A Severn Barrage?

ItisregrettablethatthepaucityofdetailavailablefromHPdoesnotallowmoremeaningfulanalysisof theirclaims forthe effectsonthe tidalregimeupstream oftheir barrageproposal.Analysis ofsuchdetail that isavailableshowclearlythattheirclaimsareunrealisticandbaseduponmanyassumptions.

The loss of HW at Avonmouth will remove TBPC’s unique access to deep water and the associated deep-draught trades which use it. Any notion that allowing free-flow through the turbines to replicate the existingtidalregime,letalonepumpingtoimprovethewaterlevelsavailabletoday,simplydoesnotstandup tothemostbasicofscrutiny. March2013 87 SEATopicPaperHydraulicandGeomorphologyAnnex8—Investigationofchangestohydraulicsforshort-listedoptions(water levelsandflows)—Addendum2 cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev143 WrittenevidencesubmittedbyTheRoyalSocietyfortheProtectionofBirds Introduction 1.1TheRSPBwelcomestheEnergyandClimateChangeSelectCommittee’sintentiontoscrutiniseHafren Power’s Severn Barrage proposal. However we are concerned that the ability of the Committee to do so, and our ability to respond to the questions posed by the Committee, are seriously constrained by the absence of anydetailedorpubliclyavailableinformationonthisproposal. 1.2TheRSPBhashadsomeearlydiscussionswithHafrenPowerandtheirsupporters(includingPeterHain, MP). These have provided a welcome opportunity to outline our concerns and to seek to inform the scope of thesubstantialamountofworkthatwouldberequiredbeforethenatureandscaleoftheimpactsoftheHafren Power proposal could be properly assessed. They have also provided an opportunity for the RSPB to make cleartoHafrenPowerourpositionontheirproposal,basedonwhatlittleinformationhasbeensharedtodate: — We attach great value to the Severn Estuary for its international importance for wildlife, as is recognisedthroughitsdesignationasaSiteofSpecialScientificInterest(SSSI),aSpecialProtection Area(SPA),aSpecialAreaofConservation(SAC)andaRamsarsite. — Climate change is the greatest medium to long-term threat to biodiversity. The deployment of renewable energy is essential for decarbonising the UK economy and putting us on the right trajectorytoavoidtheworstoftheclimatechangeimpactsthathavebeenpredicted. — That said, we recognise that, like all forms of development, inappropriately designed and/or sited renewableenergydevelopmentscancauseserious,irreparableandunnecessaryharmtobiodiversity. — Todatewehavenotbeenpresentedwithsufficientdetailonthecurrentproposal,orontheimpactsof thatproposal,toproperlyassesstowhatextenttheimpactswoulddifferfromthoseofthecompletely unacceptablehighheadCardifftoWestonbarrageconsideredbytheSevernTidalPowerFeasibilily Study(STPFS)andrejectedbyGovernmentin2010. — We remain deeply sceptical that a shore-to shore barrage on the scale of that envisaged by Hafren Power can be delivered without unacceptable damage to the Severn Estuary, its wildlife, and its communities. 1.3 At this time it is unclear that a major barrage scheme can be brought forward for the Severn which would be affordable for the consumer, and acceptable in terms of its environmental impact. An alternative wouldbeastepbystepapproach,giventhepotentialforsevereadverseenvironmentalimpactstotheEstuary and our lack of detailed understanding of the nature and scale of actual impacts. This would begin with a smallerprojectorprojectswhichcouldbemonitoredcarefullyandusedastestcasesforevaluatingtheimpacts ofpotentiallargerscaleprojectsfurtherdowntheline(whichmightbelocatedwithintheSevernorelsewhere). Bythis pointthere mayalsobe awiderrange ofwave andtidalstream technologiesavailableto deploy,with lowerenvironmentalimpactsthanthetidalrangetechnologiescurrentlyavailable.

TheRSPB 2.1 The Royal Society for the Protection of Birds (the RSPB) is the charity that takes action for wild birds and the environment. We are the largest wildlife conservation organisation in Europe with a membership of overonemillion.TheRSPBmanages213naturereservesintheUKcoveringanareaof143,780hectares,of which 98,800 hectares are classified as Special Protection Areas (SPAs), 73,995 hectares are designated as SpecialAreasofConservation(SACs)and53,392hectaresaredesignatedasRamsarsites. 2.2TheprincipalobjectiveoftheRSPBistosavenature.TheRSPBthereforeattachesgreatimportanceto all international, EU and national law, policy and guidance that assist in the attainment of this objective, including those aimed at mitigating climate change. The RSPB campaigns throughout the UK and in internationalforaforthedevelopment,strengtheningandenforcementofsuchlawandpolicy.

TheRSPB,ClimateChangeandRenewableEnergyGeneration 3.1 Climate change is the greatest medium to long-term threat to biodiversity. It is already affecting birds and wildlife in the UK and globally, and it threatens to drive future biodiversity loss unless urgent action is taken to reduce emissions and keep the world within “safe” levels of climate change. One study published in Nature indicates that climate change could cause up to 35% of species to be committed to extinction by

TheRSPBandTidalPower 4.1 The RSPB was heavily engaged with the Severn Tidal Power Feasibility Study (STPFS). Whilst we objected to the barrage proposals, which would have had an irreversible and detrimental impact on the geomorphology of the estuary with consequential effects on the unique and internationally important biodiversity in the estuary and on flood risk, we were open to innovative means of sustainably exploiting the energy resource in the Severn. We consistently called for greater resources and effort to be put behind developing these options, and asked that acceptable environmental impact be considered a priority for the feasibility study. Whilst we welcomed the Severn Embryonic Technologies stream of the study, it was under- resourcedandformedonlyasmallpartoftheoverallstudy(£0.5mn).Asaresult,the£20mnSTPFSultimately deliveredrecommendationsthatwereunworkablebecauseoftheirexcessivecosts,dueinparttotheirenormous environmentalimpacts.SoonaftertheGovernment’srejectionofthecaseforsupportfortidalpowergeneration in the Severn estuary in 2010, the Mersey barrage proposal by Peel Holdings followed a similar trajectory to thatoftheSTPFS,withplansshelvedbecauseofcostsandoppositiononthegroundsofenvironmentalimpact. 4.2 The RSPB set out both our response to the findings of the STPFS, and our views on priorities for any future consideration of tidal power proposals in the Severn in our letter to the Department for Energy and ClimateChangeinJanuary2011(attachedatAnnexI). 4.3 Subsequently, the RSPB also set out its view on tidal range in its evidence to the Energy and Climate ChangeSelectCommittee’sInquiryinto“TheFutureofMarineRenewablesintheUK”inNovember2011in whichwestated(atpara3.3)that: “TheUK’s tidalrange resourceis considerablymore difficult[than tidalstream orwave] toexploit withoutcausingmajoralterationstoestuarinegeomorphology,resultinginunacceptabledamageto wildlifeandfloodrisk,andatanacceptablefinancialcost.Webelievethatfuturesupportshouldbe smarter, and targeted at low impact technologies, and consideration should be given to what combination of R&D investment and ROC support is needed to develop and commercialise lower- impact tidal range technologies. This should be coupled with a removal of ROC support for shore- to-shore high head barrage schemes, which would send a clear signal to potential developers that impactsofsuchmagnitudeareunacceptable,andthatrewardswillbereapedbythosewhoinnovate lowerimpactapproaches. This position also applies to the level of support that would be made available to renewable and low carbon sourcesthroughContractsforDifference,assetoutinthedraftEnergyBill. 4.4 The RSPB’s views on tidal range in general, and on tidal power proposals in the Severn Estuary in particular,remainasstatedintheafore-mentionedsubmissionstoDECCandtotheCommittee.

