannot be quantified and, therefore, the risk of
an impact on estuarine communities, particularly Corallina, cannot be ruled out (without
mitigation).
6.2.86 As mentioned in relation to construction impacts (see paragraph 6.2.62), a significant number of
mitigation measures have been identified in relation to avoiding (wherever possible) potential
pollution or discharge effects from surface water, or as a result of accidents or incidents, in
addition to measures that minimise the potential volume of discharge and contaminants and
provision of measures to prevent them being discharged into the estuary. A summary of these
measures is presented later on in this section (see paragraph 6.2.97). Furthermore, it is
assumed that, where relevant, discharges to the environment would be subject to the agreement
of a discharge consent with the Environment Agency and that potential impacts would be avoided
or reduced such that discharges to the Hinkley Point C Drainage Ditch and into the estuary would
be managed at attenuated run-off rates (including suspended sediment, with any potential
contaminants would be removed), which would result in no change from the existing situation (the
mitigation measures proposed would be able to meet the requirement). Consequently, as no
increase (in freshwater discharge volumes, suspended sediments and contaminants) would
occur, no effect would be expected on estuary features (including Corallina) within the intertidal
and subtidal zones from surface water derived sources.
Dismantling and Restoration (Removal / Reinstatement)
IMPACT: Re-suspension and deposition of sediment during jetty dismantling
6.2.87 Compared to capital dredging during the jetty’s construction and maintenance dredging during the
jetty’s operation, sediment disturbance would be small in scale as a result of infrastructure
removal activities and other works in the subtidal areas. In the case of activities in the intertidal
areas, the potential for disturbance would be very limited because the large majority of the
intertidal area is comprised of exposed wave-cut platforms (i.e. rock rather than sediment) and
working would preferentially occur when the tide is out.
6.2.88 The potential impact on estuary water quality can be determined with reference to the
assessment of sediment disturbance and contaminant mobilisation during construction (i.e.
capital dredging and piling works). This assessment, as described above, concluded that the
likely values of metal contaminants mobilised into the marine environment due to sediment
disturbance by dredging would be orders of magnitude below the annual marine EQSs set by the
WFD and the Dangerous Substances Directive. Accordingly, sediment disturbance and
contaminant mobilisation due to jetty dismantling would also result in a change to water quality

that would be orders of magnitude below the annual marine EQSs set by the WFD and the
Dangerous Substances Directive (i.e. highly unlikely to lead to any adverse impact on water
quality).
6.2.89 The magnitude of impact associated with jetty dismantling would be dependent on the techniques
adopted by the appointed contractor but, given the limited amount of plant likely to be working in
the subtidal area and the limited potential for sediment disturbance in the intertidal area, would be
smaller than that associated with dredging (during construction and operation) and would not
result in any change to the water quality within the estuary.
6.2.90 Given the highly mobile nature of the seabed sediments, no smothering effect would be expected
that would result in a noticeable change in subtidal habitats and fauna.
IMPACT: Disturbance to habitats due to dismantling of the jetty and construction plant and
machinery on the foreshore
6.2.91 Dismantling works in the upper foreshore would result in plant movement above mean high water
on the rocky wave cut platform (hard substrate habitat), over a length of approximately 400m with
a working width of 20m (i.e. a total area of 8,000m2); which is similar to the construction phase.
These works would not take place when the rocky shore is submerged and, therefore, no
temporary reduction in estuary habitat area would occur during the works in the intertidal zone.
6.2.92 The intertidal habitats which would be affected by construction activities consist predominantly of
a rocky wave cut platform (with Corallina described below), and the rocky shore itself is not
considered to contribute substantially to the maintenance of the qualifying features of the Severn
Estuary SAC and Ramsar site. The biotopes potentially affected by jetty dismantling and
restoration (removal and reinstatement) activities contain no known protected species of intertidal
invertebrates. Given the overall area of estuary habitat within the Severn Estuary is
approximately 736,780,000m2, and that the area of the potential effect would be a maximum of
8,000m2 of rocky shore intertidal habitat (within the estuaries feature), this negligible change (i.e.
effecting less than 0.001% of the estuaries feature) would not alter the extent, variety and spatial
distribution of estuarine habitat communities. The hard substrate habitats within the SAC cover
an area of 15,000,000m2 and, therefore, in relation to this intertidal habitat feature, the maximum
area of effect would constitute 0.05% of this feature. The hard substrate habitats are not
considered to substantially contribute to the maintenance of the estuary qualifying feature,
however, the presence of Corallina which is of interest and the predicted impacts on it are
described below.
6.2.93 The movement and operation of plant and personnel along the foreshore for dismantling of the
jetty and cutting out the jetty piles could disturb the Corallina channels. That is, the channels
supporting Corallina swards may become blocked during dismantling and restoration (removal
and reinstatement) due to disturbance from construction plant, the deposition of materials or
modifications to allow the passage of personnel, plant and vehicles, and possible blockage or
alteration to drainage channels due to removal of the piles. This is likely to create disturbance to
the longshore Corallina channels close to the jetty. However, even if the dismantling works were
to extend further than 20m from the alignment of the jetty itself, this suggests that, in total, an
area of less than 4% of the Corallina biotope would be present in the footprint of the works.
Similar to the construction phase, this represents a relatively small area and indicates that even if
all of the Corallina biotope within this area were disturbed, which is highly unlikely, the change
would be of a low magnitude.

6.2.94 Although the more important cross-shore features are to be avoided, areas of Corallina are
present within the longshore channels on the foreshore near the areas of proposed jetty
dismantling / restoration (removal / reinstatement). The dismantling (removal) of the piles
themselves has the potential to damage channels that maintain Corallina and to damage or
change the measures put in place to maintain water flow across the foreshore. The scale of the
impact would be the same as the habitat loss identified in paragraph 6.2.66 above and,
therefore, a significant effect would be unlikely to occur due to the low magnitude of disturbance
on the Corallina community and its short-term nature.
salinity, or discharge of contaminants during dismantling and restoration activities
6.2.95 Similar to construction and operation, the dismantling or removal of the jetty development has the
potential to result in the run-off of rainwater and potential contaminants from plant, materials and
sediment mobilisation to the intertidal and subtidal zones (see ES Section 12.5). Contaminants
potentially could be associated with spills and leaks of fuels, oils and other chemicals. However,
as for the construction and operational phases, discharges to the environment would be subject
to the agreement of discharge consent with the regulators, and a dedicated WMZ would be used
to manage the discharges from the onshore storage area to greenfield run-off rates. Given that
discharges would be managed via the WMZ at greenfield run-off rates, this would present no
change from the existing situation (ES Section 12.5) and no effect would arise on estuary
features in terms of changing salinity, suspended sediment levels and associated smothering due
to deposition, or increases in concentrations of potential contaminants.
Mitigation Measures
6.2.96 The jetty has been designed such that it would have the least possible impact on the foreshore
and the marine environment. Good working practices throughout the jetty construction and the
implementation of mitigation measures to minimise effects on marine water quality and marine
ecology would reduce the level impact associated with the scheme. An EMMP for the jetty (see
ES Appendix 26-1, Volume 4) summarises the mitigation measures aimed to protect the marine
environment and the EMMP is designed to ensure implementation of these measures. The
EMMP would also ensure that if any adverse effects are identified during monitoring or
inspections, there would be appropriate corrective actions implemented to rectify these effects
and prevent them from happening in the future.
Mitigation measures to minimise and avoid water quality effects
6.2.97 A large number of avoidance and mitigation measures have been identified in order to protect the
marine environment from adverse effects, and these are identified in detail in ES Section 12.6
and cover:
• The requirement for a discharge consent which would provide controls regarding the
discharge of sediment and substances;
• Discharges to the Hinkley C Drainage Ditch would be made following attenuation to
greenfield run-off rates and treatment within the WMZs;
• The adherence to Pollution Prevention Guidance;
• The use of oil interceptors in all site drainage, though not along the jetty itself;
• A number of (surface) sediment reduction measures identified within a Water and Sediment
Management Plan (which will be implemented as part of the EMMP) in order to minimise
sediment transfer in surface water run-off;

• The use of Sustainable Drainage Systems (SuDS) to minimise run-off;
• The use of quick setting concrete;
• A variety of measures related to oil fuelling areas (on land);
• Concreting as often as possible in low tide periods;
• Use of biodegradable lubricants and oils on all plant where possible;
• Implementation of an Accident and Incident Response Plan; and
• Monitoring.
Mitigation measures to minimise and avoid effects on marine ecology
6.2.98 The key ecological mitigation measures have focussed on the protection of the Corallina habitat
within the intertidal zone from physical disturbance and disturbance to its drainage channels. The
measures detailed in ES Section 10.6 include:
• Carry out a study, particularly of ebb tide drainage of the affected channels and their
connectivity to adjacent channels, in order to inform a range of mitigation measures;
• If a pile is to be located within a channel, blocking it, then diverting the channel, while
minimising damage to any other features of value, around the pile to ensure continuity of flow
would be required;
• If a pile location opened up a crack or gully previously not present, then the creation of
blockage structures across the channel might be required to maintain ponded seawater at
low tide to support Corallina;
• Any modification of drainage channel connectivity would have to be very carefully planned
and managed to ensure (a) no interruption of existing channel drainage, (b) existing
connectivity between channels was maintained, (c) appropriate materials were used in any
mitigation works and (d) works were limited to manual activities to prevent unnecessary
physical disturbance to the immediate environment;
• Any materials used would need to be able to withstand the rigours of a harsh tidal
environment. Any measures would also need to be of low profile (i.e. within profile of existing
channel) to minimise any hydrodynamic effects and potential changes to sediment transport
(i.e. they should not encourage additional deposition of materials into gullies);
• Use of appropriate geotextiles to minimise damage to intertidal habitats;
• The working corridor to be as narrow as possible;
• A fenced area to ensure that individuals and plant remain within agreed working corridor; and
• Access would be designed to avoid areas of Corallina where possible, especially areas of
Corallina run-offs as identified by the study proposed above. If channels need to be crossed,
however, this would only take place if they are narrow enough to enable positioning a track
over the rock channels containing Corallina turf, and measures would be taken to limit the
likelihood of channel blockage.

b) Reefs Feature (and Ramsar Criterion 3)
6.2.99 A review of MarLIN habitat preferences and the seabed surface map Figure 10-2, Volume 3 of
the application suggests that areas dominated by mud and sand are unlikely to support the
development of Sabellaria reefs in Bridgwater Bay. The recent extensive surveys have not
revealed any Sabellaria alveolata reef structures within these sandy and muddy areas, and their
presence in these areas of substrate is unlikely.
6.2.100 Coarser seabed habitats are most likely to support the development of Sabellaria reefs.
Sabellaria presence has been recorded from some of the survey sites where such substrates are
present, but not in a form that would constitute reef habitat.
6.2.101 Sabellaria is, however, present in a form that would constitute reef on the lower shore directly in
front of Hinkley Point A. The distributions of the reef forms on the Hinkley Point foreshore are
directly coincident with the midfield dispersion pattern of the Hinkley Point B power station
thermal plume.
6.2.102 Surveys of Sabellaria reef fronting the Hinkley Point site (for the distribution of Sabellaria, see
Figure 10-4, Volume 3 of the ES) show that coverage on the lower shore fronting the Hinkley
Point A power station is relatively extensive covering lower shore bedrock. The reef in this area
was generally low lying, with high percentage coverage throughout its distribution; large areas
were covered with a thin layer of sediment and some of the areas of the reef higher up the shore
were overgrown with ephemeral algae. Overall, based on the classifications summarised in
Connor et al. (Ref. 41) it was considered that the reef in this area was generally of reduced
quality, with some areas of moderate quality in which colonies were 10cm in height.
6.2.103 Recent characterisation surveys of Sabellaria aggregations off Hinkley Point (Ref. 42) indicate
that Sabellaria alveolata is more widespread and abundant than S. spinulosa in this area.
6.2.104 However, Sabellaria reef is not located within the jetty or berth pocket area, and the nearest
Sabellaria reef is located in excess of 500m away to the east (see Figure 10.4, Volume 3 of the
application).
Construction Phase
6.2.105 The construction works would extend for around 15 months duration, with many of the offshore
works occurring in 12 months or less. The outfall structure would discharge freshwater onto the
upper shore at 7.5m AOD. Although the area of upper shore that is likely to be affected by the
discharge is extremely small, given the proximity of the SAC it is relevant to consider the potential
for the works to influence the interest features that fall within the SAC.
IMPACT: The re-suspension and subsequent deposition of sediment during jetty construction
6.2.106 Dredging would occur over 500m away from the nearest areas of Sabellaria reef and, given the
naturally high suspended sediment concentrations in the water column and the tidal regime, any
increase in suspended sediment concentrations would be slight and likely to be advected by the
tides. It would not, therefore, be expected to result in an increase in suspended sediment levels at
Sabellaria reef communities outside of existing levels. Subsequently, there would be no expected
increase in sediment deposition over the Sabellaria reef communities, as the hydrodynamic

effects and increased suspended sediment levels would only occur in the area around the jetty
and berth pocket. Overall, no impact is expected on Sabellaria reef communities in the study
area.
salinity, or discharge of contaminants during the land-based construction activities
6.2.107 There is the potential that the land clearance could result in potentially significant increases in
suspended sediment and freshwater volumes, which could affect the Sabellaria reef communities
in the nearshore subtidal zone. The extent of any potential loss is difficult to quantify. However, it
is considered that the nature of the discharge and the extent and distribution of communities over
the foreshore suggest that any such loss would not be of significance.
6.2.108 It is considered to be unlikely that contaminated soils would enter controlled waters that discharge
into the estuary, as identified in paragraph 6.2.60 and ES Chapter 16, therefore a potential
impact on Sabellaria reef is considered unlikely during construction. However, there is a potential
for contaminants to be associated with run-off from construction materials or derived from
accidents and incidents, including spillages and leaks of fuels, oils and other chemicals. As
described above, because these would be accidental or incidental events, the volume,
concentrations and types cannot be quantified and, therefore, the risk of an impact on Sabellaria
reef cannot be ruled out without mitigation.
6.2.109 As identified in paragraph 6.2.62, a significant number of mitigation measures have been
identified in relation to avoiding (wherever possible) potential pollution or discharge effects from
surface water, or as a result of accidents or incidents, in addition, measures that minimise the
potential volume of discharge and contaminants and provision of measures to prevent them being
discharged into the estuary. A summary of proposed measures is presented in paragraph
6.2.97. Furthermore, it is assumed that, where relevant, discharges to the environment would be
subject to the agreement of a discharge consent with the Environment Agency and that potential
impacts would be avoided or reduced such that discharges to the Hinkley Point C Drainage Ditch
and into the estuary would be managed at attenuated run-off rates (including suspended
sediment, with any potential contaminants would be removed), which would result in no change
from the existing situation. Consequently, as no increase (in freshwater discharge volumes,
suspended sediments, and contaminants) would occur, no effect is predicted on Sabelleria reefs
from surface water derived sources.
IMPACT: Movement of construction plant and machinery on the foreshore and storage of
materials on the foreshore during the construction phase
6.2.110 The intertidal Sabellaria present on the lower foreshore is greater than 500m from the jetty and,
hence, would not be directly affected by any plant or machinery movements.
Operational Phase
IMPACT: Loss of or alteration to estuary feature and habitats
6.2.111 Given the proposed location for the jetty, there would be no Sabellaria present within 500m of it
and the feature would not experience any loss or alteration due to the presence of the jetty.

IMPACT: Increased scour or deposition as a result of the presence of the jetty and berth pocket
6.2.112 The worst case radial scour for the jetty piles is calculated to be 2.7m, and limited scour is
expected at the jetty berthing pocket due to the dredge slope, hence any scour there would be
localised. Consequently, given that there is no Sabellaria present within 500m, no scour effects
would occur on the reef habitat.
IMPACT: The re-suspension and subsequent deposition of sediment during jetty operation
(maintenance dredging)
6.2.113 The maintenance dredging would be likely to take place at a lower magnitude than that of the
capital dredge, and consequently, as no impact would arise during capital dredging, no impact
would arise on Sabellaria reefs during maintenance dredging due to the distance, limited scale of
impact at source (re-suspended sediment), and the existing high and variable nature of
suspended sediment levels in the marine environment within the study area.
6.2.114 Potentially significant increases in suspended sediment and freshwater volumes could arise as a
result of surface water run-off during operation, which could affect the Sabellaria reefs. Because
the volume increase of potential freshwater discharge and the likely suspended sediment of the
discharge water compared to present cannot be quantified, the possibility of a significant impact
on Sabellaria reef cannot be ruled out.
6.2.115 There is a potential for contaminants to be associated with run-off from stored materials or
derived from accidents and incidents, including spillages and leaks of fuels, oils and other
chemicals. Because these are accidental or incidental events the volume and concentrations and
types cannot be quantified, therefore, the possibility of a significant impact on Sabellaria reefs
cannot be ruled out.
6.2.116 However, as mentioned in relation to construction impacts in paragraph 6.2.62, a significant

number of mitigation measures have been identified in relation to avoiding (wherever possible)
potential pollution or discharge effects from surface water, or as a result of accidents or incidents.
In addition, measures that minimise the potential volume of discharge and contaminants and
provision of measures to prevent them being discharged into the estuary have also been
identified. A summary of measures is presented in paragraph 6.2.97. Furthermore, it is
of a discharge consent with the Environment Agency and (as set out above) that potential impacts
would be avoided or reduced such that discharges to the Hinkley Point C Drainage Ditch and into
the estuary would be managed at attenuated run-off rates (including suspended sediment, with
any potential contaminants would be removed), which would result in no change from the existing
situation; the mitigation measures proposed would be able to meet that requirement.
Consequently, as no increase (in freshwater discharge volumes, suspended sediments and
contaminants) would occur, no effect is predicted on Sabellaria reefs from surface water derived
sources.

Dismantling and Restoration (Removal and Reinstatement)
IMPACT: Re-suspension and deposition of sediment during jetty dismantling (removal)
6.2.117 The dismantling and restoration (removal and reinstatement) works would only result in sediment
re-suspension during the removal of the jetty piles. This would result in re-suspension of
sediments at much lower levels than that of maintenance dredging and capital dredging and,
consequently, as no impact would arise during capital dredging or maintenance dredging, no
dismantling (removal) impact would arise on Sabellaria reefs due to the distance, limited scale of
impact at source (re-suspended sediment), and the existing high and variable nature of
suspended sediment levels in the marine environment within the study area.
IMPACT: Disturbance to habitats due to dismantling (removal) of the jetty and construction plant
and machinery on the foreshore
6.2.118 The location of the jetty in relation to Sabellaria is set out in Figure 10-4, Volume 3 of the
application. It can be seen that there are no areas of intertidal or subtidal Sabellaria in close
proximity to the proposed jetty location. The nearest area of Sabellaria is a small section of
intertidal Sabellaria reef which is >500m from the proposed jetty location. As such, no impacts
are predicted on this receptor associated with direct habitat loss.
salinity, or discharge of contaminants during dismantling (removal) activities
6.2.119 Similar to construction and operation, the dismantling or removal of the jetty development has the
potential to result in run-off of rainwater and potential contaminants from plant, materials and
sediment mobilisation to the Sabellaria reefs. Contaminants potentially could be associated with
spills and leaks of fuels, oils and other chemicals. However, as for the construction and
operational phases, discharges to the environment would be subject to the agreement of
discharge consent with the regulators, and would include a dedicated WMZ that would be used to
manage the discharges from the onshore storage area to greenfield run-off rates. Given this, no
change from the existing situation would occur (ES Section 12.5) and no effect would arise on
Sabellaria reefs in terms of changing salinity, suspended sediment levels and associated
smothering due to deposition, or increases in concentrations of potential contaminants.
Mitigation Measures
6.2.120 Other than those mitigation measures identified earlier in Section 6.2a, no additional measures
are identified in relation to the reefs feature (and Sabellaria in particular).
c) Migratory Fish (and Ramsar Criterion 4)
6.2.121 Of the seven diadromous (migratory) fish species that are known to migrate through the Severn
Estuary, and which form the qualifying features of the Ramsar and SAC designations, all are
anadromous (mature at sea and migrate from marine to freshwater to spawn) with the exception
of the eel. There is little information describing the abundance of these fish in the nearshore
waters close to Hinkley Point, since no systematic targeted surveying or sampling of diadromous
species is undertaken in the Estuary. However, data are available from the Hinkley Point B
Power Station intake records (Ref. 43) and the paucity of diadromous species in these records
indicates that these species are highly dispersed in the estuary.

Published Information
6.2.122 Numerous studies have been conducted examining fish assemblages within the Severn Estuary
and the Bristol Channel (e.g. Ref. 44). As a result, information is available regarding species
richness, assemblage composition and population dynamics of the Estuary and Channel (e.g.
Ref. 45, Ref. 46, and Ref. 47), and a number of studies have been conducted to investigate the
life history and migratory movement of specific species (e.g. Ref. 48, Ref. 49, Ref. 50, and Ref.
51).
6.2.123 The recent designation of the Wye, Usk and Tywi for shad, and the Wye and Usk for sea and
river lamprey has created the impetus for monitoring of these populations. Recent reports on
lamprey by Harvey et al. 2006 (Ref. 52) and shad by Noble et al. 2007 (Ref. 53) provide the basis
for assessment of these species. Both reports also discuss the results of surveys for these river
populations in terms of the Severn Estuary. River specific datasets have been used to assess the
status of riverine populations of species directly; the status of these species in the Estuary has
been inferred largely from this data.
The Hinkley B Severn Estuary Dataset (SEDS)
6.2.124 A comprehensive source of information regarding the abundance and species richness of fish in
the inner Bristol Channel is provided by the entrainment and impingement data collected at
Hinkley Point B Power Station. Since 1981 monthly samples have systematically been taken,
providing a long-term dataset that is primarily of use in assessing the status of purely marine
species, but is also relevant to some diadromous species, most notably eel.
Migratory Fish Species
6.2.125 Other than the abundant estuarine fish community of the estuary, migratory fish primarily utilise
the Estuary for migration between their natal rivers, most notably the rivers Wye, Usk and Severn,
and marine feeding grounds. They may also use the estuary for feeding, e.g. in the case of
juvenile shad, and river lamprey. Seasonal migratory utilisation of the Severn Estuary is
described in Table 10.
Table 10: Migratory movements of migratory fish species within the Severn Estuary,
showing important months and directions of movement
Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Salmon
Smolt
Sea trout
Shad
Shad
(Juvenile)
Sea Lamprey

Species Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Sea Lamprey
(Juvenile.)
River Lamprey
River Lamprey
(Juvenile)
Eel
Elvers
6.2.126 The migratory fish species known to migrate through the Severn Estuary are; Atlantic salmon,
twaite shad, allis shad, river lamprey, sea lamprey, sea trout, and eel. Each of the species is
anadromous with the exception of the catadromous eel.
6.2.127 At least two individuals of five of the seven migratory species have been recorded at the intake
screens of Hinkley Point B Power Station (the exceptions being allis shad and sea trout). In
particular, relatively high numbers of juvenile twaite shad have been entrained at Hinkley Point
with annual catches ranging from less than 10 in 1981, 1982, 1987, 1988, 1991 and 1993 to over
100 in 1989 (Ref. 54). Numbers of twaite shad impinged at Hinkley Point tend to peak in July and
August.
Estuarine Populations of Migratory Species
6.2.128 In the context of estuarine fish species as a whole, other than eels, anadromous species of
populations belonging to the adjacent rivers are rare, and infrequently recorded. For these
migratory fish, the long-term data from Hinkley Point B Power Station is of more limited value, and
other data are required to assess these populations, which form the basis of the statutory nature
conservation designations of the Severn Estuary and the adjacent rivers. Given that anadromous
fish populations are more amenable to survey when aggregated in rivers of origin, river specific
data is more meaningful due to each river representing a discrete management, (and for some
species, biological) unit. Riverine survey data have been relied upon and the available data, as
presented for individual species below, have been interpreted in the context of the Estuary.
6.2.129 Lamprey and shad surveys carried out on the rivers Wye and Usk indicate conditions for these
rivers. In the absence of direct data, the Severn Estuary populations for these species can be
inferred, and the validity of inferring the health of estuary populations from the adjacent rivers
specifically in the context of the Severn Estuary is discussed by Harvey et al. 2006 (Ref. 52). The
main uncertainty lies in the extent to which other rivers (most notably the Severn) contribute to the
estuarine population, and the health of these populations. If, as has been suggested, lamprey
populations are less faithful to their river of birth and the Severn population is therefore a more
homogenous population, then the status of the species in any one river (e.g. the Wye and Usk)
cannot be considered to be representative of the estuarine population as a whole. However, the
Usk and Wye are likely to comprise a sufficiently large proportion of the Severn Estuary
population that the assumption is nonetheless correct.

Salmon
6.2.130 Adult salmon migrate upstream primarily from July to September, with fish migrating during this
time being primarily one sea-winter salmon. Adult salmon also migrate in earlier months of the
year, and although inferior in number, these comprise higher numbers of multi-sea winter salmon.
Multi-sea winter salmon and those which migrate upstream in earlier months (traits partially
genetically determined and co-related) are of higher conservation importance than salmon
generally and have undergone disproportionately large declines. This is more pronounced in the
River Wye stock than perhaps any other UK river. This is reflected in their being afforded a range
of specific conservation measures of both a non-statutory and statutory nature (e.g. national
spring salmon conservation byelaws).
6.2.131 Salmon smolts migrate downstream through the estuary towards marine feeding rounds between
April and June. Available evidence suggests that salmon smolts migration is characterised by
selective tidal stream transport on the ebb tide, near the water surface in the areas of strongest
flow and takes place during the night (Ref. 55). Studies indicate that smolts pass rapidly through
the estuary and do not require a significant period of acclimation to saline conditions (Ref. 55).
6.2.132 Adult salmon migration within estuaries is characterised by utilisation of tidal flows, and prior to
entry to freshwater, salmon may reside in estuaries for varying periods. Potter, 1988 (Ref. 56)
found this to vary between 9 hours and 190 days in the Fowey Estuary. During this time, salmon
move up and down estuaries and progress upstream by making effective use of the flood tide and
seeking refuge from outflowing tidal currents (ebb tides) by utilising more marginal, lower velocity
parts of the Estuary.
6.2.133 Residence time in estuaries is largely dependant on riverine flow and temperature with high
riverine flows and low temperatures resulting in relatively quick river entry, and low flows with
delayed entry whereby salmon reside in the estuary, or return to sea. An important feature of
delayed entry is that this results in lower likelihood of salmon entering the river (Ref. 57).
6.2.134 Fisheries in the Severn Estuary exploit salmon from four principal salmon rivers (Severn, Wye,
Usk and Taff/Ely) and several small recovering rivers in South Wales. Salmon are considered to
be in unfavourable condition within both the River Wye and Usk SACs. They are currently failing
to meet their Conservation Limits (CLs) set by Salmon Action Plans (SAPs) on the Rivers Wye
and Taff/Ely. Although there is some uncertainty, the Rivers Usk and Severn appear to be
complying with their CL targets. Overall, it is likely that the estuary population is below the
population sought by managers to maintain its conservation and fisheries objectives.
Lampreys
6.2.135 Adult river lamprey are known to enter UK rivers generally in the late Autumn although unlike sea
lampreys which undertake more extensive marine migrations, river lamprey make more use of
estuarine habitats throughout their marine phase (Ref. 58). Sea lamprey migrate through the
estuary and enter rivers to spawn in the early Spring.
6.2.136 Claridge et al. (Ref. 59) recorded peaks in abundance of downstream migrating juvenile river
lamprey in the Severn Estuary between October and January.
6.2.137 The most recent condition assessment round in 2007 classified all UK SACs with the exception of
the River Usk as unfavourable for river lamprey and all but the River Wye as unfavourable for sea
lamprey. In the absence of a comprehensive understanding of the amount of available lamprey
habitat within each of the rivers, the current conservation status assessment procedure does not
enable an assessment of standing stock to be made, therefore precluding the derivation of a

species population estimate. No estimates have been made of the number of returning adults or
out-migrating transformers of river lamprey or sea lamprey within the tributary rivers of the Severn
Estuary.
Shads – Allis Shad & Twaite Shad
6.2.138 Adult shads enter the Severn Estuary between April and June on their way to spawn in the rivers
Severn, Wye and Usk, with peak immigration occurring in May.
6.2.139 Young of the year shad colonise the estuary from rivers from July, until migrating seaward in
Autumn. Claridge et al. (Ref. 59) recorded maximum numbers of juvenile twaite shad in the
Severn in August and September. Juveniles may also return to the estuary the following April to
May before returning seaward again in the late Summer. This indicates that the estuary is more
than merely a migration route for shad, and that it is of importance as a feeding ground for
juveniles.
6.2.140 Inferring status of twaite shad populations in the Estuary from the adjacent riverine populations
leads to an uncertain conclusion. Although data comparable to that of Noble et al. (Ref. 53) does
not exist for the Severn, its status is thought to be improving. However, both twaite and allis shad
are currently classified as in unfavourable status for all of their designated rivers (Usk, Wye and
Tywi). Few estimates of the stock sizes of twaite or allis shad within the Bristol Channel or the
Severn Estuaries tributary rivers have been made and the current conservation status sampling
protocol does not enable quantitative assessments of standing stock to be made. During the
derivation of the UK BAP priority species list, estimated twaite shad populations in the UK totalled
approximately 100,000 returning adults split between the Rivers Severn, Wye, Usk and Tywi at a
ratio of 20,000, 50,000, 20,000 and 10,000 individuals respectively (Aprahamian, pers. comm.).
Eel
6.2.141 Eels are catadromous, reproducing in the sea, and migrating to freshwaters to undertake most of
their feeding and growth. The Severn Estuary and its rivers constitute the largest eel fishery in
the UK; constituting 95% of all glass eels (juveniles migrating towards freshwater) caught in
England and Wales. The majority of upstream migration of elvers (juveniles) takes place between
April and September inclusive although closer to tidal limits this may be concentrated within the
months of April to July (Ref. 60). The same authors suggest that peak downstream runs of adult
eels take place between September and November.
6.2.142 European eel is categorised as critically endangered on the IUCN Red list of threatened species.
Eel are considered to be under threat and have seen a significant decline in stocks. The
International Council for the Exploration of the Sea (ICES) state that the European eel stock is
outside safe biological limits. In 2007, the European Community entered into force a Europe wide
recovery plan (EC Council Regulation No. 1100/2007/) with implementation measures which
began in 2009. In March 2009, eel was also added to the Convention on International Trade in
Endangered Species (CITES) Appendix II list, which details species in which trade must be
controlled.
6.2.143 Eel Management Plans have been implemented for the Severn Catchment, which aim to provide
an escapement of silver eel biomass that is at least equal to 40% of the potential escapement to
be expected in the absence of anthropogenic influence. It is currently estimated that an
escapement rate of approximately 34% is being achieved (Ref. 61).

