Summary of the Issues and our objections with the permitting of Hoveton Great Broad Fish Barriers
Please feel free to respond to the consultation at the link below before the 6th April 2021
https://consult.environment-agency.gov.uk/east-anglia-c-e/hoveton-great-broad-fra-permit/consultation/intro/
Issue 1
Under the Environment Permit Regulations, all material should be presented to the public as part of its consultation.
The previous permit was quashed last year for this very reason.
However this applications still doesn’t provide any evidence on the agreed fisheries science, without having to search back through the previous permit register and even then the primary document showing the impact of the barrier is still missing from both this and previous data.
This report produced by the EA Northern Broads Bream Spawning Assessment 2019 Interim Summary V1.4 must be included as it clearly shows the impact the barrier would have on fish. But is available on the above link to view.
Issue 2
We should also point out in the strongest terms the attitude from Natural England against EA staff who undertook their statutory fishery duties in challenging the evidence with clear fishery science. This attitude, together with the actions and conduct of the Environment Agency Management led to the resignation of senior fisheries staff. This puts the whole ambition and leadership of the project into question, the lengths they will go to protect their position and project outcomes.
Issue 3
The submitted Environment Statement Vol 1 formed part of the projects planning conditions. In the current submitted papers Natural England wishes to clarify paragraph 8.5.24 of the Environmental Statement of July 2014. The third sentence of this paragraph ought to read as follows: “If these impacts are assessed by the Environment Agency as being significant, bio-manipulation will not proceed.”
We cannot have any applicant of a planning application changing agreed and accepted conditions, without following the due legal process. The current valid environment statement reads “If these impacts are assessed by Environment Agency fisheries specialists as being significant, bio-manipulation will not proceed”
Issue 4
The whole concept of any form of advisory group with seemingly a confirmed fund of over £170k, seems like box ticking when viewed against the TOR of such advisory group and its findings. NE have made it very clear that even with evidence of significant impact to cyprinid fish and ecological damage this would cause the objectives of the project still stand and the barriers would be legally defended. Under these terms, it is unacceptable for fishery interests to be treated so shamefully.
Issue 5
Natural England has directly approached the Institute Fishery Management (IFM) for they views on the current proposals and the IFM response is very clear. That isolation and removal of fish alone will NOT restore HGB to favorable conditions for macrophytes. Again, this information is again NOT in the public domain.
Issue 6
The IFM has concluded “it is not clear that exclusion of spawning bream from entering HGB will be sufficient to reduce phytoplankton densities, increase water clarity and ensure macrophyte recovery.”
It has made a number of recommendations which should ensure a precautionary approach is adopted, rather than the policy of install the barriers and the fish don’t matter.
Issue 7
NE state quite clearly that once deployed the barriers will not be removed and will become subject to the constraints impowered by the Habitat’s Directive. Do you have to ask what is the point of any extensive monitoring and advisory group, if the findings are completely overruled by the overriding outcomes and commitments of the project, however, damaging to the wider Broads ecosystem?
Issue 8
How can you assess something with a long history associated with eurytopic habitat and by installing a barrier, classify it as something it has never been?
We have explored the historic context of the Bure Catchment and found that in the 19th century tonnes of bream were removed commercially for food. This was at a time when recent core samples have shown the broad full of weeds. The 1877 Norfolk and Suffolk Fisheries Act gave protection to these fish from man’s interference and is something we wish to see in the 21st century also.
Issue 9
The plans to install semi permanent barriers to fish to a height of 0.76 AOD by your own flood risk assessment shows that the river levels will breach this level at an ever increasing rate with the forecast changes to river levels. Indeed they were breached in the past two winters.
Issue 10
BASG has challenged the lack of forward planning on waste water treatment in supporting the growth planned around Norwich as defined within the GNDP, today the overall River Bure Phosphate load remains no different than 30 years ago. So eutrophication pressures will continue, without this being addressed.
Issue 11
Geese and gulls continue to roost on HGB in vast numbers, which as previously evidenced on Hickling Broad was a cause of eutrophication and loss of stonewort species in the mid-eighties.
Look at this image right of gulls within Hoveton Great Broad.
This just demonstrates again that fish aren’t the single issue.
Issue 12
We have modelled the life cycle of Broads Bream and shared this with the project team.
This uses the agreed parameters and constraints to build a model on future fish stocks.
This clearly shows a 80% decline in Bream stock if the spawning success if limited to 20% for 10 years.
Issue 13
What does a 80% decline in Bream stock mean to the wildlife and birds that feed off them and could potentially change the whole ecology of the Broads wildlife.
Our full submitted response is here: EPRRB3557SW-Response-BASG-Final
BASG CIC Directors 24th March 2021