AnswerstoCommitteequestions Q1.WhatcontributioncouldtheCardiff-WestonBarragemaketoUKenergysecurityandclimatechange objectives? 5.1 In terms of UK energy security, there are two main concerns that need to be addressed: meeting UK electricity demand at any given time, particularly at times of peak demand, and the risk of interruption to importedfuelsupplies.Allrenewableenergytechnologieshelptominimisetheriskposedbythelatter,butas manyrenewableenergytechnologiesareintermittentinsupply,theneedforlowcarbonbaseloadgenerationis particularly acute. A low-head barrage would partially fit this requirement as it generates a predictable and consistentsupplyofelectricity.Althoughthisisbeneficialforprovidingabaseloadonthenetwork,theamount of electricity would not be flexible and it would therefore be restricted in its ability to respond to peaks indemand. 5.2 In terms of helping the UK to meet its climate change objectives, we consider sustainable tidal range technologies to offer potentially significant amounts of low carbon electricity. No detailed or published information has been made available about the proposed level of electricity generation from Hafren Power’s low-head tidal barrage, but the estimate for the previous high-head Cardiff-Weston Barrage was 17TWh per year, and we understand from Hafren Power that they believe their proposal could generate a similar amount of electricity. This is 4.56% of predicted electricity generation in 2020 and 3.86% by 203089. This would be 89 http://www.decc.gov.uk/en/content/cms/about/ec_social_res/analytic_projs/en_emis_projs/en_emis_projs.aspx#2012 Annex E— Totalenergygenerationbysource cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev145 asignificantproportionoftotalUKelectricitysupply,andenergydemandmoregenerallyasusessuchashome heating and transport are increasingly converted to electricity. However, the evidence shows that existing commercial technologies are not capable of harnessing this without causing major and unacceptable environmentalimpacts. 5.3ThetotalUKcarbonbudgetfor2023–2027is1950MtCO e,whichisequivalentto390MtCO peryear. 2 2 Itwasestimatedthatthe Cardiff-Westonbarragecouldsaveupto1million tonnesofcarbondioxideperyear which would make a significant contribution to achieving this target. However, for comparison, DECC estimated that in 2011 approximately 6.3 million tonnes of carbon dioxide were avoided in the UK by displacing electricity generated from fossil fuels with onshore wind90. A further 3 million tonnes were saved byoffsettingfossil-fuelswithoffshorewind,andthisfigureissettogrowsignificantlyincomingyears. 5.4 If carbon targets are to be met without causing severe and in some cases, irreparable, damage to biodiversity, it is clear that we need to understand how we can deliver the maximum amount of electricity outputforminimumenvironmentalimpact.Webelieve,therefore,thatGovernmentshoulddirectgreatereffort and support to research, development and demonstration of renewable technologies that could have lower environmentalimpacts. Q2.WhatrisksandopportunitiescoulditposewithregardtofloodingintheSevernestuary,andhowmight anyrisksbemitigated? 5.5 Inthe absence of anydetailed or publicly availableinformation on the HafrenPower proposal, itis not possibletoprovideaproperlyinformedresponsetothisquestion. 5.6 While barrage proposals have often been promoted in part on the basis of assumed flood risk benefits, theconclusionsoftheSTPFSmadeclearthatahigh-headCardiff-Westonbarragewouldinfactincreaseboth flood risk and the costs of maintaining flood defences. For example, to seaward of the barrage, the study identified“far-fieldeffects”includingincreasedhightidelevelsalongthewestcoastofWales,thenorthDevon coastline and the east coast of the Republic of Ireland91. Upstream of the barrage, the study showed that the loss and erosion of intertidal habitats caused by the construction and ongoing presence of a barrage would threatentheintegrityof67—201kmofflooddefences,necessitatingadditionalexpenditureof£672to£2,015 million92.Furthermore,impactsonlanddrainagewerepredictedtoincreasefloodriskoveranareaof370km2, containing45,000residentialproperties,3,400non-residentialpropertiesand28criticalinfrastructureassets93. 5.7 The findings in respect of intertidal erosion and associated flood defence impacts appear broadly consistent with the observed impacts of the construction of a storm surge barrier on the Eastern Scheldt (“Oosterschelde”)intheNetherlands(seeparas5.18to5.20below)whereongoingerosionofintertidalhabitat postconstructionisresultingintheneedforadditionalinvestmentinflooddefences,withextracostsoverthe next50yearsestimatedatbetweenatbest£25—45,andatworst£90—260millioneuros94. 5.8 Until the technical details of Hafren Power’s barrage proposal are defined, and the impacts of the proposal assessed, it is not possible to assess the extent to which flood risk impacts will differ from those identified for a high head Cardiff to Weston barrage by the STPFS. Impacts of a low head barrage could be lowerin termsofthe effectsonland drainage(assumingthat alowerhead shouldresultinlower waterlevels behind the barrage and therefore a lesser impact on gravity outfalls and fluvial flood risk), but in all other respects it is not possible to identify how far-field, downstream and flood defence impacts might differ, especially in the long-term post construction, or to identify what, if any, mitigation measures might be viable andappropriate. Q3.WhatrisksandopportunitiescoulditposetowildlifeandhabitatintheSevernestuary,andhowmight anyrisksbemitigated? 5.9 Inthe absence of anydetailed or publicly availableinformation on the HafrenPower proposal, itis not possibletoprovideaproperlyinformedresponsetothisquestion. 5.10Thefindings oftheSTPFSmadeclearthat ahigh-headCardifftoWestonbarrage wouldhaveentirely unacceptable and unprecedented impacts on wildlife and habitats both within, and far beyond, the boundaries of the estuary itself. For example, it was concluded that it would result in the loss of 39—66% of the entire area of intertidal habitat over a 120 year period. (Experience from the Eastern Scheldt suggests that erosion couldcontinuefarbeyondthemodelled120yearperiod,andcouldintheworstcasescenarioeventuallyresult in the loss of all such habitat95). It should be noted that such losses would be far in excess of those expected asaresultofsealevelrise.Itwasalsoconcludedthatthehigh-headbarragewouldreducebirdpopulationsof up to 30 bird species96, and would severely affect fish populations with local extinctions and population 90 http://www.decc.gov.uk/en/content/cms/meeting_energy/wind/onshore/delivering/why_onshore/why_onshore.aspx 91 HMGovernment,2010.SevernTidalPower:FeasibilityStudyConclusionsandSummaryReport,Pg38 92 HMGovernent,2010.SevernTidalPower:SEATopicpaper—FloodRiskandLandDrainage.Pgxxii 93 HMGovernment,2010.SevernTidalPower:FeasibilityStudyConclusionsandSummaryReport,Pg38 94 http://www.rspb.org.uk/Images/RSPBbriefEasterScheldtreportfinal_tcm9–240984.pdf 95 http://www.rspb.org.uk/Images/RSPBbriefEasterScheldtreportfinal_tcm9–240984.pdf 96 HMGovernment,2010.SevernTidalPower:FeasibilityStudyConclusionsandSummaryReport,Pg5 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev146 EnergyandClimateChangeCommittee:Evidence collapses97.In addition,ancillary developmentsuch asadditional transportlinks wouldput increasedpressure onterrestrialhabitatsandspecies,includingonotherdesignatedsitesincludingtheSomersetandGwentlevels. 5.11 Until the technical details of Hafren Power’s barrage proposal are defined, and the impacts of the proposal assessed, it is not possible to assess the extent to which impacts on wildlife will differ from those identifiedforahighheadCardifftoWestonbarragebytheSTPFS. 5.12 Hafren Power have suggested that their barrage proposal would entail 60% less loss of intertidal than thehigh-headbarrageconsideredbytheSTPFS.Thereisnodetailedinformationavailabletosubstantiatethis claimalthough itis reasonableto assumethat alow headbarrage wouldresult inless habitatloss thana high head barrage at the point of construction, because a lesser area would become permanently inundated behind thebarrage.However,itshouldbenotedthatthiswouldstillconstitutehabitatlossonanunprecedentedscale from a site protected under national and EU legislation, that the STPFS predicted ongoing erosive effects resultinginfurtherintertidalhabitatlosspost-construction,andthatexperienceontheEasternScheldtsuggests that intertidal loss at the point of construction may represent only a small proportion of that which could subsequently occur as a result of changes to the structure and function of the estuary98. Without a detailed technicaldesign,anddetailedmodellingoflong-termeffects(overwhatevertimeperiodsucheffectscontinue tooccur)it isnotpossibletoassessto whatextent,ifany,thelong termimpactsofalow headbarragemight differfromthoseofahigh-headbarrage. 5.13 A number of potential wildlife “benefits” have been claimed by proponents of both the high-head and Hafren Power barrage proposals, based in part on inappropriate reliance on the La Rance tidal barrage (see paras 5.16 to 5.17 below). There are two key points that should be noted in relation to such claims. First, in both nature conservation and legal terms, the value of the Severn lies in its particular geomorphological, hydrological and ecological characteristics. It is therefore essential that the “gross” impacts on the Severn are assessedandaddressedbyanybarrageproponent,asitisinappropriateto“discount”lossesagainstanyfuture non-characteristic habitat or species that might develop as a result of barrage construction. Second, all such claimshave,tothebestofourknowledge,notbeensubstantiated.Itisclaimedthatlow-headturbinesoperating at slowerrotational speeds and onboth the flood andebb tides would be“fish-friendly” by comparisonto the high-head,highervelocityandebb-tideonlyturbinesconsideredbytheSTPFS.Thiscouldbethecase,butto date asfar aswe areaware HafrenPower havenot undertakenwork toaddress gapsin understandingof how fish species use and move through the Severn, and they do not have a confirmed turbine design. Therefore, there has been no testing of these—or any other—low head turbines, or of any potential mitigation measures undertherelevantenvironmentalconditions(includingmultiplepassagesbyindividualfishofawiderangeof speciesbothwithandagainsttheflow). 5.14 Given the severity of the predicted impacts of a high-head barrage, any new design would have to reliably demonstrate a scale of impact on geomorphology, hydrology, habitats, birds, fish and other wildlife some orders of magnitude less than those identified by the STPFS. Impacts should be mitigated and where possibleavoided throughgooddesign, andanyunavoidable residualimpactsmust, asaminimum, bebrought within the realms of the realistically compensatable and therefore potentially acceptable (subject to rigorous application of the tests set out in Article 6(4) of the Habitats Directive (“alternative solutions”, “imperative reasons of overriding public interest” and compensation secured). We remain deeply sceptical that any shore- to-shorebarragecouldachievethis. Q4.WhatlessonscanbelearnedfromthesuccessfuldevelopmentofLaRancetidalbarrageinFranceand othertidalpowerprojects? 5.15 While no two estuaries or barrage developments will be the same, there is a clear value in identifying relevantcomparatorsitestoinformbothtechnicaldesignandimpactassessment. 5.16 The tidalbarrage at La Rance wasconstructed and has beenin operation since the 1960s,and as such maybeofsomerelevanceintermsoftechnicaldesign. 5.17 However, in terms of understanding and assessing potential impacts of a tidal barrage on the Severn Estuary,relianceonLaRanceasacomparatorfortheSeverniswhollyinappropriateforthefollowingreasons: — TheestuaryatLaRanceisarelativelysmallsteep-sidedria(anestuarycreatedbythefloodingofa rocky river valley), with low suspended sediment loads—and therefore has little in common with theSevernwhichisalargemuddycoastalplainestuarywithhighsuspendedsedimentloads.Atthe most basic level, the Severn is therefore a dynamic estuary where sediment is key, and which will fundamentallychange itsshapeandfunction inresponseto changesinerosion andaccretiondriven by alterations to factors such as the tidal prism (the cross section of water that flows in and out on eachtide),andflowratesetc,whiletheshapeofLaRanceislargelyfixedbyhardsubstrate. — The constructionof thebarrage at LaRance was,according toits operator, thefirst timethat coffer damswereusedtofacilitatedevelopmentintheintertidalandsubtidalenvironment.Thismeansthat theestuarywascompletelycutofffromtheseathroughoutthe3yearconstructionperiod99,thereby 97 HMGovernment,2010.SevernTidalPower:FeasibilityStudyConclusionsandSummaryReport,Pg5 98 http://www.rspb.org.uk/Images/RSPBbriefEasterScheldtreportfinal_tcm9–240984.pdf 99 Perscomm.withtheEDFoperatorsoftheLaRancebarrage cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev147 fundamentally changing the nature of the environment upstream of the barrage before the barrage becameoperational. — Therewasno properenvironmentalassessmentpriorto theconstructionofthebarrage, andnopre- construction monitoring or survey was undertaken to provide a baseline against which the impacts of the barrage could be monitored. Furthermore, post-construction monitoring of the barrage which became operational in the 1960s did not commence until the 1980s100. As such, there is no robust evidence to allow any assessment of the impacts of the barrage on the estuarine system or wildlife atLaRance. — Thereareanumberofclaimsmadeabouttheenvironmentalperformanceofthebarrage(forexample inrelationtofishmortality).However,despiterepeatedenquiries,weareunawareofanyrobustdata tosupportsuchassertions. 5.18 Long-ignored during the early stages of the STPFS, research by the RSPB suggested that the construction of a storm surge barrier on the Eastern Scheldt was likely to provide a much more robust comparatorforaSevernbarrage,andwethereforeworkedwiththeDutchgovernmentscientistschargedwith understandingtheimpactsofthatdevelopmenttotranslatekeyaspectsoftheirresearchintoEnglish101,andto providebriefingsbythosescientiststodecision-makersintheUK. 5.19 The construction on the Eastern Scheldt is not a tidal barrage—it is a storm surge barrier, but in the simplesttermsit—likeatidalbarrage—isasolidwallwithholesin,builtfromshoretoshoreacrossanestuary. Instead of turbines (as in the case of a tidal barrage) the holes contain sluice gates, shut only on the highest tides to protect the hinterland from storm surges. We consider the Eastern Scheldt storm surge barrier to be a robustcomparatorforaSevernbarragebecause: — Both the estuaries and the structures concerned are physically similar—construction of large and only partially permeable barriers across dynamic coastal plain estuaries with high suspended sedimentloads — There was extensive monitoring to establish baseline conditions in the Eastern Scheldt prior to construction, and detailed post-construction studies and analysis continue to this day. These studies show that the barrier, constructed in the 1980s, has had, and continues to have, massive negative implicationsforbothwildlifeandfloodriskincluding: — Significant and ongoing erosion following construction: By c2050 the area of intertidal will havehalved-by2100only1500hectaresoftheoriginal11,000hectareswillremain — The losses of intertidal habitat due to the construction of the barrier far exceed losses due to sealevelrise—5100haand1200harespectivelyby2045 — Asintertidalareasinfrontofflooddefences(“dikes”)areloweredorlosttoerosion,floodrisk increases,resultinginaneedforadditionalinvestmenttoprotectlives,landandproperty.Extra costs over the next 50 years on the Eastern Scheldt are estimated to be at best 25–45 million euros,andatworst90–260millioneurosdependingonfactorssuchratesofsealevelrise — Astidalflatsareeroded,theareaanddurationoftheirexposureforfeedingbirdsisreduced— calculationssuggestan80%declineinOystercatchersby2045102. 5.20 The RSPB therefore welcomed the findings of the STPFS103 which noted the short-comings of the La RanceschemeasacomparatorfortheSevern(intermsofboththelackofpre-andpostconstructiondataand the significant differences in the physiography of the two estuaries). Whilst rightly recognising important differences between the Severn and the Eastern Scheldt, the study also concluded that of the three potential comparator sites considered, (La Rance, Annapolis Royale and the Eastern Scheldt), the latter was the only comparatorthatcouldbeassignedahighlevelofconfidence. 5.21Itisessentialthatpotentialcomparatorsites(whichalsoincludeAnnapolisRoyaleinCanadaandcould also include recent developments in South Korea) be assessed to determine their relevance in terms of both similaritiesbetweentheestuariesconcernedandthestructuresinstalled,andtheirvalueintermsoftheavailable pre-and post construction data available to inform and support impact assessment. Appropriate and well- evidenced comparators should be used to identify the key environmental and technical parameters likely to determine the nature and scale of effects, and to inform assessment of the nature and scale of those impacts. Once impacts have been properly assessed and are understood, it may also be possible to use appropriate comparatorstoassessthelikelyefficacyandviabilityofmitigationandcompensationmeasures.Forexample, in the Eastern Scheldt there are ongoing studies looking into the viability of options to mitigate against, and compensatefor,ongoinglossesofintertidalhabitat. 100Perscomm.withtheEDFoperatorsoftheLaRancebarrage 101http://www.rspb.org.uk/Images/RSPBbriefEasterScheldtreportfinal_tcm9–240984.pdf 102http://www.rspb.org.uk/Images/RSPBbriefEasterScheldtreportfinal_tcm9–240984.pdf 103HMGovernment,2010.SevernTidalPower:HydraulicsandGeomorphologyTopicPaper—Appendix2:Analogues,Pg28 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev148 EnergyandClimateChangeCommittee:Evidence Q5.Whatrisksandopportunitiescoulditposetolocalemploymentandcommunity,andhowmightanyrisks bemitigated?Inparticular,whataretheconsequencesforcurrentports,fishingandaggregateextraction industriesintheestuary? 5.22WenotethattheSTPFSstudy104concludedthatthenumberofjobscreatedbyconstructionofaCardiff to Weston barrage could potentially be more than offset by the number of job losses in the region owing to impacts on the Estuary’s ports, aggregate extraction, commercial fisheries, and tourism. The net job impact was estimated to fall between minus 1,600 and plus 5,500 (construction phase). In the medium to long-run (operationalphase),thetotalimpactontheoverallnumberofjobsintheregionwasshowntobetrivial. Q6.WouldtheprojectrequiresupportundertheproposednewContractsforDifferencemechanism?Ifso, approximatelywhatlevelofstrikepricewouldberequiredtomaketheprojecteconomicallyviable? 5.23 The proposed barrage would require support under the proposed Contracts for Difference mechanism. The cost of building the high-head Cardiff-Weston barrage was previously estimated at over £30 billion, the majorityofwhichwasexpectedtocomefrompublicfunding.Duetothescaleoftheriskinvolvedandalack ofconfidenceinthefinancialreturns,theschemedidnotattractprivateinvestors.Theproposalwasdismissed in 2010 because the Government didnot think there was a strategic case for public investment inthat, or any oftheothershort-listedtidalpoweroptionsconsideredbytheSTPFSatthetime. 5.24 Although few details are known about the Hafren Power proposal, including whether the costs are likelytobemoreorlessthaninitiallyestimated,thedevelopershaveclaimedthattheprojectcouldbefunded entirelybyprivateinvestors.However,theseinvestorswillonlycommitprovidingtheGovernment“...stabilizes theelectricitypricefor25–30years”105,ietheGovernmentintroducesContractsforDifferencewithaspecific strikepriceforelectricityfromtidalbarrages. 5.25TheEnergyBill(published29thNovember2012)doesincludeamechanismforContractsforDifference which could involve, initially at least, setting individual strike prices for different technologies. However, the question will be whether the strike price needed to persuade investors that this project represents a sound investmentwillbesignificantlyhigherthanthatneededforotherformsofrenewableorlowcarbontechnology. TheGovernmenthasclearlystatedthat“anyvariationsagreedwillhavetorepresentvalueformoney…”106. 5.26 Based on the 2010 cost estimates for the Cardiff-Weston Barrage (in the absence of any equivalent information from Hafren Power), a barrage development would almost certainly require considerable price support, given that it is a relatively uncompetitive technology compared to other forms of renewable energy generation. Any new proposals would need to be subject to a comprehensive economic assessment. In this context it is important to note that according to the STPFS, the costs per MWh of alternative low-carbon technologiesmaybeaslittleasaquarterofthecostforalargeSevernbarrage107. 5.27TheUK’stidalrangeresourceisverydifficulttoexploitwithoutcausingmajoralterationstoestuarine geomorphology, resulting in unacceptable damage to wildlife and flood risk, and at an unacceptable financial cost. We believe that future support should be smarter, and targeted at low impact technologies, and consideration should be given to what combination of R&D investment and support through Contracts for Differencewouldbeneededtodevelop andcommercialiselower-impacttidalrangetechnologies.Thisshould be coupled with removal of support for shore-to-shore high-head barrage schemes, which would send a clear signaltopotentialdevelopersthatimpactsofsuchmagnitudeareunacceptable,andthatrewardswillbereaped bythosewhoinnovatelowerimpactapproaches. 5.28 The UK’s tidal stream and wave resources offer a significant source of low carbon, renewable energy. Ifdeployedwithcareandsitedcorrectly,webelievethisresourcecanbeexploitedwithoutunacceptableimpact onthemarineenvironment,andthereforestronglysupportpublicinterventiontoresearch,developanddeploy thesetechnologiessustainably. Q7.Howdoesthecompanyplantoengageandconsultthecommunityinthedevelopmentoftheproject? 5.29 The RSPB considers that release in the public domain of the full details of the Hafren Power barrage proposal and assessment of its impacts is an essential prerequisite for an informed debate and effective engagement and consultation. We therefore urge the Energy and Climate Change Select Committee to recommend that this information be made available at the earliest possible opportunity, and that any further consideration ofthe proposalby Governmentbe postponeduntil such timeas thisinformation hasbeen made availableandsubjecttorobustreview. 104HM Government, 2010. Severn Tidal Power: Feasibility Study Conclusions and Summary Report. October 2010. HM Government. 105http://www.guardian.co.uk/environment/2012/aug/20/severn-estuary-tidal-power-project 106http://www.decc.gov.uk/assets/decc/11/meeting-energy-demand/energy-markets/7090-electricity-market-reform-policy- overview-.pdfp.16 107HMGovernment,2010.SevernTidalPower:SevernTidalPower:FeasibilityStudyConclusionsandSummaryReport. cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev149 Q8.AretheproposalsinbreachofEUlegislation,andifsohowwillthisbeaddressed? 5.30 In the absence of any detailed or publicly available information on the Hafren Power proposal, and a detailedassessmentofitsimpacts,itisnotpossibletoprovideaproperlyinformedresponsetothisquestion. 5.31IthasbeensuggestedbysomethattheHabitatsDirectivemaypresentabarriertolarge-scalerenewables deployment, particularly in relation to tidal range technologies. The RSPB strongly rejects this assertion. The EU Birds and Habitats Directives provide a clear and robust legal framework for achieving sustainable development—a conclusion shared by the Sustainable Development Commission (SDC) in their authoritative report,TurningtheTide108.Inthevastmajorityofdevelopmentcases,considerationofenvironmentalimpacts at the earliest stages in marine renewable technology design and site selection should ensure that effects on Natura2000sitescanbeavoidedand/ormitigated.Thisiswiththecaveat,however,thatthefailuretoidentify and deliver a complete Natura 2000 network at sea has made this more difficult for both developers and regulators. Where avoidance and mitigation is not possible, the Habitats Directive does not preclude development. Instead, it requires that this development only be permitted where there are no less-damaging alternative means of delivering the public interest, where there are reasons of imperative overriding public interestwhythedevelopmentshouldproceed,andwhereadequatecompensationhasbeensecured. 5.32 For tidalrange, we acknowledge thateven the least damagingalternative may have adverseeffects on the integrity of one or more Natura 2000 sites. However, we believe that it should be possible to limit any damage,suchthatitcanbeaddressedthroughmitigationand/or(whereappropriate)compensation. 5.33ApplicationoftheHabitatsDirectiveArticle6(3)and6(4)testswillactasalitmustestfortheviability and acceptability of any proposal. These require that the nature and scale of impacts on all Natura 2000 sites affected (SPAs, SACs and (as a matter of UK Government policy) Ramsar sites) be thoroughly assessed. If it is not possible to ascertain that there will be no “adverse effects” on the integrity of the site or sites affected, development may only proceed ifit can be demonstrated that there are noless damaging alternative solutions that could deliver the same public interest, that there are imperative reasons of overriding public interest why a development should proceed in spite of “adverse” effects on the integrity of Natura 2000 site(s), and that sufficient, adequate and effective compensation can be secured to maintain the coherence of the Natura 2000 network. 5.34 In addition, we believe that the EIA Directive will be relevant due to the size of any proposal, its locationandpossibleimpactsitmayhave.CompliancewiththeDirectivewouldrequireinclusionofanoutline of the main alternatives studied by the developer and an indication of the main reasons for its choice, taking into account the environmental effects. As a matter of government policy (and good practice) the nature of certaindevelopmentsandtheirlocationmaymaketheconsiderationofalternativesitesamaterialconsideration. Moregenerally,considerationofalternatives(includingalternativesites,choiceofprocess,andthephasingof construction) is widely regarded as good practice, and resulting in a more robust application for planning permission.Ideally,EIAshouldstartatthestageofsiteandprocessselection,sothattheenvironmentalmerits ofpracticablealternativescanbeproperlyconsidered. 5.35However,beforetheabovecanoccur,theSEADirectiverequirementsshouldbeappliedandallpossible alternatives considered. The purpose of the SEA Directive is plain—it is to ensure that environmental considerations are properly taken into account at all stages in the decision making so as to ensure that the projects which ultimately emerge have taken into account and sought to limit adverse environmental implications.Thisisanaidtoeffectivedecisionmaking—andisnomorethancommonsense—tothinkabout and design out implications in working up options, rather than seeking to mitigate harm once options have beenchosen.Thusitisvitalthatafullconsiderationofalternativesoccurbeforeafinalisedprojectisidentified andproposed. 5.36 The STPFS concluded that a high-head Cardiff-Weston barrage would have an adverse effect on 19 SACs,fiveSPAsandfiveRamsarsites,includingnotonlytheSevernSPA,SACandRamsarsitesbutalsothe riverineSACsupstreamoftheSevernwhichwouldbeaffectedbypopulationcrashesandlocalisedextinction of migratory fish species, and other sites including those designated for the bird populations affected. Furthermore, the STPFS found thatit was not possible to conclude no adverseeffect on another 96 SPAs and 84 Ramsar sites109, and it is possible that these numbers would have been higher (particularly in respect of SPAsandRamsarsitesdesignatedforthemigratorybirdpopulations),hadthestudynotlimitedtheassessment ofeffectstoUKsites.Itwasnotedthatinanyfutureassessment,studiesofeffectsonotherNatura2000sites (SPAsandSACs)shouldbeconsidered.110 5.37Itseemsreasonabletoconcludethatitwouldnotbepossibletoprogressaschemewithimpactsonthe scale of those identified by the STPFS for a high-head barrage in compliance with EU legislation because no such development could pass the tests set out for development under Articles 6(3) and 6(4) of the Habitats Directive. Any new proposal would have to reliably demonstrate a scale of impact on geomorphology, hydrology, habitats, birds, fish and other wildlife some orders of magnitude less than those identified by the 108SustainableDevelopmentCommission,2007.TurningtheTide:TidalPowerintheUK 109HM Government, 2010. Severn Tidal Power: Report to Inform Stage 2 (Appropriate Assessment) Habitats Regulations Assessment,Pgxviii 110HM Government, 2010. Severn Tidal Power: Report to Inform Stage 2 (Appropriate Assessment) Habitats Regulations Assessment,Pg17,2.9.5 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev150 EnergyandClimateChangeCommittee:Evidence STPFS in order to potentially satisfy those tests. On the basis of the little evidence available to date we are scepticalthattheHafrenPowerbarrageproposalcouldachievethis. 5.38 Impacts of any barrage or other tidal power proposal should be mitigated and where possible avoided through good design. In the context of the Severn this will be particularly important in relation to impacts on fish, as we do not consider that population crashes and localised extinction of fish species in the Severn catchment could be compensated for in a way that would secure the coherence of the SAC network for these species as required by the Habitats Directive. Any unavoidable residual impacts (such as loss of intertidal habitat and associated bird populations)must, as a minimum, be brought within therealms of the realistically compensatableona“likeforlike”basisandthereforepotentiallyacceptable(subjecttorigorousapplicationof the tests set out in Article 6(4) of the Habitats Directive (“alternative solutions”, “imperative reasons of overridingpublicinterest”andcompensationsecured). Q9.AreanyotherproposalsfortidalpowerprojectsintheSevernestuarycurrentlyunderconsideration? 5.39 The Severn Embryonics Technology Scheme (SETS) carried out as part of the STPFS considered a range of innovative, and potentially less damaging tidal stream and tidal range technologies, at least one of which (the VerdErg Spectoral Marine Energy Converter) is subject to ongoing development work and testing. In addition, we are aware of a proposal for a land-attached tidal lagoon in Swansea Bay, with a quoted generatingcapacityof250/350MW. 5.40 As described at para 1.3, above, the RSPB considers that at this time it is unclear that any acceptable major barrage scheme can be brought forward for the Severn. Instead we would suggest that an alternative approach wouldbe tofocus onoptions fora smaller project,sited soas tominimise itsenvironmental impact andimpactsonotherestuaryusers,whichcouldnone-the-lessgenerateasignificantamountofelectricity,and couldfacilitateabetterunderstandingoftheimpactsoftidalenergygenerationatmuchlowerrisktoinvestors, theenvironment,andthewiderbusinessandresidentcommunities. 5.41 We note that RegenSW and partners are advocating a similar approach in a useful new discussion document,“BristolChannelEnergy:ABalancedTechnologyApproach”111,whichoutlinesmostoftheknown ideas for marine energy generation from the Bristol Channel/Severn system and proposes adopting a multi technology approach encompassing concepts such as tidal lagoons and tidal fences, deployed in conjunction with tidal stream technology, wave and wind power. The report’s authors highlight that the key advantage of this approach would be to enable the incremental roll-out of a series of large scale energy schemes as technologies are proven and their environmental impacts can be properly managed. Ultimately they suggest thatthislowerriskstrategycouldprovideupto14GWoflowcarbonenergycapacityandwouldenhancethe UK’s position as a hotbed for new technology development. The RSPB welcomed this discussion document andbelievesitspublicationmarksagoodstartingpointforamoreconsciousstrategyforbuildinguprenewable energyoutputsthatbuildinthehighnaturevalueoftheBristolChannelandSevernestuary. 5.42 We also note that SW Parsons Brinkerhoff, and as a logical consequence of their work for DECC, the Welsh Assembly Government and the South West Regional Development Agency as lead contractor for the STPFS, have sought to take the lessons learnt from that study and to develop a “next steps” concept—the 600MW“SteppingStonesTidalLagoon”.Developmentofthisconceptappearstobebroadlyinlinewiththe approachadvocatedintheRegenSWreport. 5.43 Development of any scheme should be conditional upon its compliance with the requirements of the EIA, SEA and HabitatsDirectives, and also in our viewupon its use to monitor, test anddevelop tidal power technologies and their impacts. It may be necessary and appropriate for the state to support such activity in order to maximise benefits to inform future technology design and impact assessment, and thereby support futurerenewablesdeployment. Q10.WhatcouldbethewiderinternationalimplicationsoftheschemeforUKengineeringandUKlow- carbonindustry? 5.44Weconsiderthistobeaquestionforindustry. AnnexI RSPBCommentstoDECContheoutputsoftheSevernTidalPowerFeasibilityStudy SubmittedJanuary2011 TheRSPBwelcomestheopportunitytoshareitsviewsontheoutputsoftheSevernTidalPowerFeasibility Study. We think that there is much to be learnt from the process that should inform future discussions about the deployment of low Carbon infrastructure. Here we include a commentary on the process, the geomorphologicalimpactsandtheinterpretationoftheregulations. 111http://regensw.s3.amazonaws.com/bristol_channel_energy_balanced_technology_approach_20121127_c541010d0b3719f8.pdf cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev151 Scopeofstudy Whileitwasunderstandable,fromapoliticalperspective,whytheUKGovernmentchosetoputaspotlight ontheSevernanddeterminehowbesttoharnessthepoweroftheestuary,thecaseforneedwasnotclearand as a result, the debate became divisive. The process would have been helped by establishing the contribution that tidal power needed to maketo help move towards a low C economy. This would haveprovided the right contextandjustificationforexploringthepotentialcontributionfromtheSevern,comparedtootherestuaries. SEAEnvironmentalReportandtheSevernEmbryonicTechnologiesScheme The RSPB welcomed DECC’s decision to conduct a Strategic Environmental Assessment of options for harnessingtidalpowerintheSevern,andisgratefulfortheopportunitiestoprovideinputthroughparticipation intheSteeringGroup. The SEA process made a thorough analysis of the five options selected, generating a wealth of valuable information to inform any future proposals to harness the Severn’s tidal energy resource. Unfortunately, however, the process for selecting those options was defective in our view, undermining the prospects for finding an acceptable scheme to take forward. The short-listing process over-emphasised technical and economicconsiderations,therebyfavouringestablishedtechnologiessuchaslargebarragestotheexclusionof schemesthatseektominimiseenvironmentalimpactsfromtheoutset. While we wholeheartedly welcomed DECC’s decision to provide some financial support to the Severn Embryonic Technologies Scheme for technical development, we believe that the decision to exclude these schemesfromthefullSEAprocesswasamistakeandthatitunfairlydisadvantagedtheSETSdevelopers. Looking forward, andnotwithstanding current financial constraints, we urgeGovernment to provide further funding for research and developmenton environmentally benign tidal energy technology, and tosend a clear signal to the engineering community that, when the debate about harnessing tidal power from the Severn reopens,itwouldexpectalldesignstotakeenvironmentalconsiderationsintoaccountfromtheoutset. ReportstoinformStage1andStage2HabitatRegulationsAssessments Thesereportsservetoconfirmthescaleofdamagethatalloftheshort-listedoptionswouldentail,witheach havinganadverseeffectontheintegrityofmultiplefeaturesonmultipleNatura2000andRamsarsites. We note that analysis for both the screening and Appropriate Assessment Reports has been limited to the considerationofNatura2000sitesandRamsarsiteswithintheUK,onthebasisthattheHabitatsRegulations, andthe jurisdictionof theUK Governmentand itsagencies applyonly toGreat BritainandNorthern Ireland. However,thesamecannotofcoursebesaidoftheHabitatsDirective,whichappliesacrossEurope.Therefore, any future Habitats Regulations assessment(s) of any option(s) for tidal power generation in the Severn (or elsewhere) must consider effects on all Natura 2000 sites, regardless of their location. This would be in line withtheapproachadoptedbyotherMemberStates(egtheAppropriateAssessmentofoffshorewindproposals intheDutchNorthSeawhichconsideredeffectsonbiogeographicseabirdpopulations,includingUKbreeding colonysites). Hydraulics,Geomorphology,FloodRiskandLandDrainage It is clear that a significant amount of work has been done to investigate the likely impacts of the short- listedoptionsonhydraulics,geomorphology,floodriskandlanddrainage.However,thevalueofthisisclearly compromisedbythehighlevelsofuncertaintyaroundsomepredictionsandlimitationsassociatedwiththeage andpaucityofbaselinedata(anissuewhichwehaveraisedthroughouttheSTPFSprocess). We must also reiterate our comments made in response to both the Phase 1 consultation, and to the SEA 2 H&GTechnicalWorkshop,thattheeffectsofsealevelriseandclimatechangecannotbeusedtodiscountthe effects of a barrage or other tidal power construction, as there is a separate obligation (under Article 6(2) of theHabitatsDirective)toaddressthose.Inaddition,thereisbroadagreementamongstthescientificcommunity that protecting, buffering and extending the best sites for wildlife is essential to buy species time to adapt to climate change. Any attempt to discount damage done now against that which may later occur as a result of climatechangeisthereforelogically—aswellaslegally—flawed. The results of the hydraulics, geomorphology and flood risk analyses confirm that the hydraulic and geomorphological impacts of all of the short-listed options—and of the Cardiff to Weston barrage in particular—are as severe, if not more so, than previously suggested. For example, the results are broadly consistent withthe predictionsmade by Pethick,Morris andEvans (2009)112before the detailedSTFPS work hadbeenundertaken. In particular the results highlight the extent to which technologies often promoted as beneficial to reducing flood risk could in fact exacerbate it, with the Cardiff-Weston barrage predicted to increase flood risk over an area of 372km2 containing 45,436 residential properties, 5,037 non residential properties and 28 critical 112Pethick,J.S.,etal.NatureconservationimplicationsofaSeverntidalbarrage—Apreliminaryassessmentofgeomorphological change.JournalforNatureConservation,(2009),doi:10.1016/j.jnc.2009.04.001 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev152 EnergyandClimateChangeCommittee:Evidence infrastructure assets113. They also highlight the extent to which barrage development could exacerbate the erosion of existing flood defences, with the cost of revetment works to address this for the Cardiff-Weston barrageoptionbeingestimatedatbetween£672millionand£2,015million. Bothpriorto,andduringthelifeoftheSTPFS,theRSPBhascriticisedtheinappropriatefocusonLaRance as a comparator for the Severn, and we note that the results of the STPFS reinforce the value of the Oosterschelde storm surge barrier as an analogue—in particular in relation to flood risk issues. We therefore warmlywelcomeinclusionoftheAnaloguesreportatAppendix2oftheHydraulicsandGeomorphologyTopic Paper and broadly endorse its assessment of levels of confidence in, and the relevance of, the analogues identifiedtotheSeverncase. CompensatoryMeasuresandEqualValue TheRSPBbroadlyagreeswiththemainfindingsoftheassessmentofthenatureandmagnitudeofthemain compensatory measure requirements identified by the strategic level study, and which of those is, or is not, likely to prove possible to supply on a “like for like” basis. In general, the assessment confirms the RSPB’s viewthattheecologicalimpactsoftheshort-listedschemeswouldbesevere.Thisismanifestintheeffortsto considerso-called“equalvalue”compensationduetotheinabilitytoidentifysuitablemeasurestocompensate forkeyimpacts:thisstrainsthelimitsofwhatcouldbeconsidered“sustainable”. The RSPB considers the approach to “equal value” compensation outlined in the SDC paper and the underlying report to be flawed, both legally and from a conservation perspective. It argues for a system of speciesorhabitat“substitution”butfailstojustifythisinlegalorconservationterms.Itessentiallyacceptsthat networkcoherencecannotbeprotectedfortheimpactedspeciesandhabitats,thusunderminingthepurposesof the Habitats Directive. We are disappointed that the SDC report fails to acknowledge legal advice received fromWWFandothers. At the other end of the spectrum, the RSPB would suggest that the approach adopted to the definition of “like for like” compensation is sometimes too narrow and unduly constrained. A key reason for this is that it frequently fails to adopt a functional and purposive approach to the compensatory requirement or understand its relationship with the delivery of favourable conservation status (FCS), especially at site level. As a consequence, optionsthat could supportFCS at siteor networklevel are unnecessarilyruled out, e.g.the role of saltmarsh in supporting waterbird populations as an alternative to intertidal mudflat provision in locations whereroostavailabilityisknowntobealimitingfactoronforaging. In this context, we do not agree with the blanket branding of any managed realignment compensation for birdsatadistancefromtheSevernEstuaryas“nonlike-for-like”compensation.Thesituationismorecomplex and requires more detailed and case-specific consideration. This is recognised in relation to recommendations forfuturework,butthatcomplexityisgenerallydownplayedelsewhereinthereport. WedisagreewithanapproachthatconsidersthereisgreaterflexibilityinthecompensationoptionsforSAC features that are not a “primary reason for selection” compared with those that are a “primary reason for selection”.TheEUHabitatsDirectivedrawsnosuchdistinctionintermsofcompensationprovision. TheRSPBisconcernedthatsocio-economicimpactswereincludedasacriteriaforevaluatingcompensatory measures, although we note that no options were excluded on this basis. While we would accept their listing as a factor to be aware of for future planning purposes, they should not have been included as a weighting factorinconsideringtheviabilityofpossiblecompensatorymeasures. RegionalEconomicsImpacts Much local and regional interest in a Severn tidal energy project has been focussed on the prospect of a Severnsideeconomicwindfall.Thefeasibilitystudyreportsasetofeconomicimpactestimates114. The Cardiff-Weston barrage (by far the largest scheme and associated impacts) with a cost of £20.5 billion andconstructiontakingnineyearsisexpectedtogenerateanetregionalbenefit(asacentralestimate)interms of GVA of £2.4 billion. In terms of employment, the estimate is for 840 net additional jobs per year during construction and 120 during operation, with this latter figure being based on a range from +800 to—2000, in recognition of the fact that potential negative impacts on the ports industry could actually result in a net loss in employment—not much of a legacy from a £20 billion project. These figures include estimates of leakage andalocalmultiplier.Impactsoftheotherbarrageandlagoonoptionsaremuchsmaller. LetterstotheEUEnergyandEnvironmentCommissioners The RSPB welcome the confirmation provided here that environmental legislation was not the reason for theGovernment’srecommendationnottoproceedwithatidalpowerschemeintheSevernatpresent,andthe clear statement of the Government’s support for the Habitats Directives tests. That said, we were somewhat 113ThesefiguresaretakenfromtheFloodRiskandLandDrainageTopicPaper—itisnotedthatthesedonotmatchthosepresented intheSTPFSsummaryreport 114SevernTidalPowerFeasibilityStudyPhase2:RegionalEconomicImpactsStudyProducedbytheWelshAssemblyGovernment onbehalfofSevernTidalPowerFeasibilityStudyRegionalWorkstreamApril2010. cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev153 surprisedto seethe Cardiff-WestonBarragedescribed asoffering“the greatestvalue formoney”of theshort- listed options considered by the STPFS, given that the decision not to proceed was attributed in large part to excessivecostsandrisksfortaxpayersandenergyconsumers. However, the RSPB does not accept the fundamental premise of Ms Spelman and Mr Huhne’s enquiry to the Commissioners—i.e. that large scale renewables projects cannot be delivered without impacts so severe thattheycannotbecompensatedforwithinthecurrentregime. The RSPB has repeatedly criticised the folly of an approach which focuses on economic and technical considerations, without due regard to environmental impacts. It is unsurprising that such an approach has led to the identification of schemes which—when their environmental implications are eventually considered— haveimpactssoseverethattheyareimpossibletocompensateforonalikeforlikebasis,andthusimpossible to deliver without causing serious and irreparable harm to the environment in general, and Natura 2000 in particular.Instead,wewould urgetheGovernmenttoprioritiseactiontowards findinglessdamagingschemes whichbringimpactswithintherealmsofthecompensateable. The RSPB supports the need for large scale renewables deployment, and recognises that this will not be possibleto achievewithout causingsomeenvironmental harm.However, allpossible stepsshouldbe takento avoidandtominimisedamage.Thisisimportantnotjusttoavoidneedlessharmbutalsotohelpsecurepublic acceptabilityfor theseschemes—crucialto thesuccessof themuchneeded lowcarbonenergy revolution.We would argue that a process akin to the STPFS, if focussed on environmental sensitivities and impacts as a matter of primary concern from the outset, should be able to come up with the least damaging alternative meanstoharnesslargescalerenewableenergy—somethingthattheSTPFShasmanifestlyfailedtodo. We acknowledge that even the least damaging alternative may, none-the-less, have significant—and potentially adverse—effects on the integrity of one or more Natura 2000 sites. However, we would argue it shouldbepossibletoachievethiswithintherealmsofthecompensateable—andwouldarguethatanyscheme whichfailstocomplywiththeDirectiveswouldnotbesustainable—apointthatwasveryclearlymadebythe SDC intheir Turning theTide Report in2007, priorto the establishmentof the STPFS(as presented onPage 15oftheSTPFSsummaryreport). December2012 WrittenevidencesubmittedbyHafrenPower Hafren Power is a private limited company, incorporated in the UK and owned and controlled by a group ofBritishentrepreneursandinvestors.ItwaspreviouslynamedCorlanHafren.Ithasbeencreatedtobuildand operateaprivatelyfinanced electricitybarrageacrosstheSevernestuary.Thus far,thecompanyhasremained dormantwhileitsownershavefinancedtheresearchanddevelopmentnecessarytobringtheprojecttoapoint at whichthe next tranche ofprivate investment could beattracted. The company isnow active. Inthe last six monthsateamofspecialistshasbeenfundedtofinetunethebusinesscase,verifythetechnology,addressthe environmentalandcommercialissuesfortheestuary,plantheexecutionoftheprojectanddeterminehowbest tohandlebothdeliveryoftheprojectwithpotentialpartnersanditsfinancing. Aconfidentialbusinesscaseandsupplementarydocumentation,preparedfortheDepartmentofEnergyand Climate Change (DECC), was submitted to government by Corlan Hafren in November 2011 and February

