Cirrus Shell Flat Offshore Windfarm
Comments and Formal objection from the North western and North Wales Sea Fisheries Committee
The NWNWSFC objects to the location of the CSFA offshore windfarm on the grounds set out below.
Grounds for objection
The EIS does not contain an accurate assessment of the fisheries that take part within the proposed CSFA area. The Committee can provide more accurate data than is contained in the report on the fisheries which use the area today and have used the area over the past 50 years.
The radar plots in the EIS do not indicate that the area is not of great importance to the local fishing industry. They confirm our own observations that the area is of vital importance to local fishermen who depend upon it for a substantial part of their livelihood.
The suggestions in the EIS report that fishermen will be able to work elsewhere with little inconvenience are disputed by the NWNWSFC. Such suggestions are simply not true and demonstrate the author’s clear lack of competence to comment on fisheries matters.
There is a very strong case that the proposed wind farm would present a serious hazard to small boat navigation in the area.
CSFA Environmental Statement Jan 07.
Comments from NWNWSFC
The information contained in the document on the fisheries in the area is more noticeable for what is excluded than what is included. Great emphasis is placed upon the satellite plots of four over 15 metre vessels working from Fleetwood. Only one of these vessels has any real interest in the CSFA area, UL 160 ‘Colleen’. The plots reflect our own observations that this vessel shoots her trawl as soon as possible, in the area below Shell Warf, tows out along the edge of the bank and after 24 or 36 hours repeats the tow on the return to port. This is standard practice for local Fleetwood fishing vessels. It estimates that 8.1% of her time is spent in the CSFA area which is a significant component of the income of a single boat.
The report does clarify the problems of depending on the statistical rectangle for fishing returns and unlike the non technical summary admits that shellfish are not taken in the CSFA area.
The report has not obtained evidence of fishing patterns from the other local vessels which depend on the CSFA area. It is selective claiming that little information was available on the activities of the predominantly under 10 metre fleet.
While it is quite clear that the producers of the report have done a considerable amount of work radar plotting small fishing vessels working in the area, the surveys have not been representative of fishing effort over a year and do not reflect seasonal variability. The Committee states that this is an important inshore fishing ground of vital interest to local fishermen.
In the physical environment section the report admits that the area has not yet been properly surveyed. Clearly the engineers are not aware of the extremely expensive difficulties experienced in building the adjacent Fylde long sewer outfall, or more recently problems with improperly buried cables becoming exposed on the Fylde foreshore.
In the cultural heritage section there is a list of wrecks, intertidal features and seabed obstructions. The list of seabed obstructions could not be relied upon as they came from Kingfisher charts. The positions of some of the prominent intertidal features listed were not accurate to within a mile.
The Committee has its own sightings and boardings data for the area which have not been reviewed and one of the Committee’s Fishery Officers is an ex Fleetwood fisherman who has very detailed records of his patterns of fishing up to the late 1980s.
Section 2.1. The report states that the area consists of "consolidated soft sediment"; in fact the eastern part of the area is granite boulder clay, so hard that it caused considerable excavation difficulties when a nearby outfall pipe was laid. It may not even be possible to erect turbines in the eastern part of the array a factor that could seriously affect the viability of the project. Has a proper survey of the geological structure of the seabed been carried out?
3.2.2. Scour protection. In the southerly and westerly part of the array scour protection will probably be needed, the area has a strong tidal regime. Guarantees will be needed that any rock dumping that takes place will be fully removed on decommissioning of the site.
3.5.1. Inter turbine and export cables. Full guarantees of cables being properly buried will be required. Previous attempts to bury cables particularly approaching intertidal areas have proved unsatisfactory.
3.9. Decommissioning. Full guarantees will be needed for the total removal of all debris to a considerable depth below the surface of the sea bed. This is an important trawling area and decommissioning must leave it pristine. This task has not been included in the assessment.
5.1.2. Commercial fisheries. This is the major fishing area for inshore trawling. Although comparatively little of the over 15 metre fleet remains the effect upon the inshore fleet would be the loss of their predominant fishery. Compensation for the industry would be required.
5.1.2.1. Restricted or loss of access. This statement is misleading. As the major inshore fishing ground in the Fleetwood areas, it cannot be replaced nor can boats simply work elsewhere. The grounds to the north south and west of the CSFA are different in nature and do not provide the same fishing opportunities. The costs of going further afield to fish would put most vessels, already operating marginally, out of business.
5.1.2.2. Interference with fishing activities. This project has the potential for serious disruption of fisheries the statement made is incorrect.
5.1.2.4 Increased steaming time to the fishing grounds. This statement is false. The CSFA area is the start of the fishing grounds leaving Fleetwood and all small vessels work it. Larger vessels pass through the area and would therefore have to incur additional costs.
5.1.2.6. Safety issues for fishing vessels. Angling only may be possible within the array. There is a very little potential for static gear over a very limited period in the eastern part of the area. The primary fishing method trawling would be extremely hazardous. Fishermen would not attempt to trawl through a wind farm array even if they were permitted to do so.
5.1.3.1. Commercial shipping and vessel routes. Anybody who is familiar with small boat navigation in the area will know that this area is extremely hazardous in a north westerly wind. This proposal has the potential to induce fatal casualties. It is an unacceptable hazard to navigation.
5.1.3.2. Marine radar systems. Our own observations suggest that the array will produce a significant radar blind spot.
5.1.3.3. Visual navigation and collision avoidance. If you have ever tried to find Shell Warf buoy in adverse weather you will know that this statement is false.
5.3.3. Fish and Shellfish. The authors of this report appear to have relied on the previously discredited information used for the Shell Flat application. There are no queen scallops within 10 miles of the area. The primary species landed from the area are plaice, flounder, thornback ray and cod. The inference is that the development will have little interference with the fish species while the Committee reports that it will have a serious detrimental effect on the fishery.