Roger Cooper
"As a Whitstable fisherman for more than 30 years, who has carried out the vast majority of my work on the Kentish Flats, I am deeply concerned about the further loss of fishing grounds that will occur should the proposed extension proceed. As in 2004, before the first 30 turbines were installed, local fishermen met with GREP and expressed our concerns regarding the loss of this area to fishing and oystering operations. As a result GREP took these concerns seriously, consequently moving the windfarm development to less sensitive fishing grounds, roughly a kilometre to the north. The current extension proposal, will now encroach back to the south, onto sensitive native oyster beds, which we had previously thought 'safe'. This will have a detrimental impact on our income from fishing in this area. A further concern is that the ecology of the area will be altered, with a massive influx of starfish on the seabed covered by the windfarm, as has happened with the existing area. These have a devastating impact on shellfish, in particular bivalves, and also render the ground almost unworkable to fishermen."

Medway Council
"The Development is unlikely to have any significant impact on the Medway Councils administrative area and Medway Council therefore has no comments on this application"

Highways Agency
"Developments Affecting Trunk Roads and Special Roads Highways Agency Response to an Application for Planning Permission From: Divisional Director, Network Delivery and Development, South East, Highways Agency. To: Chief Executive Infrastructure Planning Commission IPCs Reference: EN010036 Extension of Kentish Flats Offshore Wind Farm, with cabling connection works in the Herne Bay area Referring to the notification of an IPC application dated 28 November 2011, your reference EN010036, in connection with the above proposed development (cabling connection works) in the vicinity of the A2, notice is hereby given under the Town and Country Planning (Development Management Procedure) (England) Order 2010 that the Secretary of State for Transport:- a) offers no objection; By authority of the Secretary of State for Transport Date: 13 December 2011 Name: Kevin Bown Position: Asset Manager, Area 4 (Kent) Address: The Highways Agency: Federated House, London Road, Dorking, Surrey, RH4 1SZ"

?
"i will be working for and on behalf of the fisherman to ensure that we get a fair voice in the proceedings of building the windfarm and to try and keep a working relationship between the windfarm and the fisherman."

The Royal Society for the Protection of Birds
"The area around the existing Kentish Flats Offshore Windfarm - and the proposed extension – is designated as the Outer Thames Estuary Special Protection Area (SPA) under Article 4 (1) of the EU Directive on the Conservation of Wild Birds (2009/147/EC) - the “Birds Directive”. The SPA has been designated to protect an internationally important wintering population of red-throated divers Gavia stellata. On average the site supports 6,466 individuals each winter, equivalent to some 38% of the UK wintering population. Our concern lies in the assessment of the impacts of the proposed extension on the diver population, and we welcome the Applicant’s provision of relevant environmental information to assist the IPC in this regard. It is the RSPB’s view that an appropriate assessment is required as set out in Regulation 61 of the Conservation of Habitats and Species Regulations 2010 (as amended) – the “Habitats Regulations” – to establish whether, either alone or in combination with other projects, this proposal would have an adverse impact on the diver population. The RSPB has engaged in the helpful pre-submission discussions organised by the Applicant, and our preliminary views on the project have been made to them in writing. We understand that this correspondence is available to the IPC. But in summary, our view is that the impact of the proposed Kentish Flats Offshore Windfarm extension, considered alone, may not constitute an adverse effect on the integrity of the Outer Thames Estuary SPA, by virtue of its impacts on the wintering red-throated diver population. However, the in-combination effects on the SPA are currently unclear, particularly with respect to the possible impacts of the London Array Offshore Wind Farm – in-confidence discussions on Phase 2 of that project are currently underway. It is our view that - in seeking to reach a conclusion on the in-combination test in the present case - the IPC need to also consider London Array Limited’s intentions with respect to the remaining part of their consent. As set out in our correspondence with Vattenfall, our final position is subject to our review of the submission documents. This is underway and we may wish to submit and/or present further evidence if appropriate, or appear at any hearings the IPC may wish to convene on the matters of concern to us. Should the IPC need to contact the RSPB during the period 24th December 2011 to 16th January 2012 inclusive, please contact Anna Heslop at the following address: Anna Heslop Casework Officer Casework Unit RSPB The Lodge Sandy Bedfordshire SG19 2DL"