The key benefits provided by the barrage for security of UK electricity supply are diversity and predictability. The barrage will harvest the electricity from the world’s second largest tidal range (14 metres), not only capturing power from a massive latent national asset, but also thereby reducing dependence on non- renewable fossil fuels and introducing a highly desirable diversification into the mix of renewable energy generation.Thebarrage119wouldgenerateonaveragefor15.25hoursoutofthe24hour50minutetidalcycle, generating on both ebb and flood tides to provide annually 16.5 TWh120 of low carbon renewable energy. Relative to the National Grid Gone Green scenario121 of 328 TWh, this represents 5% of UK electricity demand.Thisamountofelectricityisequivalenttothatproducedbythreetofournuclearreactors. 117CommitteeonClimateChange,Costoflowcarbontechnology,2011 118Thelevelisedcostisthecostofgeneration,includingcapitalcosts,averagedoverthelifeofageneratingasset. 119FigurestakenfromHafrenPowerdocument“TheSevernbarrageprojectoverview”,November2012. 1201terawatthour(TWh)=1,000,000megawatthours(MWh).Roughlyspeaking,1MWhofelectricityisenoughtopower1000 homesfor1hour. 121AsperNationalGridUKFutureEnergyScenarios,September2012,“GoneGreen”scenarioandconfirmedbyArupknowledge oftheIndustrialEmissionsDirective(IED)requirements(alimitofindustrialandpowerplantemissions) cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev157