6.2.144 In addition, the European Eel Regulation requires that a system is in place to ensure that by
2013, 60% of eels less than 12cm long which are caught commercially each year are used for
restocking in suitable habitat. On the basis of an estimate that the glass eel/elver fishery on the
River Severn takes 10% of the stock, it has been estimated that the glass eel population was
within the region of 3 million individuals in 2008.
6.2.145 Data from long-term monitoring at HPB indicates a long term exponential decline in catches from
the commencement of records in 1980. This trend is also evident in the recruitment of glass eels
to Europe, which has declined since the late 1970s by as much as 99% according to selected
indices and the most recent observations do not indicate recovery.
Sea Trout
6.2.146 Sea trout share much of the of the Atlantic salmon’s biology as well as having a similar life
history. Key differences include a higher degree of iteroparity in sea trout (i.e. individuals have a
greater propensity to survive to undertake repeated spawnings), and sea trout undertake their
marine phase in coastal waters rather than undertaking the more extensive marine migrations of
salmon. Adult sea trout generally enter rivers in south Wales and the south-west of England from
June to September, with smaller numbers entering at other times of the year.
6.2.147 Studies have indicated that sea trout smolt migratory behaviour is similar to that of salmon, taking
place between April and June, utilising selective transport by ebb tides primarily at night, near the
water surface in the fastest moving part of the water column (Ref. 55).
6.2.148 Data from rod, putcher and net fisheries indicate that sea trout occur at much inferior numbers
than salmon. This is in contrast with nearby rivers in south Wales which have strong sea trout
populations (e.g. Tywi and Teifi). This suggests that riverine and estuarine conditions within the
Severn are inherently not favourable to sea trout. Given that the marine phase of sea trout is
more coastal and estuarine than salmon, it may be that the highly dynamic nature of the Severn
does not offer suitable inshore habitat.
Summary Table
6.2.149 To compliment the above information, Table 11 provides a summary of the population dynamics
for the qualifying migratory fish species (Source: DECC (Ref. 62); CCW (Ref. 63); CCW (Ref. 64);
NBN (Ref. 65); NBN (Ref. 66); CCW (Ref. 67); CCW (Ref. 68); DEFRA (Ref. 69)).
Table 11: Fish population dynamics for qualifying migratory fish species
Species Site Population Estimates Population Conservation

trends status
Atlantic River Wye River Wye annual rod catch counts Declining Unfavorable
Salmon SAC for selected years:
1996 >1800*; 2001 >700;
2007 > 600.
River Usk River Usk annual rod catch counts
SAC for selected years: Increasing Unfavorable
1996 >500; 2001 >800;
2007 > 1,158*.

Species Site Population Estimates Population Conservation
trends status
Sea trout River Wye River Wye annual rod catch counts Stable Stable
SAC for selected years:
1996 >28; 2001 >45;
2007 > 40
River Usk River Usk annual rod catch counts
SAC for selected years: Stable / Stable /
1996 >200; 2001 >100; 2007 > 100 Increasing Increasing
Shads River Usk Shad egg survey counts in the River Unclear Unfavorable
SAC Usk for CCW SAC monitoring
reports:
1994 – 1; 2003 – 18;
2010 – 53.
River Wye Shad egg survey counts in the River

SAC Wye for CCW SAC monitoring Unclear Unfavorable
reports:
1997 – 4;
2004 –19.
Lamprey River CCW SAC monitoring data for Declining Favorable (Sea
Catchments lamprey based on electro-fishing lamprey, River
of the Dee, counts: Wye; River
Tywi, Teifi, lamprey River
1986 – 1;
Cleddau, Usk).
Usk and 1996 – 0;
Wye. 1998 – 109*;
Unfavorable
2001 – 20; (Sea lamprey,
2005 – 99. River Usk;
River lamprey,
Mean site densities of up to 74 sea River Wye).
2
lamprey (m ) have been recorded
along the River Usk SAC and River
Wye SAC (Ref. 68).
Eel Severn Catch data not available. However, Declining Currently
Estuary for the Severn River Basin District outside safe
Ramsar the peak declared monthly elver biological limits.
(glass eel) catch between 2005 –
2007 ranged between 500kg (2005);
> 350kg (2006); and 800kg (2007)**.
* Peak counts; ** Average individual weight of an elver is approximately 0.5g.

Offshore Fish Surveys
6.2.150 A recent 2m beam trawl did not catch a single individual of any species of prime conservation or
ecological concern, such as eel, salmonids (salmon and sea trout), smelt and shad. However,
BEEMS (Ref. 70) notes that the River Parrett, which discharges into Bridgwater Bay east of the
power station, historically had an eel population that was once heavily fished, with an estimated
10,000 eels per night in the river at peak migration times. Data collected by the Environment
Agency for the period 1990 to 2006 indicate a general decline in eel density on the Parrett since
the 1990s with little recruitment of small eel into the river. In 1992 maximum densities of up to
100 individuals per 100m2 were recorded with this decreasing to below ~20 individuals per 100m2
in 2006. Current eel populations are depleted, and the evidence available suggests it is likely that
only a small fraction of the historical eel run now takes place.
Fish Impingement at the Hinkley Point B Power Station in 2008 and 2009
6.2.151 Forty two species of fish were recorded from the monthly impingement samples between January
2008 and June 2009. As is normal for the Bristol Channel, whiting and sprat were the most
abundant fish species. A notable feature was the large number of snake pipefish impinged on the
screens (this was the first time large numbers of this species have been recorded over a sampling
period extending over the last 30 years). It is likely that many snake pipefish were able to
penetrate the 1cm mesh and therefore passed through the cooling water circuit. This suggests
that this pelagic pipefish has recently become extremely abundant in the estuary.
6.2.152 A comparison of the relative abundances of fish impinged upon the power station screens and
those sampled offshore showed that sprat and whiting dominate the fish fauna at all sampled
localities. Furthermore, of the 18 recorded species impinged on the screens in 2008, 13 were
also caught in one or more of the offshore samples. A comparison of the fish species and relative
abundances recorded offshore and from the power station screens, showed that herring, sprat
and whiting dominated the fish fauna at all localities.
6.2.153 Sixteen species of fish were recorded from the monthly impingement samples in May and June
2009. As is normal for this locality at this time of year, the catch was dominated by whiting, with
Dover sole and flounder also common (737, 217, and 90 individuals caught respectively). Late
Spring and early Summer is the time of year when fish abundance and species richness is at the
minimum for the year. A notable feature of the June 2009 sample was the unusually large
number of 0+ cod impinged. This was the largest number yet recorded in a 6 hour sample since
sampling began in 1981 and reflects a previously recognised trend of increasing cod abundance
in the region.
6.2.154 Of the 32 species impinged during the survey period (November 2008 to October 2009), 21 were
sampled offshore. In addition, four species were sampled offshore which were not recorded at
the intake during this period (anchovy, pearlside, sand eel, and solenette).
Overview of Fishing Activity in the Bristol Channel and Severn Estuary and Migratory
Fisheries
6.2.155 Commercial fisheries is undertaken for migratory species including salmon, sea trout, and eels in
the Severn Estuary and surrounding rivers. Fisheries for migratory species are of significant
economic value, particularly in rural areas. However, overall salmon and sea trout netting is
declining, in response to the phasing out of mixed stock fisheries and falling demand for wild
salmon. Eel and elver net fishing in recent years has fluctuated in response to market forces.

6.2.156 Migratory species that are targeted commercially in the Severn Estuary and surrounding rivers
include salmon, sea trout and eels. Both allis and twaite shad are also present in the Severn
Estuary and were formerly fished commercially before numbers declined and the fishery
collapsed. In the middle of the 19th century the value of shad rivalled that of salmon, and in the
River Severn, shad made up about one-third of all catches.
6.2.157 Many of the net fishing methods used to target migratory species on the Severn Estuary are
unique to the area and have a long history, notably lave netting (using a '
Y'shaped net and
'
stalking'or '
cowering'in the shallows to catch the salmon migrating) and putcher nets (rows of
baskets which use the ebb tide to trap salmon).
Salmon and Sea Trout
6.2.158 The Estuary fisheries exploit mixed stocks of salmon originating from at least 7 rivers entering the
Estuary, most notably the Severn, Wye and Usk. Net licences issued for catching salmon also
allow the fishermen to take sea trout. Hence, it is impossible to distinguish the allocation of effort
between salmon and sea trout fishing. Sea trout are found in 26% of all rivers, and their
distribution across England and Wales is very irregular. Wales has the widest distribution, with
sea trout present in 49% of rivers.
6.2.159 Salmon caught before June 1st must be released, with catches continuing from then until August.
In 2000, local interests bought out drift netting in the mouth of the Usk, in Newport Bay and the
putcher rank just upstream of Uskmouth which accounts for the lack of reported salmon net
catches in the Usk after 1999.
Eels
6.2.160 Eels are found in all European countries bordering or connected to the North Atlantic. They are
caught as elvers (juveniles returning from the sea) or adults in a variety of fisheries each with
different levels of exploitation. Over the past two decades, catch data from across Europe show
glass eel populations declining rapidly from the high levels of the 1970s, while 2001 produced a
record minimum of just one percent of previous peak levels, and most recent data show a
continued decrease and no significant recovery from the 2001 all-time low.
6.2.161 Only hand-held dip nets are permitted for the capture of glass eels or elvers, and fishing is
concentrated where the fish are plentiful and easy to catch, principally in estuaries of the Severn
and other rivers draining into the Bristol Channel such as the Parrett. Catch returns from these
fisheries have been compulsory over the past few years and provide a good indication of the
trend in eel recruitment. The fishing season is short, coinciding with the elvers entering rivers on
spring tides in April and May (Ref. 61).
6.2.162 The number of licenses issued to fish for glass eel / elver in the Severn Estuary and Bristol
Channel ranged from 487 to 577 between 2002 and 2004. Elvers are known to be targeted
during their landward migration between November and March using dipnets within the area just
seaward of Bridgwater Bay. The national 2007 catch was 2,051kg of which the Severn Estuary
and Bristol Channel is estimated to represent 95% equating to a catch of 1,948kg. Based on an
average individual weight per elver of approximately 0.5g this would equate to 3,896,000
individuals. Only a small proportion of elvers caught are for domestic consumption, the majority
are sold for re-seeding eel farms in Asia.

6.2.163 Eels are caught commercially in a number of locations and by a variety of instruments including
fyke nets, putcheons and weir traps. The level of eel fishing effort is measured as the number of
licensed instruments of all types. Licence sales in England and Wales have ranged between
1500 and 2700, (per year) most likely in response to market price fluctuations. Many rivers
throughout the Severn Estuary catchment support eel fyke net fisheries between Spring and
Autumn. Fyke nets fished on the Wye take yellow eels in Spring and Summer and silver eels in
Autumn.
6.2.164 Between 2002 and 2004 the number of licenses issued for this fishery reduced from 80 to 47
although catches in fact rose over this period from 156kg in 2002 to 980kg in 2003 followed by a
slight decline in 2004 to 569kg. The 2007 annual adult eel catch for Wales, South West England
and the Midlands was 2,396kg (data provided by the Environment Agency). The 2004 catch
indicates that the Severn Estuary represents approximately 12% of this regional catch. As such,
the 2007 adult eel catch for the Severn Estuary is estimated at approximately 288kg. Based on
empirical data there is presumed to be a 20:1 ratio of male to female eel in the Severn Estuary.
Male and female eel reach maturity and migrate at different ages and as such will vary in weight.
Taking an average weight however for male silver eel of 90g and 580g for females (based on the
most common ages at maturity) the adult eel catch for the Severn Estuary and Bristol Channel
would equate to 3,040 males and 24.8 females.
6.2.165 Construction activities taking place within the intertidal and subtidal zones would increase levels
of ambient noise and vibration, principally from the use of various heavy vehicles and machinery,
jetty piling, dredging, vessel movement and berthing. Levels would also increase during operation
due to the berthing of vessels and operation of the conveyor. Hence there is the potential for
increased levels of noise and vibration to affect migratory fish utilising the intertidal and subtidal
zone of the estuary. High frequency vibration (70-300 kHz) can be a barrier to migration,
affecting movement both up and downstream and preventing fish reaching spawning areas (see
ES Chapter 10). Shad and lamprey in particular are identified as being vulnerable to noise and
vibration.
6.2.166 As the construction works for the discharge outfall (surface drainage pipe) would be confined to
the upper shore, above MHWS, it is highly unlikely that noise generated by the works would
propagate into the estuary water column (see Figure 4). If this were to occur, any effect would
be limited to the shallow areas of the intertidal in close proximity to the construction activity, and
would be highly unlikely to affect areas of deeper water that are likely to support larger numbers
of fish. Levels of noise and vibration would not be significant relative to existing background
levels. However, within the marine environment, jetty piling and dredging of the berth pocket
during construction, maintenance dredging during operation, and removal of the jetty structure
during dismantling and restoration (removal and reinstatement) could potentially disturb migratory
fish species and result in increased suspended sediment concentration due to the re-suspension
of seabed sediments.
6.2.167 Potentially lighting along the jetty during construction and operation could affect migratory fish
behaviour and cause a barrier to migratory passage. Whilst surface water discharges from land
during construction, operation and dismantling and restoration (removal and reinstatement) could
also result in increased discharges of freshwater, sediment and potential contaminants.
6.2.168 Finally, the assessment of effects examines the potential effect of the presence of the jetty
structure within the marine environment.

Construction Phase
IMPACT: The re-suspension of sediment and physical disturbance during jetty construction
6.2.169 Piling, dredging and the use of construction plant and materials could disturb the physical
environment (and its species and habitats) and drainage characteristics of the intertidal area in
and around the site of these works for the jetty development. Migratory fish could be present in
the study area during certain times of year and / or intermittently; consequently they could be
affected by physical disturbance associated with the piling works and the capital dredging.
However, migratory fish would be able to avoid areas of physical disturbance and only a very
small percentage of the sub-tidal habitat would be affected at any one time, hence the magnitude
of the impact is predicted to be very low.
6.2.170 Piling and dredging would result in increased levels of suspended sediment concentrations.
However, as described in Section 6.2a, the suspended sediment levels within the estuary and
the area of the works are high and extremely variable, and the increased levels resulting from the
works would not exceed the natural variation. Migratory fish are habituated to the changing levels
of suspended sediments within the estuary and, given the variability of suspended sediment
levels likely to derive from the works, no barrier to migration is expected.
salinity, or discharge of contaminants during construction
6.2.171 The volumes and lateral extent of freshwater that would be discharged to the upper shore could
impact upon migratory fish by causing an influx of water of a different quality and salinity.
Furthermore, a high concentration of suspended sediment could arise in the discharge water due
to land clearance.
6.2.172 Due to the changing salinity on the tide and within Bridgwater Bay, specifically due to the
discharge of the River Parrett, migratory fish species in the study area are likely to be habituated
to changing salinity. Furthermore, much of the discharge would also quickly infiltrate into the
upper shore sediments during low tides, and any discharge would effectively replace the existing
discharge to the foreshore from the unnamed watercourse / drainage ditch that currently provides
some drainage to the northern part of the application site (see ES Chapter 13).
6.2.173 The likelihood of any land contamination is described in paragraph 6.2.60 and ES Chapter 16.
The spatial extent of any ground preparation works are limited to the proposed jetty storage area
and the rock extraction area and as contamination is unlikely (as identified in paragraph 6.2.60),
the dispersal of contaminants into the estuary from surface waters is considered unlikely during
construction. However, there is a potential for contaminants to be associated with run-off from
construction materials or from accidents and incidents, including spillages and leaks of fuels, oils
and other chemicals. Because these are accidental or incidental events, the volume,
concentrations and types cannot be quantified, and the possibility of a significant impact on
migratory fish cannot be ruled out without mitigation.
6.2.174 As mentioned above, a significant number of mitigation measures have been identified in relation
to avoiding (wherever possible) potential pollution or discharge effects from surface water, or as a
result of accidents or incidents, in addition to measures that minimise the potential volume of
discharge and contaminants and provision of measures to prevent them being discharged into the
estuary and hence impacting on migratory fish. A summary of measures is presented in
paragraph 6.2.97. Furthermore, it is assumed that, where relevant, discharges to the
environment would be subject to the agreement of a discharge consent with the Environment
Agency and that potential impacts would be avoided or reduced such that discharges to the

Hinkley Point C Drainage Ditch and into the estuary would be managed at attenuated run-off
rates (including suspended sediment, with any potential contaminants would be removed), which
would result in no change from the existing situation; the mitigation measures proposed would be
able to meet that requirement. Consequently, as no increase (in freshwater discharge volumes,
suspended sediments, and contaminants) would occur, it is concluded that no effect would be
expected on migratory fish species from surface water derived sources.
IMPACT: Construction Noise and Vibration
6.2.175 Several activities associated with the jetty’s construction are likely to generate noise and
vibration. The following sources of noise and vibration could affect migratory fish species:
• pile driving;
• vessel movement; and
• dredging.
6.2.176 In order to assess impacts from construction noise and vibration on migratory fish, this
assessment considers:
• levels and frequencies of noise and vibration from different types of piling activities;
• noise and vibration from different kinds of vessels;
• potential effects of construction noise and vibration on fish;
• off-shore noise environment in the vicinity of the proposed jetty; and
• noise propagation underwater.
Noise from Pile Driving
6.2.177 It has not yet been confirmed what method of piling would be employed, although a drill and drive
or pre-drilled and socket approach is believed to be most likely (see ES Chapter 6). Given that
the best practicable environmental approach would be adopted, rotary piling is likely to be the
favoured approach, although percussive piling probably would be necessary to reach bedrock.
Whichever technique is used, as appropriate, a soft start would be adopted to allow migratory fish
present in the area to move away prior to the commencement of full-scale piling.
6.2.178 Although no specific values for the predicted noise levels for piling are available as yet, a number
of previous studies have examined noise levels during construction for coastal developments
requiring pile driving. For example, pile driving has been found to generate sound pressures
significantly greater than 192dB re: 1µPa (Ref. 71) (Note: The SI unit for the measurement of
sound in water is decibels relative (dB re:) to a reference pressure (1µPa)). The level of sound
generated can vary in relation to different factors including the size of piles and the scale of the
operation (Ref. 72). Examples of the level and frequency of noise from hammer piling and vibro-
piling are provided in Table 1 in Appendix 10-1, Volume 4 of the ES.
6.2.179 Studies measuring the noise levels generated by impact piling found variation in peak to peak
pressure changed from 195dB at the pile driver, to approximately 152dB at a distance of about
240m, with a linear decline in sound pressure with distance (Ref. 73).
6.2.180 A study in Southampton Harbour found that at a distance of about 400m from the source of the
sound, no signal of vibratory piling could be detected, as it was drowned by shipping noise (Ref.
73). This study also found no evidence that trout reacted to vibro-piling at even a close range of

less than 50m. It is probable that the lack of behavioural responses was largely due to the sound
energy from the piling being at frequencies at which the fish were relatively insensitive. In
summary it may be concluded that, in respect of the vibro-piling, at the range at which monitoring
was conducted (417m), there was no discernible contribution from the piling above background
noise. It was noted when listening to the recordings that the vibro-piling could not be heard above
the background noise caused by the movement of vessels.
Vessel Noise due to Dredging Works and Other Movements
6.2.181 Dredging would be required for the berthing pocket at the end of the temporary jetty.
6.2.182 Very large tankers and container ships can generate sound levels in the range 180-190dB re:
1µPa at 1m which is similar to that generated by pile driving (Ref. 74), although for smaller
vessels the potential impact is greatly reduced. Table 12 shows the sound frequencies and
source levels produced by various vessels that may be required during the construction of the
jetty.
6.2.183 Richardson et al. (Ref. 74) provide a review of underwater noise in relation to marine dredging
and construction activities. Generally, noise generated by dredgers depends on the type of
vessel and the activity that is being undertaken. A study by Cefas (Ref. 75) of sound levels
generated during aggregate dredging found that sound pressure levels were generally found to
fall below the ambient noise level (100dB re 1~Pa) within 25km, however some dredging vessel
activities were found to emit strong tonal sounds which were detectable to distances greater than
25km (Ref. 75). Low frequency sounds were found to be generated by the dredger maintaining
position. Higher frequency sounds (>2KHz) were generated by full dredging activities whilst
maintaining position (Ref. 75).
Table 12: Vessel Sound Frequencies and Source Levels
Vessel Frequency (Hz) Source Level (dB re 1 Pa @ 1m)
Supply vessel 20 – 1,000 110 – 135 (without thrusters)
121 – 146 (with thrusters)
Fishing boat 250 – 1,000 151
Tug (pulling empty barge) 37 – 5,000 145 – 166
Tug (pulling loaded barge) 1,000 – 5,000 161 – 170
Twin diesel work boat 630 159
6.2.184 There would also be vessel movements associated with the delivery of materials during
construction of the sub-tidal sections of the jetty. Large vessels can cause an aural and
potentially a visual disturbance for fish. Generally, vessel noise can elicit avoidance or attraction
responses in fish at very low or very high frequencies (Ref. 76). Some behavioural changes have
been observed in fish in relation to vessel noise, such as forming tighter formations, avoiding
noise sources and increasing swimming speeds (Ref. 77). Experimental studies have shown that
avoidance occurs at 118dB within the range of 60Hz to 3,000Hz (Ref. 78).

6.2.185 There are already large vessels operating within the Severn Estuary / Bristol Channel (although
most shipping occurs close to south Wales rather than in Bridgwater Bay). Fish are, therefore,
likely to have become accustomed to a background level of underwater noise and vibration
resulting from these activities to some extent. Fish also have the ability to move away from the
sources of vessel noise. As the fish species in the study area are all marine migrants moving to
the Hinkley Point area from the Bristol Channel, Irish Sea and further afield, it would be expected
that they would be frequently exposed to vessel noise during their lifetime. Young-of-the-year
migratory Atlantic salmon, twaite shad, allis shad, river lamprey and sea lamprey passing through
the estuary, however, would be less acclimatised to vessel noise.
Potential Effects of Construction Noise on Fish
6.2.186 In order to assess potential impacts of noise on fish an understanding of the hearing abilities of
fish is required. Fish use three organs to detect sound; the lateral line, the ear, and the swim
bladder. The presence / absence and characteristics of these organs determine the hearing
abilities of fish species, which can be considered to be hearing non-specialists, specialists, or
generalists (Ref. 79 and Ref. 80). Non-specialist fish are those with no swim bladder, e.g.
lamprey. Clupeiformes (e.g. shad) fall within the specialist category and as such can hear sounds
over a far greater range than other species (Ref. 81). Species of conservation importance which
are considered to be hearing generalists, and potentially are present near the study area, include
salmon, sea trout and eel.
6.2.187 In addition to auditory problems, more severe impacts could include the perforation of swim
bladders by high-energy underwater noises (Ref. 82) which can cause fish to sink, lose the ability
to orientate themselves, or lead to internal bleeding and fatality. Nedwell (Ref. 83) states that
“provided animals are free to flee the noise, those within the area bounded by the 90 dBht level
contour will strongly avoid the noise” and that “Animals within the area bounded by the 130 dBht
level contour may suffer injury or permanent damage to hearing”. The sound pressure levels
which may cause harm to fish differs between species and is largely dependant on the presence
or absence of a swimbladder. Underwater noise may also create disturbance to local fish
populations, although fish are known to rapidly acclimatise to background noise.
6.2.188 Nedwell et al. (Ref. 73) measured audiograms of the hearing ranges of both noise level and
frequency for some of the species of conservation importance known to be present within the
Severn Estuary / Bristol Channel (see Table 13).
6.2.189 Of particular importance in the Severn Estuary are populations of migratory salmon and shad that
may be migrating through the estuary during the works. Salmon are only sensitive to low
frequency sound and do not react to frequencies above 380Hz. The lowest response threshold
and presumably the frequency of greatest sensitivity are between 100Hz and 160Hz. Above this
sensitivity rapidly declines. Vibratory piling produces sound within the range of frequencies
detectable by salmon (Ref. 73).
6.2.190 Shad are clupeids belonging to the herring family, and as such it could be considered that they
are morphologically very similar. Studies on American shad Alosa sapidissima found shad could
detect sound from 200Hz to over 180,000Hz, although the two regions of best sensitivity ranged
from 200 to 800Hz and the other from 25 to 150kHz (Ref. 81), with the lower bandwidth similar to
that reported in herring by Blaxter et al (Ref. 84). It has been suggested there are significantly
subtle differences in the ears of Clupeinae and Alosinae that may provide a mechanical
explanation for why only the shads are able to detect ultrasound (Ref. 81).

Table 13: Hearing Frequency Range for Fish Species of Conservation Importance in the
Area around Hinkley Point
Common Name Hearing Frequency Hearing threshold Reference

category range (Hz) range over this
frequency range (dB re
1 Pa)
Atlantic salmon Generalist 30-350 95-130 Nedwell et al. 2004
Twaite shad Specialist 30,000-60,000 190-198 APEM 2008
River lamprey Non-specialist Unavailable Unavailable NA
Sea lamprey Non-specialist Unavailable Unavailable NA
Sea trout Generalist 30-350 95-130 Nedwell et al. 2004
Eel Generalist 10-300 Unavailable Jerkø et al. 1989
Notes:
Where data are lacking for specific species other data are presented where possible for other species
of similar physiology.
6.2.191 Data on the response of allis shad to sound are limited, however data on the closely related
twaite shad indicate noise levels of 158dB and a ramped frequency range of 100Hz to 500Hz
caused fish to undertake avoidance reactions at 138dB, which was >40dB above ambient noise
levels (Ref. 85).
6.2.192 Comparing the data on vessel noise generation (Table 12) with the hearing capabilities of the fish
species (Table 13) it can be seen that supply vessels, fishing boats and tugs (pulling empty
barge), can generate sound within the hearing frequency range of most species, the only
exception being twaite shad. A tug pulling a loaded barge however can generate sound at much
higher frequencies (1,000-5,000Hz) which lies outside the range of the majority of fish species
(salmon, twaite shad, sea trout, and eel). Similarly the frequency of sound generated by a twin
diesel work boat is outside the hearing range of these species.
6.2.193 For fish species to hear the vessels and demonstrate an avoidance reaction, both the frequency
and noise level indicated in Table 12 would need to be within the range of a particular species.
However, attenuation of sound means that as distance from the vessel increases, noise levels
would reach values less than those indicated to be source noise levels in Table 12 (e.g. a tug
pulling an empty barge has a source level of 145dB -166dB re 1 Pa at 1m, but at a greater
distance the noise level may be detectable by, for example, salmon (upper hearing threshold of
130dB re 1 Pa)).
6.2.194 The impact of vessel noise would be expected to be smaller than that associated with pile driving,
even though vessel noise may be of a more continuous nature. While it might be anticipated that
there could be a greater effect due to the combination of vessel plus piling noise, it is considered
unlikely that the significance of this cumulative effect would be any greater than that for piling
alone. This is again due to the fact that any fish within the zone of influence would no longer be
present in the affected area or would avoid it while noise levels were raised.

