The Lancashire Wildlife Trust has objected to an application to run a series of cables underneath the Fylde Sand Dunes, from the planned Morgan and Morecambe Offshore Windfarm. The Trust is one of three participating partners in the Environment Agency funded Fylde Sand Dunes Project. The Trust is fully supportive of the need to transition to green energy production, however we believe that any infrastructure projects must be done right and not at the expense of nature. We are facing an ecological emergency with 41 per cent of wild species in decline in the UK. The climate and nature crises are inextricably linked, we cannot solve one without solving the other. 

It is for this reason that we have submitted an objection to aspects of the current proposals on the following grounds. It will be necessary to work with the applicant to ensure that the highest levels of environmental protection are achieved, alongside providing sustainable energy for the future. 

In summary the objection relates to: 

• Disturbance to sand lizards 

• Adverse effects on the hydrology of the Fylde Sand Dunes 

• Inadequate or missing environmental mitigation plans  

• Inadequately mitigated sea floor habitat loss 

• Subsea construction noise  

• Disturbance to protected bird species 

• Inadequate data and errors in habitat mapping 

• Impact on Fylde Sand Dunes Project dune creation work 

You can read our full response here or find more information below. 

Find out more about the Morgan & Morecambe Offshore Windfarms Transmission Assets proposal here.

Adverse hydrological impacts 

Proposals to dewater areas during the creation of pits to sink the cables are liable to affect the underground aquifer and reduce groundwater levels. This could have a serious effect on the Fylde Sand Dunes habitat which relies on this water table; already drained and affected by existing aquifer abstraction and land drainage in the adjoining golf course.  

We are also concerned that, in the long term, the presence of the cables under the Lytham St Anne’s Site of Special Scientific Interest (SSSI) & Lytham St Anne’s Local Nature Reserve (LNR) could disrupt the aquifer that sustains dune slacks on a temporary, long term or permanent basis. This is a huge ‘known unknown’ risk, the impact of which would not be known unless the proposal were already consented and when a full hydrogeological risk assessment would be undertaken. 

Inadequate data and errors in habitat mapping 

We have identified several errors in habitat mapping, for example areas of dune slack being reported as scrub. As dune slack is much more susceptible to hydrological disturbance than scrub it is vital that this be addressed for environmental impact to be properly assessed. 

Several key species seem to have been missed or vastly under recorded, for example populations of smooth newt and common toad. There is also no specific species data for insects or plants. This information was not sought but could have been provided by the Fylde Sand Dunes Project, with an offer now extended to share data. 

Disturbance to protected bird species 

The area is home to several bird species that are protected under Special Protection Area (SPA) designations, and we are concerned that these could be adversely affected by the proposal during the lifetime of the project. 

Fairhaven saltmarsh mitigation plans 

We feel that the proposed environmental mitigation plans for the Fairhaven saltmarsh area will not be effective in compensating for the disturbance and temporary habitat loss on wading birds. 

The Fylde Sand Dunes includes Lytham St. Anne’s SSSI, Local Nature Reserve (LNR), Biological Heritage Site (BHS), and Geological Heritage Site (GHS). We would have expected detailed plans to be provided assessing any environmental impact, but unfortunately, these were not made available. 

Impacts on the Fylde Marine Conservation Zone (MCZ) 

The application states that there will be 30,400m2 of potential habitat loss in the Marine Conservation Zone. At this level Natural England recommend that an additional Stage 2 Marine Conservation Zone assessment should be undertaken, which would further identify potential risks and any avoidance/mitigation measures. This has not been done and therefore we are asking for further information to be provided. 

The reduction in sand-wave clearance for the Morgan offshore export cables (from 60 per cent to 5 per cent) and the Morecambe offshore export cables (from 30 per cent to 5 per cent) is a necessary improvement which is included in the proposal. Sand-wave clearance involves the removal or reduction of natural sand formations on the seabed to allow for cable installation, which can impact marine habitats. 

Fylde area 

We welcome the avoidance of the Queensway Farmland Conservation Area, and of areas with a high concentration of peat along the onshore cable route. However, two Biological Heritage Site (BHS) ponds (Freshfield Farm Ponds – North, and - South) will be destroyed by sub-station construction. There is also concern about the effect on birds at Lytham Moss Biological Heritage Site, but further detail would need to be provided to effectively assess this. 

Lea Marsh BHS 

The proposal includes measures for temporary mitigation of impact on otters to be delivered within Lea Marsh. However, these measures do not identify any protective measures for populations of key species that might otherwise be damaged by that mitigation work; notably the county rarity, meadow barley grass, and the nationally scarce long-stalked orache wildflower. 

There are also little or no detailed plans for any environmental mitigation to other Biological Heritage Sites that the onshore cable route goes through including Howick Hall Ponds Biological Heritage Site and Mill Brook Valley Biological Heritage Site. We have requested for more information to be provided before a decision can be made. 

It is important that there is commitment to voluntary Biodiversity Net Gain (BNG) measures (BNG will only be mandatory for national infrastructure projects after November 2025), along with the proposed commitment to look for further environmental enhancement opportunities. This includes accessing the Great Crested Newt District Level Licencing Scheme to create new ponds within the local area. 

The main grounds of the objection are based upon our findings of substantial deficiencies in the content and clarity of the application, along with several errors and omissions. This has meant that our ecologists have been unable to conduct a thorough evaluation of the environmental impacts of the proposal, as presented.