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1 The Planning Inspectorate, 3/18 Eagle Wing, Temple Quay House, 2 The Square, Bristol, BS1 6PN WalneyExtension@infrastructure.gsi.gov.uk PINS Reference: EN Our Reference: Dear Sir/ Madam, 4 th December 2013 WDC comments on Walney Extension Wind Farm Application Summary Given the considerable uncertainties that remain we recommend that if the development proceeds, it is important that at the very least a well-considered robust research monitoring strategy is in place to understand and recognise potential individual and population level impacts on both nationally and internationally important species. We suggest for Walney Extension wind farm that: Monopile, or pin pile, foundations should not be used, Should consent be given to pile, noise levels during construction remains a key concern and, as a very minimum, noise-reduction measures should be a requirement, All noise modelling should be ground-truthed and noise levels should be monitored, An effective impact monitoring strategy is developed for the range of species that can reasonably be impacted; The monitoring strategy is appropriate to consider cumulative impacts of identified developments in the ES; Collected data are made available to government, and all stakeholders, in a timely fashion and, An adaptive approach is applied where development is halted should significant impacts be observed. General comments WDC are endeavouring to assist with the environmentally sustainable development of marine renewable energy in the UK. Whilst welcoming the Governments commitment to renewable energy generation, particularly noting the potential consequences of climate change for cetaceans 1, we have serious concerns about current levels of uncertainty and the possible negative impacts these developments, both individually and cumulatively, may have on cetaceans (whales, dolphins and porpoises) in UK waters. We recognise the timeframes within which the industry is required to build in order to meet targets is tight and we also recognise the existing technological limitations in using alternative sources to pile driving as well as the lack of established mitigation measures, however, the requirement to understand 1 - See Whales in Hot Water available at

2 and mitigate impacts to ensure strict protection of European Protected Species (EPS), including all cetacean species, remains. We recognise that worse case scenarios have been used when assessing the impact on marine mammals and believe this to be appropriate given the considerable unknowns surrounding the development of the wind farm. Survey methodologies We have reviewed the surveys undertaken as described in chapter 12 of the Environmental Statement. We note that although there have been a number of surveys undertaken that in particular the boat-based surveys have not been continuous (4 months in 2011 and 8 months in 2012 with a break of 3 months in between), and therefore cannot give a true representation of marine mammal populations and their use of the area. We note how SCANS II surveys have been used to assist with assessing populations, and potential impacts of Walney Extension on marine mammals. However the SCANS surveys are only one seasonal snapshot in time, with a 10 year gap between the collection of datasets. It is not therefore appropriate to be used for estimates of density and finer-scale information are required where such data are not available (Green et al. 2012). Whilst the data shows that densities of cetaceans in this area are only low, the data cannot be entirely relied upon. The applicant does acknowledge the limitation of the data collected during the marine mammal surveys as it has been only collected over 2 years. However we strongly disagree that the trends can be drawn from this data as it is not 2 years full data (as noted above). Trying to extrapolate trends from patchy data will result in inaccurate results that could result in, potentially dangerous, conclusions being drawn. Potential impacts Pile driving We note monopile foundations are considered as the foundation for Walney Extension. We highlight our strong concerns surrounding the intense noise pollution resulting from pile driving during the construction of the wind farm; pile driving, even with the use of pin piles, has the potential to cause physical harm, as well as displacement. Reactions of harbour porpoises (Phocoena phocoena) to the pile driving process for wind development have been recorded at distances up to 15 km from the piling site (Carstensen et al., 2006). Thomsen et al. (2006) found that the noise generated by the construction of offshore wind farms was loud enough to be audible by harbour porpoises beyond 80 km from the source and could mask communication at km. Bottlenose dolphins could exhibit behavioural responses at distances of up to 40 km from pile driving locations (Bailey et al., 2010). This potential is considered by the applicant where it is considered that temporary displacement of marine mammals may occur but that displacement is unlikely to be biologically significant at the population level. We strongly disagree with the applicant that the impact of pile diving will be short, intermittent and that animals will return in the first year. The limited research conducted so far has shown pile driving to cause behavioural changes in harbour porpoises which leave the area during construction and in some instances did not later return to their usual numbers. Even where areas have been recolonised, it is not clear if these are the same animals returning or new animals moving into the area. The significance of