6.2.195 Dredging would only be undertaken for around a month during the construction phase and mobile
organisms can evade the noise source if required. Consequently, noise impacts associated with
dredging are not expected to affect migratory fish species.
Offshore Noise Environment in the Vicinity of the Proposed Jetty
6.2.196 The inter-tidal area in the vicinity of the proposed jetty location consists of a rough rocky wave-cut
platform which is subject to intense wave action over a high tidal range, with substantial boulder,
cobble, shingle and sediment transport. This habitat is, therefore, considered unsuitable for fish
spawning or as a nursery area. It is likely that any fish present would be larger and stronger and
hence able to move independently of tidal activity and currents to avoid noisy activities.
6.2.197 The shoreline to the west of Hinkley Point is predominantly rocky and exposed to extreme wave
action and it is likely that shore and surf noise will be a major contributor to ambient noise in these
coastal waters. The ambient noise will mostly comprise impact noise as the wave hits the rocks,
spray noise as the water falls back onto the sea, bubble oscillation noise and, depending on wave
energy, transport of boulders and cobbles across the wave cut platform and some shingle and
sediment transport noise. The nature of the intertidal zone at Hinkley Point, therefore, maintains
high ambient noise levels (see Table 2 in ES Appendix 10-1, Volume 4 for a comparison of
ambient noise levels and frequencies from different sources in the marine and coastal
environment).
Noise Propagation Underwater
6.2.198 Because sound can interact strongly with the seabed, the sediment types and seabed roughness
can affect propagation loss. Similarly, waves on the surface can also affect propagation loss by
scattering the sound interacting with the surface rather than just reflecting it. Suspended
sediments or bubbles can also cause additional propagation loss.
6.2.199 Because of reflection at the surface of the sea and at the seabed, sound can travel between a
source and receiver by a multitude of paths. This has the effect of dispersing the arrived signal in
time. This effect is particularly important for wideband impulsive sounds such as explosions, pile
driving or seismic exploration air guns.
6.2.200 At high frequencies (>10kHz) increasing absorption prevents sound propagating over great
distances so the ambient noise is dominated by local sound sources such as surf. In coastal
waters, the water is too shallow to support long range propagation of very low frequencies, so the
ambient noise at these frequencies will generally be lower in shallow water.
6.2.201 Intertidal surveys undertaken c.2km east of the proposed jetty location have recorded the
presence of a number of fish species including the Annex 1 species and eel (Ref. 86). The inter-
tidal surveys sampled soft shore habitats within Bridgwater Bay and, while the results provide
some indication of the species present within the area, the proposed jetty is located in an area of
rocky and turbulent inter-tidal conditions (see above) which is likely to be less attractive for these
fish.
Migratory Fish (Pile Driving)
6.2.202 For migratory fish within the range of the works it is certain that an effect would occur but that,
based on hearing range and sensitivity, only species such as twaite shad and allis shad would be
likely to be sensitive to the generated noise levels. For these migratory species, within the
immediate vicinity of the piling it would be expected that some disturbance would occur and,
potentially, if fish were within very close proximity to the piling (i.e. within a couple of metres)

physical damage could occur. However, given the adoption of a soft-start and that at any one
time only a very small percentage of the overall population of the migratory fish species would be
within close proximity to the piling works, the potential magnitude of the impact would be very low.
Once pile driving is initiated then the potential for physical damage effectively ceases as any fish
within the zone of influence (ensonification) would move out of the area to avoid the increase in
noise levels / pressure.
6.2.203 Section 5 of the advice given under Regulation 33(2)(a) of the Conservation (Natural Habitats,
&c.) Regulations (Ref. 30) identifies that shad are considered sensitive to vibration which can
arise from noisy activities. High frequency vibration (70–300Khtz) can be barrier to migration
affecting movement both up and downstream and preventing fish reaching spawning areas.
6.2.204 There is still considerable uncertainty about the effects of piling noise on migratory fish species,
although the available data suggests that levels sufficient to cause serious injury or death are only
likely to occur at distances of less than 5m from the source, and at >400m it is unlikely that
salmon or trout would react at all to vibratory piling. Based on salmonid and clupeid hearing it
can be anticipated that migratory fish in the vicinity of piling activities would be expected to show
avoidance behaviour to noise levels above 90dB, depending on the intensity of background noise.
6.2.205 Anadromous species migrating seaward are unlikely to be prevented from migrating by noise
impacts as the size of seaward migrating salmon (smolts), shads and lamprey means that their
swimming speeds are typically lower than tidal stream velocities. The movements of juveniles of
anadromous species will thus be determined by tidal transport, which means that individuals
would tend to pass the area of disturbance fairly rapidly. In the case of salmon smolts, the
utilisation of the fastest flowing portion of the estuary would ensure animals are rapidly conveyed
past any area subject to disturbance impacts.
6.2.206 The estuary is a known migratory route and, given the designated status and importance of the
migratory fish populations, the disturbance and potential physical impact of piling could be
considered to be an impact of moderate adverse significance. However, given the estuary is
approximately 20km wide at the point of disturbance and that it is unlikely that elevated noise
levels that would lead to avoidance would extend beyond 400m, there would be sufficient space
for any displaced migratory fish to continue migration. Based on the relatively small area of the
estuary that would be impacted during the construction and in particular the piling phase, no
barrier to migration is predicted and an effect on the population through serious injury or death is
considered to be unlikely.
Migratory Fish (Vessel Movements and Dredging)
6.2.207 Migratory fish could similarly be affected by the temporary noise and vibration associated with
vessel movements and dredging. However, the magnitude of these impacts is predicted to be
very low and, given the habituation of many of the migratory species to vessel noise (due to the
environment) and their ability to move away from the noise, no barrier to migration is expected.
IMPACT: Light disturbance during construction
6.2.208 Light is known to have a strong influence on fish behaviour, with photoperiod and artificial
manipulation of this acting as an environmental cue in relation to reproduction, and also as a
factor determining migration. Changes in natural reproductive development rates as a result of
artificial light regimes have been demonstrated for a range of fish species. However, this has
generally been where the light environment experienced by fish is overwhelmingly determined by
that artificial source (e.g. in aquaria, laboratories or fish farm facilities). Light has also been
demonstrated to influence fish migration, with species such as salmon and sea trout migrating

predominantly at night rather than day. Similarly, various species have been demonstrated to
either be attracted to or repelled by light, with the majority being repelled (Ref. 87).
6.2.209 Lighting has the potential to affect the migratory fish species, as they would be present at several
stages (seasonally) during the construction period (due to extend over a period of 15 months).
However, it is anticipated that migratory fish would avoid and / or leave illuminated areas, which
would be restricted to the area immediately surrounding the jetty (as the lighting design would
minimise light spillage). Within the zone of influence immediately around the jetty, light is also
expected to attenuate rapidly in the turbid waters of the estuary and, overall, the magnitude of the
impact is predicted to be very low, such that no barrier to migration is predicted.
Operational Phase
IMPACT: The re-suspension of sediment and physical obstruction during operation
6.2.210 It is possible that maintenance dredging would be required at the berthing pocket to ensure a
minimum depth of 3m, with a requirement to over dredge to a depth of 3.5m. Dredging is likely to
locally mobilise sediments, and potentially contaminants, and re-suspend particulates in the water
column (see ES Chapter 12). Evidence suggests that local changes due to such activities can
result in the deposition of layers of sediment of >5cm over underlying substrates (Ref. 88).
6.2.211 Maintenance dredging could affect the migratory fish species present in the study area during
certain times of year. However, migratory fish would be able to avoid areas of physical
disturbance (and turbid areas), which would only be temporary, short-term (up to one week per
dredging run) and localised. Furthermore, the suspended sediment levels within the estuary and
the area of the berth pocket are high and extremely variable, and the increased levels resulting
from the maintenance dredging would not exceed the natural variation (see Section 6.2a).
Migratory fish are habituated to the changing levels of suspended sediments within the estuary
and, given the variability and short-term nature of suspended sediment levels likely to derive from
the maintenance dredging, no barrier to migration is expected.
6.2.212 The presence of the jetty piles and jetty head within the estuary potentially could result in a barrier
to migration. However, the ‘barrier’ width or extent would be dependent on the state of the tide;
the further out the tide, the smaller the barrier that would be presented. However, given that the
piles are located approximately 8m to 9.5m apart lengthways and perpendicular to the tidal flows,
and would not form an enclosed barrier; the piles would result in an intermittent barrier across 9%
to 11% of the estuary from the jetty head to the shore. Consequently, no barrier to migration
would be expected.
6.2.213 Freshwater (i.e. surface water run-off) would drain from the onshore storage area and discharge
into the Hinkley Point C Drainage Ditch and, ultimately, to the foreshore. There is the potential
that the volumes of freshwater and suspended sediments discharged into the estuary could
increase above the current discharges. Further drainage of freshwater may also be expected
from the foreshore service road which has no developed drainage system. Surface drainage will
be dispersed through lateral soakaway although the volumes from this source are expected to be
very low. Given that potentially significant increases in suspended sediment and freshwater
volumes could arise, these could affect migratory fish species. Because the volume increase of
potential freshwater discharge and the likely suspended sediment of the discharge water
compared to present cannot be quantified, the possibility of a significant impact on migratory fish
species cannot be ruled out.

6.2.214 There is also a potential for run-off waters to contain elevated concentrations of petroleum
hydrocarbons derived from mechanised plant used in the operation of the jetty development.
Run-off of hydrocarbons, particularly from road drainage, may have a deleterious effect on the
water quality status of receiving waters and, hence, impact on migratory fish species. There is
also a potential for contaminants to be associated with run-off from stored materials or from
accidents and incidents, including spillages and leaks of fuels, oils and other chemicals. Because
these are accidental or incidental events the volume and concentrations and types cannot be
quantified, the possibility of a significant impact on migratory fish species cannot be ruled out
without mitigation.
6.2.215 As mentioned in relation to construction impacts above, and in paragraph 6.2.62, a significant
number of mitigation measures have been identified in relation to avoiding (wherever possible)
potential pollution or discharge effects from surface water, or as a result of accidents or incidents,
in addition to measures that minimise the potential volume of discharge and contaminants and
provision of measures to prevent them being discharged into the estuary and hence impacting on
migratory fish. A summary of measures is presented in paragraph 6.2.97. Furthermore, it is
of a discharge consent with the Environment Agency and that potential impacts would be avoided
or reduced such that discharges to the Hinkley Point C Drainage Ditch and into the estuary would
be managed at attenuated run-off rates (including suspended sediment, with any potential
contaminants would be removed), which would result in no change from the existing situation .
Consequently, as no increase (in freshwater discharge volumes, suspended sediments, and
contaminants) would occur, no effect would be expected on migratory fish species from surface
water derived sources.
IMPACT: Noise and vibration during operation of the jetty and berth
6.2.216 Maintenance dredging would produce noise that potentially could affect migratory fish. In
addition, vibration resulting from the operation of conveyor drive units mounted on the jetty, and
possibly from the moving conveyor belt itself, has the potential to cause the vibration of the jetty
infrastructure (e.g. its piles) which could radiate to the marine environment and bedrock.
Vibration could also affect migratory fish when they are present in the study area. However, the
magnitude of vibration is likely to be very low, as the conveyor would be fitted with integral
vibration isolation mounts, and migratory fish would be able to move away from the source of the
vibration. Therefore, overall, the magnitude of the impact is predicted to be very low (particularly
given that the existing environment is subject to wave and tidal movements) within the existing
foreshore environment.
6.2.217 For the purpose of this assessment, it has been assumed that fish would be habituated to the
noise associated with vessel movements.
6.2.218 As described above in relation to construction noise, noise from maintenance dredging could
affect migratory fish present in the study area at certain times of year; however this impact is
expected to be limited because migratory fish would only be affected seasonally. Furthermore,
these species could move away from the source of the noise. Therefore, overall, the magnitude
of the impact is predicted to be very low, i.e. these receptors would experience little or no
degradation and disturbance within the range of natural variability and limited to areas within and
adjacent to the development for the short duration of the dredging.
6.2.219 Overall, migratory fish would experience little or no degradation. The fact that disturbance is
likely to be within the range of natural variability, and given the ability of larger fish to swim away
from the vibration and the temporary nature of the maintenance dredging, indicates that there
would be no barrier to migration for the SAC or Ramsar migratory fish species.

IMPACT: Light disturbance during operation
6.2.220 The operation of the temporary jetty has the potential to cause light disturbance to migratory fish
(assuming that unloading works could occur at any time within any 24 hour period, see ES
Chapter 6). However, although there is the potential for operational lights to be on at any time
over a 24 hour period, such events are likely to be limited in nature and the jetty operational
lighting is designed specifically to prevent light spill.
6.2.221 Migratory fish would only be present at certain times of the year and, therefore, would only
coincide with offloading operations on a limited number of occasions during the eight year
operational life of the jetty. It has also been assumed that migratory fish would avoid and/or leave
illuminated areas, during periods of illumination. Due to the temporary nature of the impact, the
seasonal presence and movement of migratory fish, and the rapid attenuation of light with depth
in the turbid waters, the magnitude of the impact is predicted to be very low and no barrier to
migration is predicted.
IMPACT: The re-suspension of sediment and physical disturbance during jetty dismantling and
restoration (removal and reinstatement)
6.2.222 The primary potential impact associated with the jetty’s dismantling (removal) and site restoration
(reinstatement) works would be the physical disturbance of habitats within the zone of influence,
and re-suspension of sediment resulting in elevated levels of suspended sediments, which could
act as a barrier to fish migration. However, migratory fish would be able to avoid areas of
physical disturbance and only a very small percentage of the sub-tidal habitat would be affected
at any one time (due to pile removal); hence the magnitude of the impact is predicted to be very
low.
6.2.223 The works could result in sediment re-suspension, however, as described in Section 6.2a, the
suspended sediment levels within the estuary and the area of the works are high and extremely
variable, and the increased levels resulting from the works would not exceed the natural variation,
being localised and negligible in scale in comparison with the amount of sediment transport
during differing tide states. Migratory fish are habituated to the changing levels of suspended
sediments within the estuary and, given the variability of suspended sediment levels likely to
derive from the works, no barrier to migration is expected. Hence migratory fish species would
experience little or no degradation as disturbance is likely to be within the range of natural
variability and limited to areas within and adjacent to the development.
salinity, or discharge of contaminants during dismantling and restoration (removal and
reinstatement) activities
6.2.224 Similar to construction (see paragraph 6.2.61) and operation (in paragraph 6.2.214), the
dismantling or removal of the jetty development has the potential to result in run-off of rainwater
and potential contaminants from plant, materials and sediment mobilisation to the estuary and,
hence, impact on migratory fish species (see ES Section 12.5). Contaminants potentially could
be associated with spills and leaks of fuels, oils and other chemicals. However, as for the
construction and operational phases, discharges to the environment would be subject to the
agreement of discharge consent with the Environment Agency and potential impacts would be
avoided or reduced such that discharges to the Hinkley Point C Drainage Ditch and into the
estuary would be managed at attenuated run-off rates (including suspended sediment, with any
potential contaminants would be removed), which would result in no change from the existing

situation; the mitigation measures proposed would be able to meet that requirement. Given this,
no change from the existing situation (ES Section 12.5) and no effect would arise on estuary
features in terms of changing salinity, suspended sediment levels, or increases in concentrations
of potential contaminants.
Mitigation Measures
6.2.225 Other than those mitigation measures identified above in Section 6.2a, no additional measures
are identified in relation to the migratory fish species for which the SAC and Ramsar are
designated.
6.3 Severn Estuary SPA and Ramsar
a) SPA Interest Feature 3: wintering dunlin, SPA Interest Feature 4: wintering

redshank, SPA Interest Feature 5: wintering shelduck, and SPA Interest Feature 7:
Assemblage of waterfowl (and Ramsar Criterion 5 and 6)
Intertidal Birds
Desk Study Information
6.3.1 Baseline intertidal survey data were available from Wetland Bird Survey (WeBS) high and low tide
counts, from the Somerset Ornithological Society. WeBS Core Counts for the five most recent
available years and Low Tide Counts for the most recent available winter were obtained for count
sectors within Bridgwater Bay. The locations of the Count Sectors are shown on Figure 18.27 in
ES Appendix A Volume 4.
6.3.2 Table 14 presents a summary of the WeBS data, which include quantitative information on the
proximity of the Count Sectors to the temporary jetty development; the seasonality of counts; bird
species; designated status; and peak counts for sectors. This is followed by a brief discussion on
the relevance of the WeBS data (along with other previous survey data) in relation to the jetty
development boundary.
6.3.3 In relation to core counts, Count Sector 13411, which covers the majority of Steart Flats more
than 2km to the east of the jetty development, the WeBS data indicates that the cited species of
the Severn Estuary SPA and Ramsar that occur regularly within this extensive mudflat habitat are
wintering dunlin, lapwing, shelduck, golden plover, teal, curlew, wigeon and redshank. On
passage ringed plover generally displays considerable variation between years (peak counts
ranging from 30 - 320).
6.3.4 The low tide count data for 2002/03 for those Count Sectors that form the western part of the
Steart Flats (BV670 and BV691-4 inclusive) indicate that a number of species forming part of the
cited interest of statutorily designated sites occurred in this area, including dunlin, grey plover,
curlew, shelduck and redshank.
6.3.5 The WeBS data do, however, provide an indication of the number of cited species of the Severn
Estuary SPA and Ramsar that occur regularly in the vicinity of the jetty development based on
Count Sectors BV697 and BV696. These indicate that wintering lapwing, shelduck, and pintail
are the dominant species which feed or forage along the intertidal foreshore that directly
encompasses the jetty development during low tides.

Table 14: Characteristics of the Intertidal Count Sectors (CS) for the WeBS data
Count Distance from the Temporary Jetty Site Seasonality Species Status Peak count in
Sector each sector
Wigeon 10
The jetty development boundary is located Low tide counts Nov-Feb SPA
BV697 Curlew 15
within this Count Sector. between 2002/2003
Redshank SPA & Ramsar 1
Shelduck 70
Teal 6
SPA & Ramsar
Pintail 30
Low tide counts Nov-Feb
BV696 2km east Dunlin 10
between 2002/2003
Curlew 16
Mallard SPA 8
Lapwing 4
BV695 1.3km south/east Lapwing SPA 90
between 2002/2003
Mallard 8
SPA
Curlew 50
BV694 3km east Redshank SPA & Ramsar 2
between 2002/2003
Mute Swan Ramsar 2
Golden plover SPA 30
Shelduck SPA & Ramsar 150
Ringed plover SPA & Ramsar 2
Low tide counts Nov-Feb Lapwing SPA 50
BV693 3km east
between 2002/2003 Dunlin SPA & Ramsar 600
Curlew SPA 15
Low tide counts Nov-Feb Dunlin SPA & Ramsar 4,500
BV692 3.3km east
between 2002/2003 Curlew SPA 85

Count Distance from the Temporary Jetty Site Seasonality Species Status Peak count in
Sector each sector

Low tide counts Nov-Feb Mallard SPA 42
BV691 3.6km north/east
between 2002/2003 Dunlin SPA & Ramsar 10,000
Curlew SPA 50
Low tide counts Jan-Feb Lesser black-backed
BV670 3.6km north/east Ramsar 4
between 2002/2003 gull
Bewick`s Swan 0*
European White-
0*
fronted goose
Shelduck 2,900
Gadwall SPA & Ramsar 0*
Teal 1,800
Ringed plover 320
Redshank 950
Large area encompassing the majority of Dunlin 14,500
Steart Flats and lower limits of the River Core counts Pochard 0*
Parrett. July to the following June
13411 Lapwing 8,400
between 2001/02 to
Mallard 180
Western boundary of 13411 is 2km from jetty 2005/06
Tufted duck 0*
development boundary.
Golden plover SPA 1,950
Grey plover 820
Whimbrel 85
Curlew 1,550
Wigeon 950
Mute Swan 1
Lesser black-backed Ramsar
52
gull
* Zero indicates Count Sector surveyed, but species not seen or not counted.

Survey Data
6.3.6 In order that any potential disturbance effects on birds using the intertidal areas and inshore
marine waters adjacent to or in close proximity to jetty development could be evaluated,
additional surveys commissioned by EDF Energy were undertaken between April 2007 and
March 2009 inclusive. These locations, and the areas surveyed from them (Count Sectors), are
shown on Figure 9. The red area on the figure indicates where count sectors overlap and,
consequently, for these count sectors bird counts may be higher than in reality.
Figure 9: Intertidal and inshore marine survey area (including Count Sectors)
6.3.7 All waders, wildfowl and seabirds flying over the intertidal area and the inshore waters up to 500m
from the shore were systematically recorded. The distance of 500m offshore from each location
was selected as the maximum threshold for standard recording on the basis that all relevant bird
species within this distance were generally identifiable in normal sea states and weather
conditions, and accurate and comparable counts could therefore be made. It was also
considered likely that any potential disturbance effects would be most likely to affect birds
occurring in relatively close proximity (i.e. < 500m) from the jetty development.
6.3.8 In total, each of the five survey locations (Sectors 1-5) was visited on 182 occasions between
April 2007 and March 2009. The survey at each of the five locations visited during the survey day
lasted for 45 minutes, resulting in a total of 136.5 hours of survey per point and an overall survey
effort of 682.5 hours. The physical characteristics of the count sectors are summarised in Table
15 which also provides quantitative information on the proximity of the Count Sectors to the jetty
development.

Table 15: Characteristics of the Shore within the Intertidal Count Sectors
Count Distance from the Description of extent and Description of extent and
Sector Temporary Jetty characteristics of shore at characteristics of shore at
Site high water mean low water
1 Jetty development Approximately 10m to 20m of Approximately 350-400m of
boundary lies within sand generally remains exposed open shore with large areas
the eastern offshore on the upper shore throughout of sand bordered to the east
end of the Count much of the sector. A by rock platforms and loose
Sector. strandline, mainly consisting of boulders. Some pools are
Fucoid seaweeds is present. present in the rocky areas,
The area of sand borders a these being dominated by
supralittoral storm beach. The Fucoid seaweeds.
eastern part of the sector has
more rock at high water than
sand.
2 Encompasses the Between 0 and 30m of exposed Slightly in excess of 200m of
Jetty development rock platforms partially covered mainly solid rock platforms
frontage, including by areas of pebble/boulder with some overlying large
the foreshore access storm beach and a strand line loose rocks. Some shallow
route to the jetty. dominated by Fucoid seaweeds. gullies and pools dominated
by Fucoid seaweeds.
3 Adjacent to the A strip of between 0 and 10m of Approximately 400-450m of
eastern end of the loose boulders, some solid rock open rock platforms
Jetty development with pockets of shingle and an traversed by narrow east-
boundary. Furthest intermittent strand line. west bands of sand and mud
boundary limit of and bordered by an
Count Sector 3 is extensive and dynamic area
900m to the east of of open sand and mud in the
the Jetty western part of the count
development sector.
(eastern) boundary.
4 Western limit of A boulder shore/storm beach of Approximately 400-450m of
Count Sector 4 is between 0 and 15m in width, exposed shore featuring a
900m to the east of with a brown seaweed mosaic of areas of open rock
the Jetty dominated strand line. A (particularly around the warm
development relatively linear band of sand water outfall) and extensive
boundary. runs east from the survey mud covered by loose
location parallel to the coastal pebbles and boulders with
defence in front of the built some pools.
nuclear power stations.
5 Western limit of 0 to 5m of sand with occasional Between 700 and 800m of
Count Sector 5 is > boulders and a strand line very extensive open mud.
1km to the east of following neap tides. Some Patchy areas of rock on the
the Jetty areas of boulder shore/storm upper reaches of shore and
development beach in the western part of the in the western part of the
boundary. sector. count sector.

6.3.9 Table 16 provides a summary of the results obtained from the intertidal surveys undertaken
between April 2007 and March 2009 inclusive. The figures show the peak number of each
species recorded in each count sector (excluding counts of birds flying through the area). For
each species a description of the level and type of use (foraging, roosting, etc.) in each count
sector is also provided.
6.3.10 In summary, survey data for Count Sectors 1-3, which adjoin or are located close to the jetty site
(see Figure 9), indicate that the cited species of the Severn Estuary SPA and Ramsar site that
occur regularly in the vicinity of the application site are wintering shelduck, wigeon, pintail and
curlew, and passage whimbrel and ringed plover. However, apart from the occasional large flock
of shelduck offshore of the site and use of the foreshore by small numbers of wigeon, only very
limited use of the intertidal area fronting the jetty development was made by other species of
waterbirds (Table 16). Similar results were also obtained by the WeBS data (see Table 14).
6.3.11 Shelduck were recorded on a regular basis throughout the survey period. The largest numbers
occurred between July and September to the east of the Hinkley Point Power Station Complex,
with the intertidal area fronting the jetty site receiving relatively low level use by this species.
Congregations of birds were seen loafing on the sea in all count sectors during high water,
although no regular onshore roost sites were identified. Wigeon were recorded consistently
during the autumn and winter, with the largest numbers between the months of November and
February inclusive. The largest numbers of foraging birds were recorded to the east of the
Hinkley Point Power Station Complex, with low level use in Count Sectors 1-3. Intertidal habitat
in Count Sector 1 was identified as a regular roost site for passage ringed plover and that in
Count Sector 4 for curlew.
Use of Coastal Fields by Birds
Desk Study Information
6.3.12 A series of field walkover surveys were conducted over successive winters in connection with the
West Hinkley Wind Farm application, submitted in December 2006. Survey effort included 12
survey visits between October 2003 and March 2004, a further 18 survey visits between August
2004 and March 2005, and six survey visits in March 2006. The survey area covered the
northern half of the Hinkley Point C Development Site, plus a perimeter area extending to
(approximately) Little Dowden Farm in the east and Newnham Bridge and Burton to the south.
The area surveyed extended at least 1.5km to the west of the Temporary Jetty Site.
6.3.13 The following information has been summarised from the survey work undertaken for the West
Hinkley Wind Farm ES in relation to SPA / Ramsar designated species:
• Shelduck were recorded in large concentrations during all three phases of survey (i.e.
2003/04, 2004/05, 2006) in the western part of Steart Flats (intertidal habitat east of the
temporary jetty and power stations) and in small numbers on the foreshore in close proximity
to the Temporary Jetty development boundary;
• Teal were recorded infrequently during the 2003/04 and 2004/05 winter bird surveys, but
were observed in large numbers in March 2006 around the outfall at Hinkley Point and the
open mud flats to the east;
• Shoveler were not recorded during the 2003/04 and 2004/05 winter bird surveys, however
small counts were recorded with teal around the outfall and at Hinkley Point; Curlew were
recorded regularly in the intertidal habitat directly adjacent to Hinkley Point A and B Stations
and exceeded the 1% SPA Review population during six of the seven survey visits; and

Table 16: Level and Type of Use by Each Bird Species in Each Count Sector
Species Status Peak count in each sector Type and level of use
(2007-2009)
CS1 CS2 CS3 CS4 CS5
Shelduck were recorded on a regular basis throughout the survey period, with the largest
numbers occurring between July and September inclusive. The largest numbers of
SPA foraging birds were recorded on the mudflats in CS5 at low water, with smaller numbers
Shelduck 33 500 200 71 700
Ramsar regularly seen in CS4. CS1, 2 and 3 received relatively low level use of the intertidal
habitat by this species. Congregations of birds were seen loafing on the sea in all count
sectors during high water although no regular onshore roost sites were identified.
Wigeon were recorded consistently during the autumn and winter, with the largest
numbers between the months of November and February inclusive. The largest numbers
Wigeon SPA 39 17 67 220 204 of foraging birds were recorded in CS4 and CS5, with low level use in the other count
sectors. Congregations of loafing birds were noted at high water in CS4 and CS5,
although no regular roost sites were found.
SPA Teal were recorded very sporadically during the survey period (on a total of five survey
Teal 0 1 0 25 14
Ramsar dates), with none noted during the second survey year (April 2008 to March 2009).
Relatively low level use by mallard was recorded in all months of the year, and throughout
Mallard SPA 33 4 3 2 51
the survey area, with the largest numbers of foraging and loafing birds in CS4 and CS5.
Pintail were recorded on a regular basis between the months of September and March
inclusive. The majority of foraging birds were seen in CS4 and CS5 at low water, with
SPA
Pintail 0 4 60 35 48 birds moving onto the sea nearby to loaf at high water. There was an intermediate level of
Ramsar
use in CS3, low level use in CS2 and no pintail recorded in CS1. No regular roost sites
were identified.
Use of the survey area by shoveler was infrequent (all during winter), and no large flocks,
Shoveler SPA 0 0 4 0 4
roosting or foraging birds were recorded.

Species Status Peak count in each sector Type and level of use
(2007-2009)
CS1 CS2 CS3 CS4 CS5
Ringed plover were recorded in all months of the year, with foraging associated with the
SPA
Ringed Plover 33 16 4 10 4 open mobile sand in CS1, with most roosting birds also recorded in this sector. Low level
Ramsar
use was recorded in the other count sectors.
Grey Plover SPA 3 1 0 0 0 Occurrence of grey plover was very sporadic (recorded on two survey dates).
The vast majority of lapwing were recorded (roosting and foraging on intertidal habitat) in
Lapwing SPA 2 0 35 3 102 CS5 between the months of November and February inclusive, with very low level use in
the other count sectors.
Dunlin were recorded foraging on intertidal habitat sporadically in small numbers, primarily
SPA
Dunlin 7 13 0 0 9 during the autumn passage period between July and September inclusive. One roosting
Ramsar
bird was noted on one date.
Whimbrel were predominantly recorded during the spring passage period, with most birds
noted between mid April and mid May. Return passage (in smaller numbers) was
Whimbrel SPA 1 5 1 4 16
recorded in July and August. Foraging birds were noted in all count sectors, although the
vast majority were in CS5.
Curlew were consistently recorded throughout the survey period. Numbers were lowest
between April and June, being considerably higher during other months of the year. The
Curlew SPA 16 24 25 41 63
open mud in CS5 attracted the majority of foraging birds and roosting was mainly
recorded in CS4.
Redshank were recorded intermittently in very small numbers throughout the survey
SPA
Redshank 1 1 1 1 22 period. Redshank were most consistently seen foraging on intertidal habitat in CS4 and
Ramsar
CS5, with few records from the other count sectors.