It has recently been announced that much of the coal-fired generation will be replaced by up to 30 new gas-fired turbine plants128. These have the flexibility to complement the barrage power generation profile, fillingthefullypredictableperiodsofnon-generation.However,gasisstillafossilfuel,albeithalfaspollutive ascoal,soitwillnotcontributetomeetingtheUK’srenewableenergytargets.

It is understood that the new power plants will be fired by gas imported primarily from Qatar and Norway129. To an extent which is unclear at this early stage, gas may also be available through fracking. The barragewillgenerateelectricitysecurelythroughthemovementoftidesinBritishwaters.

HafrenPowerisexploringtheopportunitytousethebarrageforpumpedstorage.Whenotherrenewables producesurplusenergy,thebarragecouldpumpandstorewater,ensuringthatexcesselectricityisnotwasted. The scale of the barrage is such that even if pumped storage is only used to a limited extent, it could neverthelessprovideasignificantboosttotheUK’spumpedstoragecapacity. 122Electricitypowerdemandvariesthroughdailyandseasonalcycles,withsomeofthedemandbeinglongertermandotheraspects beingmorepeakyandshorterinduration.The“baseload”representsthelongerduration,constantcomponentofthedemand profile. 123Tidal motion is dependent on gravitational attraction and interactions from various planets, but principally the moon and the sun.Asaresultpowerislunar,beingdependentongravityfromthemoon,andtidalelevations,andhenceenergygenerating potential,canbepredictedhundredsofyearsinadvance. 1241gigawatt(GW)=1,000megawatts(MW) 125DECC,UpdatedEnergy&EmissionsProjections,October2012 126DECC,AnnualEnergyStatement,2012 127As perNational Grid“Gone Green”scenario andconfirmed byArup knowledgeof theIndustrial EmissionsDirective (IED) requirements. 128FinancialTimes,“ChancellorbacksgastofireupBritain”,December32012. 129DECC,DigestofUKEnergyStatistics5.4 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev158 EnergyandClimateChangeCommittee:Evidence Figure1 SEVERNBARRAGEREDUCESELECTRICITYGAPBY30% ContributingtoClimateChangeObjectives

Thebarrage will save7.1m tonnes ofCO per yearcompared to equivalentfossil fuel generation.It will 2 be carbon neutral after the first 2.1 years of operation. This payback period secures a much longer period of zerocarbongenerationofatleast118years—muchlongerthanallotherrenewables.

Thegovernment’senergyandclimatechangegoalsare“reformingtheelectricitymarketforpurposesof encouraging low carbon electricity generation or ensuring security of supply”130. The government intends to use a variety of sources for energy—nuclear, coal, gas, wind (onshore and offshore), biomass, wave and tide. It is also understood that, to fill any gap in production of electricity, the government will import the shortfall in the form of liquefied gas. Not all of these sources support binding commitments towards the 2050 carbon emissionstarget.Thebarragedoes.

TheClimateChangeAct2008setslegallybindingtargetstoreducegreenhousegasemissionsbyatleast 80% below 1990 levels by 2050, with an interim target of 35% by 2020131. The 2009 Renewable Energy DirectivesetsatargetfortheUKtoachieve15%ofitsenergyconsumptionfromrenewablesourcesby2020.

TheDepartmentofEnergyandClimateChange(DECC)estimatesthatthe2020targetof15%renewable energyconvertstoa31%renewableelectricitytarget132.Onthisbasis,ifthetotalenduserelectricitydemand by2020is328TWh133, thiswouldsuggestthat102TWhshouldcome fromrenewablesources.Thebarrage, at 16.5 TWh, therefore represents 16% of this 2020 target renewable power share. Hafren Power is engaging withexpertstoinvestigatethecompressionoftheconstructionperiodtoassesswhetheritispossibletoproduce some initial electricity by 2020. Although the barrage will probably not be generating at full capacity until 2025,theEUwilllookfavourablyonschemesunderconstruction.

The Committee on Climate Change’s objective is to decarbonise the UK power generation sector by 2050(i.e.<50gCO /kWh).In2011,thepowersectormeancarbonintensitywas486gCO /kWh134.Ifthe50g 2 2 targetby2050ismet,thevalueofthebarrage’scarbonoffset,accordingtoDECC’scentralforecastforcarbon prices135, is £2 billion net present value over the life of the barrage. However, if the 2050 target is not met, thenthisoffsetwillbeworthfarmore.

If some degree of pumped storage were to be introduced, as mentioned above, the carbon offsetting value of the barrage would also be significantly increased, as well as its contribution to the financial value of there-saleofpeakdemandelectricity.

Norway produces 98% of its domestic electricity from hydro power. After making substantial initial investmentto buildtheir hydroplants,Norway nowenjoyswholesale electricityprices 65%lowerthan inthe 130TheEnergyBill2012 13135%ratherthan34%forthe3rdBudget(2020).Thesepercentageshavechangedsince2009whenlegislatedandquotedinthe LowCarbonTransitionPlan(DECC(2009)TheUKLowCarbonTransitionPlan)owingtoanupdateintheNationalGreenhouse GasInventorywhichrevisedtotal1990baselineUKGHGemissionsfrom777.4MtCO2eto783.1MtCO2e.Thisnumberis the denominator in this calculation, hence while the budget levels (in MtCO2e) have not changed, the 1990 baseline and percentagereductionshave. 132PublicAccountsCommittee—SeventhReport,Fundingthedevelopmentofrenewableenergytechnologies,November2010 133NationalGrid,FutureUKEnergyScenarios,“GoneGreen”Scenario,September2012 134TheCommitteeonClimateChange2012MeetingtheCarbonBudgets—2012ProgressReporttoParliament 135DECC,Updatedshort-termtradedcarbonvaluesusedforUKpublicpolicyappraisal,October2012 cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev159 UK.136 In the same way, after the 30 year period of price support, the barrage will be the cheapest electricity sourceintheUKforatleastthenext90years,producingelectricityatjust£20/MWh.

