As identified in the EIA Scoping Report, the site lies in close proximity to the Humber Estuary and its internationally important habitats. In addition, the terrestrial habitats in the vicinity of the site, including the site, are known to support significant numbers of some of the Humber Estuary’s internationally important bird populations. As such, as identified in the Scoping Report, it will be necessary for the EIA to consider the potential impacts of the proposal on the Humber Estuary, its internationally important wildlife and the designations which protect them.
– The recognition of the potential for the proposal to impact on the Humber’s internationally important wintering and migratory bird species is welcomed, however, it is unclear why the Scoping Report has only identified the autumn migration period as being of potential importance. As recorded in Appendix B of the Report, RSPB’s view is that it is vital that the assessment also properly considers the potential for impacts on spring migrants. The apparent absence of any focused surveying of the spring passage period is therefore of concern. It is also unclear from the information provided how frequently surveying has been undertaken during the autumn passage period. Weekly surveys during passage periods are preferable, reflecting the high turnover of birds that can occur during these periods.
– As correctly identified in the report, understanding bird usage of the site throughout the tidal cycle is of importance. Again, it is unclear why walkover surveys have been focused on low water periods, with apparently more extensively survey methods undertaken at high water. A more typical approach would be use all three methods at various points throughout the tidal cycle, in particular, the apparent lack of detailed coverage via diurnal walkovers of the site at high tide is of concern. RSPB’s view is that the surveys undertaken to date offer positive progress towards the necessary understanding of the site’s ornithological value but do not fully meet the requirements. Should the issues outlined here be addressed then, it would appear that the survey methods adopted should be appropriate. However, sight of the full dataset and survey details would be needed to confirm the RSPB’s views on the surveying.
– It is noted that the EIA Scoping Report highlights an absence of detailed information on habitat creation and mitigation, due to the outline nature of the application, as a key limitation of the biodiversity assessment. The proposed approach is instead to rely on design principles. Whilst the RSPB recognises that the application is only in outline and that design principles may be sufficient, it will be vital that the assessment provides enough information on the proposed habitat design, management and monitoring to ensure that a full assessment can be made of the ecological functions provided by any mitigation. As we have previously highlighted to the Applicant’s consultants, the RSPB’s view is that providing suitable mitigation for the development of this site and resultant impacts on the Humber’s internationally important bird populations will be highly challenging. The RSPB’s understanding is that the existing site is already of high quality for key bird species, and therefore providing sufficient alternative habitats of the same or better quality in an area of intensive arable farmland, industrial development and residential properties will be far from straightforward.