• Flocks of golden plover (peak count 332) and lapwing (peak count 106) were recorded in
arable fields west and south of the Temporary Jetty Site and on Wick Moor (south of the built
power station) respectively in March 2006. These records coincided with a period of very
cold weather. There were a small number of additional counts in excess of 100 birds (of both
species) over the survey period. This sporadic occurrence of relatively large flocks was
considered to reflect the fact that birds moved into the area in cold weather and as a result of
more local movements associated with the known flock at Pawlett Hams (Ref. 89).
Survey Data
6.3.14 Field surveys began in September 2007 (with the frequency increased in November 2007) and
continued through until March 2009. A total of 72 surveys were undertaken during the survey
period. Generally the survey was completed during one day, but when poor weather conditions
made this unachievable the next available opportunity (usually the following day) was used to
complete the work. Table 17 presents a summary for the most notable results of the field surveys
(those concerning species forming part of the cited interest of the designated SPA / Ramsar
sites). Figures 3.5a and 3.5b in ES Appendix 11-3, Volume 4 provide detailed information on
the locations and numbers of species recorded during the field surveys.
Table 17: Summary of field survey
Field Distance from the Temporary Seasonality Species Status Peak count
Site Jetty development
700m east of the jetty
Sept 2007- SPA
93 development boundary Gadwall 1
Mar 2008 Ramsar
(Sewage works pool)
Sept 2007-
700m east of the jetty 70
Mar 2008 SPA
93 development boundary Teal
April 2008 - Ramsar
(Sewage works pool) 110
Mar 2009
Sept 2007-
1km southeast of the jetty 18
Mar 2008
81 development boundary (Wick Mallard SPA
April 2008 -
Moor, drainage ditches) 6
Mar 2009
>800m from southern boundary
Sept 2007-
48 limits of the jetty development Lapwing SPA 67
Mar 2008
boundary
1km south/east of the jetty
Sept 2007-
81 development boundary (Wick 21
Mar 2008
Moor, drainage ditches) Curlew SPA
Adjacent to jetty development April 2008 -
17 20
(western) boundary Mar 2009
Sept 2007-
Lapwing SPA 19
Mar 2008
Adjacent to jetty development
16 SPA
(western) boundary April 2008 - Redshank 1
Ramsar
Mar 2009
Lapwing SPA 70
Within jetty development
April 2008 -
1 boundary (adjacent foreshore Curlew SPA 15
Mar 2009
access road)

Field Distance from the Temporary Seasonality Species Status Peak count
Site Jetty development
April 2008 - SPA
2 boundary (adjacent foreshore Shelduck 5
Mar 2009 Ramsar
access road)
April 2008 - SPA
Mar 2009 Ramsar
access road)
April 2008 - SPA
Mar 2009 Ramsar
access road)
Nocturnal Surveys
6.3.15 A total of 26 nocturnal surveys were undertaken between December 2007 and March 2009
(between December 2007 to May 2008 and August 2008 to March 2009). Overall, these surveys
provided no evidence to suggest that the fields or adjacent upper intertidal habitat were being
regularly used by large numbers of roosting or foraging birds.
6.3.16 Figures 3.7a and 3.7b in ES Appendix 11-3, Volume 4 show the approximate locations of
species recorded during the nocturnal surveys concerning those species forming part of the cited
interest of the designated SPA / Ramsar sites. Table 18 presents the (notable) results of the
surveys in winter 2007/08 and 2008/2009.
6.3.17 Roosting flocks of wildfowl (SPA assemblage species) were recorded in relatively low numbers
for both survey periods (2007/08 and 2008/09) along the intertidal foreshore fronting and to the
east and west of the Jetty development boundary (Count Sectors 1–3), with the exception of
shelduck and curlew. These species appear to roost in moderate numbers within Count Sector 1
which was observed for both survey periods.
6.3.18 Similar to the field surveys, the majority of cited species of the Severn Estuary SPA and Ramsar
were observed roosting within the fields of Wick Moor (North Moor), with relative few species
roosting within the fields associated with the Jetty development.
Trends in Ornithological Interests of Designated Sites
6.3.19 The collection of WeBS Data allows conclusions to be drawn at estuary level with regard to short
term (5 year), medium term (10 year) and long term (25 year or maximum available period) trends
in the numbers of individual qualifying and assemblage species. These results have recently
been subject to detailed evaluation for estuarine SPAs and SSSIs across the UK (Ref. 90). The
aim of this work is to establish a framework that can be used to alert conservationists to ‘real’
declines in bird populations that require targeted action (as opposed to natural fluctuations).
6.3.20 At the time that the impact assessment for the Hinkley Point C Project was produced, the most
recent available information was Waterbirds in the UK 2006/07, which summarises data between
April 2001 and March 2007 (Ref. 91).

Table 18: Summary of nocturnal surveys
Site Distance from the Seasonality Species Status Total count

Temporary Jetty
Site
SPA
Shelduck 19
Ramsar
Dec 2007 - SPA
Ringed plover 1
May 2008 Ramsar
Curlew SPA 2
Jetty development Grey plover SPA 1
boundary lies within Mallard SPA 1
Count Grey plover SPA 1
the eastern offshore
Sector 1 SPA
end of the Count Ringed plover 1
Sector. Ramsar
Aug 2008 - SPA
Mar 2009 Teal 1
Ramsar
SPA
Shelduck 24
Ramsar
Curlew SPA 15
SPA
Shelduck 4
Ramsar
Dec 2007 -
SPA
May 2008 Ringed plover 1
Encompasses the Ramsar
jetty development Curlew SPA 1
Count
frontage, including Curlew SPA 1
Sector 2
the foreshore access Mallard SPA 1
route to the jetty. Aug 2008 - Lapwing SPA 3
Mar 2009 Whimbrel SPA 1
SPA
Ringed plover 1
Ramsar
SPA
Shelduck 2
Adjacent to the Ramsar
eastern end of the Dec 2007 - SPA
Ringed plover 1
Jetty development May 2008 Ramsar
boundary. Furthest Curlew SPA 1
Count boundary limit of Mallard SPA 1
Sector 3 Count Sector 3 is Curlew SPA 1
900m to the east of SPA
Ringed plover 1
the Jetty Aug 2008 - Ramsar
development Mar 2009 Grey plover SPA 1
(eastern) boundary. SPA
Dunlin 1
Ramsar

Site Distance from the Seasonality Species Status Total count
Temporary Jetty
Site
Wigeon SPA 3
Dec 2007 - Curlew SPA 1
May 2008 SPA
Ringed plover 1
Ramsar
Western limit of
SPA
Count Sector 4 is Ringed plover 2
Ramsar
Count 900m to the east of
SPA
Sector 4 the Jetty Redshank 1
Ramsar
development Aug 2008 -
Whimbrel SPA 1
boundary. Mar 2009
Grey plover SPA 1
Curlew SPA 1
SPA
Shelduck 5
Ramsar
SPA
Ringed plover 1
Ramsar
Dec 2007 - Curlew SPA 1
May 2008 Wigeon SPA 1
Western limit of
SPA
Count Sector 5 is > Redshank 1
Ramsar
Count 1km to the east of
Lapwing SPA 1
Sector 5 the Jetty
SPA
development Redshank 1
Ramsar
boundary. Aug 2008 -
SPA
Mar 2009 Ringed plover 2
Ramsar
Grey plover SPA 1
Curlew SPA 2
Mallard SPA 14
Dec 2007 - Lapwing SPA 4
North Moor / Sewage
May 2008 SPA
works pool, 700m Teal 3
Ramsar
Field sites east of the Jetty
Mallard SPA 14
development
Aug 2008 - Lapwing SPA 34
(eastern) boundary
Mar 2009 SPA
Teal 4
Ramsar
6.3.21 The qualifying number of birds in the respective SPA and Ramsar assemblages are quoted as
being 84,317 and 70,919 individuals respectively. WeBS data for the most recent five years
(between 2001/02 and 2006/07 indicates a peak mean population of 68,769 birds in the estuary.
The effect on the baseline level of use of the survey area at Hinkley of a decline in numbers of
birds using the estuary will depend on population dynamics and distribution of individual species.
As a result it is probably better to consider predicted trends on a species rather than assemblage
level.
6.3.22 The data indicates that sustained declines (of 35-76% since designation) have occurred within the
Severn SPA (i.e. within the site rather than the SPA species themselves) in the following species:
Bewick’s swan, white-fronted goose, pochard, and dunlin (although there has been a short term
partial recovery in Bewick’s swan numbers). In contrast, shelduck, wigeon, gadwall, pintail,
shoveler, tufted duck, and redshank have shown sustained increases (8-124% respectively),

while numbers of other species have fluctuated, with curlew showing an 18% (net) decrease, and
mallard and teal showing respective 24% and 28% net increases since designation. Lapwing
numbers are considered to have remained stable during the period (Ref. 90).
6.3.23 The declines in white-fronted goose and Bewick’s swan seem unlikely to be reversed in the short
term, as they have been linked to wider climatic change. Numbers of wintering white-fronted
geese in the UK were at their lowest ever recorded level in 2006/07, and while this may in part
reflect lower numbers due to poor breeding success, the main reason is that the centre of
distribution of the wintering population is shifting gradually eastwards. There is also evidence to
suggest that Bewick’s swan too are remaining further east and those that are coming to the
Severn are staying for a shorter period before moving back east (Ref. 91). This suggests that it is
unlikely that either species (neither were been recorded during the survey work) will make greater
use of the area in the foreseeable future.
6.3.24 The five-year peak mean of wintering shelduck recorded in the Severn SPA between 2001/02 and
2006/07 (3,492 individuals) was broadly similar to the qualifying number quoted in the SPA
citation (3,330 birds). At national level there was a decline in wintering numbers during the
1990s, and overall numbers are relatively low at present (e.g. the peak combined UK site count
for 2006/07 was the lowest for 30 years) (Ref. 91). Recent counts indicate that the population
may now be stable, which suggests that the baseline information collected for the site is relevant
to at least the short term situation. If further population trends emerge, any perceptible changes
(which given inter-annual variation in use would be very difficult to detect) would be most likely to
affect shelduck numbers in, or frequency of use of, Count Sector 5.
6.3.25 Fluctuations in the wigeon population may become more evident over time, as mild winters are
likely to result in a larger number of birds remaining in the North Sea and the Baltic. The winter of
2006/07 was particularly poor for wigeon at the national level. Despite this, however, numbers
increased in the Severn Estuary (Ref. 91). If this trend were to continue, then the Severn would
become a proportionately more important wintering area for this species, and larger numbers of
birds would be expected in regularly used parts of the survey area (Count Sectors 4 and 5).
Shoveler, which has undergone a considerable increase in the Severn since the designation of
the SPA, has been present in internationally important numbers during the most recent winters for
which data is available (2005/06 and 2006/07) (Ref. 91). This suggests that the species could be
added to the main qualifying interest of the SPA and Ramsar Site at the next review. Numbers
recorded during the baseline survey work have been very low, however, and it is unclear if any
increase at the estuary level would result in the species making greater use of the area around
Hinkley. It would be expected that any increases would be more obvious in parts of the SPA
where shoveler already occur (such as along the River Parrett).
6.3.26 Numbers of wintering pintail have been subject to long term increase at national level, although
recent fluctuations make the current population trend difficult to discern. At the estuary level, the
five-year mean and the peak count of 1,161 individuals in January 2007 (Ref. 91) are both well
above numbers quoted in the SPA Review. Gadwall, in contrast, has shown a recent decline in
numbers at both national and estuary level. The 5-year peak mean of 255 individuals is almost
10% lower than the numbers when the site was designated (Ref. 91).
6.3.27 Teal numbers have been subject to recent fluctuations (following a period of increase), and
current population trends at UK level are unclear, although the peak count in the Severn in
2006/07 exceeded that in three of the previous 4 winters. Given these results, it seems
reasonable to assume that use of Count Sectors 4 and 5 by pintail is likely to remain similar or to
increase, that future levels of use of the local area by teal will remain relatively constant or
decline, while the frequency of occurrence of gadwall (which was recorded on only one occasion
in 2 years of survey work) is unlikely to increase in the foreseeable future.

6.3.28 Wintering mallard numbers have been in steady decline at national level for a number of years.
The reasons for this decline are not fully understood, although various theories have been
postulated that might account for it (including a decline in immigrant birds and fewer captive-bred
birds being released). It is unlikely that this national decline, if reflected on the Severn, would
result in a clearly perceptible change in numbers of birds recorded within the survey area.
6.3.29 Dunlin numbers have been in long term decline in the UK, and in winter 2006/07 the total
recorded was at the lowest level since 1970 (when far fewer sites were counted). This decline is
reflected in the peak count for the Severn of 16,625 individuals in December 2006 and the current
5-year peak mean of 21,430 birds (over 3,500 birds less than are listed as occurring in the Severn
Ramsar Site description). Assuming these trends are continued, it is unlikely that there would be
a perceptible change in use of the survey area by dunlin (due to the very low levels of use
recorded during the baseline work).
6.3.30 Whimbrel numbers also appear to have fallen considerably in comparison with the population
level quoted in the Ramsar description (333 individuals), with a peak mean of 189 for the past 5
years, and no individual annual counts exceeding 240 birds. If a continued downward trend is
assumed, over time it would be expected that numbers of birds recorded in Count Sectors 4 and
5, where they were most regularly recorded during baseline work, would fall.
6.3.31 Curlew numbers are currently considerably lower in the Severn SPA than are quoted in the
Ramsar citation (3,903 individuals). However, the 5-year peak mean of 2,974 birds is still clearly
in excess of the number of individuals quoted in the SPA Review (2,021), which recommended
that curlew be elevated to SPA qualifying species status. Against a national background of 5
years of decline in curlew numbers (between 2000/01 and 2005/06) which has only recently
started to “bottom out”, this suggests that curlew should be added to the main qualifying interest
of the SPA and Ramsar Site at the next review. Given the apparent short term stability in terms
of numbers, use of the survey area is likely to remain relatively consistent with that recorded
during baseline work, with the greatest use occurring in Count Sector 5.
6.3.32 Redshank numbers appear to have remained relatively stable since the SPA was designated, as
the most recent 5-year peak mean is 2,312 individuals (and the SPA qualifying population is listed
as 2,330 birds). Against a recent background of falling numbers at the UK level, this suggests
that a stable population in the Severn Estuary would become proportionately more important over
time. Given the very limited use of the survey area around Hinkley, however, this is unlikely to
have a bearing on the assessment.
6.3.33 Passage ringed plover numbers fluctuate considerably between years, although some
incongruities in the WeBS data may reflect the fact that counts do not necessarily always coincide
with the relatively short periods when peak numbers are present. On the Severn a count of 1,453
individuals in August 2006 was more than double the peak count for 2005. This indicates that
passage ringed plover numbers can comfortably exceed SPA qualification levels, and that the
species could potentially be added to the SPA and Ramsar Citations at the next review. In terms
of the Hinkley area, it is likely that in years when numbers of this species on passage are high
there will be a higher incidence of activity in Count Sectors 1 and 2.
6.3.34 WeBS Data indicates that the Severn is clearly of national importance for black-tailed godwit (the
national threshold of importance is 150 birds), as the 5-year peak mean count is 383 birds.
Indeed during winter 2003/04 the peak count of 540 black-tailed godwit on the Severn exceeded
the threshold of international importance (470 birds). Over the course of the baseline survey work
in the Hinkley area, however, black-tailed godwit was recorded extremely sporadically and in
variable numbers, and in this context it is not considered that an upward trend in numbers at

either UK or estuary level would necessarily be detectable against the background level of low
and infrequent use.
6.3.35 It is acknowledged in the WeBS report that trends in lapwing numbers cannot be inferred from the
data gathered. Spotted redshank, greenshank, ruff and water rail have not been considered here
due to the very low incidence or complete absence of records during the baseline work. It should
also be noted that reliable interpretation of trends in gull numbers based on WeBS data is not
possible (as counting gulls is optional during counts), and has not been attempted here.
Sensitivities and Assessment of Effects
6.3.36 The potential exists for the jetty structure to lead to the loss of habitat that may be utilised by
waterbirds that form part of the SPA and Ramsar interest species and populations. Discharges
into the intertidal zone from land-based works could also lead to a change in conditions, such that
there is a reduction or change in the availability of habitat utilised by foraging birds.
6.3.37 Disturbance due to noise, light and visual disturbance associated with jetty construction,
operation and dismantling (removal) could also affect SPA and Ramsar interest species. Based
on the Severn Estuary SAC, SPA and Ramsar Site Regulation 33 Advice from County Council of
Wales (CCW and Natural England (Ref. 30), overwintering birds (Bewick’s swan, European white-
fronted goose, gadwall, shelduck and redshank) may be disturbed by sudden movements and
sudden noises. This can displace the birds from their feeding grounds. Disturbance can prevent
the birds from feeding and, in response. they may either:
a) decrease their energy intake at their present (disturbed) feeding site through displacement
activity; or
b) move to an alternative less favoured feeding site. Such a response affects energy budgets
and thus survival.
6.3.38 There is intermittent disturbance from both the landward and seaward side of the Severn Estuary
SAC, SPA and Ramsar Site. Bewick’s swan, European white-fronted goose, dunlin, shelduck,
redshank and gadwall are considered to be moderately vulnerable to noise and visual disturbance
on the intertidal mudflats and sandflats and have a high vulnerability to this category of operation
on saltmarsh (Ref. 30).
6.3.39 There is intermittent disturbance to the internationally important migratory species (European
White-fronted goose, dunlin, redshank, shelduck, gadwall, curlew and pintail) and the waterfowl
assemblage from both the landward and seaward side of the Severn Estuary SAC, SPA and
Ramsar Site, which has increased in recent years due to the estuary becoming more populated
and the development of all weather recreational pursuits. All bird species are considered to be
sensitive to noise and visual disturbance along the Severn Estuary SAC, SPA and Ramsar Site
(Ref. 30); albeit dependent on the species and the type of noise (e.g. birds are highly sensitive to
the noise of shooting) or visual disturbance (e.g. birds are more sensitive to dogs than humans,
and less sensitive to boats).
6.3.40 Studies on bird disturbance (e.g. Laursen et al. 2005 (Ref. 94)), have shown that the disturbance
response of waterbirds to construction activity is variable, but general effects are predominately
confined to areas within 250m of the source of the disturbance. To assist in the assessment of
effects, and taking into account the potential complexity of defining disturbance zones, a core
zone of sensitivity to disturbance of 250m for the majority of waterbird species has been utilised
and 500m for species known to be of greater sensitivity to disturbance.

Construction Phase
IMPACT: Noise, lighting and visual disturbance during construction
6.3.41 There is the potential for birds using the intertidal areas close to the site to be adversely affected
by noise (see ES Chapter 20), lighting and visual disturbance (see ES Chapter 21) during
construction of the jetty and associated landward activities.
6.3.42 The key activities during construction that are likely to cause disturbance to birds feeding or
roosting on the intertidal habitat are piling for the jetty approach bridge and jetty head, and
associated works to construct the jetty, and the movement (and operation) of construction
machinery and workforce across the intertidal zone and jetty. Disturbance may reduce the
feeding efficiency of birds and either force them to seek alternative feeding areas or increase their
food-intake rates. Repeated disturbance may lead to birds not being able to maintain energy
levels which, in turn, may affect reproductive success and/or survival, particularly during cold
winter weather when energy requirements are at their highest.
6.3.43 As set out above, survey data for Count Sectors 1-3, which adjoin or are located close to the site
(see ES Table 11.8 and Figure 11-1, Volume 3), indicate that the cited species of the Severn
Estuary SPA and Ramsar site that occur regularly in these areas are wintering shelduck, wigeon,
pintail, and curlew, and passage whimbrel and ringed plover. Very low (single digit) numbers of
teal, shoveler, grey plover, lapwing, dunlin, and redshank were also recorded in some or all of the
count sectors.
6.3.44 In assessing what are likely to be the impacts of this disturbance during construction,
consideration has been given to:
• the potential for activities to generate disturbance effects;

• the numbers and distribution of wading birds and wildfowl recorded during the survey period
(as summarised above and detailed in ES Appendix 11-3, Volume 4);
• the extensive area of similar inter-tidal habitat in the vicinity of the site (and further afield but
still within the Severn Estuary SPA and Ramsar Site) that could be used by any birds that are
disturbed;
• the temporary nature of the works;
• the very low to low noise magnitude levels that are predicted to occur along the coastal
footpath (see ES Chapter 20); and
• evidence from other studies of the impacts of disturbance on birds using inter-tidal areas.
6.3.45 Collectively, the impact of disturbance effects during the construction phase of the jetty is likely to
be influenced by the presence locally of alternative feeding and roosting areas within the existing
home ranges of the individuals using Count Sectors 1 - 3. Given the infrequent nature of the
usage of these areas and the small numbers of birds usually recorded within them, it is apparent
that Count Sectors 1 - 3 do not make up a core foraging or roosting area for any of the designated
species. Therefore it can be concluded that the displacement of birds from Count Sectors 1 – 3
would not result in abandonment of usual home ranges, thereby reducing the potential for a
detectable effect on either individuals or the SPA population being realised.
6.3.46 Although activity close to the jetty development site may cause birds to stop feeding and
potentially take flight, they are likely to settle on nearby intertidal habitat areas further from the
disturbance event (see Figure 10 and Table 19). This aspect is discussed below in the context

of the individual assessments for each of the regularly occurring designated SPA / Ramsar
species that occur with regularity in the vicinity of the works.
Table 19: Areas of bird disturbance associated with jetty construction works for Count
Sectors 1 - 3 of the intertidal/foreshore bird survey for Bridgwater Bay
Count Area of Jetty construction works

sector intertidal
Area of % of Area of % of
(ha)
disturbance at disturbance at
CS CS
250m distance 500m distance
(ha) (ha)
1 33.05 6.17 19 18.07 55
2 17.70 5.71 32 10.38 59
3 34.10 0 0 0 0
6.3.47 Shelduck: The data for count sectors 1-3 show that when large numbers of shelduck were
observed close to the jetty construction area they were always roosting on the water (during their
moult) and were usually at some distance from the shore (between 200m and 1.5km). As
previously documented, beyond 250m human activity has only a limited effect upon some species
of birds. At the distance range of the observed flocks of shelduck it is likely that many of the birds
would be beyond any zone of potential disturbance. It is also of relevance that birds on open
water are less likely to be disturbed by activities on land than they would be from water-based
activities, particularly in this instance where large expanses of open water are available adjacent
to the jetty construction area. Shelduck are also an adaptable species and can move from
intertidal areas to the water if disturbed (Ref. 95).
6.3.48 If roosting (moulting) shelduck were disturbed by the construction activities, they would be able to
move away from the area of disturbance with little energetic expenditure as at most states of the
tide they would be able to make use of water flows to float either down or upstream of the
disturbance source. Moreover, an extensive area of open water would be available which birds
displaced from the area of disturbance could relocate to. It is also relevant to note that the
proposed capital dredging works avoid the period that moulting shelduck are on the water
(between July and September) and, as far as possible, working methods would be designed to
avoid impacts on them.
6.3.49 Taking these aspects into account along with their reduced sensitivity to disturbance whilst on
water, while disturbance to shelduck on the water could occur as a result of construction
activities, such disturbance would only affect birds within 500m of the shoreline and in responding
to the disturbance it is unlikely that their energy expenditure would be of sufficient significance to
have a detrimental effect upon their longer term survival.
6.3.50 Of the 40 records of shelduck within Count Sectors 1, 2, and 3, ten were of birds flying across the
area without landing. During activities that may cause disturbance, the displacement of such
commuting birds is not likely to result in a significant impact on individuals and hence local
populations, particularly as there is alternative habitat within their home range adjacent to the site.
This is because the energetic demands required to divert course by a few hundred metres (in the
event that individuals reacted to the source of disturbance) would be unlikely to be significant
such that it would reduce the fitness of any individual birds.

Figure 10: Potential bird disturbance zones within close proximity to the temporary jetty and seawall

6.3.51 There were 15 records of shelduck using the exposed intertidal habitats within Count Sectors 1, 2
and 3. Of these birds, all were roosting, except for a single feeding bird. The numbers of birds
present at any one time varied between 1 and 35 with a median of 5 and a mean of 9. Of these
records, only two come close to or exceed 1% of the SPA population - the remaining 13 records
range between 0.03 - 0.42% of the SPA population. Although peak numbers were occasionally
high (i.e. 1% of SPA population), on the majority of visits, zero to very few birds were recorded. It
is therefore likely that no birds are permanently resident within Count Sectors 1 to 3.
Furthermore, as the difference between peak and mean numbers is so great, it is likely that Count
Sectors 1 to 3 do not represent a core foraging, loafing or roosting area.
6.3.52 Invariably some shelduck would be displaced from the intertidal area during the construction
period for the temporary jetty. However, given the sporadic use of the area (shelduck were
present in intertidal habitats on only 34% of survey visits) and the number of individuals likely to
be affected at any one time would be small. Any individuals subject to disturbance effects would
be able to move the relatively short distance (several hundred meters at most) from the
immediate vicinity of the disturbance source to surrounding undisturbed habitats within their home
range, which survey data indicates shelduck already use extensively.
6.3.53 Wigeon: Given the low and sporadic use of intertidal habitats within close proximity to jetty
construction (Count Sectors 1-3), with the majority of foraging and loafing birds observed in Count
Sectors 4 and 5, disturbance from construction of the jetty is unlikely to cause any detectable
effect upon wigeon or their usage of the area. Potential disturbance effects generated by the
construction activities are therefore considered not to be significant with respect to the SPA
population.
6.3.54 Pintail: Sporadic use by a small number of pintail was recorded for the intertidal habitats in close
proximity to the jetty construction site (Count Sectors 1-2), with the majority of foraging and
loafing birds observed in Count Sectors 3, 4 and 5. A peak of 60 birds was recorded in Count
Sector 3, representing approximately 5% of the peak number (Ref. 96). Count Sector 3 lies
outside of the 500m zone of potential disturbance. Based on this data, therefore, construction of
the jetty is therefore unlikely to cause any detectable effect upon pintail usage of the area and
potential disturbance effects generated by the construction activities are considered not to be
significant with respect to the SPA population.
6.3.55 Curlew: The majority of curlew were recorded either flying through the area or feeding and
roosting, with the majority of the recorded birds occurring in Count Sectors 4 and 5, further to the
east and away from areas of potential disturbance form jetty construction. The peak numbers
noted in count sectors 1-3 range from 16-25 respectively, representing approximately 0.5% of the
population quoted in the Ramsar citation and approximately 1% of the population quoted in the
SPA review (Ref. 97). Mean numbers show that overall usage is significantly lower than peak
usage.
6.3.56 It is likely that curlew forage widely over the entire Hinkley frontage, although the survey data
shows a preference for the muddier substrates to the east (Sectors 4-5). As such, it is considered
that habitat along the entire frontage is suitable for use by this species. While disturbance effects
could occur during construction with regard to this species (the flushing distance of 300m
recorded for curlew (Ref. 98) suggests that it may susceptible to disturbance by human activity),
habitat for any displaced individuals is available within areas in close proximity to Sectors 1-2 and
areas (within existing home range areas) in Sectors 3-5 are located greater than 500m from the
works. Taking into habitat availability and the observation that usage by this species is generally
low across the western half of the frontage, it is considered that although birds may be disturbed
during construction of the jetty it is unlikely that this would be of significance at the SPA
population level.

6.3.57 Whimbrel: These species were noted on summer passage in Count Sectors 1-3 (within close
proximity jetty construction), but in very small numbers (i.e. a maximum of 5), with most of the
birds flying through or loafing rather than foraging. There was no specific use of any one location
within the site by the species, although counts of foraging birds were much greater in Count
Sector 5. This suggests that only occasional and opportunistic use of the foreshore at Hinkley
Point is made by this species. Given the very low and sporadic use of the foreshore fronting the
development site by this species, potential disturbance effects generated by the construction
activities are considered not to be significant with respect to the SPA population.
6.3.58 Ringed plover: were noted most often in Count Sector 1 feeding on the mobile sands. In Count
Sectors 2 and 3, the level of occurrence was sporadic. In Count Sector 1 the peak count
exceeded 1% of the SPA population. However, on all but 5 of 46 occasions when the species
was recorded, numbers were much lower (five birds or less). As the numbers are small it is likely
that the foreshore habitats in Count Sector 1 provide only a small foraging area relative to other
areas within the Severn Estuary. As shown in Table 19, 80% of the area of Count Sector 1 is
located greater than 250m from the proposed jetty site and 45% of the zone falls outside 500m.
This suggests that if ringed plover present in Count Sector 1 were disturbed, there would still be
significant area available to them within the sector in which to relocate. Notably there are also
extensive areas of similar habitat to that present in Count Sector 1 immediately to the west into
which birds could also relocate. On this basis, it is considered that, while the foreshore to the
west of the jetty site may sometimes support significant numbers (1% of SPA population) of
ringed plover, these birds are largely located in an area that would fall outside of the zone of
potential disturbance of the works (>250m). Any potential disturbance effect on this species is
therefore considered to be of limited extent and not significant with respect to the SPA population.
6.3.59 Teal: Sporadic use by a small number of teal was made of the foreshore in Count Sectors 1-3.
Construction of the jetty is therefore unlikely to cause any detectable effect upon teal usage of the
area and potential disturbance effects generated by the construction activities are considered not
to be significant with respect to the SPA population.
6.3.60 Shoveler: The species were not recorded in Count Sectors 1 and 2, and were infrequent in Count
Sector 3 (with a maximum number of 4 birds present). Construction of the jetty is, therefore,
unlikely to cause any detectable effect upon shoveler usage of the area and potential disturbance
effects generated by the construction activities are considered not to be significant with respect to
the SPA population.
6.3.61 Grey plover: These species were not recorded in Count Sector 3, and were only recorded in
Count Sectors 1 and 2 (within close proximity to jetty construction) on two occasions and at low
numbers (less than 3). Given the very low and sporadic use of the foreshore fronting the
activities are considered not to be significant with respect to the SPA population
6.3.62 Lapwing: This species were predominately recorded (roosting and foraging on intertidal habitat)
in Count Sector 5 to the east, with no birds recorded in Count Sector 2 and a maximum count of 2
in Count Sector 1 (both within close proximity to the jetty construction), though with increasing
numbers in Count Sector 3 moving eastwards. Given the very low and sporadic use of the
foreshore fronting the development site by this species, potential disturbance effects generated
by the construction activities are considered not to be significant with respect to the SPA
population.