As Hurricane Sandy in New York demonstrated in October 2012, storm surges can be devastating. In 2010, a storm surge from the Atlantic, dubbed Xynthia, narrowly missed the Severn estuary. When it made landfall in France, it overwhelmed flood defences and caused €1.3 billion of damage138. Funnel-shaped estuaries,suchastheSevern,exacerbatethethreat.Thenotorious1607GreatFlood,whichinundatedswathes of theSevern and Bridgwater floodplains, resulting in considerableloss of life, isnow believed tohave been astormsurgeandnotatsunami139.Assealevelsriseoverthenextcentury,theincidenceofseverestormand tidalevents(depictedinFigure4)areexpectedtoincrease.AccordingtoDECC,theSevernestuarycanexpect surges of 2m above the normal tide140. The barrage will be designed to ensure that such events could not overwhelm Cardiff, Bristol and Newport and would protect all upstream coast line. In the event of extreme weather, the barrage would simply be closed and act as a sea defence. It is hard to place a clear monetary value on this protection. However, it is undoubtedly substantial, as extreme weather becomes a more regular naturalphenomenonaroundtheworld.

TheDepartmentforEnvironment,FoodandRuralAffairs(Defra),theEnvironmentAgencyandDECC predict that over the next century annual average flood damages in the Severn estuary will increase as sea levels rise. However, their projected costs of flood damage and defence vary substantially, from £2 billion to £15billiononanetpresentvaluebasis141.Itisincontestablethattheconstructionofthebarragewillresultin substantial reductions in flood costs. On the basis of these government numbers, Hafren Power estimates that the barrage will reduce flood costs by at least £2 billion but probably closer to £8.5 billion net present value. Thisisasavingtotaxpayersandtothenation.HafrenPowerhassoughttoverifythegovernmentcostestimates withDefra,buthasbeenunabletoarrangemeetingstodoso.Theestimateswillberefinedanddiscussedwith Defra and the other relevant government departments in the course of preparing the Environmental Impact Assessment.

Hafren Powerisstudying theoptionof buildinga BridgwaterBaybund toprotectthe 160,000hectares ofSomersetLevelsfromseawaterflooding,whichwouldotherwisebeparticularlyvulnerabletosea-levelrise. Thebundcouldcompriseanadditionalsmallbarragewithlocksandturbineelectricalpoweredgeneration.

FurtheranalysisisprovidedinAppendixItem1. 138CourdesComptes,Lessonsfromthe2010floodsontheAtlanticcoast(Xynthia)andintheVar,July2012 139StudycommissionedbyDefraFloodManagement,ThethreatposedbytsunamitotheUK,June2005. 140DECC,SevernTidalPowerFeasibilityStudyConclusionsandSummaryReport,October2010. 141Netpresentvalueisthevalueintoday’smoneyofaseriesoffuturecashflows. cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev161 Figure4 EXAMPLESOFSEVERESTORMANDTIDALEVENTSAFFECTINGTHESEVERNESTUARY142 Q3.WhatrisksandopportunitiescoulditposetowildlifeandhabitatsintheSevernEstuaryandhowmight anyrisksbemitigated? The barrage will affect both birds and fish. Hafren Power will work with all stakeholders to minimise this impact to a level that is as low as reasonably possible. Hafren Power’s turbines will be designed to be fish friendlyandadditionalmudflatscanbecreated.

Thebarragewasdesignedfromtheoutsetwithconcernforitsimpactonbothbirdsandfishuppermost. Hafren Power is already engaging with all stakeholders to minimise this impact to a level that is as low as reasonable possible. Hafren Power’s turbines will be designed to be fish friendly and additional mudflats can becreatedforwadingbirds.

Therewillbeanumberofchangestothetidalregimeupstream(totheeast)ofthebarrage: — Reductionintidalrange:forspringtides,therangewouldreducefromaround14mtoaround10m. — Reductionintidalcurrents:thebedoftheestuarywillbesubjecttolesserosion. — Reductioninsuspendedsedimentlevels:increaseinlightpenetrationthroughthewatercolumn. — Increaseinphotosyntheticactivity:enhancedbiodiversityintheestuary. — Reductioninwaveheightsandturbidity.

Themainrisksofthebarragetowildlifeandhabitatsofthebarragewouldbe: — Intertidal habitat (mudflats and saltmarsh): This is protected under the EU Habitats Directive and the Ramsar Convention. The spring tidal range upstream of the barrage will reduce from 14m to around 10m. This will reduce intertidal habitat by 49km² and affect biodiversity. However, current projectionsfora sealevelriseof0.76mby 2095143willreduceintertidalhabitatanyway byaround 30km2.Sealevelriseof1.43mby2140144willincreasetheloss. — Winteringbirds:TheserelyonintertidalhabitatandareprotectedundertheEUBirdsDirectiveand the Ramsar Convention. Changes in tidal regime and estuary morphology would affect the extent, availability and quality of the intertidal feeding resources and therefore the appeal of the estuary tovulnerableanddependentspeciesintheabsenceofappropriatemitigation. 142SevernEstuaryPartnership|ClimateChangeReportCard3:Sealevel,waves,stormsandsurges(Sept.2010) 143UK Climate Projections 2009, UKCP09: Briefing Report, http://www.ukcip.org.uk/wordpress/wp-content/PDFs/UKCP09 Briefing.pdf 144DefraFCDPAG3EconomicAppraisalSupplementaryNotetoOperatingAuthorities—ClimateChangeimpacts,October2006 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev162 EnergyandClimateChangeCommittee:Evidence — Migratoryfish:ThesemovepastthebarragelineandsixspeciesareprotectedundertheEUHabitats Directive.Forfish,themainrisksarelikelytobedamagepassingthroughturbinesorfrompressure, disorientationleadingtopredationanddelaystomigrationandpredation. — Other risks: These include secondary effects on terrestrial and marine ecology further afield as a result of the proposed development (temporary and permanent works, ancillary and associated development),impactonhabitats downstreamofthebarrageaffectedbyflooding andtheeconomic impactonbusinessesdependentontheestuaryi.e.fishingetc. — The impact on biodiversity will be mitigated through the operation of the barrage and the optimisation of the turbine design. The development of turbines specifically designed to allow safe transit for fish and crustacea (eg shrimp) is key to this proposal, and there has been considerable progress in the past few years by manufacturers worldwide—such as Rolls Royce, Voith, MJ2 Technologies, and Alstom—who recognise the absolute significance of this to the future of tidal energy. Hafren Power will work in collaboration with several manufacturers. Among them, Rolls Royce145 have designed a high efficiency turbine which also has “fish friendly” characteristics including: low risk of physical damage, low turbulence and low pressure changes. Research and product design is on-going in conjunction with turbine manufacturers and with internationally recognised aquatic biologists. The objective is 100% survival of all species of fish transiting the barrage,includingresidentmarinespecies. — Thebi-directionalVLHturbinesrequireamuchlowerheadofwaterthanconventionalbulbturbines and so can operate both across the breadth of the estuary and over a longer part of the day. They generate on flood as well as ebb tides, in contrast to conventional bulb turbines, and will more closely emulate the natural tidal flows. This results in significantly less damage (up to 60% less) to intertidalhabitatthanpreviousproposals. — The tip speed of the turbine blades (around 9m/s) will be significantly lower than for conventional bulbturbines(around25m/s).Turbinesoperatingatbelow12m/sresultinnegligiblefishmortality146. — Turbinedesignwillbeoptimisedtominimisetherunnergap(theareabetweenbladetipsandturbine casing)andotherpotentialsourcesoffishtrappinganddamage. — The turbines will have geometry that can be varied during operation to pass more or less flow and also to control any rates of change of pressure to reduce incidences of fish injury from pressure duringpassagethroughtheturbines. — Theseprovisions areexpected significantlytoreduce therisk ofstrike andpressuredamage aswell asthedisorientatingeffectsoftheturbinesonfishpassageandthusthepropensityforfishpredation aroundthebarragewithoutthem. — Screeningtechnologieswillbeconsideredforreducingorpreventingthepassageoffishthroughthe tidal energy turbines. These are likely to be based on behavioural guidance, which exploits the reactionsofthefish,suchasapreferenceforswimminginspecificpartsofthechannelorinspecific layers of the water column. This would include consideration of fish ladders, which over the past decade have been developed by the US Army Corps of Engineers together with turbine manufacturers,orbyusingbubbletechnologytoguidefishintofishpasses.

Othermitigationmeasuresinclude: — Bridgwater Bay bund: As part of its mitigation strategy, Hafren Power is studying the option of building a bund around the entrance to the Parrett River. This would defend shelduck breeding groundsinBridgwaterBayandStertPoint,aswellasdefendingBridgwaterandtheSomersetlevels fromsea-level-riseinducedflooding. — Marine construction works: These can provide additional or improved intertidal mudflats and saltmarsh habitat for wintering birds upstream of the barrage. For example, topographic raising to increase foraging space for wading birds which, in combination with habitat enhancement, can improvequalityoffeeding,amelioratingthelossofhabitat.Saltmarshcreationisalsobeneficialto supportwildlifeandoffsethabitatloss. — Preventing the recession of salt marshes: A benefit of reducing the tidal range, current speeds and wave heights will be to reduce the current progressive recession of salt marshes and thus bird foraging around the perimeter of the estuary. This was demonstrated in recent geomorphological studiesforWelshWatertobearound1mperyearoverthepast120years. — Proposed compensation for residual loss of intertidal habitat: It will not be possible to retain the entire intertidal habitat that currently exists in the Severn estuary, with or without a barrage. Therefore,following mitigationworks, andinorder tooffsetthis loss,it willbenecessary tocreate compensatoryhabitatfortheresiduallosses(whichincludesimprovementstohabitatselsewhere). 145AtkinsPLCandRollsRoyceLimited2010:ConceptDesignofaVeryLowHeadDualGenerationTidalSchemefortheSevern Estuary.Volume1:SummaryReport 146USDepartmentofEnergy(IdahoOperationsOffice),ASummaryofEnvironmentallyFriendlyTurbineDesignConcepts,1999 cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev163

Thebarragewillcreateanumberofopportunities: — Changed sediment characteristics, resulting from decreased turbidity upstream of the barrage, decreasederosionandincreaseddepositionoffinesediment. — Reduced turbidity will increase light penetration and photosynthesis and result in an increase in biologicalproductivity. — Higher invertebrate densities, greater fish populations and better opportunities for birds to feed as a resultofprobableincreasesinwatertemperatures. — Improved habitats such as salt marshes, although changes in the tidal range may affect the balance ofthebirdspeciesintheestuary. — Anincreaseoflifeintheestuaryfacilitatedbytheconsequentialincreaseindissolvedoxygenlevels — Support for as many, or even more, wading birds and wildfowl147 than at present, based on comparisonwithotherUKestuaries,eventhoughthespeciescompositionmightchange.

ThebarrageprovidestheUKwithoneofthegreatconservationopportunities.HafrenPowerhasbegun speaking to NGOs and to Swansea University about the potential to create the equivalent of several Newport Wetlands,SlimbridgesorWallaseaIslands. Q4.WhatlessonscanbelearnedfromthesuccessfuldevelopmentofLaRancetidalbarrageinFranceand othertidalpowerprojects? TheLaRancebarragehasprovedtheconceptoftidalpower.ItnowgeneratesthecheapestelectricityinFrance at €20 per MWh. Wildlife and fish proliferate around the La Rance barrage and its construction has provided the region with an economic stimulus that is still ongoing after nearly 50 years. Hafren Power will engage withtheoperatoratLaRancetogainfullknowledgeofthelessonslearnedandbestpractice.

The Severn barrage has the potential to generate much more electricity than the La Rance barrage. However, La Rance embraces the same fundamental principles as proposed by Hafren Power. La Rance has for 46 years produced cheap, predictable, consistent power (240 MW). It provides the cheapest electricity generatedanywhereinFrance,currentlyataround€20/MWh.Noturbineshaveneededreplacement.Basedon the proven experience of La Rance, the Severn barrage should produce very cheap electricity for the nation overmanyyearswithoutsignificantmechanicalproblemsandwithoutaneedtoreplaceturbinesregularly.The prime difference between the Severn project and La Rance is the scale of the Severn and the much greater contributionitcanmaketotheUK’snationalenergyneeds.

La Rance was constructed using a cofferdam, which involved draining all the water from the basin. Consequently,therewassignificantimpactonwildlifeduringthethree-yearbuild.However,lessthanadecade later,theestuarywasrichlydiversified,withover70fishspecies,110wormspecies,47crustaceanspeciesand 120 bird species148. There is even a seal that lives in the basin. As construction took place in the 1960s, it is unclear whether a survey of wildlife was conducted prior to construction. It is therefore difficult to draw definitiveratherthananecdotalconclusions.

La Rance barrage has become a tourist attraction, with around 50,000 visitors per annum. It has regenerated the surrounding area by providing a steady stimulus, creating new jobs and economic activity in the form of oyster and scallop farming. A new road over the barrage is also a benefit to the local region and inconnectingcommunities.

InthecaseoftheSevern,thepotentialstimulusisverymuchgreaterthanthis.TheHafrenPowerproject will regenerate the whole region of South Wales and South West England. It is likely to attract many more touriststhanLaRance,asitwouldbeonthescaleoftheØresundBridgeorMillauViaduct.Upstream,calmer and clearer waters will provide the right conditions for the development of a marina-driven tourist industry, previously impossible in the Severn’s fierce tides and currents. The construction of the barrage and its supply chain will provide a major increase in regional and national employment. The creation of two large turbine manufacturing plants for the manufacture, assembly and maintenance of the installed equipment, one in Port Talbotand onein theBristolarea, willlay thefoundation foranew export-ledindustry. Ashasbeen thecase atLaRance,thestimuluswillthereforecarryonbeyondtheconstructionofthebarrageitself.

Thereareotherexamplesoftidalbarrageprojectsaroundtheworld.TheCardiffBaybarrage,completed in 1999, provides further solid evidence of the positive regenerative outcome which could be expected. The Sidney A. Murray Jr barrage at Vidalia on the Mississippi, built in 1989, has produced similar results to La Rance. The recently constructed Sihwa Tidal barrage Scheme in South Korea has addressed similar issues to theSevernbarrage.HafrenPowerislearningasmuchasitcanfromthesebarrageprojects,hasconsultedwith all the leading turbine manufacturers and scheme designers, and will seek to incorporate their best practices intoitsdesign. 147Thisincludesswansandgeesewhicharealsopartoftheestuarydesignations. 148EDF,LaRanceTidalPowerPlant—40yearoperationfeedbackandlessonslearnt,2009 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev164 EnergyandClimateChangeCommittee:Evidence Q5.Whatrisksandopportunitiescoulditposetolocalemploymentandcommunity,andhowmightanyrisks bemitigated?Inparticularwhataretheconsequencesforcurrentports,fishingandaggregateextraction industriesintheestuary? The constructionof the barragewill provide amajor opportunityto increase employmentin the regionand to create a new UK based renewable technology. Some local communities will be affected during construction, but Hafren Power will consult with all stakeholders to keep disruption to a minimum. During construction of thebarrage,allsignificantportsintheregionwillbekeptverybusy.Allportsupstreamwillbeabletocontinue theirbusinesses,astoday,bothduringandafterconstructionofthebarrage.