3 such disturbance is not understood. We note that harbour porpoises and white-beaked dolphins are the only cetaceans that have been considered with regards to the impacts of piling driving noise; we would recommend that Risso s dolphins, bottlenose dolphins and minke whales are also considered. Currently there are no studies to demonstrate the potential impacts of pile driving other cetacean species; however minke whales are very vulnerable to the impacts of intense noise pollution. There was a significant decrease in northern minke whale (Balaenoptera acutorostrata) sightings rates in western Scotland during periods of naval exercises (Parsons et al., 2000). From recordings taken during pile driving in the Moray Firth, Bailey et al. (2010) suggested that northern minke whales, and other mid- and low-frequency hearing cetaceans, may exhibit behavioural disturbance up to 50 km away from the source. The potential ranges noted above are highlighted in appendix 1 2, alongside known critical habitat and areas of interest 3 for species that may be affected by noise generated from pile driving at Walney Extension. The map highlights the potential for important habitats for harbour porpoises, minke whales and bottlenose dolphins to be affected. It shows that the potential range for pile driving noise to be generated by harbour porpoises crosses an area that is critical habitat for that species (Clark et al. 2010). The applicant details that the study area for the assessment of marine mammals was a 4 km buffer area extending from the boundary of the Project site. However due to the potential impacts of pile driving (as noted above and in appendix 1) we feel that this should have been extended to fully assess the impacts on marine mammals. Cumulative impacts It is clear that the cumulative impacts of other offshore wind farm developments in the area have been considered. We feel that activities other than offshore wind farms need to be considered e.g. shipping, oil and gas exploration to give an accurate assessment of the potential cumulative impacts. A robust monitoring programme should be a requirement of consent to ground-truth any conclusions. Corkscrew injuries We note that the applicant has studied the potential for corkscrew injuries on seals; we feel that the potential for corkscrew injuries to harbour porpoise (for example, Deaville et al., 2013) should also be considered. 2 The marked location of Walney Extension does not take into account the whole area of the planned wind farm; therefore the potential range of impacts will be much greater once the actual area of the proposed extension is taken into account. 3 - Clark, J., Dolman, S. J., Hoyt, E Towards Marine Protected Areas for Cetaceans in Scotland, England and Wales. A scientific review identifying critical habitat with key recommendations. Available at

4 Prey availability We note that the applicant states that marine mammals would adapt to any changes in prey availability, not enough is known to make this conclusion. We have considerable concerns about prey impacts resulting from the development, particularly cod and sandeels. A robust monitoring programme should be a requirement of consent to ground-truth these speculations. Operational noise Whilst the applicant anticipates that operational noise levels will be much lower than construction noise, there is no data available on impacts of the species that can be anticipated in the Irish Sea and so a long-term monitoring plan should incorporate operational noise impacts on cetaceans. Decommissioning We note that a decommissioning plan has yet to be drawn up, and that explosives are just one of a variety of methods that may be used to remove foundations. We have concerns that the use of explosives in decommissioning has the potential to cause physical harm or be lethal to cetaceans (Prior and McMath, 2007). Mitigation methods We note that there are plans to use a marine mammal monitoring protocol (MMP) that will try to ensure, and avoid, piling ramp up when a marine mammal is within 500m, if possible. We appreciate the consideration of marine mammal during this procedure; however the measures of a 500 m exclusion zone around any piling, along with a soft start, cannot be relied upon to reduce the impact on cetaceans, to this level as soft starts of pile driving has not been proven as an effective mitigation measure. Shut down of the source should be a requirement should marine mammals enter within a predetermined radius of pile driving activities. Soft starts are only a reduction in sound source at the initiation of a piling event. Consideration of real-time mitigation measures should include acoustic barrier methods and other techniques that are identified and proven in recent studies to reduce noise impacts that may result in injury and/or disturbance (for example, Wilke 2012 and Diederichs et al., 2013). Conclusion/ Summary Given the considerable uncertainties that remain we recommend that if the development proceeds, it is important that at the very least a well-considered robust research monitoring strategy is in place to understand and recognise potential individual and population level impacts on both nationally and internationally important species. We suggest for Walney Extension wind farm that: Monopile, or pin pile, foundations should not be used, Should consent be given to pile, noise levels during construction remains a key concern and, as a very minimum, noise-reduction measures should be a requirement, All noise modelling should be ground-truthed and noise levels should be monitored, An effective impact monitoring strategy is developed for the range of species that can reasonably be impacted;