6.3.63 Dunlin: Small numbers of dunlin were recorded in Count Sectors 1 and 2 (within close proximity
to jetty construction), primarily during the autumn passage period between July and September
inclusive, with only one roosting bird noted on one date. Given the very low and sporadic use of
the foreshore fronting the development site by this species, potential disturbance effects
generated by the construction activities are considered not to be significant with respect to the
SPA population.
6.3.64 Redshank: Recorded intermittently within Count Sectors 1-3, but a maximum of one bird was
recorded in any one sector. Given the very low and sporadic use of the foreshore fronting the
activities are considered not to be significant with respect to the SPA population.
6.3.65 On the basis of the assessment, supported by the desk study, survey field data and literature that
is set out above, disturbance effects (noise, lighting and human activity) associated with jetty
construction are unlikely to be of significance for the majority of bird species that are known to
use the foreshore and offshore waters. Table 19 clearly demonstrates that for those birds which
may be impacted by disturbance within 250m to 500m of the jetty (Figure 10), in particular those
occurring in Count Sector 2, there are areas of intertidal habitat that would remain undisturbed to
the west and east of the jetty. It is considered that the small number of displaced birds would be
able to relocate to these areas (and further afield) without any significant implications for their
energy expenditure or survival.
6.3.66 The only species that occasionally occurs in numbers that are considered to be significant in
relation to the SPA is shelduck. As discussed, this species may be present as large flocks of
birds (200) at distances 1.5km from the shore during its summer moulting phase. While activities
that may cause disturbance are considered to be less of a concern to birds on water, given the
large number of shelduck that may be present, disturbance during construction may be of
significance. However, the birds may be able to habituate to continued construction activity and
noise and they would also be able to move away from any potential zone of disturbance without
significant energy expenditure.
6.3.67 In relation to lighting, the temporary jetty would be constantly rather than intermediately lit during
construction. This would be achieved through use of directional lighting, so only the jetty and
immediate works area would be lit and light spill into the intertidal would be limited. This would
allow any birds using the intertidal and inshore waters to habituate to the development area rather
than being regularly displaced from roosting areas as a result of lighting that works on a motion or
switch activated basis. Survey data indicates that overall use of the foreshore by birds at night is
low. Lighting of the temporary jetty is, therefore, not expected to have a significant effect upon
intertidal bird populations
Operational Phase
IMPACT: Loss of habitat from jetty structure during operation
6.3.68 The jetty development would result in the loss of ~20-30m2 of intertidal habitats as a result of the
presence of the jetty piles. The scale of the loss is insignificant in comparison to the intertidal
habitats surrounding the jetty, and this insignificant loss would not represent a measurable
reduction in the available feeding habitat available for SPA and Ramsar interest species and
populations.

IMPACT: Disturbance during operation
6.3.69 The jetty has been designed as a simple steel and concrete structure, with no hanging wires or
other components or attachments, thereby minimising the risk of bird strike during low visibility
conditions (see ES Chapter 6). In view of this, impacts on birds using the intertidal habitats in the
vicinity of the jetty during the operational phase are most likely to result from disturbance caused
by ships docking to unload cargo, maintenance dredging vessels, and human activity, light and
noise along and on route to the jetty. The disturbance caused by these activities is likely to be
less than that during the construction stage and would also be of an intermittent nature.
6.3.70 Anecdotal and available information indicates that waterbirds are quite tolerant of activities in and
around port facilities and generally it can be stated that vehicular activity and vessel movements
(including maintenance dredging vessels) have a much less disturbing effect on birds than the
presence of people within their line of sight. While the unloading of cargoes and the conveyance
of aggregates to land may generate an increase in noise levels, it is not considered that this
would be of sufficient magnitude to cause a significant response in birds using the area. Usage of
the jetty by people would be unlikely to occur on a regular basis, except to undertake routine
maintenance of the conveyor system. As the jetty bridge would also be located significantly
above the foreshore, it is also likely that human activity would be out of the sight line of the
majority of birds that may be using the foreshore and a response to activity may therefore not be
elicited.
6.3.71 Given the lower intensity of potentially disturbing activities that could occur during operation of the
jetty, it is concluded that the potential for disturbance to the range of SPA and Ramsar species
and the bird assemblage as a whole would be less than that which could occur during
construction. On this basis, it is concluded that the operation of the jetty would not lead to a
significant disturbance effect.
Dismantling and Restoration (removal and reinstatement)
IMPACT: Disturbance during dismantling or removal
6.3.72 The dismantling/restoration (removal/reinstatement) phase of the jetty development would result
in impacts that mirror those associated with construction (see above). As such, whilst the jetty is
dismantled (removed) there is the potential for birds using the inter-tidal areas within and in close
proximity to the site to be adversely affected by noise, security lighting and visual disturbance.
Mitigation Measures
6.3.73 No specific mitigation measures are identified, other than those described in Section 4.4b.
6.4 Exmoor and Quantocks Oakwoods SAC
a) The SAC Site
6.4.1 The Exmoor and Quantocks Oakwoods SAC is located approximately 5.8km to the southwest of
the jetty development application site (see Figure 11). It is designated for various habitats under
Annex I of the Habitats Directive, including old sessile oak woods with Ilex and Blechnum in the
British Isles, and alluvial forests with Alnus glutinosa and Fraxinus excelsior. Annex II species
associated with the site include Barbastelle bat, Bechstein’s bat, and otter.

Figure 11: Location of Exmoor and Quantocks Oakwoods SAC and 9km Buffer Zone, and SCC Bat Consultation Zone

6.4.2 The SAC comprises six component SSSIs located within Somerset and Devon as follows:
• Barle Valley SSSI;

• River Barle SSSI;
• North Exmoor SSSI;
• The Quantocks SSSI;
• Watersmeet SSSI; and
• West Exmoor Coast & Woods SSSI.
6.4.3 Of the SAC’s five qualifying features, barbastelle is the only feature that could possibly be
affected by the proposed jetty development. This reflects the fact that the closest part of the SAC
to the application site (the Quantocks SSSI) is approximately 5.8km away, which is within the 5km
- 9km range that barbastelles have been recorded travelling, on average, to reach foraging areas
(Ref. 99, Ref. 100, and Ref. 101). No barbastelle roosts have been located within the Quantocks
SSSI, although there are recent records of barbastelles present within the SSSI. On a
precautionary basis, it has therefore been assumed for the purposes of this assessment that this
species is likely to roost within the SSSI.
b) Barbastelle bats feature
6.4.4 ES Chapter 11 (Terrestrial Ecology and Ornithology) and the further information contained with
the ES Addendum (Section 4 and Appendix 4) confirms that barbastelle has been recorded
using habitats within the temporary jetty site. These documents also provide a summary of the
available baseline information pertaining to barbastelle records from the other parts of the HPC
site and the wider area (including data from the Steart realignment site. A summary of the
barbastelle activity on and around the site is presented in Figure 12.
6.4.5 The assessment set out below has been undertaken with respect to the key activities associated
with the construction, operation and dismantling and restoration (removal and reinstatement)
phases of the Jetty and the attributes identified as part of the conservation objectives for the
Exmoor and Quantocks Oakwoods SAC.
6.4.6 The main activities during the described development phases that could have an impact upon
barbastelle bats have been identified as:
• terrestrial habitat loss and alteration due to construction of the jetty and related landward
works;
• disturbance impacts related to night time lighting during construction;
• terrestrial habitat loss and alteration due to the operational footprint of the jetty;
• disturbance impacts related to night time lighting during operation of the jetty;
• terrestrial habitat gain and alteration due to dismantling and restoration (removal and
reinstatement) of the jetty site; and
• disturbance impacts related to night time lighting during dismantling and restoration (removal
and reinstatement) of the jetty site.

Figure 12: Summary of barbastelle activity

Construction Phase
IMPACT: Loss of or alteration to foraging habitat and/or fragmentation of the available foraging
habitat
6.4.7 Survey work has confirmed that barbastelle bats occur within the jetty development application
site. These bats are not likely to be from the known Exmoor roost within the SAC, given that (as
described above) barbastelle generally travel up to 5km - 9km to reach foraging areas and the
Exmoor roosts are some 30km away. However, the Quantocks SSSI part of the SAC is within
5km - 9km of the proposed jetty development and it is, therefore, possible that the barbastelle
recorded on or adjacent to the site could be from roosts that may be present within this SSSI.
6.4.8 The survey data show that most barbastelle activity within and adjacent to the jetty development
site is likely to represent commuting activity, with foraging activity being much more limited
(although greater levels of foraging activity were recorded off-site).
6.4.9 However, given that the jetty development would result in a reduction in the extent of available
habitat that could be used by foraging bats in response to habitat loss and alteration,
consideration has to be given to the potential for a significant effect to occur if any of the foraging
barbastelle using the development site originate from the Quantocks SSSI part of the Exmoor and
Quantocks Oakwoods SAC.
6.4.10 Barabastelle will make use of a range of habitat types for foraging, although the intensity of use
will vary according to the capacity of the various habitats to support the invertebrate species that
the bats prey upon. Research evidence (Ref. 102) shows that woodland edges, hedgerows,
unimproved grassland and wetlands are the habitats that are most used by foraging.
6.4.11 Within the jetty development site, the area that would be lost to land clearance and excavation
work covers 32ha, which comprises arable land, improved and semi-improved grassland, 0.21ha
of calcareous grassland and 925m of hedgerow (which equates to 0.28ha based on an average
3m width over this length). All habitats, with the exception of the calcareous grassland and
hedgerow, that would be lost are agriculturally improved and are likely to be of limited value for
foraging. Therefore, the construction phase for the Jetty would result in the following loss of
habitats that are of potential value for foraging barbastelle:
6.4.12 The habitats that would be lost as a result of the proposed jetty are typical of those found across
the eastern part of West Somerset district, and the extent of habitat lost within the 9km foraging
area for barbastelles is negligible in scale.
6.4.13 With respect to barbastelle that may originate from potential roost sites in the Quantocks SSSI,
there are no comprehensive data on the extent of potentially good foraging habitat located within
a 9km radius area of the SAC. It is not therefore possible to precisely determine the extent of
habitat loss in the context of all available habitat within a potential 9km area of travel from the
SAC. In view of this, two alternative approaches have been used to compare the habitat loss
from the jetty development site with the available area of habitat within 9km of the SAC.
6.4.14 One of the two approaches makes use of Somerset County Council’s ‘bat consultation zone’ for
barbastelle associated with the Quantocks SSSI part of the SAC (see Figure 11). This zone
provides the best available measure of the extent of habitat known to be favoured by foraging
barbastelle (based on information from the available literature) and the locations of known
barbastelle records within 9km of the SAC (as of July 2010). However, it does not relate directly
to the extent of specific habitats that are favoured by barbastelle (e.g. there are areas of
woodland and hedgerows outside of the bat consultation zone).

6.4.15 The bat consultation zone area that is associated with the Quantocks SSSI part of the SAC (that
is within 9km of the SAC) totals 7,112ha. The extent of the consultation zone that lies within the
area covered by the jetty development site is 2.85ha. This represents 0.04% of the total area of
the bat consultation zone.
6.4.16 The second approach that has been used for considering habitat loss is to compare the total area
of the site with that of land within 9km of the SAC, on the basis that recent survey data from the
jetty development site and surrounding areas, including the Steart peninsula, show that
barbastelle also utilise land within the 9km zone that is not within the bat consultation zone.
Using this approach, the area of land within 9km of the SSSI is 28,712ha and the area of the site
is 32ha; hence a maximum of 0.12% of the total area available to barbastelle from the SAC would
be lost.
6.4.17 Thus, under both of the comparative methods that have been used, the extent of habitat loss
within the site would be substantially less than 0.2% of the area of habitat available to any
barbastelle bats originating from the Quantocks SSSI part of the SAC. This limited loss of
habitats that are typical of the wider area and which are at a considerable distance from any
roosts within the SAC, in a location that the survey data indicates is most likely to be used for
commuting, is not expected to result in a decline in the population of barbastelles in the SAC; and
hence a significant effect is not predicted.
6.4.18 Disturbance and lighting effects upon the possible areas of foraging (the coastal edge and
habitats adjacent to the boundary of the site) would be minimised through measures defined
within the Lighting Strategy and lighting mitigation (see Appendix 3 of the ES Addendum).
IMPACT: Loss and/or fragmentation of commuting corridors, which in turn affects access to
foraging habitats
6.4.19 As noted above, the survey data show that most of the recorded activity by barbastelle bats on
the site is likely to be associated with commuting, with foraging activity being much more limited.
However, due to the size and location of the development, commuting routes through the site
would be restricted to sections of four hedgerows, a small section of the Hinkley Point C Drainage
Ditch and the coastal strip. Whilst limited in extent, these linear features may provide an east-
west link between forging and roosting habitats, although it is likely that the established and more
sheltered routes to the south of the jetty development site, such as the Green Lane and Bum
Brook, would provide more suitable commuting routes and would be used in preference to those
within the site.
6.4.20 The development would not disturb the Hinkley Point C Drainage Ditch but would result in the
loss of the hedgerow sections and temporary disturbance of the coastal strip during construction
of the jetty (predominantly where the jetty passes over the coastal edge - no excavation is
expected as the jetty would be elevated above ground). As a result there may be a temporary
loss of connectivity across the site where the coastal strip is disturbed. However, throughout the
works the habitat corridors to the south of the site (Green Lane and Bum Brook) would be
available to barbastelle and would provide alternative commuting habitat. Given the availability of
this alternative and better quality provision, it is unlikely that the loss of commuting corridors
would affect the population of bats using any potential roost(s) within the Quantocks SSSI
component of the Exmoor and Quantocks Oakwoods SAC (and hence a significant effect would
not arise).
6.4.21 Disturbance and lighting effects on the retained habitat corridors and off-site habitats would be
minimised through measures defined within the Lighting Strategy and lighting mitigation (see
Appendix 3 of the ES Addendum).

Operational Phase
IMPACT: Loss of or alteration to foraging habitat or commuting corridors
6.4.22 During operation there would be no additional loss of habitat from within the jetty development
site that could be used for commuting or foraging by bats.
6.4.23 Disturbance and lighting effects upon the possible areas of foraging (the coastal edge and
habitats adjacent to the boundary of the site) would be minimised through measures defined
within the Lighting Strategy and lighting mitigation (see Appendix 3 of the ES Addendum).
Therefore, it is predicted that the operational phase of the jetty would not result in a significant
reduction in the extent of foraging habitat for barbastelle.
Dismantling and Restoration (Removal and reinstatement)
IMPACT: Loss of or alteration to foraging habitat and/or fragmentation of the available foraging
habitat
6.4.24 As for operation, during dismantling and restoration (removal and reinstatement) there would be
no additional loss of habitat from within the jetty development site that could be used by foraging
barbastelle. In addition, whilst much of the jetty on-shore site would be within the built power
station footprint, the western part of the site would be restored to a mixture of semi-natural and
farmland habitats, which would include one arable field, one species-rich grassland field, broad-
leaved woodland and calcareous grassland. Therefore, following completion of the restoration
there would be an increase in habitats of value to foraging barbastelle within the jetty site (based
on the small area of potential foraging available currently, as described above).
6.4.25 Should reinstatement of the site occur instead, habitats of a similar type to those currently
present, but of greater biodiversity value (ES Chapter 11), would be created. Therefore, in the
medium to long-term the habitats within the site would be more diverse and are, therefore, likely
to offer improved foraging opportunities for barbastelle bats.
IMPACT: Loss and/or fragmentation of commuting corridors, which in turn affects access to
foraging habitats
6.4.26 Similarly, during dismantling and restoration (removal and reinstatement), there would be no
additional loss of potential commuting corridors from within the jetty development site. In
addition, whilst much of the jetty on-shore site would be within the built power station footprint, the
western part of the site would be restored to a mixture of semi-natural and farmland habitats,
which would separated by new hedgerows. Therefore, following completion of the restoration,
habitat connectivity within this area would also be restored and the linear features created by the
hedgerows and woodland edge would be available to commuting barbastelle.
6.4.27 Should reinstatement of the site occur, as stated above, habitats of a similar type to those
currently present but of greater biodiversity value (ES Chapter 11) would be created, including
habitat corridors such as hedgerows. Therefore, whilst the number of habitat corridors would be
broadly similar to that currently present on site, the increased diversity of the habitats would
increase the value of these corridors for barbastelle.

Mitigation Measures
Construction
6.4.28 A range of impact avoidance measures have been incorporated into the proposed scheme
design. It is proposed that the following measures would also be implemented and would further
contribute to the avoidance and/or minimisation of any potential adverse effects to barbastelle
(including habitat use and behaviour).
6.4.29 The artificial lighting of construction areas may pose a potential disturbance for foraging and
commuting barbastelle. The following measures to minimise or avoid the potential effects of
lighting will be incorporated into a construction lighting strategy:
• Lighting would be positioned as far from the hedges as is conducive with security and
engineering requirements; and
• Lighting closest to the hedgerow and woodland features (i.e. where works are close to the
Green Lane at the southeastern rock extraction area, the southwestern boundary of the site,
and along the coastal strip at the north of the site) would take account of the following:
− low UV output lights (e.g. sodium lamps) would be used - these are preferable to
mercury or metal halide lamps (as they attract fewer insects away from the hedgerow,
any insects drawn to the lights will only be available to light tolerant species);
− light spill towards retained hedgerows would be reduced to a minimum (using cowls as
necessary);
− the height of the lighting columns would be modelled and optimised in order that extent
of light spill can be clearly understood, and this can be used to demonstrate the likely
effectiveness of the mitigation; and
− lighting should use suitable controls to maximise the periods of darkness (subject to
operational need) during which bats can traverse areas that require lighting.
Operation
6.4.30 No further measures have been identified as required in addition to the lighting strategy (which
would incorporate the measures identified above for construction lighting).
6.4.31 No additional measures are required, other than those identified for the construction phase
above.
6.5 Summary of effects on receptors
6.5.1 Table 20 summarises whether it is concluded that a ‘likely significant effect’ would arise for each
of the activities and designated features identified in the screening process.
6.5.2 Based on the assessment above, it is concluded that the various phases of jetty development,
alone, would not lead to a change in the habitats outside of the Exmoor and Quantocks
Oakwoods SAC, such that any significant detrimental affect to the designated barbastelle
population would occur. Hence no likely significant effect would occur with respect to the SAC.

Table 20: Jetty Development – Summary of effects on receptors and determination of likely significant effect
Activity Likely significant effect Comment
Severn Estuary SAC
1 Habitat loss or No ‘likely significant Initial screening identified the potential for effects on the estuaries feature of the SAC.
modification resulting effect’ on the estuaries However, further analysis confirmed no likely significant effect on account of:
from construction of the feature
jetty and berthing pocket • The limited and temporary disturbance to hydrodynamic processes during
on the estuaries feature construction.
• The localised nature of sediment disturbance, with the greatest magnitude occurring
during dredging, and the levels of suspended sediment would be low in comparison to
the background levels, and temporary; whilst land-based discharges would achieve
greenfield rates of suspended sediment and hence would not change from the current
levels experienced.
• Potential contaminant levels from re-suspended sediments would be an order of

magnitude below the annual marine EQSs, and no contaminants would be expected to
arise from land-based discharges.
• Freshwater discharges would be at greenfield rates and, therefore, no change to

salinity would occur.
• Dredged sediment would be retained in the estuary, being disposed of at the Cardiff
Grounds.
• Estuarine communities (including Corallina) would experience little or no degradation

due to sediment deposition as it would remain within current rates of deposition;
contaminants would not measurably increase; and changes in salinity would not be
expected as they would not be altered by land-based discharges. A negligible extent
of intertidal habitat and associated communities (including Corallina) would be affected
by construction plant disturbance and effects would be short-term.

2 Habitat loss or No ‘likely significant Initial screening identified the potential for effects on the reefs feature of the SAC.
modification resulting effect’ on the reefs feature However, further analysis confirmed no likely significant effect on account of:
from construction of the
jetty and berthing pocket • Reef communities (Sabellaria) would experience little or no degradation due to
on the reefs feature sediment deposition as they are located 500m away and suspended sediment levels
would remain within current rates; contaminants would not measurably increase; and
changes in salinity would not be expected as they would not be altered by land-based
discharges.
• No physical disturbance would occur to reef communities as they are located over
500m away from any of the works.
3 Obstruction or No ‘likely significant Initial screening identified the potential for effects on migratory fish since the propagation
disturbance resulting effect’ on migratory fish of noise underwater may disturb fish using the estuary in close proximity to construction
from construction of the activity in the estuary. However, further analysis confirmed no likely significant effect on
jetty and berthing pocket account of:
on migratory fish
• Very small localised areas of physical disturbance during the piling and dredging
works.
• Levels of suspended sediment would occur only locally and temporarily, and would
remain within current levels experienced within the estuary at this location.
• Levels of contaminants would not measurably increase; and changes in salinity would
not be expected as they would not be altered by land-based discharges.
• Elevated levels of noise and vibration during piling and dredging are expected to be
very low in magnitude and given the availability of habitat for the avoidance of
increased noise levels, and the use of soft start for piling, it is expected that for the
short-term duration of the works no barrier to migration would occur, and any effect on
population from death or injury is unlikely.

from presence and feature
operation of the jetty and • Extent of the physical alteration to the cross-section or tidal prism of the estuary is
berthing pocket on the extremely small and localised, with only localised scour predicted to occur (affecting
estuaries feature around 0.0003% of seabed habitat).
• The loss of estuary habitat (and communities) due to presence of the jetty piles and
any increased scour would be extremely small (less than 0.00004% for the estuary,
less than 0.002% for hard substrate, and 0.3% for Corallina), and other than Corallina
no notable species or communities would be affected. Small scale alteration of
subtidal habitat would occur affecting less than 0.0013% of estuary feature due to
maintenance dredging of the berthing pocket and localised scour, but no notable
communities would be affected.
• The localised nature of sediment disturbance occurring during maintenance dredging

would result in no noticeable change to background levels of suspended sediment;
whilst land-based discharges would achieve greenfield rates of suspended sediment
and hence would not change from the current levels experienced.


• Maintenance dredged sediment would be retained in the estuary, being disposed of at

the Cardiff Grounds.

from presence and
operation of the jetty and • Reef communities (Sabellaria) would experience little or no degradation due to
berthing pocket on the sediment deposition as they are located 500m away and suspended sediment levels
reefs feature would remain within current rates; contaminants would not measurably increase; and
discharges.
• No physical disturbance would occur to reef communities from hydrodynamic changes

as they are located over 500m away from the jetty and berth pocket.
disturbance resulting effect’ on migratory fish of noise underwater may disturb fish using the estuary close to the jetty and berth pocket.
from presence and However, further analysis confirmed no likely significant effect on account of:
operation of the jetty and
berthing pocket on • No obstruction to migratory fish from physical presence of the jetty, and only localised
migratory fish changes to flow which would not affected migratory fish.
• Levels of suspended sediment would occur only locally and temporarily from scour or
maintenance dredging, and would remain within current levels experienced within the
estuary at this location.
• Elevated levels of noise and vibration during dredging, vessel movements or conveyor
operation are expected to be very low in magnitude and given the availability of habitat
for the avoidance of increased noise levels, it is expected that for the short-term
duration of dredging or vessel movements no barrier to migration would occur, and
any effect on population from death or injury is unlikely.

from dismantling and feature
restoration (or removal / • The limited and temporary disturbance to hydrodynamic processes during dismantling
reinstatement) of the of the jetty would then cease and no long term effects would arise due to removal of
jetty on the estuaries any structures.
feature
• The localised nature of sediment disturbance, with the greatest magnitude occurring
during pile removal, and the levels of suspended sediment would be low in comparison
to the background levels, and temporary; whilst land-based discharges would achieve
greenfield rates of suspended sediment and hence would not change from the current
levels experienced.


• No sediment removal would occur.
• Estuarine communities (including Corallina) would experience little or no degradation

due to sediment deposition as it would remain within current rates of deposition;
contaminants would not measurably increase; and changes in salinity would not be
expected as they would not be altered by land-based discharges. A negligible extent
of intertidal habitat and associated communities (including Corallina) would be affected
by plant disturbance, and effects would be short-term, and in the long-term there
would be no structures present and habitats would recover.

from dismantling and
restoration (or removal / • Reef communities (Sabellaria) would experience little or no degradation due to
reinstatement) of the sediment deposition as they are located 500m away and suspended sediment levels
jetty on the reefs feature would remain within current rates; contaminants would not measurably increase; and
discharges.
• No physical disturbance would occur to reef communities as they are located over
500m away from any of the dismantling and restoration (or removal / reinstatement)
works.
disturbance resulting effect’ on migratory fish of noise underwater may disturb fish using the estuary in close proximity to dismantling
from dismantling and works in the estuary. However, further analysis confirmed no likely significant effect on
restoration (or removal / account of:
reinstatement) of the
jetty on migratory fish • Very small localised areas of physical disturbance during the pile removal, after which
all structures would not be present and therefore no obstruction to movement.
• Levels of suspended sediment would occur only locally and temporarily, and would
remain within current levels experienced within the estuary at this location.
• Elevated levels of noise and vibration during pile removal are expected to be very low
in magnitude and given the availability of habitat for the avoidance of increased noise
levels, it is expected that for the short-term duration of the works no barrier to
migration would occur, and any effect on population from death or injury is unlikely.

Severn Estuary SPA
1 Disturbance to No ‘likely significant Initial screening identified the potential of disturbance to waterbirds from human activity
waterbirds onshore and effect’ on the interest during construction activity, particularly noise, lighting and movement. However, further
offshore during features of the SPA analysis confirmed no likely significant effect on account of:
construction
• The data indicate that there is very limited use of the foreshore and coastal fields
within the vicinity of the works by wintering and passage birds.
• In the event that birds are displaced, similar quality habitat within their home range is
available within a few hundred metres.
• The capital dredging would avoid the period that moulting shelduck are on the water
and working methods would be designed, as far as possible, to avoid impacts on
them.
• Extent of light spill would be limited to the immediate jetty, with limited spill onto the
intertidal habitat, and use of the intertidal area at night is low.
2 Loss of or change to No ‘likely significant Initial screening identified the potential of disturbance to waterbirds from human activity
habitat (coastal and effect’ on the interest during construction activity, particularly noise and light. However, further analysis
marine) as a result of features of the SPA confirmed no likely significant effect on account of:
presence and operation
of the jetty and • Data indicates that there is very limited use of the foreshore within the vicinity of the
implications for bird jetty by wintering and passage birds, and the extent of habitat lost is negligible.
usage
• Habitat loss would be very small-scale and unlikely to lead to the loss of invertebrate
species that constitute key prey items for the SPA bird species.

waterbirds onshore and effect’ on the interest and vessel movements during operation of the jetty, particularly noise, light, and human
offshore during features of the SPA activity. However, further analysis confirmed no likely significant effect on account of:
operation of the jetty and
berthing pocket • Data indicates that there is very limited use of the foreshore within the vicinity of the
jetty by wintering and passage birds.
available within a few hundred metres. However, displacement by the infrequent
movement of vessels (i.e. one every 1 to 2 days on average), limited human activity on
the jetty itself, as well as the limited noise generated at the jetty head during unloading
of cargoes, would result in very low magnitude disturbance.
waterbirds onshore and effect’ on the interest during dismantling and restoration (or removal / reinstatement) works, including noise and
offshore during features of the SPA lightinh. However, further analysis confirmed no likely significant effect on account of:
dismantling and
restoration (or removal / • Data indicates that there is very limited use of the foreshore and coastal fields within
reinstatement) the vicinity of the works by wintering and passage birds.
available within a few hundred metres. However, displacement by the movement of
vessels, human activity during dismantling, and noise generated during dismantling,
would be of a lower magnitude than during construction and localised in nature.