HafrenPowerestimatesthat20,700149directjobswillbecreatedinSouthWalesandSouthWestEngland over the ten years of its construction. These will be supplemented by a further 30,000 indirect and induced jobs150.Theinfluxofmaterialintheshapeofhardrock,cement,sandandotherconstructionmaterialislikely to create much increased activity in all the ports in the region, especially in Bristol, Cardiff and Port Talbot. The ports will also have a major role in supporting the extensive maritime fleet that will be utilised during construction and, afterwards, in servicing and maintenance. The increased activity that will result is likely to provide a substantial new impetus not only in each of these cities but also to the economy of the region. According to a study commissioned by the UK Contractors Group151, every £1 spent on construction output generatesatotalof£2.84economicactivity,i.e.GDPincrease.Oncethebarrageiscompleted,therewillbea permanent staff of around 1,000 working on the barrage alone—24 hours a day, 365 days a year. It is highly likely that, as with La Rance, the general stimulus in the region over 10 years, combined with the tourist opportunities and enhanced local infrastructure, will result in a permanent upswing in economic activity there.HafrenPowerwillofferopportunitiesformanylocalcompaniesandsmallandmedium-sizedenterprises toworkinthesupplychain.

The barragewill consistof an18km lineof largecaissons (approx.75m x50mx 30m).These caissons will be constructed in specialised casting basins, most likely in Port Talbot. It is intended to create two manufacturingplants,oneinWalesandtheotherintheBristolareafortheassemblyandmaintenanceof1,026 turbines. Additionally there will be many further job opportunities in areas such as concrete/cement manufacture, mechanical, civil and electrical engineering, turbine manufacture and maintenance, environment management,projectmanagement/supervisory,managerialandadministration.

It is Hafren Power’s intention to work with local partners in the South West and South Wales to offer civilandmechanicalengineeringtrainingandapprenticeshipschemesand,ifnecessary,toopenitsowntraining centre. The barrage team intends to work closely with local employment and skills schemes and colleges, not only for the supply of trained staff for the project, but also to make the technology exportable thereafter, potentiallycreatingnewlonger-termjobopportunitiesforthosewithspecialistskills.

More generally, the barrage will make the estuary a safer and more attractive place to live by calming conditions upstream.The creation ofa new maritimerecreational activity—in anarea at hightide of 500km2, equivalentto1.5timesthesizeofLakeGarda—willclearlycreatejobsintourism.TheprecedentoftheCardiff Baybarrageisagoodindicatoroftheregenerationanddevelopmentpotentialandtheassociatedemployment andcommunitybenefitsthatcomewithit.Thechallengewouldbetorealisethisopportunity.

There will be locks in the barrage to allow all current shipping movements. There should be minimum delay to shipping, which anyway already has to wait to move upstream for an appropriate tide. The estuary will be dredged to ensure shipping lanes are kept open with minimal inconvenience to navigation. Hafren Powerintendstominimiseanyimpactoncurrentbusinessatportsupstream.

The barrage may help regenerate fishing in the area as has happened in La Rance. The increased photosynthesis and nutrients in the waters upstream of the barrage could stimulate to the creation of new molluscandfishfarmingindustries.

Hafren Power is in discussionwith The Crown Estate over long-term lease of the sea bedand the need for aggregate and sand. The Crown Estate has the remit to maintain and increase the value of its assets including the UK coastal areas. The barrage has the opportunity to support these objectives, as it will need theiraggregatefromtheestuarytoconstructthebarrageandcreatenewwetlandareas.

By eliminating the upstream risk of coastal, storm and tidal flooding and the impact of sea level rise, the barrage would increase land and property values in the upstream region, and facilitate inward investment forcommercialandindustrialdevelopment. 149Fulltimeequivalentjobs. 150Direct employment is directly related to construction. As a result of this direct employment, employment is also generated indirectlyinbusinessesthatsupplygoodsandservices.Finally,whenthesedirectlyandindirectlygeneratedincomesarespent andrespentonavarietyofitemsinthebroadereconomy(e.g.,food,clothing,entertainment),itgivesrisetoinducedemployment effects.(Adaptedfromwww.ccfm.org) 151SourceONS(2002);LEKanalysisforConstructionintheUKEconomy—AStudycommissionedbytheUKContractorsGroup. ThisincreaseinGDPmaybebrokendowninto£1directimpact(wageincomeandcorporateprofitgeneratedintheconstruction sector),£1.09forindirectimpact(supplychainimpactsofconstructionandtheirknock-oneffects)and£0.75forinducedimpact (increase in household income as a result of increased employment where income in construction and other sectors leads to increaseinspendinganddemand/outputintheoveralleconomy). cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev165

Itisclearthattheconstructionofabarrageofthisnaturecouldfacilitatethecreationofpermanentroad and rail links. Hafren Power plans to build the barrage as a power station and that is the full extent of the proposal.However,ifitisfeltdesirable,HafrenPowerisopentodiscussionwithgovernmentandotherparties over the possibility of road and rail links. It should be noted, however, that a decision on this question would be needed at an early stage since the design of a barrage to carry road and/or rail would differ significantly fromabarrageforthegenerationofelectricityonly. Q6.WouldtheprojectrequiresupportundertheproposednewContractsforDifferencemechanism?Ifso, approximatelywhatlevelofstrikepricewouldberequiredtomaketheprojecteconomicallyviable? In common with all other renewables, the project will require support from the Feed-in Tariffs with Contract for Difference (FiT CfD) or Renewables Obligation Certificate (ROC) mechanisms. Importantly, however, it willonlyrequiresupportduringthefirst30yearsofitsminimum120yearlife.Foratleast90yearsthereafter the barrage will generate the cheapest electricity in the UK. Furthermore, the barrage brings the unique opportunity to reduce or eliminate current and anticipated costs of flood defence and damage and related benefits to the nation. As a result, much of the support the barrage receives will be fully mitigated in savings to the nation and the net strike price or net ROC for this project will be significantly reduced. This will dramaticallycutthenetcosttothenationofsupportforaSevernbarrage.

The Severn barrage project requires the passage of a hybrid bill along with an Environmental Impact Assessment(EIA)andsupportingdocumentation.ThiswillrequirethesupportofallmainpartiesinParliament andthoroughconsultationwithallstakeholders.

In addition to the hybrid bill, and to provide the necessary confidence for investors, Hafren Power also requires a CfD or ROC mechanism. Hafren Power’s strike price is commercially sensitive and is a matter for negotiationwiththegovernment.However,HafrenPowerunderstandsthegovernment’sobjectiveistoachieve anetstrikepriceforallrenewablesof£100/MWhandisworkingwiththisfigureinmind.

HafrenPowerbelievesthebarrage’snetstrikepricewillbeconsiderablylessthanthenetstrikepriceof wind andnuclear power, particularlywhen proper accountis taken ofthe associated floodprotection that will beabenefitofthebarrage.AsmentionedinresponsetoQuestion2,thenetpresentvalueofprojectedsavings arebetween£2billionand£15billion.

AsmentionedinQuestion1,iftheCommitteeonClimateChange’s2050targetof50gCO /kWhismet, 2 accordingtoDECC’scentralforecastforcarbonprices152thevalueofthebarrage’scarbonoffsetis£2billion netpresentvalueoveritslife.However,ifthetargetisnotmet,thenthisoffsetwillbeworthfarmore.

Ithasbecomenormalforgovernmenttoassessthecosttothenationofrenewableenergyovera30year period. This is appropriate for comparing renewables for which 30 years is at, or close to, the life of the generatingassets.However,itisinappropriateforthebarrage,forwhichoneofitsmanyvirtuesisitlongevity. Aftertheinitialperiodofsupport,thebarragewillgenerateverycheapelectricity—thecheapestinthelandby far—foraperiodofatleast90years.Thisimportantfactorshouldbetakenintoaccountwheneverthequestion ofthecost ofsupportforthebarrageis underconsiderationorcomparisonsaremade betweensupportforthe barragesandsupportforotherformsofgeneration.Netstrikepricealonedoesnottakeaccountofthelongevity ofgenerating assets.Considerationshouldbe giventotheadoption oflevelisedcost(see Figure2)asa better measureoftherelativecosttothenationofsupportfordifferentformsofgenerationor,atleast,levelisedcost shouldbetakenintoaccountatthesametimeasnetstrikeprice. Q7.Howdoesthecompanyplantoengageandconsultthecommunityinthedevelopmentoftheproject? Hafren Power and its delivery team has wide experience of the consultation process required for major infrastructureprojectsofthiskind.

HafrenPowerisalreadyconsultinginterestedstakeholdersandiscommittedtocontinuingtodoso.This projectcanonlysucceedwithfullconsultationofallinterestedparties.HafrenPowerwillcontinuetoworkwith governments,politicians,localauthorities,unions,non-governmentalorganisations,charitiesandenvironmental groupsasitseekstogetafullpictureoftheviewsofallstakeholders.

Hafren Power has already set up both a Regional Committee and an Expert Panel with distinguished members to ensure that it is always available for consultation. The members of both, as well as the board of directors,areappendedtothissubmission(Appendixitems3,4and5).

Inaddition,HafrenPowerhasappointedtheindependentengineeringfirmArupastheleadengineering andtechnical consultant.Arup hasconsiderableexperience ofcommunity engagementand consultationsfrom other major UK infrastructure projects, fully recognising the need to properly set out and explain the project scope, inherent benefits, possible disbenefits and the opportunities to mitigate these, in order to enable a balanced informed debate that can seek to achieve “win:win” outcomes. It is recognised that this needs to properly distinguish between the three stages of (a) planning uncertainty and planning “blight” prior to the consenting of majorinfrastructure, (b) consequences ofconstruction activities during theproject delivery, and (c)thelongtermaspectsassociatedwiththecompletedandoperationalbarrage. 152DECC,Updatedshort-termtradedcarbonvaluesusedforUKpublicpolicyappraisal,October2012 cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev166 EnergyandClimateChangeCommittee:Evidence

Arup is able to bring experience in these processes from other major infrastructure projects and their associated regeneration opportunities, including the Channel Tunnel Rail Link (now known as HS1) and St Pancras station London, London 2012 Olympics and Stratford City, New Forth Crossing, Thames Tunnel TidewayLondon,HinkleyPointCnewnuclear,NuGenCumbrianewnuclearandHS2railway. Q8.AretheproposalsinbreachofEUlegislation,andifsohowwillthisbeaddressed? Hafren Power has already opened discussions with a range of NGOs and intends to meet all appropriate EU legislationinagreementwiththerelevantUKgovernmentdepartments.

TheSevernbarragewillneedtocomplywiththefollowingEUlegislation: — WaterFrameworkDirective(2000/60/EC). — TheFloodsDirective(2007/60/EC). — TheHabitatsDirective(92/43/EEC). — TheBirdsDirective(2009/147/EC). — The Environmental Impact Assessment (EIA) Directive (85/337/EEC as amended by 97/11/EC and 2003/35/EC).

ThemostchallengingdirectivesaretheHabitatsandBirdsDirectives,sincetheprojectislikelytohave an impact on a number of European Sites and habitats/species included in Annex I and II of the Habitats DirectiveandonspeciesofbirdsincludedinAnnexIofBirdsDirective.

InordertobefullycompliantwiththeHabitatsDirective,theproposalmustdemonstratethat: — Therearenofeasiblealternativesolutionstotheprojectwhicharelessdamagingand — ItcanbecarriedoutforImperativeReasonsofOverridingPublicInterest(“IROPI”),includingthose of a social or economic nature (this may, in circumstances where priority habitat and species are affected, include reasons relating to human health, public safety or beneficial consequences of primary importance to the environment—Regulation 62(2)(a) of the Habitat Regulations 2010, as amended)and — TheMemberStatecantakeallcompensatorymeasuresnecessarytoensurethattheoverallcoherence of Natura 2000153 is protected. The Member State may need to seek the opinion of the European Commission concerning the project and then shall inform the European Commission of the compensatorymeasuresadopted.

Notwithstanding these conditions, Hafren Power has already opened a regular dialogue with a range of environmentalNGOswhoseinterestsarepotentiallyaffected,inordertolistentotheirconcernsandjointlyto reachsolutions.

Hafren Power intends to conform with all appropriate EU legislation in agreement with the relevant UK government departments. Discussion will be needed to reach agreement on the basis for assessment and demonstration that impacts on intertidal habitat, wintering birds and migratory fish can be fully mitigated, or alternativelythatacceptablecompensatorymeasures(eitheron-siteoroff-site)canbeimplemented.

Through the EIA process and in agreement with government departments, Hafren Power will ensure compliance with EU legislation. There are precedents of EU developments where similar large scale projects reconcilethethreeconditionsoftheHabitatsDirective(paragraph53).SeeAppendixitem2foraCaseStudy ofthenewportinGranadilla,Tenerifeillustratingtheapproachtocomplianceadoptedinoneinstance.

Under the EU Habitats Directives and application of IROPI, the question has to be asked: “Are there otherbetterormoreviablemarineenergytechnologieswhichwouldbepreferabletotheHafrenPowerbarrage and which would provide the same energy at less environmental cost?” The following issues and options are thereforeconsidered: — Barrage: It would, at an output of 16.5 TWh per year, provide, by a very large margin, the most efficientandcosteffectivemeansofexploitingtheextraordinarypowerandtidalrangeoftheSevern estuary.ItwouldformacoreenergycapturesystemfortheSevernyieldingfarandawaythehighest output for that location. It could and should be integrated with follow-on systems which are in the course of development, including large scale low velocity tidal stream and off-shore wave, as well as off-shore wind, all in the outer approaches of the Bristol Channel and around its headlands, asappropriate. 153Natura2000isthecollectivetermforallEuropeanSites—andhighlightstheirinterdependency. cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev167 — Lagoons: All options and combinations would cost proportionately more to build and yield less energy.ThehighestoutputwithintheareaenclosedbytheCardiff-Westonalignmentwouldbefrom 3 Russell lagoons yielding only 6.45 TWh/y154. They would provide only very limited protection against sea level rise and cause significant habitat and tidal current impacts. Because there are no operationallagoons, itisuncertainhow muchelectricitythey wouldactuallyproduce. Forthesame reason, it is also difficult to estimate how much they would cost to construct. The only lagoon options considered viable would bea Bridgwater Bay impoundment as an adjunct tothe barrage. It is estimated that this would yield a further approx. Five TWh/y and as mentioned in Question 2, it wouldprotectthevulnerableSomersetcoastline. — TidalReef:Thisisalowlevelbarragewithoutthelockenclosure.Asaresultitwouldnotremotely exploit the tidal range effectively, nor approach a similar energy output, nor could it provide protection against sea level rises and storm surges in the estuary which would be provided by theBarrage. — Tidal Fence: Current analysis155 shows that for a tidal fence in the absence of a shipping lock, a “tidalhead”wouldnotbeachievable.Theveryconsiderableleakageofthetidethroughtheshipping gap would entirely waste the tidal range resource of the Severn. The Sustainable Development Commission in 2007 estimated only 0.88 TWh/y output would be achievable (approximately one twentieththeoutputofthebarrage),andthiswasconfirmedintheGilesetalstudy(2010).Itwould alsofailtoprovideprotectionagainstsea-levelrise,stormsurgesandfloodingupstream,becauseno shippinglockisincluded,andcouldleadtoacceleratedcurrentsthroughthelockopening. Q9.AreanyotherproposalsfortidalpowerprojectsintheSevernestuarycurrentlyunderconsideration? ToHafrenPower’sknowledge,therearenoviablealternativesofasimilarscaletothebarrageproposal.There isaplacefordifferentmarinetechnologiestoharnesstidal,windandwavepowerbutnothingwhichremotely harnessesthepotentialenergyoftheSevern’stidalrangelikeHafrenPower’sproposal.HafrenPower’sbarrage andtheseotherschemesarenotmutuallyexclusive.