5 The monitoring strategy is appropriate to consider cumulative impacts of identified developments in the ES; Collected data are made available to government, and all stakeholders, in a timely fashion and, An adaptive approach is applied where development is halted should significant impacts be observed. All in-field monitoring should be undertaken during construction and operation to ensure that the proposed population modelling impacts calculated in theory are accurate. Should any more negative impacts occur then the development should be halted. However we note that it is likely that any long-term negative impacts are unlikely to be documented during the timing of construction itself, unless these impacts are dramatic. Yours sincerely, Vicki James WDC Science Assistant References Bailey, H., Senior, B., Simmons, D., Rusin, J., Picken, G., and Thompson, P. M Assessing underwater noise levels during pile driving at an offshore wind farm and its potential effects on marine mammals. Marine Pollution Bulletin 60, Carstensen, J., Henriksen, O. D., and Teilmann, J Impacts of offshore wind farm construction on harbour porpoises acoustic monitoring of echolocation activity using porpoise detectors (T-PODs). Marine Ecology Progress Series 321, Clark, J., Dolman, S. J., Hoyt, E Towards Marine Protected Areas for Cetaceans in Scotland, England and Wales. A scientific review identifying critical habitat with key recommendations. A WDCS report. Deaville, A. Brownlow, A., Penrose, R., Smith, B., Barnett, J., Perkins, M. and Jepson, P Turning the screw: shipstrike in UK stranded cetaceans. Abstract submitted to and presentation made at the 27th European Cetacean Society Conference, Setubal, Portugal. Diederichs, A., Pehlke, H., Brandt, M., Bellmann, M., Oldeland, J., and Nehls, G Does a big bubble curtain during pile driving minimise negative effects on harbour porpoises? Abstract Book. 27th Conference of The European Cetacean Society Interdisciplinary Approaches In The Study Of Marine Mammals. Page 52 Available at Green, M., Caddell, R., Eisfeld, S., Dolman, S., and Simmonds, M Looking forward to 'strict protection': A critical review of the current legal regime for cetaceans in UK waters. A WDCS Science report.

6 Parsons, E. C. M., Birks, I., Evans, Pg. G. H., Gordon, J. C. D., Shrimpton, J. H., Pooley, S The Possible Impacts of Military Activity on Cetaceans in West Scotland. European Research on Cetaceans 14, Prior, A., McMath, M.J Marine Mammals and Noise from Offshore Renewable Energy Projects UK Developments. In: Evans, P.G.H. (ed.) Proceedings of the ASCOBANS/ECS workshop: offshore wind farms and marine mammals: impacts & methodologies for assessing impacts. San Sebastian, Spain, 21st April ECS special publication series no. 49 Feb Thomsen, F., Betke, K., Schultz-von Glahn, M., Piper, W Noise During Offshore Wind Turbine construction and its effects on Harbour Porpoises (Phocoena phocoena) European Cetacean Society 20th Annual Conference. Wilke, F., Kloske, K., and Bellman., M ESRa Evaluation of Systems for Ramming Noise Mitigation at an Offshore Test Pile.

7 Legend _ ^ Central Location of Walney Extension Potential Range of Pile Driving Noise Audible by Bottlenose Dolphins (Bailey et al. 2010) Potential Harbour Porpoise Disturbance Range (Carstensen et al., 2006) Potential Masking of Harbour Porpoise Communications Range (Thomsen et al. (2006) Potential Range of Pile Driving Noise Audible by Harbour Porpoises (Thomsen et al. 2006) Potential Mike Whale Disturbance Range (Bailey et al. 2010) Bottlenose Dolphin Area of Interest (Clark et al. 2010) Harbour Porpoise Critical Habitat (Clark et al. 2010) Harbour Porpoise Area of Interest (Clark et al. 2010) Minke Whale Area of Interest (Clark et al. 2010) Risso's Dolphin Area of Interest (Clark et al. 2010) Sources: GEBCO, NOAA, National Geographic, DeLorme, and Esri, Copyright: 2011 Esri, DeLorme Appendix 1. Potential Impact of Pile Driving on Whales, Dolphins and Porpoises from Walney Extension