English Heritage
"English Heritage is the Government’s advisor on all aspects of the historic environment in England. English Heritage is an Executive Non-departmental Public Body sponsored by the Department for Culture, Media and Sport (DCMS) and we report to Parliament through the Secretary of State for Culture, Media and Sport. The National Heritage Act (2002) enabled English Heritage to assume responsibility for maritime archaeology in the English area of the UK Territorial Sea. We have reviewed ‘Kentish Flats Offshore Wind Farm Extension – Application for Development Consent Order’, prepared by Vattenfall Wind Power Ltd (dated October 2011) and we offer the following comments (with particular attention to the marine area): 1) Chapter 14 Landscape, Seascape and Visual Impact Assessment – we noted the statement made in paragraph 14.2.3 and we have considered the detail of Appendix 14.1 (methodology) and that reference is made to Historic Seascape Characterisation studies commissioned by English Heritage and that the definition of visual receptor sensitivity included ‘cultural or historic attributes’. 2) Chapter 16 Maritime Archaeology – we noted the detail given in paragraph 16.4.10 regarding the identification of palaeo-channel features and the detailed planning of this project is to be informed by archaeological interpretation of geotechnical (i.e. borehole) survey material to determine what impact the proposed development may have on features and elements of the submerged and buried historic environment. The format for the archaeological interpretation should be set out in a Written Scheme of Investigation to be agreed with English Heritage. In reference to the information provided in paragraph 16.4.27 (Unknown and Uncharted Sites) and in consideration of material included in paragraph 6.4.18 (Quaternary Channel Fills), the applicant should apply The Crown Estate ‘Protocol for Archaeological Discoveries: offshore renewables projects’ (published 2010). The purpose of this is to ensure that appropriate action is taken if the proposed project encounters any unidentified wreck (vessel or aircraft) or other material of archaeological interest. Section 16.5 (Potential impacts during the construction phase) alludes to seabed contact by vessels employed to construct the wind farm. We therefore support archaeological interpretation of geophysical survey data to inform the installation programme so that if any floating barge or jack-up barge is employed using an anchor spread it does not impact any sites or other anomalies of archaeological potential. We noted the detail in paragraphs 16.5.18 and 16.5.19 regarding Archaeological Exclusion Zones and we encourage further discussion regarding AEZ monitoring requirements (paragraph 16.5.20) and all further aspects of their effective identification, assessment and avoidance. We have considered the information provided in Appendices 16.1 and 16.2 which comprises an updated desk-based assessment of archaeological potential and revised palaeo-geographic interpretation and we concur with the proposed mitigation strategy (as detailed in both appendices)."

Hampton Pier Yacht Club
"I write on behalf of the Trustees and General Management Committee of Hampton Pier Yacht Club. Hampton Pier Yacht Club is a Community Amateur Sports Club situated close to Hampton Pier in Herne Bay, and is within a few metres of the cable transition pit proposed to be located in the Hampton Pier car park. Should cables be routed anywhere in the area we occupy then we believe there is a risk that Club premises or other Club property and/or member's boats may become damaged. Depending on the timing of the work, there may also be significant disruption to the Club's activities. We are pleased that Vattenfall's communication with the Club has been good and are satisfied that the developer intends to mitigate our general concerns about disruption to Club activities, as set out in Section 7.8.1 to 7.8.3 of the Consultation Report. We have some remaining concerns, however, about the boundary of the onshore part of the application site. The Club, and members of the Club, keep boats in a designated area of the beach next to the Club and on the coastal slope behind the Club, both areas being leased from Canterbury City Council. Since the public consultation was held in early 2011, Vattenfall have extended the area of the DCO application site boundary beyond that initially proposed. The DCO application site boundary now encompasses the entire area occupied by Hampton Pier Yacht Club, including all of our buildings and both of our boat parking areas. We believe it is unnecessary for the DCO application site boundary to include the coastal slopes, or indeed, any land other than is required for the cables to take a direct route to the transition pit. We have expressed to Vattenfall our concerns about potential damage to Club property and the property of Club members that could arise from installation work within the onshore part of the application site boundary. In a meeting with Vattenfall on 6 July 2011, we were assured that the route of the export cables would be about 70m east of the existing cables and that the cables would run directly up the beach to the transition pit. However, we would point out that the onshore area within the DCO application boundary is much greater than is necessary for the cables to follow this route. The boundary includes a significant area of coastal slopes, for example, and the developer has provided no reasons for inclusion of the coastal slopes in the Project Design Statement. We remain concerned, therefore, that the boundary of the DCO application site includes a much larger area of land than the beach and the transition pit site, since there is potential for damage to Club and members' property if this extended area is used in the installation process."