Two additional proposals for tidal power generation in the Severn estuary have been put forward since theDECCfeasibilitystudies.Theseinclude: SteppingStonesTidalLagoons(ParsonsBrinckerhoffandBlack&Veatch)

The Stepping Stones tidal lagoon has been designed as the first step in an incremental approach to a large-scaletidalpowergenerationprojectintheSevernestuary.Itisaproposalforasmallscaledemonstration project between Barry and Aberthaw which aims to demonstrate that tidal power can be harnessed with acceptablecostsandenvironmentalimpacts.Thelocationofthelagoonhasbeenchosentoensurethatitdoes notcompromisethefuturedevelopmentoflarge-scaletidalpowerintheSevernestuary.

The tidal lagoon proposal is significantly smaller, producing 600 MW and 1.2 TWh of electricity per annumatanetstrikepriceof£194/MWh156.Incomparison,HafrenPower’sproposalistoproduce6,464MW and16.5TWhofelectricityperannum. TidalLagoonSwanseaBay(TidalLagoonSwanseaBayLtd)

The Swansea Bay Tidal Lagoon is the proposal for a 250–350 MW tidal lagoon, capable of generating 0.4 TWh/year. The lagoon is located around the Swansea Bay Port where there are shallower water depths betweenthenavigationchannelsfortheSwanseaandNeathPortsandawayfromtheSwanseaBaydesignated bathingbeaches.

Tidal Lagoon Swansea Bay Ltd has recently submitted a scoping report to the Planning Inspectorate. Thecostoftheschemeiscurrentlyunknown.

The lagoon and barrage proposals are not mutually exclusive. Looked at pragmatically, the UK may need many technologies, strategically placed in their most viable and appropriate locations, if it is effectively toutilisethemarineenergyresourceswithwhichthisislandisblessed.Thereisaplaceforeachtechnology— off-shore wave farms, major tidal stream arrays, strategic coastally attached and off-shore lagoons, and tidal rangebarrages,suchastheoneHafrenPowerisproposing. Q10.WhatcouldbethewiderinternationalimplicationsoftheschemeforUKengineeringandUKlow- carbonindustry? HafrenPower’sbarrage wouldbeanexemplar projectandwouldfirmly placetheUKat theforefrontoftidal range technology that can be applied globally, there being locations around the world (as well as in the UK) whichcouldreplicateHafrenPower’splans. 154SustainableDevelopmentCommission,TurningtheTide,TidalPowerintheUK,October2007 155Giles,J,etal2010AninnovativetidalfencedevelopmentfortheSevernEstuary,UK3rdInternationalConferenceonOcean Energy,6October,Bilbao,2010 156“SteppingStonesTidalLagoon:AnoutlineproposalforanewtidalrangeprojectintheSevernEstuary”byParsonsBrinckerhoff, inassociationwithBlack&Veatch(PeterKydd—August2012) cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev168 EnergyandClimateChangeCommittee:Evidence

The creationof thebarrage andits associatedlow-head turbinetechnologies hasthe abilitytomake the UKtheglobalcentreofexcellenceforsuchlarge-scalebarrages.Thereareotherlocationsgloballywheresuch barragescouldbebuiltandtheimplicationsforBritishskillsandopportunitiesareclear.Justasthereareother estuarieswithhightidalranges,sothechangingclimatewillencourageboththeadoptionoflow-carbonenergy schemesandtheprotectionofestuarialhabitatsandenvironments.

Thetechnologydevelopedforthebarragewouldbeexportable.Theturbines,forexample,willbeanew development of bi-directional VLH turbines and would be suitable for a number of similar sites around the world.Inaddition,therewouldbeotherspin-offlowcarbontechnologieswhichwouldbedevelopedincluding control systems for managing the generating regime to cause the least environmental damage as well as for interfacingwiththeremainderoftheNationalGrid.

With the development of new low-carbon technologies, the reputation of the region’s universities and other supportingresearch institutionswould beenhanced andso be ableto attractmore overseasstudents and researchfellowsandprovideopportunitiesforthosewhostudyinthesenewfieldstotransfertheirknowledge tootherinstitutionsaroundtheworld.

Working with local partners in the South West and South Wales, Hafren Power will offer civil and mechanical engineering training and apprenticeship schemes which will create opportunities for the development of skill sets which are exportable thereafter. This will create the potential for new longer-term job opportunities for those acquiring these specialist skills and expertise, which are not only transferable and exportable,butshouldalsounderpinthecreationofawholenewUKskill-setattheforefrontofglobalbarrage/ low-carbonelectricitygeneration.

The barrage will provide the opportunity to revitalise the manufacturing skill base around the region furthertoenhancethepotentialforinwardinvestment.

The barrage presents a transformative growth opportunity for the UK, concentrated in South Wales and the South West of England. New jobs will be created in exportable industries. Flood defence will open up previously unusable land to development. The clearer and calmer waters will stimulate tourism and resettlement. AppendixItem1:Supplementaryinformationonflooding ExistingFloodProtection

The Environment Agency’s tidal flood zone for the Severn estuary is 530km2of tidal floodplain. This areacoverstheSevernestuarycoastlinebetweenLavernockPoint,uptoGloucesterandbackdowntoHinkley Point.Theseareasarecurrentlyatrisk,notonlyfromregulartidalflooding—especiallyassealevelsrise—but also from storm surges coming up the Severn estuary, in particular if coinciding with spring tides. Protection is currently provided by a series of artificial and natural flood defences, but rising sea levels as a result of climate changemean that thesewill need tobe augmentedprogressively over thenext few years(The Severn EstuaryShorelineManagementPlanReview(SMP2)exploresthisindetail157).

OntheWelshsideoftheestuary,themainfloodriskareasarefromCardifftoNewport.OntheEnglish side, the most heavily affected areas are from the Somerset Levels to Gloucester. The Department of Energy and Climate Change (DECC)158noted that the flood risk areas includes some 80,000 residential and 10,000 non-residentialpropertiesaswellastransportarteries,otherinfrastructure,agricultureandamenityland.These areasareatriskoffloodingandalsoincludetheM4andM5motorwaynetworkandtherailnetwork. 157SevernEstuaryCostalGroup(SECG)SevernEstuaryShorelineManagementPlanReview(SMP2)FinalStrategicEnvironmental AssessmentReport,Dec2010. 158DepartmentofEnergyandClimateChange,2010.SevernTidalPower—SeaTopicPaper(FloodRiskandLandDrainage) cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev169 Modelling PreviousStudies

There have been four previous studies which have examined the effects of the Severn barrage on flood risk.Thescopeofthesestudiesandtherisksandopportunitiesidentifiedinthestudiesaresummarisedbelow: Scope Risks Opportunities Sustainable Thestudyaimedtopredictthe Potentialdecreasesinflood Reductionsinhighwater Development impactsoftheCardiff-Weston riskdownstreamofthebarrage levels(0.5to1m)and Commission, (Ebbonlygeneration)onflood duetoadecreaseinhigh thereforefloodrisk 2007159 risk. water. upstreamofthebarrage. Thepotentialincreaseinflood Protectiontoupstreamareas riskupstreamifintertidalareas fromhighwaterlevels aredeprivedofsediment generatedbysurges(upto supplies. 2m). Thepotentialincreaseinflood Theabilitytoadjustbarrage riskifraisedwaterlevels operationtoassistin upstreamofthebarrier managingtheoccurrenceof impededexistingland hightidesandhigh drainage.Themitigationcosts freshwaterevents. wereestimatedasbetween £24.5millionand£61.9 millionat2006prices. DECC, Thisstudyaimedtopredictthe Raisedlowwaterlevelscould Changesinwaveandtide 2008160 effectofasmall,mediumand makemaintenanceofsome patternswouldincrease largebarrageonthetidal structuremoredifficult. floodriskinsomelocations regimeintheSevernestuary. Inadditiontooutfallsthe andreduceitinothers,but Thefindingsofthereportwere barragecouldalsoimpacton overalltherewouldbeanet basedonthemodelledoutputs surfacewateroutfalls,highway benefit,especiallyunder fromthe1980sstudiesandthe drainageandcombinedsewer highsealevelrise Defrapredictionsforsealevel overflows scenarios. rise. Liverpool TheUniversityofLiverpool Theprimaryimpactofthe ThetidesintheBristol University, havecarriedoutmodellingto barragesistheincreased Channelarereducedin Schoolof determinethecombinedeffect floodingrisk,duetothe amplitudeandthismayhelp Engineering, ofbarragesontheNorthWest increaseintidalamplitudeof reducestormsurgeflooding 2010161 estuariesactingincombination 0.15mto0.20malongtheeast risksinthisarea. withabarrageontheSevern. coastofIrelandandNorthern Theadditionoffivebarrages Ireland. withintheSolwayFirth, MorecambeBay,Mersey,Dee andSevernestuarieswas simulated. DECC, Thestudylookedattheimpact TheEbb-Floodmodeincreases TheEbb-floodmodeof 2010162 oftheCardiff-Westonbarrage thefar-fieldwaterlevelsbyup operationwillreducethe inEbb-FloodandEbbonly to30cmintheBristolChannel floodriskupstreamofthe modes. andupto10cmontheEast barragethroughloweringof CoastofIreland. thehighwaterlevelbyup to1.5m. TheEbb-Floodmode reducestheriskoftide- lockingoftidaloutfalls comparedtotheEbbonly scheme. 159SustainableDevelopmentCommission,2007.TidalPowerintheUK.ResearchReport3—Severnbarrageproposals.Anevidence basedreportbyBlackandVeatchfortheSustainableDevelopmentCommission.October2007. 160DECC,2008.SevernTidalPower—ScopingTopicPaperFloodRiskandLandDrainage.December2008. 161Liverpool University,School of Engineering,2010. Tapping the TidalPower Potential ofthe Eastern IrishSea, March 2009, RichardBurrows,IanWalkington,NickYates,TerryHedges,DaoyiChen,MingLi,JianguoZhou,DepartmentofEngineering, University of Liverpool, Liverpool L69 3GQ, Judith Wolf, Roger Proctor, Jason Holt, Proudman Oceanographic Laboratory, DavidPrandle,Consultant. 162DepartmentofEnergyandClimateChange,2010.SevernTidalPower—SeaTopicPaper(FloodRiskandLandDrainage) cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev170 EnergyandClimateChangeCommittee:Evidence HafrenPowerStudies Scope

AnumericalmodelhasbeencreatedtoassesstheenergyavailablefortheBusinessCasefortheSevern barrageandtounderstandtheeffectsofthebarrageonboththeupstreamandfar-fieldwaterlevels.Themodel isa state-of-the-art2D flexiblemeshhydrodynamic model,basedon theMike suiteofmodelling software163. ThemodelcoverstheareafromFrampton(ontheRiverSevern)toopenoffshoreboundariesthatextendfrom Cape Cornwall (Cornwall) to Cobh (Republic of Ireland), and from Ramsey Sound (Wales) to Rosslare (RepublicofIreland).

The model was run for five scenarios: existing conditions, barrage with bulb turbines operating in Ebb only generation mode, barrage with bulb turbines operating in Ebb-Flood generation mode, barrage with bi- directional turbines operating in Ebb only generation mode and barrage with bi-directional turbines operating inEbb-Floodgenerationmode. Results

The modelling undertaken for Hafren Power confirms the earlier studies on power generation. It also givesindicationsonhowthebarragewillacttoreduceupstreamtidalrangebyreducinghighwaterlevelsand raisinglowwaterlevels.

Thefindingsfromthemodellingtodateare: — That there is no significant change to water levels outside the Bristol Channel viz. off the coast of IrelandorofftheWestcoastofWales.ThisdiffersfromthefindinginearlierDECCStudy164since themodelboundarieshavenowbeentakenoutbeyondIrelandandtheContinentalShelfaroundthe UKthusgivingbetterrepresentationofthe“farfield”effects. — Thatthere isabouta20cm levelincreasewithinthe BristolChannelwestof thebarrageinthe area around Swansea. This requires further modeling and, in particular, refining the way in which the boundary conditions for the more detailed modeling within the estuary have been set up and this is expectedtoreducetheseobservedlevelincreases. — That the water levels to the east of the barrage (upstream) will reduce. Present modeling suggests that this reduction could be of the order of 2m for Spring tides. This tallies with “broad brush” calculations for the amount of energy that can be produced from the observed head difference (or differenceinelevation)betweenthewaterlevelsoneithersideofthebarrage. Verification

A further independent model has also been built by Cardiff University, as part of the research being undertaken by Professors Roger Falconer and Binliang Lin with the Low Carbon Research Institute, which gives a comparison with the results of the numerical model for Hafren Power. Initial results show general agreementbetweenthetwomodellingapproacheswhichgivesconfidenceintheresults,althoughbothremain subjecttofurtherdevelopmentandvalidationinfuturestagesofthedesignofthebarrage. AppendixItem2:NewPortinGranadilla,Tenerife,CanaryIslands TheProject

The reasons for the proposals are: existing port facilities in Santa Cruz are inadequate and that new facilitieswithincreasedcapacityshouldbedevelopedtorespondtoprojectedincreaseinmaritimetraffic.

Theprojectforeseestheconstructionofa650mlongcontainerterminalcovering26ha,a200mdockfor generalgoodswithanannexed5.7haareaanda19.5hatradingharbourareaforrawmaterialstraffic.

The port works are made up of a main breakwater of 2,557m length going down to 55m seabed depth and a total land filling of 786,000m2 by using 12m m3 of quarry material. The new harbour will dispose of a contiguousterrestrial areawith 12.4hafor thedevelopment oflogistic activitiesand anarea with15hafor the installationofanaturalgasplant. TheNATURA2000Network

The Natura 2000 sites involved are “Sebadales del Sur de Tenerife” (ES7020116) and “Montaña Roja” (ES7020049). The site hosts a habitat type “1110 Sandbanks which are slightly covered by sea water all the time “(Listed in annex I of Council Directive 92/43/EEC) and a habitat required for the conservation of the priorityspecies*Carettacaretta2(loggerheadturtle).

