IFM Submission to the Hinkley Point C Development Consent Order

The Institutes response to the recent Hinkley Point C consultation on the use of fish deterrents on the water intake can be read below.


The Institute of Fisheries Management rejects and strongly opposes the proposals on the

following grounds:

1. HPC is the largest and most advanced nuclear new build in western Europe. It is seeking to

abstract colossal amounts of water from a rich, diverse and highly protected estuarine

environment which is home or a migration pathway for millions of fish, including important and

protected species. In this environment, a state-of-the-art development requires state-of-the-art

mitigation in the form of an acoustic fish deterrent.

2. In that respect, you are not applying Best Available Technology, contrary to planning and

environmental law.

3. You have not demonstrated, as is required by environmental and planning law, that the

development will have no net impact on the environment.

4. The package of environmental compensation measures proposed is welcome, however:

a) When you are not monitoring the impact on fish populations and other wildlife, the impact

cannot be known and therefore the extent of compensation cannot be assessed, or

whether it is sufficient;

b) The ‘compensation’ package should be considered instead as your contribution to

environmental net gain, as is required by law. It should be provided as well as the AFD

5. You have not applied the Precautionary Principle.