Severn Estuary Ramsar Site
1 As for SAC and SPA As for SAC and SPA As for SAC and SPA
Exmoor and Quantocks Oakwoods
1 Loss of or alteration to No ‘likely significant Land clearance during construction would not have a discernible effect on the availability
habitat, and disturbance effect’ on the interest of foraging resource, and whilst connectivity across the site would be reduced by the
to foraging / commuting features of the SPA removal of hedgerows, the commuting corridor along the coast would only be temporarily
barbastelle bats during disturbed, and overall access to foraging areas would be maintained and no effect on the
construction barbastelle population would occur.
2 Loss of or alteration to No ‘likely significant No habitat would be lost during operation, and there would be no obstruction to commuting
habitat, and disturbance effect’ on the interest along the coast. Lighting mitigation would avoid or reduce any potential deterrence to
to foraging / commuting features of the SPA foraging areas or commuting corridors, which are located outside the site.
barbastelle bats during
operation
3 Loss of or alteration to No ‘likely significant Reinstatement or restoration would result in similar or enhanced habitat within the site
habitat, and disturbance effect’ on the interest suitable for foraging or commuting barbastelles.
to foraging / commuting features of the SPA
barbastelle bats during
dismantling and
restoration (or removal /
reinstatement)

7 IN COMBINATION EFFECTS
7.1 Introduction
7.1.1 Regulation 61 of the Habitats Regulations requires the competent authority to make an
appropriate assessment of any plan or project which is likely to have a significant effect on a
European site, either alone or in combination with other plans or projects.
7.1.2 The Regulations limit the scope of the in combination test to “other plans or projects” where these
should include:
• approved but as yet uncompleted plans or projects;

• permitted ongoing activities (e.g. discharge consents or abstraction licences); and
• plans and projects for which an application has been made and which are currently under
consideration but not yet approved by the competent authorities.
7.1.3 The approach to dealing with in combination effects is to determine potential environmental
parameters where spatial and temporal overlap between plans and projects may occur (i.e.
scoping of potential interactions). For these identified interactions the likelihood of any increase
(or possibly decrease) in the level of assessed impact significance for the relevant environmental
parameter can be determined, if sufficient information is available, and assessed against the
relevant conservation objectives for the designated feature.
7.1.4 Chapter 8 of the jetty development ES describes the other plans and projects with which the
works could have cumulative effects. These are:
• the site preparation works (i.e. the other Preliminary Works to the Hinkley Point C Project),
see Section 1.2b for details – these works are considered in the in combination assessment
presented below;
• the Hinkley Point C Project (i.e. the Hinkley Point C nuclear power station, on-site Associated
Development and off-site Associated Development), see Section 1.2d for details – also
considered in the in combination assessment below; and
• other plans and projects unrelated to the Hinkley Point C Project.
7.1.5 ES Chapter 8 further presents the results of a screening exercise which concluded that the
following ‘other’ plans and projects could have the potential to cause effects cumulatively with
those of the temporary jetty development:
• Hinkley Point A nuclear power station decommissioning;

• Hinkley Point B nuclear power station operation (only with respect to planned outages as the
existing and ongoing impacts of the station are baseline);
• The Bridgwater – Seabank 440kV electricity transmission line upgrade;
• Steart coastal management project;
• development of a container terminal at Bristol Port, Avonmouth (the Bristol Deep Sea
Container Terminal – BDSCT);
• decommissioning of the existing nuclear power station at Oldbury, Gloucestershire;
• development of a new nuclear power station at Oldbury, Gloucestershire; and
• aggregate extraction licence area 472 in the Bristol Channel.

7.1.6 With regard to the above projects, the Bridgwater-Seabank electricity transmission line upgrade,
Steart coastal management project and proposed nuclear power station at Oldbury would all take
place following construction of the jetty and, therefore, would only be of relevance for the
operational and dismantling (removal) stages of the jetty. The present timescale for work on the
proposed nuclear power station at Oldbury, Gloucestershire indicates that work on site would not
begin prior to 2016 (see ES Chapter 8) (Ref. 97). Decommissioning of the existing nuclear
power station at Oldbury is scheduled to commence during 2011 - 2012 and would, therefore, fall
within the timescale for the construction and operation of the jetty. With regard to aggregate
extraction licence area 472, the ongoing works essentially form part of the baseline against which
impacts have been determined in the ES. Therefore, for the purposes of this cumulative
assessment, it is only included in order to consider potential navigational interactions.
7.2 Details of Other Plans and Projects
a) Continued operation of Hinkley Point B Nuclear Power Station
7.2.1 Hinkley Point B is due to operate until at least 2016, although there is the potential that the life of
the station could be extended for at least a further 5 years beyond 2016. This means that
potentially there would be overlap in construction, operation, dismantling / restoration, and/or
removal / reinstatement of the jetty with Hinkley Point B.
b) Hinkley Point A Decommissioning
7.2.2 Hinkley Point A power station ceased generation for the final time on 23rd May 2000. It has been
defuelled and is currently being decommissioned. The decommissioning project that is now
underway at Hinkley Point A includes in the early phase, the removal of most of the buildings, the
building of a radioactive waste storage building, and alteration to the reactor buildings. Then,
following a period of deferment, total site clearance and de-licensing will take place. A summary
of the works is provided below:
• construction of a Radioactive Waste Storage Building for the storage of intermediate level
waste, until such time as an off-site disposal facility is available to receive those wastes:
• construction of 4 temporary buildings, each required for a period of up to 15 years following
construction, as follows:
• one Low Level Radioactive Waste (LLW) Management building for the purpose of sorting and
packaging low level wastes prior to despatch of those wastes off-site;
• one Wet Intermediate Level Radioactive Waste (ILW) Encapsulation building for the purpose
of encapsulating and packaging non solid ILW;
• one Solid ILW Encapsulation Building for the purpose of encapsulating and packaging
principally solid form ILW; and
• one Access Control Building to control the movement of personnel and equipment to and
from the Radiation Controlled Area (RCA); and
• construction of Reactor 1 Solid Waste Export Building and Reactor 2 Solid Waste Export
Building, each required for a period of up to 5 years following construction;
• temporary storage on land adjacent to the Hinkley Point A nuclear licensed site, for a period
of no longer than 6 years from the start of construction of the development, of materials
associated with this development;
• temporary storage on land adjacent to the Hinkley Point A nuclear licensed site, for a period
of no longer than 5 years from the start of construction of the development, of material

excavated during the construction of the Radioactive Waste Storage building referred to
above, prior to re-use of that material for the purpose of in-filling below ground voids on the
Hinkley Point A site; that is, to in-fill underground parts of existing structures following their
demolition;
• installation of a new active effluent discharge pipeline; and
• associated fence moves to facilitate the above development.
7.2.3 According to the NDA, the key milestones for decommissioning are:
• 2012 - complete decommissioning and backfill of turbine hall;

• 2013 - complete decommissioning of Magnox vault;
• 2016 - complete processing of historic ILW;
• 2017 - start of Safestore care and maintenance (C&M);
• 2095 - reactor buildings decommissioning complete; and
• 2104 - final site clearance and closure.
c) The Bridgwater – Seabank 440kV electricity transmission line upgrade
7.2.4 The proposed new nuclear power station at Hinkley Point would be connected to the national grid
high voltage electricity transmission network via a new 400kV overhead line between Bridgwater
and Seabank. There would also need to be associated electrical infrastructure; modifications and
diversions to existing overhead lines in the vicinity of Hinkley Point. These three components will,
together, form a separate project and DCO application by National Grid to the IPC (or its
successor).
7.2.5 A number of routeing options for the overhead lines have been identified and consulted upon by
the National Grid. Two preferred corridor options were selected and further consultation has
been undertaken with respect to these options (see below). As of early 2011, no decision has
been reached on which route option will be taken forward into the detailed planning stage:
• One option (1A) involves removing an existing Western Power Distribution 132,000 volt
overhead line and using its corridor for a new 400,000 volt overhead line. This option would
also require a new substation at Churchill in North Somerset and a new 4km length of
400,000 volt overhead line to connect it with the new Bridgwater to Seabank overhead line.
• The second option (1B) involves the construction of a new 400,000 volt overhead line next to
the existing 132,000 volt overhead line. Under Option 1B the existing 132,000 overhead line
would not be removed.
7.2.6 The National Grid intends to apply for development consent in 2012, with the works planned to be
undertaken 2014 – 2017.
7.2.7 A new 400kV Gas Insulated Switchgear (GIS) substation, overhead line landing gantries and
terminal towers which will facilitate connections between Hinkley Point C and the national grid
high voltage transmission network and will be covered under the EDF DCO application.
7.2.8 Four overhead line gantries will be situated along the south side of the compound to facilitate the
transition from overhead line to gas insulated line and subsequent through wall entry into the GIS
building. These four line entries form connections to the main interconnected transmission
system. Similarly, two other overhead line gantries are provided to the east of the compound

which forms the overhead line route to interconnect with the existing Hinkley Point B 400kV AIS
substation to the east.
7.2.9 The landing gantries will connect via overhead line to three overhead line terminal towers (pylons)
outside the substation compound to the south and east. Modifications to the existing overhead
line network south east of the substation will also be required but will form part of a separate DCO
application by National Grid.
d) Bristol Deep Sea Container Terminal
7.2.10 The Bristol Port Company has consent to the Bristol Deep Sea Container Terminal (BDSCT) on a
site at Avonmouth Docks approximately 45km north of the proposed development up stream in
the Severn Estuary. The new container terminal would be designed to service existing large
container ships and future generations of Ultra Large Container Ships (ULCS) with a draught of
up to16m with the capacity to transport up to 14,000 containers per year. The proposals would
involve:
• capital and maintenance dredging to deepen and widen the existing approach channel.
During construction there would be a requirement to dispose capital dredged material at an
offshore disposal site. The footprint of the dredged area would extend from Avonmouth in
the east to approximately 20km to the west; and
• redevelopment and reclamation of land for a new quay; and container storage facilities.
7.2.11 The western limit of the dredged channel is located approximately 30 km north of the location of
the proposed Hinkley C Power Station. Dredged material deposited at Holm Deep (located
approximately 8km off Sand Point and approximately 24km from Hinkley C Power Station) would
be expected to be transported to within approximately 15km – 20km of the proposed location of
the Hinkley C Power Station. Capital dredging would remove mudstone, sand, gravel and silt.
Analysis undertaken as part of the Bristol Deep Sea Container Terminal EIA indicates that during
dredging there would be:
• approximately 10.5 million tonnes of fine sediment released into the estuary;
• approximately 16.9 million tonnes of mudstone would need to be deposited in the deepwater
disposal site at Holm Deep; and
• Approximately 2.05 million tonnes of sand sized mudstone would be released into the
estuary.
7.2.12 Maintenance dredging would require the removal of muddy and sandy sediments that accumulate
in the turning area and berths. Muddy sediments would be deposited locally and sandy
sediments would be deposited at the new deepwater disposal site at Holm Deep.
7.2.13 Consent for the BDSCT was given by the Department for Transport in April 2010 and it is likely
that work on developing the new facility could commence 2011/12 with the container terminal
expected to be operational during 2015/16.
e) The Steart Peninsula Project
7.2.14 The Steart Peninsula is located approximately 7km east of the proposed Hinkley C Power Station
on an area of low lying agricultural land on the Somerset coast of the Severn Estuary. It is
flanked to the west by Bridgwater Bay and to the east by the lower reaches of the Parrett Estuary.

7.2.15 The Environment Agency is promoting the Steart Peninsula Coastal Management Project. The
project would manage flood risk while taking the opportunity to create new natural habitat and,
according to the Environment Agency’s 2010 consultation document, it has the following
objectives:
• flood management - to manage flood risk to people, properties and public infrastructure on
the Steart Peninsula;
• habitat creation - to create about 500ha of wetland habitat, of which at least 300ha is to be
intertidal/brackish; and
• sustainability - to be consistent with naturally functioning and sustainably managed land use
on the Steart Peninsula.
7.2.16 The Environment Agency has undertaken consultation on the following coastal management
options at Steart:
• do nothing – under this option the present defences would be allowed to overtop or breach
without repair;
• do minimum – under this option there would be maintenance of present sea defences in the
short term although maintenance would cease in the short to medium term (i.e. reverts to ‘do
nothing’) leading to the need for secondary flood defence to power lines and Stockland
Bristol;
• managed realignment scheme (Severn Estuary opening) - one large opening cut through the
foreshore to the east of Wall Common and west of the road, leading to the project’s
objectives identified above; and
• managed realignment scheme (River Parrett opening) - small, medium, or large opening(s)
through the existing flood defence banks.
7.2.17 After detailed consultation with local communities and interested parties, the preferred option is
that realignment would be undertaken via breaches to the existing defences along the River
Parrett. The Environment Agency believes that planning approval would be sought in 2011 and
hopes that construction would start in 2012.
f) The Bristol Port Company - Habitat Compensation Scheme at Steart
7.2.18 The Bristol Port Company will be undertaking a habitat creation scheme on the Steart Peninsula
to provide compensation for intertidal habitat that would be lost or altered as a result of its
consented port expansion (see above) at Avonmouth. The creation scheme comprises an area of
approximately 150ha of land at the north-western end of the peninsula that would be breached
through the existing defences (from the Severn Estuary) in order to allow tidal inundation and
intertidal habitat to establish. Significant excavation works would be undertaken within the site in
order to lower the height of some areas and produce a creek network to enable tidal flow into and
out of the site. A set-back embankment would protect Steart Road and the pylons from flooding.
The Bristol Port Company is working closely with the Environment Agency on the project to
ensure compatibility with the habitat creation works that would be undertaken by the Steart
Peninsula Project. It is planned to start works on site in 2012.

g) Decommissioning of the existing nuclear power station at Oldbury
7.2.19 The existing Oldbury nuclear power station is situated in South Gloucestershire on the eastern
bank of the Severn Estuary. It was due to cease generating electricity in 2008 but has received
the go-ahead to continue operating both reactors to mid 2011. Proposals are in hand to extend
the operation of reactor 1 to the end of 2012. Once operation ceases, the nuclear power station
will be decommissioned by the NDA.
7.2.20 According to the NDA (nda.gov.uk) and based on generation ceasing in 2008, the key milestones
for decommissioning were:
• 2008 - cease generation;

• 2009 - commerce defueling;
• 2010 - complete defueling;
• 2010 - care and maintenance preparations begins;
• 2023 - care and maintenance commences;
• 2109 - final site clearance begins; and
• 2118 - final site clearance and closure.
7.2.21 Since generation is not planned to cease until 2010-2012, these milestones would be subject to
change. However, assuming decommissioning to commence sometime between 2010 and 2012,
it is likely that elements would overlap with the jetty development.
h) New nuclear build at Oldbury, Gloucestershire
7.2.22 The draft National Policy Statement for Nuclear Energy identifies land at Oldbury, in South
Gloucestershire, on the eastern bank of the Severn Estuary as a potential site for the
development of a new nuclear power station. The site is being progressed by a Joint Venture
(Horizon Nuclear Power Ltd.) between E.ON and RWE. The site is located immediately north
east of the existing Oldbury nuclear power station, which lies approximately 60km upstream
(north-east) of Hinkley Point. The land proposed for the permanent development covers an area
of approximately 150ha, largely comprising mainly agricultural grassland.
7.2.23 The proposed new nuclear development at Oldbury is expected to comprise the following:
• a power station comprising up to three nuclear reactors with a combined expected output of
about 3300 megawatts (MW);
• up to four cooling towers of between 70m and 200m in height;
• interim waste storage facilities;
• electricity transmission infrastructure;
• access roads and highways improvements and a possible Park & Ride facility;
• a marine off-loading facility (MOF), and other such construction transport options (subject to
the outcome of a Transport Options Study);
• implementation of a flood defence strategy for the site (a range of options are being
assessed);
• construction areas and facilities;

• ancillary development such as other buildings and infrastructure associated with the nuclear
site; and
• landscape and biodiversity initiatives and mitigation measures associated with the
construction and operation of a new power station.
7.2.24 This development is still in the early planning stages. Its construction phase is anticipated to start
in 2016 and would, therefore, overlap with the end phase of the jetty development, should the
development at Oldbury proceed.
i) Aggregate Dredging Area 472, Culver Sands, Bristol Channel
7.2.25 There are 13 licensed aggregate extraction sites in the Bristol Channel. These sites cover an
area of approximately 130km2, although approximately 56km2 is available for dredging and 90 per
cent of effort took place from approximately 3.5km2 (in 2008).
7.2.26 The closest extraction site to Hinkley Point is Area 472. This site covers 3.8km2 and is situated
approximately 12km to the north-west of Minehead, on the English side of the England / Wales
territorial sea boundary. It is located at a minor sand bank positioned to the south-west of the
main bank forming Culver Sands. Three companies are licensed to extract materials from this
site; Cemex UK Marine Ltd, Hanson Aggregates Marine Ltd, and Tarmac Marine Ltd.
7.2.27 Culver Sands itself is part of the Severn Estuary Special Area of Conservation and includes two
qualifying habitats. These habitats are sandbanks which are slightly covered by seawater at all
times and biogenic reefs. The biogenic reefs at Culver Sands are Sabellaria alveolata reefs.
7.3 Findings of In-Combination Test for Likely Significant Effect
7.3.1 This section of this HRA uses the results of the screening exercise presented in ES Chapter 8 to
further identify those plans or projects that may have an effect, in combination with the jetty
development, on the designated features of the European sites that have been subject to
assessment in the previous section (on the determination of likely significant effect of the jetty
development alone). The results are set out in Table 21.
7.3.2 Of the screened projects, there are two that have the potential for direct interaction with the jetty
development (i.e. they overlap with the footprint of the jetty development). These are the site
preparation works and the commencement of the Hinkley Point C Project under the DCO
application. However, only one project at a time (i.e. the site preparation works or the Hinkley
Point C Project) would overlap with the jetty development. For the other projects any interactions
would be of an indirect nature, as spatially their footprints do not overlap although effects on the
same receptor may combine to generate a cumulative impact.
7.3.3 With regard to the Hinkley Point C Project, the following components could interact with the jetty
development (during construction and operation) and have potential implications for the European
sites being assessed:
During Construction
• Initial construction of the seawall.

Table 21 Temporary Jetty Development – In combination test of other plans or projects
Plan / Project Potential for Description and comment

In
Combination
Effect on
European
Site
site preparation works The site preparation works form part of the Preliminary Works for Hinkley Point C and would take place within the
(part of the Preliminary defined Hinkley Point C development site. The proposed works involve site clearance, earthworks, provision of earth
Works) retaining structures; deep excavations; provision and relocation of drainage infrastructure, the provision and operation
of plant and machinery (including plant for concrete batching), site establishment works (including the provision of
construction compounds and associated facilities, car parks, haulage roads, site access points and roundabouts, and
laying, replacement and/or diversion of utilities); and other associated works. In the event that Hinkley Point C is not
consented, all structures would be removed and the site reinstated. It should be noted that the site clearance and
earthworks required for the land-based component of the jetty development are also included for and assessed in the
application and ES for the site preparation works. The works are planned to run concurrently with the jetty
construction and would be completed within 15 months.
Hinkley Point C Project Assuming a DCO is granted for the Hinkley Point C Project, there would overlap in time with the construction works
for the jetty development. During this period, several components of the Hinkley Point C Project would commence, of
which the initial works on the new seawall to the proposed nuclear power station would be of most relevance In which
there would be up to a 6 month overlap with that of the jetty development.
The operational phase for the jetty would be concurrent with the development of the Hinkley C Project up until the end
of construction of the second EPR unit, scheduled for completion in 2019. During this period much of the Hinkley
Point C Project would be completed including, the seawall, intake and outfall structures and tunnels for the cooling
water system, reactor buildings, upgrade to and operation of Combwich wharf and EPR1 would become operational.
National Grid Hinkley C The elements of the National Grid project that are potentially relevant to the assessment of impacts associated with
Connection Project the site preparation works are the overhead line modifications and diversions to overhead lines in the vicinity of the
Hinkley Point C site, and the overhead line route corridors and associated infrastructure. These works are due to take
place from 2014-2017 and would therefore not coincide with the construction phase for the jetty. Potential in
combination effects with the jetty development are considered unlikely, but given the potential for the works to have
an influence upon the bird species that form part of the Severn Estuary SPA populations, further consideration of the
potential for an in combination effect with the jetty is given here.

Temporary Jetty Development - 137 - June 2011
In
Combination
Effect on
European
Site
Continued Hinkley Point A power station is currently being defueled and decommissioned. The decommissioning project
Decommissioning of includes, in the early phase, the removal of most of the buildings, the building of a radioactive waste storage building
Hinkley Point A Power and alteration to the reactor buildings. Then, following a period of deferment, total site clearance and de-licensing will
Station take place.
Decommissioning would overlap in time with the jetty development. However, the works would be confined largely to
the Hinkley Point A power station site and have been ongoing for a number of years. t is not anticipated that the
phase of the decommissioning works, which would coincide with the jetty development (both construction and
operation) would have any implications for the adjacent designated sites.
Continued Operation of Hinkley Point B is due to operate until at least 2016. The operational period includes a series of ‘outages’, during
Hinkley Point B Power which the station undergoes refuelling and maintenance at regular periods. The length of these outages varies
Station according to the maintenance and inspections required. At present it is known that two outages for the operation of
Hinkley Point B would coincide with the construction of the jetty development, the first in 2011 and the second in 2012.
These outages have been an ongoing feature of the operation of Hinkley Point B and do not have any implications for
the designated interests of the European sites. The operational activities of Hinkley Point B form part of the
environmental baseline against which the effects of the jetty development have been assessed. The effect of the
Hinkley Point B cooling water outfall together with that of Hinkley Point C has been modelled and included in the
assessment work for Hinkley Point C. This potential in combination aspect is therefore included for with the Hinkley
Point C Project (see above).
Bristol Deep Sea The Bristol Port Company is proposing to develop the BDSCT on a site at Avonmouth Docks approximately 45km
Container Terminal, northeast of the application site. The western limit of the dredged channel is approximately 30km northeast of the
Avonmouth application site. The distance of the facility from Hinkley Point suggests that potential interaction of effects between
the projects would be unlikely, except potentially at the wider estuary level where effects on mobile species could
potentially occur.
It is possible that work on developing the BDSCT could commence in 2011, with the container terminal expected to be
operational during 2014/15. Accordingly, the jetty development would coincide with the port’s construction and
operation phases.

In
Combination
Effect on
European
Site
Steart Coastal The Steart Peninsula is an area of low lying agricultural land on the Somerset coast of the Severn Estuary located
Management Project, approximately 7km east of Hinkley Point. It is flanked to the west by Bridgwater Bay and to the east by the lower
Steart Peninsula reaches of the River Parrett estuary.
As part of the Steart Peninsula Coastal Management Project the Environment Agency is currently consulting on
various options available to manage flood risk in the area and to create up to 500ha of wetland and intertidal habitat
and. These options are likely to involve the construction of new defences and bunded areas and removal or breaching
of existing sea defences. Several options for realignment of existing defences are being considered and these could
involve an opening into the site being made from the Severn Estuary or the River Parrett.
The overall proposals currently include a habitat creation scheme being promoted by The Bristol Port Company. This
comprises a proposal to create approximately 150ha of intertidal habitat north of the pylon line and west of Steart
Road to provide habitat compensation for its proposed port expansion at Avonmouth. The Environment Agency is
working with The Bristol Port Company on an overall vision for the Steart Peninsula. If The Bristol Port Company’s
scheme goes ahead, it is expected to allow water to enter the site from the Severn Estuary to create intertidal habitat
by managed realignment. A set-back embankment would protect Steart Road and the pylons from flooding.
The timescale for both projects at Steart is presently unknown. However, it is considered more likely that they would
coincide with the scheduled operation rather than construction phase of the jetty development.
Potential The existing Oldbury nuclear power station, in South Gloucestershire on the eastern bank of the Severn Estuary, was
decommissioning of the due to cease generating electricity in 2008, but received the go-ahead to continue operating both reactors to mid-2011.
existing Oldbury nuclear Proposals are in hand to extend the operation of 1 reactor to mid 2012. Once operation ceases, the nuclear power
power station, South station will be decommissioned by the NDA. Decommissioning could commence sometime between 2010 and 2012
Gloucestershire and would therefore possibly coincide with the jetty construction phase, but more likely the operational phase.
The proposed decommissioning works would largely be confined to the existing footprint of the Oldbury site. Given this
and the large spatial separation between Oldbury and Hinkley Point (approximately 60km), it is not envisaged that
there is any significant potential for the interaction of effects between the projects with regard to the interest features
that could be affected by the jetty development.

In
Combination
Effect on
European
Site
Proposed New Oldbury The revised draft Nuclear NPS identifies land at Oldbury as a potential site for the development of a new nuclear
Nuclear Power Station, power station. Works at the site not scheduled to begin until 2016 and would, therefore, potentially overlap with up to
South Gloucestershire three years of the operational phase of the jetty (and the dismantling/removal phase). While specific details on the
construction programme and potential impacts are not yet available, it is anticipated that these initial works at Oldbury
would be confined largely to the development site and would not have any wide ranging effects on estuarine ecology.
Given this, and the fact that the site is approximately 60km upstream of Hinkley Point, the potential for any in
combination effects is considered to be very low and, as a consequence, this project is not considered any further in
the assessment.

During Operation
• Completion of the seawall;

• Discharge of waters to the foreshore from deep excavation dewatering and construction site
run-off;
• Construction of the cooling water system intake and outfall structures and Fish Recovery and
Return System;
• Commissioning and operation of EPR1; and
• Construction and operation of a refurbished wharf at Combwich.
7.3.4 The following sections set out the predicted in combination effects on European and international
designated nature conservation interests with respect to those features for which a potential likely
significant effect has been assessed for the jetty development. The assessment of the potential
in combination effect is based on review and interpretation of information that is available on the
screened projects at the time of writing. The following sources of information have been used in
this respect:
• Site Preparation Works – EDF Energy - Environmental Statement submitted to West

Somerset Council, November 2010 (Ref. 92);
• Hinkley C Project – Stage II Consultation, Environmental Appraisal; July 2010 (Ref. 93);
• Steart Coastal Management Project – Environment Agency – Scoping Consultation
Document; Appendix A - Preliminary Environmental Assessment, March 2010 (Ref. 96); and
• BDSCT – The Bristol Port Company, Environmental Statement, July 2008 (Ref. 36).
7.3.5 Commentary and assessment is provided below for the site preparation works and the Hinkley
Point C Project in the first instance, given their proximity and potential for direct interaction with
the jetty development. Following this, consideration is given to the other projects whose effects
have the potential to interact with those of the jetty development and for which it has been
identified that the same receptors could be affected.
7.3.6 Potential in combination effects that could occur as a result of the projects under consideration
are described for each of the international sites with respect to the relevant interest features. A
judgement is then provided as to whether an in combination impact would be likely to constitute a
significant effect on the feature.
7.3.7 Although the potential for such in combination effects may exist, as highlighted in the previous
sections, where it is apparent from the assessment work undertaken that the jetty development is
unlikely to have an adverse impact on ecological interests or physical processes, it is also unlikely
that in combination (and cumulative) effects would occur. In these instances, for those projects
being considered, it is their effects alone to which the potential impact(s) may be attributed.

7.4 Severn Estuary SAC
a) Estuaries feature – intertidal communities
7.4.1 The intertidal component of the Estuaries feature could be affected by the following activities
related to the development of Hinkley Point C:
• construction of the jetty;

• construction of the headwall structure for the site preparation drainage discharge;
• discharge of water across the foreshore from the site preparation works;
• construction of the seawall for Hinkley Point C;
run-off;
• the influence of the thermal plume from EPR1; and
• Construction and operation of a refurbished wharf at Combwich.
Jetty Development
7.4.2 As detailed above, the area over which the jetty would be constructed comprises a rocky
foreshore that supports typical estuarine communities dominated by fucoid seaweeds. However,
some small areas supporting Corallina would also be affected by the works where the jetty
crosses the western extent of foreshore channels that support Corallina. It is estimated that the
piling works would affect approximately 320m2 of intertidal and shallow subtidal area, but that only
a small proportion of this would be direct intertidal habitat loss under the footprint of the piles (i.e.
approximately 15m2); the remainder of this area representing the area that could be disturbed
during construction.
7.4.3 The jetty has been positioned to avoid the more significant cross-shore drainage features that
maintain Corallina turf. However, the movement and operation of plant and personnel along the
foreshore for the pile driving during the jetty construction is likely to disturb the channels, some of
which support a Corallina turf community. Any blockage of such channels due to construction
plant, the deposition of construction materials or modifications to allow the passage of personnel,
plant and vehicles could disrupt the natural along-shore and cross-shore drainage patterns of the
foreshore. In turn, this could influence the locations in which Corallina swards can develop or
continue to flourish. Sediment generated during these works could also potentially lead to
smothering of Corallina turf and other foreshore communities in the vicinity of the jetty works. The
potential for this impact to occur would be minimised through the collection and disposal of any
arisings from the piling operations.
Site Preparation Works
7.4.4 The drainage headwall works would obscure a small area of upper foreshore (estimated at less
than 180m2) between MHWS and HAT and, therefore, within the boundary of the Severn Estuary
SAC. This area forms part of the rocky shore community sub-feature of the Estuaries feature.
The ES for the site preparation works identifies that the uppermost part of the foreshore is largely
devoid of marine flora and fauna and that no species of nature conservation interest or ecological
importance (e.g. Corallina) occur above MHWS.