The site “Montaña Roja” is one of the sites hosting a priority habitat type-” 2130* Fixed coastal dunes withherbaceousvegetation(greydunes”). 163The software used for the modelling was MIKE 21 by DHI Software (more details on http:// www.dhissoftware.com). This softwareisindustryleadingforthesepurposes. 164DECCSevernTidalPower—ScopingTopicPaper,HydraulicsandGeomorphology,December2008 cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev171

In addition, the species Atractylis preauxiana (a species of plant endemic to the Canary islands) and priority species Caretta caretta, included in Annexes II and IV of the Habitats Directive, are also affected by theproject. Environmentalimpacts

The most significant environmental impact on the new port will result from the disruption of natural patterns of sand removal and deposition. Under natural conditions, submarine sand covering the seabed near the coastline is progressively displaced from NE to SW due to the main water stream flow. The port project willinterruptthisnaturalsandflowandthisinturnwillresultinerosionofthesea-bedfurtherdownthecoast. In order to mitigate this, the Spanish authorities have proposed a new “North South sand bypass in the Granadilla harbour”. This proposal provides for pumping machinery and associated pipe work to take all the sanddepositedonthenorth-sideofthenewportandtopumpittothesouthernendoftheport.Windturbines builtintheprojectareawouldproducethenecessaryelectricityforpoweringthesystem. Alternativesolutions

There are no alternative solutions: regarding the possible alternatives to Granadilla as site for the new port, the Commission has assessed the authorities’ opinion that Granadilla is the only appropriate site for the new port in Tenerife. This opinion is based on different technical reasons that have to be considered when identifyingasitefortheconstructionofanewport. Imperativereasonsofoverridingpublicinterest(“IROPI”)

As the main purpose of project is not concerned with improvements to human health or public safety andnor isit expectedto haveany beneficialconsequencesof primarybenefit tothe environment,justification for the projects should be based on “other imperative reasons of overriding public interest.” and the Commissionshouldgiveitsopinionontheseconsiderations(Article6.4HabitatsDirective).

Thenewportisexpectedtogenerateasoundeconomicrateofreturnanditwillalsoprovidetheisland with the possibility of attracting international container transhipment traffic. The Commission recognises that there is a demonstrated need to increase and develop port capacity in order to promote economic and social developmentintheislandofTenerifeandthesurroundingregion,thereforeanIROPIexists. ProposedCompensatoryMeasures

Asetofnecessarycompensatorymeasureshavebeenproposedthatarespecificallyrelatedtotheeffects of the species and the integrity of the sites. The Commission considers the proposed compensatory measures areadequateiftheyareexecutedinatimelymannerandrequestsannualreportsontheimplementationofthe projectandontheresultsoftheimplementationofproposedcompensatorymeasures.

To ensure that the Granadilla port is built and managed in an environmentally sensitive manner, and independent and permanent foundation will be set up before the construction works are started. The role of thisfoundationwillbetomonitorthestatusandtrendsinlocalbiodiversityaswellasensuringthatmitigation andcompensationmeasuresarecarriedoutproperly.

The compensatory measures proposed for the effects on the populations of the species Atractilys preauxianalisted inAnnex IIandIV ofCouncilDirective 92/43/EECof 21May1992 ontheconservation of naturalhabitatsandofwildfaunaandfloraare: — Designationofanewsiteofcommunityimportancefortheprotectionofthepopulationsdetectedin theareaoftheindustrialparkofGranadilla.ThetotalareaofthisnewSCIwillbe0.93hectares.In addition, it is proposed that this area would serve as a donor for the restoration of southern areas wherethesesubpopulationshavedisappeared(speciesreintroductioninSCI“MontañaRoja”)

The compensatory measures proposed for the effects on the natural habitat of Community interest 1110 “Sandbankswhichareslightlycoveredbyseawaterallthetime”intheSCI“SebadalesdelSur”are: — Designationoftwonewsitesofcommunityimportancehostingareasofsandbankswhichareslightly covered by sea water all the time (habitat type 1110): Antequera (Tenerife island), total surface 272.61ha;andGüiGüi(GranCanariaisland),totalsurface7.219.74ha.

ThecompensatorymeasuresproposedfortheeffectsonCarettacarettaare: — Any effects on the priority species Caretta caretta, due to impacts on the habitat required for its conservation,wouldbecompensatedthroughtheabove-mentionedmeasures.

Inadditiontotheabovecompensatorymeasures,thefoundationwillestablishandcarryoutamonitoring programmetoassesstheconservationstatusofthisspecies’ populationintheCanaryIslands,asrequestedby article 11 of the 92/43 Habitats Directive. Methods and conclusions drawn out by the LIFE project B4–3200/ 97/247willbeconsideredbythefoundationwhenestablishingtheabovemonitoringprogramme.

The compensatory measures proposed for the Site of Community Interest ES7020049 “Montaña Roja” are: cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev172 EnergyandClimateChangeCommittee:Evidence — ImplementationoftherestorationprojectontheSCI“MontañaRoja”forre-establishingafavourable conservation status. This measure implies enhancing the conservation status and will allow a significant increase of the area covered by the habitat type “Fixed coastal dunes with herbaceous vegetation(greydunes)”withinthesite. OpinionoftheCommission

The Commission holds the view that the new port of Granadilla project can be executed for reasons of overriding public interest on the condition that all necessary compensatory measures to ensure overall protectionofthecoherenceofNatura2000canbetakeningoodtime. AppendixItem3:HafrenPower—BoardofDirectors GregoryShenkman Chairman Greg has almost 40 years’ experience in international finance. He has held senior positions with several leading investment banks, including Rothschild, Kleinwort Benson and Swiss Bank Corporation (now UBS). Mostrecently,hewasaGlobalPartnerandManagingDirectorwithRothschild,wherehewasresponsiblefor the Asian investment banking and other businesses from 2000 to 2004. Greg holds several directorships in bothpublicandprivatecompanies. AnthonyPryorCBE BA,FICE,MInstRE ChiefExecutive Tony was non-executive Chairman of Halcrow group from 2007 to 2012. Before this, he spent 30 years in the defence industry and until 2005 was Chief Operating Officer of Kellogg Brown and Root (UK). He was ChairmanofDevonportRoyalDockyardfrom1997to2006.Tonyhasconsiderableexperienceandknowledge ofpublic-privatepartnerships,andisrenownedforhisworkinthedefenceandnuclearsectors. JuliaBarfieldOBE Non-ExecutiveDirector Julia is an award-winning architect. Her firm, Marks Barfield Architects, conceived and designed the landmark London Eye, the UK’s most popular paid-for attraction. Marks Barfield will design the Hafren Power Severn barrage. Following appointments with Richard Rogers Partnership and Foster Associates, Julia establishedMarksBarfieldin1989. RichardBazley ExecutiveDirector Richard is the visionary behind the Hafren Power Severn barrage. He has devoted the past seven years to makinghis ideaof aprivatelyfinanced barragea reality.An entrepreneuroversome 50years, withnumerous commercialpropertycompaniesandfinancialinstitutions,Richardbeganhiscareerasaneconomistandvaluer withHMRC. ProfessorChristopherFleming FREng Non-ExecutiveDirector Chris is a Fellow of the Royal Academy of Engineering. He was a Board director of Halcrow Group until 2007, concluding a 40 year association with the organisation, and was previously CEO of Halcrow Maritime. Chris was closely involved in previous Severn barrage proposals and is Visiting Professor of Coastal EngineeringatPlymouthUniversity. JosephHannah Non-ExecutiveDirector Joseph is an international lawyer who in 1997 established the firm Hannah & Mould. The partnership specialises in infrastructure and energy projects, with expertise in project finance and contract drafting, and energyandconstructionlitigationandarbitration,bothintheUKandinternationally. LordRowe-Beddoe Non-ExecutiveDirector David is a life peer and a crossbench member of the House of Lords. He was CEO of Thomas De La Rue andDeLaRueplc,RevlonInc.andMorganStanley/GFTAandwasknightedin2000forservicestoindustry andeconomicdevelopment.HewasChairmanoftheWelshDevelopmentAgency(WDA)from1993to2002 cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:51] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev173 and is currently Deputy Chair of the UK Statistics Authority. In 2005, he received the Beacon Prize for his contributiontotheeconomicandsocialdevelopmentofWales. AppendixItem4:ExpertPanel ProfessorChrisBinnie FREng EnvironmentandEngineering ChrisalsositsontheRegionalCommittee.HisCVcanbefoundin“AppendixItem4:RegionalCommittee”. ProfessorRogerFalconer FREng EnvironmentandEngineering Roger also sits on the Regional Committee. His CV can be found in “Appendix Item 4: Regional Committee”. ProfessorChristopherFleming FREng EnvironmentandEngineering ChrisalsositsonHafrenPower’sBoard.HisCVcanbefoundin“AppendixItem2:HafrenPower—Board ofDirectors”. RtHonPeterHainMP Politics PeterisaBritishLabourPartypoliticianandcampaigner.HehasbeentheMemberofParliamentforNeath since 1991 and served in the Cabinets of both Tony Blair and Gordon Brown, as Secretary of State for Work and Pensions, Northern Ireland, Wales and Leader of the House of Commons. He was also Energy Minister, Foreign Office Minister and Europe Minister. Peter rose to prominence for his Anti-Apartheid campaigning andin1969–70wasChairmanoftheStopTheSeventyTourCampaign. ProfessorBrianMorgan Economics BrianalsositsontheRegionalCommittee.HisCVcanbefoundin“AppendixItem4:RegionalCommittee”. StephenPrendergast Projectmanagement Stephen is a global turnaround and infrastructure director who has delivered value on some of the largest projects in the world whilst managing multi-billion pound budgets. He has more than 20 years’ international experienceoperatingatGroupExecutiveBoardlevelwithVoithHydroFarEast,AmecandCostaininsectors includingoilandgas,powerandwater.StephenisaCharteredandEuropeanregisteredengineerandamember of UKTI advisory team on infrastructure. He has specific experience in “Run of River” power stations in the USandChinaandbuildingthelargestcaissonsintheworldinMexico. MichaelPrideaux Publicrelations Michael began his career in public relations 33 years ago at the Financial Times, where he was UK AdvertisementDirectoruntil1983.From1983to1989he wasChiefExecutiveandBoarddirectorofCharles Barkerplc.Forthenext23years,heworkedforB.A.T.IndustriesplcasDirectorofGroupPublicAffairsuntil 1998andthenasCorporateandRegulatoryAffairsDirectorforBritishAmericanTobaccoplcuntil2012. JonathonPorrittCBE Environment Jonathon has been involved with environmental issues for almost 40 years. From 1984 to 1991, he was Director of Friends of the Earth. In 1996, he set up Forum for the Future, which is now the UK’s leading sustainable development charity. Jonathon is Co-Director of the Prince of Wales’ Business & Sustainability Programme,andwasChairoftheUKSustainableDevelopmentCommissionbetween2000and2009. ArchibaldWalkerMBE Engineering Archie has worked for over 40 years in large engineering construction. He has been responsible for the construction of over 15 oil and gas offshore structures worldwide and for over 80 projects as Head of cobber Pack:U PL:COE1[E] Processed:[06-06-2013 14:52] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml Ev174 EnergyandClimateChangeCommittee:Evidence Construction at a nuclear establishment. He was Project Construction Director for the Devonport Vanguard Facility Upgrade, a seven-year project, which was completed on time. Recently, he was Vice President for KBR responsible for the construction and installation of defence programmes in the UK and Iraq. Over the pastyear,ArchiehasadvisedHalcrowonconstructionissuesrelatingtotheSevernbarrage. AppendixItem5:RegionalCommittee DrElizabethHaywood Chairman Elizabeth has worked in both the private and public sector in Wales, England and internationally. She is a formerDirectorofCBIWales,andhasexperienceinthetransportsectorandeconomicdevelopment.Sheruns herownbusinessandholdsanumberofnon-executivepositions.ElizabethwontheWelshWomanoftheYear Awardin1994andin2012chairedtheMinisterialAdvisoryGrouponCityRegionsinWales. IdwalStedman Executive Idwalisoneofthefoundersofthisproject.Heranahighlyregardedarchitecturefirmwhoseclientsincluded Boots PLC, Mercedes Benz and Gwent Europark. He now devotes all his time to the barrage project. He graduated from theWelsh School of Architecture with firstclass honours and is aWelsh speaker. Bydd gan y morglawddhawliauporthmynabyddganwarthegIdwalyrhyddidigroesifelymynnant. ProfessorChrisBinnie FREng Member Chrisisanexpertinwater,engineering,damsandflooding.For17years,hewasHeadofWaterConsultancy at Atkins plc. He has been an expert witness to Parliamentary Committees, Competition Commissions and Public Inquiries, amongst others. He was Chairman of the Independent Engineering and Technical Expert Panel,appointedbyDECC,fortheSevernTidalPowerstudies.HeisavisitingProfessoratExeterUniversity. Chris is a fellow of the Institution of Civil Engineers, past President of the Chartered Institution of Water & EnvironmentalManagement,andFellowoftheRoyalAcademyofEngineering. ProfessorRogerFalconer FREng Member Roger is a Fellow of the Royal Academy of Engineering, a Chartered Engineer and a Chartered Environmentalist. He is Professor of Water Management at Cardiff University and has over 35 years’ applied researchexperienceintomodellingcoastal,estuarineandriverbasinprocesses.Hehaspublishedandpresented extensively in the field, including on the Severn estuary and Severn barrage. Roger’s models have also been usedinover100EIAstudiesworld-wide. ProfessorBrianMorgan Member Brian is an experienced economist. He has worked extensively in Whitehall, the EU and OECD and is currently Professor of Entrepreneurship at Cardiff Metropolitan University. His research focuses on the economic impact of renewable energy technologies and their contribution to regional development. Outside academia, he has been Chief Economist at the Welsh Development Agency and is currently a director of a numberofbusinessesinWales. JeremyPakenham Member JeremyisaformerpartnerofPriceWaterhouseCoopersManagementConsultancy,wherehewasresponsible for the firm’s Worldwide Energy Consulting practice. Prior to joining Price Waterhouse in 1984, he had ten years’ experience in senior financial and general business line management in the West of England. Since retirement in 2005, Jeremy has been engaged in a number of consulting roles in the energy, fossil fuel and renewablessectorsintheUKandEurope. JillShortlandOBE Member JillisaconsultantspecialisinginadviceandliaisonservicesinrelationtoLocalGovernmentandownsher own consultancy company. She works with local communities, councils, and national and local development teams.During her22years inlocalgovernment, shehasheld leadpositionsin herTown,Districtand County Councils and was Chairman of the South West Regional Assembly. Alongside running her business, Jill is cobber Pack:U PL:COE1[O] Processed:[06-06-2013 14:52] Job:026903 Unit:PG04 Source:/MILES/PKU/INPUT/026903/026903_w028_michelle_SEV93-AlanSeatter.xml EnergyandClimateChangeCommittee:Evidence Ev175 currentlytheViceChairmanoftheLocalGovernmentAssociation’sImprovementBoardandtheChairmanof theLGALiberalDemocratGroup. December2012 SupplementarywrittenevidencesubmittedbyHafrenPower