7.4.5 The area of the works for the drainage headwall would be subject to disturbance (e.g. vehicle
movements), in addition to natural events, but such impacts are not expected to be of any greater
magnitude than those caused by natural storm events. In addition, following a storm event it is
unlikely that any evidence of foreshore access for the works would remain.
7.4.6 The headwall works would eventually be subsumed within the seawall constructed for Hinkley
Point C and, therefore, from an in combination perspective, it is the total loss of upper foreshore
that would result from the seawall development that is of relevance.
7.4.7 Modelling of freshwater inundation of the foreshore from the surface water discharge associated
with the site preparation works indicates that it would not lead to inundation of any recorded areas
of Corallina present on the foreshore. The potential for smothering of foreshore communities by
sediment released during the works would also be minimised through the use of WMZs
(attenuation ponds) to reduce suspended sediment concentrations to an acceptable level prior to
discharge. Hence no impacts are predicted.
Hinkley Point C Project - construction of the seawall
7.4.8 Construction of the seawall along the upper foreshore is scheduled to commence during the final
stages of the construction of the jetty and would then continue through into its operational phase.
7.4.9 The seawall would be constructed above MHWS, although the rock armour to the wall would, in
places, extend below MHWS. In total it is estimated that the seawall (including rock armour)
would have a footprint of 4920m2. The supratidal area in which the seawall would be located is
characterised by small boulders and rocks derived from both washout from the cliff and storm-
driven longshore transport. It is practically devoid of marine fauna and flora apart from some
species of lichen.
7.4.10 The construction works would require that machinery for the excavation works and actual
emplacement of the seawall are located adjacent to the structure, either on a permanent or
temporary basis depending on whether tidal conditions permit. It is estimated that a working area
of 15-20m width would be required throughout construction. Given that rock from the foreshore
would be removed during excavation, further disturbance would be limited to any additional effect
that machinery tracking along the shore would have on existing intertidal communities.
7.4.11 Construction of the seawall would have no impact on areas of habitat supporting Corallina. The
observed distribution of the Corallina biotope shows that the nearest occurrence is approximately
75m from the site of the proposed seawall. Given the distance between the seawall and the
location of Corallina on the foreshore it is considered unlikely that the seawall works would have
the potential to impact upon this interest.
7.4.12 However, during construction of the seawall there are a number of activities and processes that
may lead to a reduction in water quality as a result of discharge of potentially contaminated water
to the foreshore. The footings for the seawall may need to be dewatered and discharge to the
foreshore is likely to be the main proposed route of disposal. This discharge and the excavation
works may lead to an increase in suspended sediment concentrations.
7.4.13 Large volumes of concrete would be used in the construction of the seawall, with the potential for
a significant increase in water pH to occur should concrete spillage occur (due to the alkalinity of
fresh concrete). The risk of such incidents occurring and the management of them to minimise
potential environmental harm would be dealt with through the application of specific construction
management guidance.

7.4.14 The location of the seawall works on the uppermost part of the shoreline, and largely above
MHWS, suggests that the potential for any significant effect on water quality in the nearshore
zone is unlikely. Under high tide conditions, any discharges from the construction area, even if
containing relatively high suspended sediment concentrations, would be rapidly dispersed and it
is anticipated that background conditions would be achieved close to the points of discharge.
7.4.15 Under low tide conditions, discharges across the intertidal area would probably infiltrate the
existing substrates (as they are permeable) and any fine sediment would probably be washed into
the upper beach fabric or deposited in existing areas of mud. Although it depends on the volume
of the discharges, it is considered unlikely that they would be sufficient to reach the Corallina
community present on the lower-mid shore. Even if discharge were to reach this area and the
drainage collected in channels containing Corallina, such events occur naturally with rainwater
draining off the foreshore and with the effects of tidal shear these materials would be quickly re-
suspended and transported elsewhere.
7.4.16 Overall, taking these aspects into consideration the magnitude of the impact on foreshore
communities, and in particular Corallina, is predicted to be low. Corallina can tolerate fluctuations
in salinity and is adapted to the changes that may occur as a result of natural exposure to
extreme salinity variations.
Influence of the thermal discharge from EPR Unit 1 during operation of Hinkley Point C
7.4.17 During the operational phase of the jetty, EPR Unit 1 would be commissioned and become
operational. The exhalent cooling water stream from EPR1 would be discharged to sea from two
seabed mounted outfall structures positioned approximately 2km offshore. The results of
modelling work have been provided in the Stage II consultation documentation for the Hinkley
Point C Project. This work indicates that the thermal plume associated with the cooling water
system, with both EPR units operating, would extend largely offshore and to the east of Hinkley
Point. The thermal plume would partially cover waters in the nearshore and would extend over
part of the intertidal and foreshore in the vicinity of the jetty. The provisional modelling work
presented in the Stage II consultation documentation indicates that within this nearshore area that
water temperature would be raised in the region of less than 1 degree (for the proposed outfall
configuration). This temperature rise is assessed as being unlikely to cause any adverse harm to
marine organisms.
7.4.18 The potential for the thermal plume from to interact with any of the effects of the jetty on marine
ecology is considered to be very limited. This is largely due to the fact that there would be only a
relatively short period of overlap between the operational phase of the jetty and operation of
EPR1 during which any effects could be manifested prior to the jetty being removed (i.e. the
potential for any cumulative impact would be short-lived). Additionally, the jetty itself has a
negligible effect upon marine ecology during its operational phase, as any intertidal / subtidal
habitat change and loss would have taken place during its construction. While it may be that the
thermal plume could result in an increase in conditions that cause additional stress to some
intertidal / subtidal organisms, it is apparent that the lack of any direct interaction with effects
associated with the jetty means that it is any effects associated with the thermal plume itself that
would predominate and, therefore, no cumulative impact would arise with respect to this potential
component of the Hinkley Point C Project.

b) Estuaries feature – subtidal communities
7.4.19 The Subtidal component of the Estuaries feature could be affected by the following activities
associated with the development of Hinkley Point C:
• dredging of the berth for the jetty;

• construction of the intake / outfall structures for the cooling water system;
• construction of the Fish Recovery and Return outfall; and
• the influence of the thermal plume from EPR1.
Hinkley Point C Project – construction of the outfall / intake structures for the cooling water
system and the outfall for the Fish Recovery and Return system
7.4.20 Habitat loss would occur due to excavation of the seabed for the construction of vertical shafts
connecting to the horizontal (intake and outfall) tunnels and the FRR outfall. Habitat loss /
modification would be permanent for the area of the estuary bed required for the vertical shaft
openings. It would be temporary at the anchoring locations (wet drill operation) or for the area
around the vertical shaft opening.
7.4.21 The benthos of this area is typical of the extensive muddy plain that makes up most of the local
seabed. Population densities are low due to the extreme tidal conditions. Typical taxa include
annelid worms, crustaceans, molluscs and bryozoans. The most prevalent species around the
proposed vertical shaft sites are the oligochaete Tubificoides amplivasatus and the polychaete
Nephtys. All species identified are commonly found at a national level. The biotope concerned is
'Nephtys hombergii and Macoma balthica in infralittoral sandy mud’ which covers approximately
76km2 out of the total of 94km2 surveyed (Ref. 103). The habitat type which is likely to be lost is
thus locally common and widespread as well as being common throughout estuaries in the UK.
7.4.22 The vertical intake shafts in total would represent a loss of subtidal habitat of ~58m2. The area of
the opening of the outfall vertical shafts would be ~48m2. This represents approximately 0.01% of
the area of the ' Nephtys hombergii and Macoma balthica in infralittoral sandy mud’ within
Bridgwater Bay. In addition, during wet drilling, there would be temporary loss of habitat around
the anchor sites, which would, again probably be in the region of 0.01% of the area of the
dominant biotope in Bridgwater Bay.
7.4.23 The predominant epifauna within the area is the brown shrimp Crangon crangon. As both this
species and other epifauna are mobile they would be able to move away from the area to seek
suitable nearby habitat and would be less affected by the habitat loss.
7.4.24 In the areas of disturbance around the shafts (through either construction approach), a typical
faunal assemblage would very quickly become re-established due to tidal mobilisation of surface
sediments. Even in less dynamic systems the evidence from studies of recovery rates in subtidal
benthic communities of the type present within the footprint of the works clearly demonstrates that
soft-sediment, bivalve-annelid dominated communities are able to recover from disturbance
events within 1-2 years (Ref. 104).
7.4.25 Overall, given that recovery of affected areas within areas disturbed during construction would be
expected, the impact of this activity would be solely related to the small-scale habitat loss. At an
approximate area of 106m2, it is considered that this total area of habitat loss would be predicted
to have a negligible impact upon the extent and functioning of the affected subtidal communities.

Cumulative intertidal and subtidal habitat loss
7.4.26 The marine habitat type that would be lost and / or disturbed as a result of construction of the
vertical shafts for the cooling water system and the Fish Recovery and Return system is quite
distinct from the intertidal and shallow subtidal habitat that would be impacted by the jetty
development and also that of the seawall. While these habitats are distinct, and therefore the
assessed impacts for each activity are confined to them, overall there would be a cumulative loss
of habitat from the estuary as a whole.
7.4.27 In total, it is estimated that between them the shafts and the jetty structure would result in a total
loss of approximately 156m2 of habitat and disturbance to a further 300m2. The seawall would
lead to the loss of 4950m2, albeit of habitat that is largely devoid of marine flora and fauna. At the
estuary level, this represents an extremely small area of marine habitat (subtidal and intertidal
combined) given that the total area of the estuary is in the order of 74,000ha.
7.4.28 Within the more immediate vicinity of the Hinkley Point frontage, the total loss clearly forms a
greater percentage of the total area of marine habitat present within the vicinity of the Hinkley
Point C Project. If it is assumed that this immediate area (excluding the potential influence of the
thermal plume) covers approximately 3km of intertidal frontage by 3km offshore, then the total
area equates to approximately 900ha. The habitat loss associated with the works, therefore,
would be in the region of 0.06% of this marine area in the vicinity of Hinkley Point. It should also
be taken into account that the habitat loss associated with the jetty is of a temporary nature and
that, following dismantling or removal, the area occupied by the piles and disturbed by the works
would be capable of supporting marine communities similar to those that exist at the present time.
Therefore, in the longer term (i.e. the post-operational period for the jetty), the impact of habitat
loss would be that of the Hinkley Point C Project alone and the in combination element of the
impact would effectively cease.
7.4.29 As for the disturbance and smothering to Corallina habitat that could occur during the jetty works,
there are no other offshore or onshore works that would result in the disturbance to Corallina and
other foreshore communities, or alteration of the physico-chemical quality of the estuary such that
an effect on Corallina would occur. Therefore there is no cumulative impact.
Other Plans and Projects
7.4.30 The potential for the Steart Coastal Management Project to lead to loss of habitat is presently
unknown, but if this were to occur it would largely affect intertidal mudflat and sandflat habitat
fronting the peninsula as a result of tidal flows from the realignment site. However, it should be
noted that any impact on the SAC estuaries feature and intertidal mudflats and sandflats feature
would be more than offset by the extensive creation of estuarine habitats that would result from
this project.
7.4.31 The Environment Agency recently completed consultation on a number of coastal defence
options at Steart. In summary, it was considered that there could be potential changes to
hydrodynamics and sediment accretion / erosion (which could lead to ecological change), but
none of these predicted changes are expected to interact with the proposed nuclear power station
development (including the jetty) at Hinkley Point due to spatial separation between the sites.
7.4.32 The BDSCT works would lead to the loss of a small area (approximately 2ha) of impoverished
intertidal mudflat and alteration to a significant area of mudflat upstream of the works at
Avonmouth. Mitigation and habitat creation to compensate for the habitat loss and alteration that
would result from the BDSCT works would be implemented at Steart as part of the Steart Coastal
Management Project. Both the Steart Coastal Management Project and the BDSCT would affect

different estuarine habitat to the rocky shore communities that would be affected by the jetty
development. There is no potential, therefore, for any in combination effect at this sub-feature
level. At the estuary level, as stated above, the implementation of the Steart Project (inclusive of
the compensatory habitat for the BDSCT project) would lead to an overall habitat and biodiversity
gain.
7.4.33 With respect to water quality, the relatively high degree of spatial separation between the jetty
development and the nearest project that could influence the marine environment (the Steart
coastal management project, located approximately 7km to the east), indicates that the potential
for any in combination effect in relation to water quality is considered to be extremely remote.
7.4.34 The BDSCT project would influence water quality through the introduction of large volumes of
suspended sediment into the water column, particularly from dredging for the berths and the
deposition of dredged material at the disposal site in the Bristol Channel. However, while
increases in suspended sediment concentrations above background variation would occur, such
an increase in concentration is not predicted to occur in the vicinity of Hinkley Point and baseline
conditions would therefore prevail.
Conclusion
7.4.35 Based on the above considerations and assessment it is concluded that the combination of the
jetty development with the site preparation works and the Hinkley Point C Project, as well as other
relevant projects, would not lead to a significant effect arising (i.e. no likely significant effect) with
respect to the Estuaries feature.
c) Reef Feature
7.4.36 The reef feature could be affected by the following activities related to the development of Hinkley
Point C:
• construction of the jetty;

• discharge of water across the foreshore from the site preparation works;
• construction of the intake / outfall structures for the cooling water system;
• construction of the seawall for Hinkley Point C;
run-off;
• influence of the thermal plume from EPR1.
Jetty Development
7.4.37 Construction of the jetty would not impact on Sabellaria as the reef habitat in the study area is
located outside the direct zone of influence of the jetty works and thus no in-combination effect
would arise.
7.4.38 The headwall structure for drainage of the site preparation works are would be located above
MHWS and, therefore, would not have the potential to lead to any loss of intertidal habitat that
could support Sabellaria.

7.4.39 Surface water discharge modelling work for the drainage from the site preparation works area
indicates that the only area of Sabellaria reef habitat is located outside the zone of influence of
the proposed discharge.
Hinkley Point C Project
7.4.40 Sabellaria reef is currently present on the lower shore several hundreds of metres away from the
construction area on the upper shore. It is therefore unlikely that any discharge from the seawall
construction works would reach the foreshore area supporting Sabellaria and, even if discharge
water were to reach this area, any such discharge would be diluted or greatly dispersed during
daily tidal inundation of the foreshore.
7.4.41 Although there is the possibility that subtidal Sabellaria may be present at the vertical shaft sites
this, given the local habitat type involved, would not include any reef formations.
Conclusion
7.4.42 As no impacts on Sabellaria are predicted as a result of the proposed works associated with the
development of Hinkley Point C, in combination, no likely significant effect would occur.
d) Annex II Fish Species
7.4.43 The Annex II fish species feature of the SAC could be affected by the following activities related
to the development of Hinkley Point C:
• habitat loss due to jetty development, seawall construction and cooling water system
infrastructure;
• noise generated during construction of the jetty, site preparation works, seawall and cooling
water system infrastructure;
• noise generated during operation of the jetty and construction of the cooling water system
infrastructure;
• water quality changes (increased suspended sediment concentrations) associated with
discharge of water across the foreshore from the site preparation works;
• the influence of the lighting.
Jetty Development, Site Preparation Works and Hinkley Point C Project - habitat loss during jetty
construction
7.4.44 The small scale of intertidal habitat loss that would result from the jetty development and the
subtidal loss associated with the cooling water infrastructure and the Fish Recovery and Return
system for Hinkley Point C is considered to be insignificant with regard to its function as a feeding
resource for migratory and other fish. As a consequence, no cumulative impact relating to this
aspect is anticipated.
Jetty Development, Site Preparation Works and Hinkley Point C Project - noise generating
activities during jetty construction
7.4.45 During construction, noise generation and its effects on fish can be viewed as disturbance events
that last as long as the activity itself. Thus, in situations where there are a number of activities
occurring over a period of time, disturbance may occur as discrete events or, if activities overlap,
noise effects may combine to generate an effect of greater magnitude or duration. The

construction schedule for the jetty development indicates that there is the potential for an additive
noise effect to occur due to the coincidence of the jetty with construction works on the upper
shore for the site preparation works, and then a later overlap between the jetty and the Hinkley
Point C seawall construction.
7.4.46 Assessment of this issue with regard to the site preparation works concludes that there would not
be an adverse impact on fish populations due to works being undertaken above MHWS and,
therefore, not having the capacity to influence fish in intertidal waters.
7.4.47 Similarly, as the construction works for the seawall would occur above MHWS and out of the
water at all times, the potential for any noise and vibration effects to occur in the water column
would be extremely limited, with noise being generated on the uppermost sections of the shore
and often at some distance from the water’s edge. Any disturbance effects on fish present in
intertidal waters, therefore, would be negligible.
7.4.48 Given the low potential for any disturbance effects to occur during construction works on the
upper shore, the cumulative impact of noise and vibration generation on fish is effectively
restricted to that of the jetty construction itself (i.e. pile driving activities and dredging) and the in
combination element is, therefore, solely that of the jetty construction.
Jetty Development and Hinkley Point C Project – noise generating activities during jetty operation
7.4.49 During the operation phase for the jetty, vibration resulting from the operation of conveyor drive
units mounted on the jetty, and possibly from the moving conveyor belt itself, could radiate to the
marine environment and bedrock via the jetty infrastructure. However, the magnitude of vibration
is likely to be very low, as the conveyor would be fitted with integral vibration isolation mounts.
The potential for an effect on migratory and other fish species in the vicinity of the jetty has
therefore been assessed as negligible.
7.4.50 During construction of the shafts for the intake and outfall tunnels of the cooling water system and
Fish Recovery and Return system the main sources for the generation of noise and vibration
would arise from any piling works and vessel movements around the construction area. For the
purposes of assessment it has been assumed that pile driving would be required. There is no
information currently available regarding the types of piling expected to be used (e.g. impact,
rotary or vibro piling). Therefore, as a worst case, it is assumed that percussion piling would be
used. Vessel movement noise would be generated regardless of whether piling is used or not.
The construction of the vertical shafts for the intake and outfall structures is likely to require a
variety of vessels to move platforms and associated equipment into place, collect discharges,
collect and transport drill cuttings and other waste materials, and supply plant and personnel to
site.
7.4.51 With regard to drilling noise during the construction of the horizontal tunnels, the depth of the
drilling within the bedrock (40-20m depth) suggests that the propagation of sound waves into the
water column would be limited. Flatfish, which are sensitive to vibration and low frequency
sound, are likely to be able to feel the vibration from the approach of drilling activity through the
seabed and, therefore, would have the opportunity to move from the area before noise levels
increased. Any avoidance reaction in fish would be likely to be confined to the immediate corridor
above the tunnel and it is considered that there would be a negligible sound level within the water
column at a distance of >1km from the source and a negligible influence due to vibration
associated with the tunnel drilling. Given this it is assessed that there would no cumulative
impact on fish or marine mammals as a result of potential interaction between the activities.

Jetty Development and Hinkley Point C Project - lighting
Lighting effects on intertidal areas
7.4.52 This effect only applies with regard to the temporary jetty. While it is possible that lighting may be
used during construction of the seawall (tidal conditions permitting) there are no intertidal
communities of significance (e.g. Corallina turfs) within 100m of the location for the seawall.
7.4.53 The organisms present on the foreshore are likely to be tolerant to exposure from artificial light as
clearly these communities are subject to intense light levels on a daily basis. Artificial lighting
would also only have an effect during low tidal conditions, which effectively means that due to
attenuation through the water column, communities would not be subject to a 24hr increase in
light levels.
7.4.54 Of the Corallina dominated biotope present on the foreshore at Hinkley only a relatively small
area falls within the footprint of the temporary jetty. Of this small area it can also be stated that
potential lightfall from artificial lighting would only affect a proportion of the Corallina biotope
present, as light levels would rapidly drop off from the source. Although an increase in light levels
could potentially promote growth of Corallina it is highly unlikely that the overall increase that
some isolated areas of Corallina might be subject to would promote growth such that it was of
significance or potentially interfere with other physiological processes.
Lighting effects on the water column
7.4.55 During the construction phase lighting of the works for drilling of the vertical shafts for the intake /
outfall structures and for the temporary jetty may influence the water column. Lightfall into the
water column would also occur during operation of the temporary jetty.
7.4.56 The key variable to take into account when assessing light attenuation through water is the
suspended sediment load of the water. Due to the very high turbidity levels within the Severn
Estuary there would be limited penetration of the artificial light into the water column, and it is
considered that light levels would be negligible after 1m - 2m of passage though water.
Consequently, only organisms near the water surface may be affected by this night time lighting
and benthic organisms on the estuary bed would not be expected to be influenced.
7.4.57 Light is known to have a strong influence on fish behaviour, with photoperiod and artificial
manipulation of this acting as an environmental cue in relation to reproduction, and also as a
factor determining migration. Changes in natural reproductive development rates as a result of
artificial light regimes have been demonstrated for a range of fish species. However, this has
generally been where the light environment experienced by fish is overwhelmingly determined by
that artificial source (e.g. in aquaria, laboratories or fish farm facilities).
7.4.58 Light has also been demonstrated to influence fish migration, with species such as salmon and
sea trout migrating predominantly at night rather than day. Similarly, various species have been
demonstrated to either be attracted to or repelled by light, with the majority being repelled.
7.4.59 While it is possible that some fish species may be present within the area affected by artificial
light, the potential magnitude of change associated with this effect (for the reasons given above)
is considered to be very low. Given that it is likely that only a very small percentage of the
estuary area would be affected, for both the temporary jetty and the shaft drilling works, and that
many species, including migrating fish, would avoid any lit areas, the overall effect on fish
movement is anticipated to be of negligible significance for the construction phase (drilling works
and jetty) and operational phase (jetty).

7.4.60 With regard to other projects that could lead to disturbance to fish populations, including SAC
Annex II species, the only identified projects within the construction timeframe for the jetty (i.e.
when the piling works would be undertaken) are the BDSCT (piling and dredging works) and the
proposed managed realignment / habitat creation project at Steart. For BDSCT, the project’s ES
makes it apparent that piling works, in particular, could have an adverse effect upon fish species
within close proximity (<500m) to the works due to the predicted increase in underwater noise
levels. A range of mitigation measures are proposed and the conclusion is reached that the
works would not have an adverse effect upon the SAC designated species populations. Although
information is not available, it is not expected that the proposed works at Steart would lead to any
significant increase in underwater noise levels such that an adverse impact on fish species would
occur. The large spatial separation between the BDSCT and Steart projects and the jetty
development, together with the nature of the noise disturbance (i.e. events rather than a continual
background increase in noise levels that may then trigger thresholds to be reached), indicate that
it is highly unlikely that the jetty development could act in combination with these projects such
that migratory fish would be affected.
7.4.61 Based on the above considerations and assessment it is therefore determined that there would
be no likely significant effect on Annex II fish species due to the jetty development acting in
combination with other plans or projects.
e) Summary of interactions between the jetty development, site preparation works and the
Hinkley Point C Project on marine habitat function
7.4.62 As discussed above, there are effects of both the jetty development and the Hinkley Point C
Project that could combine and interact to lead to a cumulative impact on the intertidal and
shallow subtidal marine ecology of Hinkley Point. The impact of the site preparation works on
marine ecology is considered to be negligible and, hence, further discussion of this aspect of the
works is excluded from this section.
7.4.63 The sections above have highlighted that the combined works at Hinkley Point could affect a
number of different components of the intertidal and subtidal ecology. For the individual receptors
the assessed impacts are not considered to be any greater than of minor significance, individually
or cumulatively. This conclusion results from a number of factors, but chiefly the spatial
separation between the activities likely to have an effect, the phased nature of the works (i.e.
covering an approximate eight year period from jetty construction through to initial operation of
EPR1) and the different receptors within the marine environment that would be affected. The
temporary nature of the jetty works and the likely high degree of ecological recoverability of the
features indicates that the potential for any longer term impact on ecological function would not
occur as a result of the jetty works alone.
7.4.64 During the overlap period with Hinkley Point C, the effects that could potentially combine with
those of the jetty would be restricted to the construction of the seawall. As discussed previously,
the location and structure of the habitat affected by the seawall indicates that the loss of area
would be unlikely to have wider implications for the intertidal ecology of the Hinkley foreshore.
Following the end of the seawall construction the foreshore would not be disturbed again by
activities until the removal of the jetty structure.
7.4.65 From an ecological perspective, other than the temporary loss of habitat due to the jetty piling
works, the jetty construction works and seawall construction can be treated as disturbance
events, from which recovery of the foreshore communities would be expected following
construction. The total area affected by the works would be relatively small within the context of

the wider area of rocky-shore intertidal communities present at Hinkley Point and to the west. On
this basis it is concluded that while the foreshore at Hinkley may be subject to a number of
construction-led disturbance events, the totality of these events would be one of prolonging the
overall period of effect across distinct parts of the foreshore rather than intensifying impact such
that a longer term loss or change in habitat function would occur.
7.5 Severn Estuary SPA
a) Habitat loss
Jetty Development, Site Preparation Works and Hinkley Point C Project
7.5.1 The jetty development’s construction works would lead to small-scale loss of intertidal rocky shore
habitat. Available information on the usage of this part of the Hinkley Point frontage indicates that
foraging activity by birds is low and confined to regular use by a small number of birds.
7.5.2 Habitat loss resulting from the site preparation works and within the designated area of the
European sites would be extremely small. The habitat affected is also of extremely limited or no
value for foraging or roosting birds, as it comprises cobbles, pebbles and a section of low cliff
above MHWS. As a consequence it is assessed that the loss of this area would not have an
impact with regard to the availability of food resources or roosting / loafing area for SPA
designated bird populations.
7.5.3 Construction of the seawall would lead to the loss of c. 0.6ha of upper shore (above MHWS)
habitat. The nature of this habitat indicates that its potential as a foraging resource for birds is
extremely limited, and this is reflected in part in the low usage of the Hinkley frontage in the
vicinity of the seawall and jetty development by birds. It is, therefore, not anticipated that the loss
of this are would have an impact upon the available foraging resource for designated SPA /
Ramsar populations of birds.
7.5.4 Overall, the Steart Coastal Management Project (inclusive of the compensatory habitat for the
BDSCT) would lead to an overall gain in estuarine habitat that could be utilised by SPA
designated bird populations. It is, therefore, not anticipated that these projects would, in
combination with the jetty development, have a likely significant effect upon the designated SPA
interests.
b) Disturbance to Birds during Construction
Jetty Development
7.5.5 The jetty development’s construction works have the potential to disturb birds foraging or utilising
the foreshore, particularly as the works would be focused on the mid-lower foreshore, an area
that is usually of significance for foraging birds. The jetty development’s construction works
would involve greater activity and noise levels adjacent to the Severn Estuary than the site
preparation works (see below), and would occur in relatively close proximity to the site
preparation works.
7.5.6 The site preparation works would be undertaken adjacent to and partially within an area of coastal
frontage that is relatively poorly utilised by birds (see ES Chapter 11 and sections above). This

suggests that the impact of disturbance generated by construction activities would be small and
the site preparation works alone would not have a significant effect on SPA / Ramsar site
designated bird populations.
Hinkley Point C Project
7.5.7 The jetty works may also overlap with the first 6 months of construction of the Hinkley Point C
Project, and construction of the new seawall that would front the Hinkley Point C power station
could commence. This work would be undertaken along the upper foreshore, although during the
overlap period it is not anticipated that the seawall works would be progressed to the extent that
any further significant alteration / loss to the upper foreshore (above MHWS) would occur.
However, if additional machinery and activity is present on the foreshore during this period, then
the potential for a continuation of and possible increase in disturbance to birds may occur.
7.5.8 The tunnelling works for the cooling water infrastructure and Fish Recovery and Return system
would be undertaken from behind the seawall and given that the works would be screened from
the shore by the seawall and underground, no disturbance would be expected to arise to birds
feeding or roosting along the shore fronting the areas adjacent to the jetty footprint and potential
disturbance zone.
7.5.9 With regard to the potential effects of other projects, the nearest is the Steart Coastal
Management Project. Specific details of the works that could occur on the immediate shoreline
frontage (e.g. breach to the existing defences) are not available, but such construction works
could have the potential to disturb birds that utilise the fronting intertidal area. In terms of
sensitivity to disturbance and the likely extent of any effect, it is apparent that the works, if they
temporally coincided, would not lead to any spatial overlap in disturbance effect as the Steart
project is located approximately 7km to the east of the jetty development. There is sufficient and
extensive habitat adjacent to the Steart site such that any birds displaced by the works would be
likely to relocate relatively close to the Steart peninsula.
7.5.10 The BDSCT project would also lead to disturbance to birds within the immediate area of the
works at Avonmouth. However, given the significant distance between the projects (60km) it is
highly unlikely that birds disturbed by the BDSCT would also be subject to disturbance as a result
of the jetty works, particularly given that there is a large area of suitable habitat between the
BDSCT location and the proposed jetty that could accommodate any birds disturbed by the
BDSCT. Also, from the information presented in the BDSCT ES, it is apparent that only a small
number of birds would be subject to disturbance. Within the area that would be subject to reclaim
and the main effects of construction activity, the BDSCT ES reports that in the context of the
estuary population the mean peak usage of the area represents approximately 0.1% of the total
estuary population of waterbirds. Redshank may be present in the area of potential disturbance
at the BDSCT site at levels up to 1.0% of the SPA population. However, this species makes rare
usage of the Hinkley Point frontage in the vicinity of the jetty development’s construction works
areas. Shelduck is also present at the BDSCT site, but typically only a few birds (<5) were
recorded using the site. Given these factors it is, therefore, concluded that even if disturbance to
birds at both the BDSCT and the jetty development sites were to occur at the same time, the
displacement effect would be negligible at the population level for the species that could be
affected by the jetty development, particularly as they would not be displaced outside their home
range.

7.5.11 The potential disturbance effects of these two other projects would, therefore, be unlikely to
combine with that of the jetty development and no likely significant effect in combination with them
is predicted.
7.6 Exmoor and Quantocks Oakwoods SAC
a) Barbastelle bats
Jetty and Site Preparation Works
7.6.1 The footprint of the site preparation works would include and cover a larger area than that
affected by the jetty development, effectively including the negligible loss or fragmentation of
foraging habitat or commuting corridors used by barbastelles arising from the jetty development
itself. Using the full extent of the site preparation works footprint of 171ha (which includes the
Jetty footprint) this would result in the loss of 0.6% of habitat within 9km of the SAC which the
barbastelles potentially use. The impact of the site preparation works would therefore be the
defining impact during the construction, operation, and dismantling and restoration phases of the
jetty development (where the latter would coincide with the operation of Hinkley Point C). The
site preparation works HRA information has identified that there would be no impact on the
population of barbastelle associated with the Exmoor and Quantocks SAC.
7.6.2 The combined impact of the jetty development and the site preparation works on barbastelle
would be no greater than that associated with the site preparation works alone. Consequently, as
the site preparation works HRA information identifies that no adverse affect on the conservation
status the barbastelle population in the SAC would arise, no adverse affect on the conservation
status the barbastelle population would arise in-combination with the jetty development.
Hinkley C Project
7.6.3 The land-based components of the Hinkley Point C Project have the same footprint as the site
preparation works and impacts arising from the Hinkley Point C construction and restoration
phases would occur over the same period as the construction, operation, and dismantling and
restoration phases of the jetty development (which would not affect barbastelle populations).
Although an increase in the extent of lighting would be expected during the construction of
Hinkley Point C, the lighting would be focussed around the key structures which are located away
from the commuting corridors and any suitable foraging habitat. Therefore, an increased level of
impact in addition to that identified above in relation to the site preparation works is not predicted
to occur with respect to barbastelle populations; particularly as the main commuting route (via
Green Lane) is to be maintained and, at this point, the advanced planting would be making a
contribution.
7.6.4 Habitat loss or fragmentation and lighting disturbance could arise at four Associated Development
sites that form part of the Hinkley Point C DCO proposal. These sites are: Cannington Bypass,
Cannington Park and Ride, Combwich Laydown Facility, and Williton Park and Ride. In total,
these sites make up 0.2% of the total land area within the 9km radius around the Quantocks
SSSI. That part of the bat consultation zone that is within these sites represents 0.1% of the total
area of the bat consultation zone within 9km of the SSSI.
7.6.5 The following habitat losses and potential effects could arise:
• Cannington Bypass – 10 hedgerows bisected, resulting in possible foraging habitat /

commuting route fragmentation; and lighting disturbance affecting foraging or commuting
barbastelles;

• Cannington Park and Ride – one hedgerow bisected, resulting in possible foraging habitat /
barbastelles;
• Combwich Laydown Facility – two hedgerows bisected, resulting in possible foraging habitat /
barbastelles; and
• Williton Park and Ride – loss of part of one hedgerow, resulting in possible foraging habitat /
barbastelles.
7.6.6 The Associated Development works would include a variety of mitigation measures to avoid or
minimise potential effects, in particular lighting mitigation, and measures to maintain commuting
routes. Furthermore, there would be planting of hedgerows and scrub that would become
established in the short- to medium-term during the operational life of these sites.
7.6.7 As set out above, the impact associated with the jetty development in-combination with the
Hinkley Point C Project on barbastelle populations would be no greater than that identified above
in relation to the site preparation works, but potential additional impacts could arise from the
Associated Developments. However given that, in-combination, a precautionary 0.8% of the
habitats within 9km would be affected by the combined works, no adverse impact is expected with
respect to the conservation status of the barbastelle population in the SAC. Following the
dismantling and restoration phase of the jetty development (in-combination with Hinkley Point C)
large areas of suitable foraging habitat would be provided and, once mature, would exceed the
areas of suitable foraging habitat lost during the Hinkley Point C construction phase.
7.6.8 Based on information about the extent of the other plans and projects screened into the
assessment (see Section 5), excluding the Hinkley Point C Associated Developments and
Preliminary Works (covered above), a total of 134ha of potential foraging habitat could be
affected by other developments that are located within 9km of the Quantocks SSSI.
7.6.9 The proposed managed realignment project at Steart would result in areas of land on the
seaward side of the proposed seawall effectively becoming part of the Severn / Parrett estuaries
and thus unlikely to be used by foraging bats. Conversely, areas of land and associated
waterbodies on the landward side of the seawall would remain available for use by foraging bats.
On this basis, those areas of land that will be on the seaward side of the seawall and that are
within 9km of the Quantocks SSSI have been treated as being unavailable to the barbastelle
population originating from the SSSI. These areas total 80ha, none of which is within the bat
consultation zone.
7.6.10 The approach that has been used to identify other consented or proposed developments draws
on the methodology for cumulative impact assessment presented in ES Chapter 25. This
involved filtering out the following categories of development:
• Extensions or alterations to an existing development.

• Erection of agricultural buildings (e.g. for housing cattle, silage clamps, feed hoppers etc.).
• Development for a proposed use that is not considered to be of a nature, or of sufficient scale
to have potential for cumulative interactions (i.e. < 8 residential dwellings, or an alternative
use in a single building).
• Planning applications that have been refused or withdrawn, or the appeal dismissed.

• Change of use or conversion of an existing building(s) (e.g. conversion of office buildings to
provide residential dwellings).
• Applications for renewal of planning permission for retention of existing operational use.
• Variations to existing planning conditions.
• Applications to change buildings materials on building frontages/roofs etc.
• Applications for window installations/alteration.
• Listed Building consent – alterations.
• Works to trees with Tree Protection Orders
• Minor infrastructure applications e.g. single wind turbine, single access road and
improvement works.
• Extensions or alterations to an existing development.
7.6.11 In the context of the HRA, these developments are screened out on the basis that their effects on
the Exmoor and Quantocks Oakwoods SAC can be safely considered to be de minimis. The
short-listed developments were then subject to a further screening exercise to exclude those that
are wholly located within built up areas and that are, therefore, unlikely to be used by foraging or
commuting barbastelle. This led to a final list of 11 developments, with a total area (i.e. within the
development application boundary) of 34ha (of which 12ha are within the bat consultation zone).
Not all of the land within the application area boundaries would be developed and at least parts of
the undeveloped areas may be suitable for use by foraging or commuting bats. However, none of
the relevant developments is closer than 4.5km from the SAC, which is close to the lower end of
the distances (5km) that barbastelle bats generally travel from a roost to their foraging habitat.
Furthermore the total area of developments within 5km is only 3.6ha.
7.6.12 The other projects within 9km of the Quantocks SSSI could potentially result in the combined loss
of 146ha of possible foraging habitat for the barbastelle bat population in-combination with the
jetty development. This equates to 0.5% of the available habitat within 9km of the SAC, all of
which is typical of habitat found in West Somerset. Consequently, the in combination impact of
loss of foraging habitat (which would contribute to commuting corridors as well) would not
adversely affect the conservation status of the barbastelle population in the SAC.
7.7 Conclusion on In combination Screening for ‘Likely Significant Effect’
7.7.1 On the basis of the information presented and assessed in the previous sections, it is concluded
that of the effects associated with the jetty development the only one that is likely to have a
significant effect with respect to the designated features of the relevant SAC, SPA and Ramsar
site is:
• the combined impact on the SPA designated bird populations that could arise through
disturbance generated by construction activities associated with the jetty development and
construction of the seawall for the Hinkley Point C Project.
7.7.2 Appropriate assessment is therefore required in relation to this component of the project and
further information and discussion is presented in Section 8. The conclusions with respect to all
of the other issues considered in the in combination assessment regarding likely significant effect
are summarised in Table 22.

Table 22: Jetty development – summary of assessment of ‘likely significant effect’ in combination with other plans or projects
Activity In combination - Summary comment

likely significant
effect
Severn Estuary SAC
1 Habitat loss or modification No ‘likely • The Steart Coastal Management Project (inclusive of habitat compensation for the
significant effect’ on BDSCT) would provide an overall habitat gain at the estuary level. However, these
the interest features projects would not affect similar habitat to that present at Hinkley Point.
of the SAC
2 Disturbance due to No ‘likely • Jetty development works would be undertaken above MHWS and, therefore, do not
construction activity on the significant effect’ on have the capacity to adversely influence fish in intertidal waters.
upper shore the interest features • The significant spatial separation between the jetty development works and other
of the SAC projects indicates that the potential for disturbance events to affect the same migratory
populations would be extremely small. Given this and the lack of any significant
disturbance effect associated with the site preparation works, the conclusion is reached
that there would be no interaction and in combination impact.
3 Discharge of drainage No ‘likely • Drainage across the upper foreshore from the jetty works would not interact with the
waters from site preparation significant effect’ on water quality effects of any other projects, including site preparation’s construction
works area across the interest features works, and therefore any impact would be that of the jetty works alone.
foreshore. of the SAC • Corallina turf would not be impacted by the site preparation works.
Severn Estuary SPA
1 Loss of or change to habitat No ‘likely significant • Habitat loss as a result of the site preparation works would be negligible and away from
(coastal and marine) as a effect’ on the interest upper foreshore habitat that is unlikely to be used either for foraging or roosting by birds.
result of construction of the features of the SPA • The Steart Coastal Management Project (inclusive of habitat compensation for the
discharge headwall and BDSCT) would provide an overall habitat gain at the estuary level. These projects would
associated outfall and also not affect similar habitat to that present at Hinkley Point.
implications for bird usage.

likely significant
effect
2 Disturbance to waterbirds in ‘likely significant • The jetty development’s construction works are scheduled to partially coincide with the
the vicinity of the foreshore effect’ on the interest site preparation works (albeit that the landward works overlap in this context) and
during construction activity features of the SPA partially coincide with the Hinkley Point C seawall construction. This could generate a
larger potential zone of disturbance than that for the jetty development alone. If the
displacement of birds occurs from the foreshore as a result of activities associated with
the seawall construction these birds could be further displaced as a result of activities
associated with the jetty works, albeit in both situations the birds would not be displaced
outside their home range. While the number of birds that could be affected is still likely
to be very small, between them the two sets of works would be likely to affect a greater
number of birds than the jetty development alone. It is therefore considered that, in
combination with the seawall construction, the jetty development’s construction works
could have a likely significant effect upon SPA designated populations.
• Other projects would be unlikely to generate disturbance effects that would spatially
interact with the jetty development to the degree that foraging of feeding of any
displaced birds would be adversely affected.
Severn Estuary Ramsar Site
1 As for the SAC and SPA As for the SAC and As for the SAC and SPA
SPA

likely significant
effect
Exmoor and Quantocks Oakwoods SAC
1 Disturbance to and loss / No ‘likely significant • Although an increase in the extent of habitat affected by the site preparation works /
alteration of foraging habitat effect’ on the interest Hinkley Point C and its Associated Developments, and the jetty development within 9km
and commuting corridors features of the SPA of the SAC would arise, this effect would remain small (less than 0.8% of the overall
used by barbastelle bats habitat). Moreover, this does not take into account the limited suitability of much of this
habitat, the retention of the key commuting corridors, and mitigation to provide hop over
points and lighting mitigation for Hinkley Point C and its Associated Developments.
• Other projects would result in potential loss of or reduction to habitat (i.e. 3.6ha of
development within 5km), but the suitability of that habitat is unknown, relevant projects
are generally greater than 4.5km from the SAC, and all habitat that would be affected is
typical of the region. It is therefore considered that this loss, in-combination with the
Hinkley Point C Projects would not adversely affect the conservation status of the
barbastelle population.

8 INFORMATION FOR APPROPRIATE ASSESSMENT
8.1 Introduction
8.1.1 Following the determination of ‘likely significant effect’ as set out in the previous sections, the
conclusion has been reached that the only aspect of the jetty development that could have a
significant effect upon the designated interests of the relevant international sites is the
disturbance to birds that may occur as a result of the jetty development works in combination with
the construction of the seawall on the foreshore for Hinkley Point C.
8.1.2 In order to determine the potential significance of this effect, further assessment, and information
where relevant, is presented in the following sections in order to enable the competent authority
to undertake an appropriate assessment of this aspect of the jetty development.
8.2 Baseline information
8.2.1 Data on bird usage of the foreshore at Hinkley Point and in the vicinity of the jetty development is
presented in Section 5.3 above and in ES Chapter 11 and ES Appendix 11-3, Volume 4.
8.3 Project activities relevant to the assessment
a) Jetty Development
8.3.1 The proposed jetty development is a temporary development in that it would be dismantled and
the site restored following construction of the Hinkley Point C Project (or removed and the site
reinstated should the DCO not be made).
8.3.2 Most of the jetty’s offshore infrastructure and all onshore infrastructure would be constructed first
so that aggregate and cement could begin to be imported at the earliest opportunity, to meet the
demands of the early stages of the construction of Hinkley Point C (upon grant of the DCO).
Additional infrastructure would then be added to the jetty so that it could also be used to import
other construction materials to the site (e.g. pre-cast concrete tunnel sections).
8.3.3 The jetty’s development comprises:
• earthworks to construct the development platform for the onshore storage area (including
topsoil and subsoil storage for use in reinstatement, if required, or restoration);
• a rock extraction area for sourcing material for the platform development;
• open and covered storage facilities for aggregates (sand and stone);
• silos for the storage of cement and cement replacement products (such as Pulverised Fuel
Ash);
• a surface water drainage system serving the onshore storage area, equipped with an oil
water separator and water management zone;
• a service road providing access to the aggregates storage area, the rock extraction area and,
temporarily for the purposes of construction, to the foreshore;
• a jetty bridge constructed from vertical tubular piles supporting horizontal cross-heads and a
deck;
• a jetty head constructed from vertical tubular piles supporting horizontal cross-heads and a
deck, and incorporating mooring infrastructure (e.g. dolphins);

• a berthing pocket dredged alongside the jetty head to accommodate vessels at various
states of the tide;
• materials handling and conveyance equipment (e.g. hoppers, pipelines and conveyors)
installed on the jetty’s head and bridge as far as the aggregates storage area;
• aids to navigation.
• a roadway along the jetty bridge; and
• the jetty head turning circle for HGVs and a mobile crane.
8.3.4 Subject to obtaining relevant consents, it is envisaged that the jetty’s construction would
commence in Q2 of 2012 and the jetty would be complete and ready for operation by Q3 2013.
Figure 8-1, Volume 3 of the application shows the indicative HEO application boundary for the
temporary jetty development.
8.3.5 Of the above activities, it is the construction of the jetty bridge, in particular the installation of piles
on the foreshore, that has the greatest potential to cause disturbance to birds that may be
foraging or loafing on the foreshore.
8.3.6 The timescale for the jetty development’s construction works (see ES Chapter 8) shows that they
and the site preparation works would coincide for much of their duration.
b) Site Preparation Works
8.3.7 With respect to the site preparation works, it is the general construction activity close to the
foreshore (where the works overlap with those forming part of the jetty development) and the
drainage outfall works on the upper foreshore that have the greatest capacity to cause
disturbance to birds that may be utilising the foreshore. However, the site preparation works
would be undertaken adjacent to and partially within an area of coastal frontage that is relatively
poorly utilised by birds (see ES Chapter 11 and sections above). This suggests that the impact
of disturbance generated by construction activities would be small and the site preparation works
would not have a significant effect on SPA / Ramsar site designated bird populations.
c) Hinkley Point C Project – Seawall
8.3.8 Construction work on the seawall for the Hinkley Point C Project could overlap by up to 6 months
with the end of the jetty works. The detailed breakdown of the activities involved in construction
of the seawall at this stage has not been determined. However, if the works are to proceed they
are expected to involve:
• setting out of the working area;

• low cliff line; and
• excavation for the seawall foundations.
8.3.9 All of these works would take place on the upper foreshore and / or from the cliff top.
8.4 Assessment of the likely impact of disturbance generated by the combined works
8.4.1 Information on disturbance effects and the likely impact on birds is presented in Section 6 above
and in ES Section 11.5.

8.4.2 In considering the in combination impact of disturbance it is pertinent to note that the construction
activity associated with the site preparation works, the jetty development and the Hinkley Point C
seawall would occur along a stretch of the coast at Hinkley Point that falls along the boundary of
Count Sectors 1 and 2 of the bird survey areas (see ES Appendix 11-3, Volume 4 of the
application). The data as provided in ES Chapter 11 and in ES Appendix 11-3, Volume 4 are,
therefore, of relevance to all projects.
8.4.3 With respect to the internationally important populations of waterbirds for which the SPA has been
designated, the specific conservation objective for dunlin, redshank, shelduck, and gadwall is ‘to
maintain their populations and supporting habitats in favourable condition’. Dunlin, redshank,
shelduck, and gadwall populations will be considered to be in favourable condition when, subject
Conditions of individual SPA interest feature:

• the 5 year peak mean population size for the wintering dunlin population is no less than
41, 683 individuals (i.e. the 5 year peak mean between 1988/9 - 1992/3);
• the 5 year peak mean population size for the wintering redshank population is no less than
• the 5 year peak mean population size for the wintering shelduck population is no less than
• the 5 year peak mean population size for the wintering gadwall population is no less than
330 individuals (i.e. the 5 year peak mean between 1988/9 - 1992/3);
Conditions common to all SPA interest features, unless otherwise stated:

• the extent of saltmarsh is maintained (exception gadwall);
• the extent of hard substrate habitats is maintained (exception gadwall):
• the extent of vegetation with a sward height of <10cm is maintained throughout the
saltmarsh (exception shelduck, gadwall);
• the abundance and macro-distribution of suitable invertebrates in intertidal mudflats and
sandflats is maintained (exception gadwall);
• aggregations of individual SPA bird species at feeding or roosting sites, are not
subject to significant disturbance.
8.4.4 The assessment against the conservation objective for dunlin, redshank, shelduck and gadwall
related to disturbance (highlighted in bold in the table above), which is the primary objective to be
influenced by the proposed jetty, is provided below.
8.4.5 Dunlin were generally recorded within close proximity to the proposed jetty site in small numbers
(0.05% of the 5 year peak mean respectively, based on Table 20 for Count Sectors 1-2), primarily
during the autumn passage period between July and September inclusive, with only one roosting
bird noted on one date. Given the very low and sporadic use of the jetty area, and the wide area
of undisturbed habitat within their home range which could be utilised by dunlin should
displacement occur (see Figure 9 and Table 19), the conservation objective related to
disturbance would not be compromised as a result of the construction, operation and dismantling
(removal) of the jetty.

8.4.6 Redshank were generally recorded within close proximity to the proposed jetty site in small
numbers (0.09% of the 5 year peak mean, based on Table 20 for Count Sectors 1-2). Given the
very low and sporadic use of the jetty area, and the wide area of undisturbed habitat within their
home range which could be utilised by redshank should displacement occur (see Figure 9, Table
19), the conservation objective related to disturbance would not be compromised as a result of
the construction, operation and dismantling (removal) of the jetty.
8.4.7 Shelduck were, during their summer moult, recorded in significant numbers along the jetty
frontage (up to 18% of the 5 year peak mean, based on Table 20 for Count Sectors 1-2). Only
small numbers of shelduck were recorded foraging along the foreshore. Shelduck are known to
be potentially vulnerable to disturbance during their moult as they are flightless during this period.
Sustained disturbance effects during this period, particularly if displaced birds were unable to
relocate to alternative areas, could potentially be detrimental at the population level. The flocks of
birds recorded from Count Sector 2 fronting the proposed jetty site were present in nearshore
waters between 200m and up to 1.5km from the edge of the water. At these distances it is
unlikely that the majority of birds would be subject to disturbance effects, particularly beyond
500m. As the birds were also rafting on the water, rather than on the foreshore, movement away
from the source of disturbance would be significantly less energetic than if the birds were on land.
These flocks of birds are likely to move up and down the coast with the tidal currents and, given
that there are extensive areas of suitable habitat (open water) that would be available to birds
should they be displaced, it is considered unlikely that any sustained disturbance impact would be
likely to occur. The conservation objective related to disturbance, therefore, would not be
compromised as a result of the construction, operation and dismantling (removal) of the jetty.
8.4.8 Gadwall were not recorded from Count Sectors 1-2 fronting the proposed jetty site. Thus, similar
to Bewick’s swans or European white-fronted geese which were not recorded during the survey
work, the conservation objectives relating to these three species would not be compromised and
no adverse effect is predicted.
8.4.9 The conservation objective the waterfowl assemblage is ‘to maintain the assemblage and its
supporting habitats in favourable condition’. The waterfowl assemblage will be considered to be
in favourable condition when, subject to natural processes, each of the following conditions is
met1:
• the 5 year peak mean population size for the waterfowl assemblage is no less than 68,026
individuals (i.e. the 5 year peak mean between 1988/9 - 1992/3);
• the extent of saltmarsh and their associated strandlines is maintained;
• the extent of hard substrate habitats is maintained;
• extent of vegetation of <10cm throughout the saltmarsh is maintained;
• the abundance and macroscale distribution of suitable invertebrates in intertidal mudflats
and sandflats is maintained;
• the abundance and macroscale distribution of suitable invertebrates in hard substrate
habitats is maintained;
• greater than 25% cover of suitable soft leaved herbs and grasses during the winter on
1
The conservation objective for the “internationally important assemblage of waterfowl” feature of the
Severn Estuary Ramsar Site is to maintain the feature in favourable condition, as defined by the
conservation objective for the SPA “internationally important assemblage of waterfowl” feature.

saltmarsh areas is maintained;
• waterfowl aggregations at feeding or roosting sites are not subject to significant
disturbance.
8.4.10 Small-scale displacement within an existing home range will lead to a small increase in energy
expenditure due to the walk or flight that is undertaken. However, detectable effects on body
condition due to temporary exclusion from areas of a home range are only likely if the places
being disturbed are considered to be core foraging or roosting sites (i.e. prey rich feeding areas or
secure roosting sites). Temporary exclusion from areas of a home range that are used
infrequently or by small numbers of birds are highly unlikely to result in a detectable population
effect. If core areas are disturbed, the level of effect will be determined by the duration and
frequency of disturbance events; long duration and frequent disturbance could result in the
abandonment of home ranges.
8.4.11 Displacement of birds outside of their usual home range is likely to have greater detrimental
effects on body condition, and hence survival rates, as the ability of individuals to utilise new
areas effectively will be reduced and the level of competition is likely to be greater. In addition the
quality of the alternative areas (with regard to foraging resources, availability of secure roost sites
etc.) may be lower than the original home range. The potential effects due to displacement
outside of home ranges will be moderated by the frequency and duration of the disturbance
event. For example, infrequent disturbance events of short duration are unlikely to have an
effect, whereas frequent yet short duration events could result in a detectable increase in energy
expenditure and a reduction in energy intake.
8.4.12 It is apparent from the survey data directly fronting the proposed jetty site (Count Sectors 1 and 2)
that relatively limited use of the intertidal area for feeding or the foreshore for roosting is made by
waterfowl. The only exception to this is the occasional presence in nearshore waters of relatively
large flocks of shelduck during their summer moult.
8.4.13 Overall, it is concluded that while some disturbance to the waterfowl assemblage fronting the jetty
site would occur due to the combined influences of the Hinkley Point C development, there are a
number of factors that indicate that the extent of this disturbance would not be detrimental at the
population level. These factors include:
• the temporary nature of the activities likely to cause the greatest disturbance effects;
• the low numbers of birds likely to be affected within the vicinity of the jetty site;
• the capacity for the majority of species to either avoid or habituate to disturbance; and
• the presence of extensive areas of suitable alternative habitat within their home range should
displacement occur.
8.4.14 It is therefore concluded that the conservation objective related to disturbance (highlighted in bold
in the table above), which is the primary objective to be influenced by the proposed jetty
development in combination with the site preparation works and the Hinkley Point C seawall
construction phase, would not be compromised.
8.4.15 On the basis of the assessment presented, it is concluded that the individual or combined
disturbance effects of construction, operation and dismantling (removal) of the jetty (with the site
preparation works and construction of Hinkley Point C) would not cause a significant adverse
effect to arise with respect to the overall coherence of the ecological structure and function of the

Severn Estuary SPA, which enables it to sustain the populations of species for which the site has
been designated. The same conclusion applies to the Severn Estuary Ramsar site.
8.4.16 However, in view of both the numbers of some birds present in relatively close proximity to the
proposed jetty development site and the potential sensitivity of some of these species (notably
shelduck), a range of measures during construction and operation would be implemented to
reduce the potential for activities to cause disturbance to birds that may be present when the
works take place. These are listed in Section 4.4b.
8.4.17 The following summary statements can be made with regard to the assessment work undertaken
to determine whether an adverse effect on integrity is predicted to arise:
• the combined site preparation works, jetty development and potentially seawall for Hinkley
Point C construction works could cause disturbance to birds utilising the foreshore in the
vicinity of the works;
• available data from surveys indicates that overall usage of the foreshore and adjoining
habitats by SPA / Ramsar site designated bird species that could be influenced by
heightened noise and levels of activity during construction is low and that only small numbers
of birds make regular use of the area. None of the species recorded regularly occur in
numbers that are significant at the SPA / Ramsar site level, either as individual species or as
a total assemblage;
• studies on disturbance effects to birds demonstrate that effects are temporary (i.e. they last
while the activity occurs) and that generally construction activity may lead to disturbance
within 250m of the activity; and
• there are large areas of available habitat adjacent to the site preparation works / jetty
development construction works, seawall and tunnelling works that any birds, if present and
displaced during the works, could relocate to.
8.4.18 It is also important to note that appropriate mitigation measures would be incorporated into the
construction methodology and programme for the site preparation works, jetty development and
the commencement of the seawall for Hinkley Point C in order to either avoid or reduce any
potential disturbance effects. These measures would include:
• construction activities and personnel movements would be confined to demarcated working

areas; and
• erection of fencing along the northern boundary of the site preparation works area to restrict
access by construction workers to the intertidal area to the north.
8.5 Conclusion on adverse effect on integrity
8.5.1 On the basis of the assessment work presented in this HRA it is, therefore, concluded that the
combined disturbance effect that could result from the site preparation works, the jetty
development’s construction works and initial works on the seawall for the Hinkley Point C Project
would not adversely impact upon the overall coherence of the ecological structure and function of
the Severn Estuary SPA, which enables it to sustain the populations of bird species for which the
site has been designated. The same conclusion applies to the Severn Estuary Ramsar site.
8.5.2 Hence, an adverse effect upon the Seven Estuary SPA or Severn Estuary Ramsar site is not
predicted to arise.

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Temporary Jetty Development

Hinkley Point C - Proposed Nuclear Development

Habitats Regulations Assessment Information

Document title Hinkley Point C Preliminary Works:

Drafted by Richard Cottle / Peter Thornton / Peter Brunner

Checked by Richard Cottle

Introduction and Approach

• Severn Estuary SAC;

Hinkley Point C Preliminary Works -i- Habitats Regulations Assessment

• The Mendip Grasslands SAC; and

Likely Significant Effect

Severn Estuary SAC (Estuaries, Reef and Migratory Fish)

Hinkley Point C Preliminary Works - ii - Habitats Regulations Assessment

Hinkley Point C Preliminary Works - iii - Habitats Regulations Assessment

• Disturbance (noise, light and movement) potentially affecting internationally important

Hinkley Point C Preliminary Works - iv - Habitats Regulations Assessment

Exmoor and Quantocks Oakwoods SAC (Barbastelle bats)

• Physical footprint of the land-based works; and

Hinkley Point C Preliminary Works -v- Habitats Regulations Assessment

Hinkley Point C Preliminary Works - vi - Habitats Regulations Assessment

2 THE HABITATS REGULATIONS ASSESSMENT PROCESS 6

4 OVERVIEW OF PREDICTED EFFECTS ON THE NATURAL AND PHYSICAL

5 SCREENING OF RELEVANT ACTIVITIES AND EUROPEAN SITES 25

6 ASSESSMENT OF ‘LIKELY SIGNIFICANT EFFECT’ 47

7 IN COMBINATION EFFECTS 130

Hinkley Point C Preliminary Works - vii - Habitats Regulations Assessment

Hinkley Point C Preliminary Works - viii - Habitats Regulations Assessment

1.1 The Application

1.2 Project Background

a) Site Enabling Works

b) Site Preparation Works

Hinkley Point C Preliminary Works Habitats Regulations Assessment

1.3 Consenting and EIA Requirements

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

1.4 Scope of this Report

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Table 1: Key steps in Appropriate Assessment

Step Description of requirements

1 Defining the need for Appropriate Assessment.

2 Consultation with relevant nature conservation agency(ies).

3 Consultation with other organisations (e.g. Environment Agency etc.).

5 Provision of further information – this information includes information already available,

6 Consideration of the potential effects.

8 Avoiding adverse effects.

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Figure 3: Step-by-step approach to determining whether a significant effect is likely on a

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

3.1 The Application Site

3.2 Description of the Jetty Development

3.2.3 An indicative photomontage of the proposed jetty development is provided in Figure 6.

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Figure 5: Detailed Plan of Jetty Head

Hinkley Point C Preliminary Works Habitats Regulations Assessment

3.3 The Temporary Jetty

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment

Hinkley Point C Preliminary Works Habitats Regulations Assessment