Port of London Authority
"The proposed extension area is within the PLA's limits and the applicant is aware of the need for a River Works Licence from the PLA for those parts of the proposed development which are located within the PLA's limits. The applicant has engaged the PLA in pre-application discussions and the PLA is grateful for this. The PLA has no in principle objection to the proposed extension. It is noted that the Draft Extension Order and Explanatory Memorandum make reference to the extinguishment of the public right of navigation and that this would be limited to the site of the towers. This is an area of open sea at present and if the towers are removed this restriction will still apply. It is therefore suggested that the extinguishment be limited to the life of the towers and that when they are removed, the public right of navigation revives. It is recommended that similar to other projects, the piles are cut to a minimum of 1 metre below bed level and the applicant has the responsibility to carry out further works to the pile stumps if they are exposed due to scour etc. The PLA has existing navigational equipment/facilities at the Kentish Flats Windfarm sites and it is necessary to ensure that our rights of access to these facilities (either escorted or unescorted) are maintained. In order that there is no ambiguity, it is suggested that full details are provided of the access arrangements (including any changes to procedures if they are proposed) for accessing F1 and the substation at redfarm, with relevant certification requirements for both sites. I was also unable to find any mention of how the existing systems are likely to be affected, so a point of contact is required to enable the PLA's Navigation Systems Engineer to be notified if there is any likelihood of service being disrupted. This may well be through the existing marine co-ordination but this should be clarified."

Ashford Borough Council
"Thank you for your letter of consultation dated 28 November 2011 I can confirm that the Council has no comment to make on the scheme at this stage."

Barry Mount
"1. The turbines will have an overbearing effect from the foreshore at Herne Bay especially those planned inside the existing configuration - what would be more logical is to have all additional turbines in line and running west of the existing ones. 2. The cable trenching planned to come ashore at Hampton Pier will cause damage to the mussel beds and Hampton Rocks itself, which were considerably damaged during the previous cable laying exercise and may have contributed to the disappearance of the sand/mud up to 100 metres to the west of Hampton Pier. 3. The planned turbines are considerably larger than existing and if approval is given must be on the basis that they are of the same height."

Clare Gruar on behalf of Health Protection Agency
"At the scoping stage, the HPA requested that the applicant conduct the assessment of compliance with the referenced Wind Farm Position Statement, and to gather and present the information clearly, leaving no additional analysis necessary on the part of the HPA. The assessment should be clearly laid out, either as an identified section of a report which can be read in isolation or as a separate report. The applicant has not provided an identified section in their application; therefore the HPA response specifically related to its remit in non-ionising radiation and chemicals, is based on the information contained within the application documents. In respect of electromagnetic fields, as the proposed wind farm is located offshore, it is not expected to create a significant public health impact. The onshore cables do have the potential to create an impact; however, as these are the subject of a separate planning application, they are not considered any further here. With regard to chemicals, the nature of the proposal (including the construction, operation, and decommissioning of the onshore works) is such that its potential to lead to exposure to chemicals is limited. The applicant has assessed the likely impacts to air, water, and land quality during the construction and decommissioning of the onshore works. Through the setting and validation of development consent conditions, the IPC should ensure that the development does not lead to adverse impacts on public health. These comments are restricted to public health impacts relating to exposure to chemicals and radiation."

Manston Airport
"Due to the impact this proposal would have on the safety and efficiency of our operation Manston Airport must lodge a safeguarding objection. As you will be aware a new radar has recently been installed at Manston. Due to the location of the new radar the previously unseen Kentish Flats windfarm is now fully visible to our primary radar. The effects of windfarm clutter on primary radar are well documented. Kentish Flats is located in an operationally significant area for vectoring traffic into Manston. Once the new radar becomes fully operational this will entail controllers having to vector aircraft around the area to maintain a safe distance, increasing track mileage and fuel burn for our customers. The proposed extension would take the clutter closer to the final approach track. This makes it more difficult for controllers to maintain a safe distance between the clutter and any aircraft established on the final approach track and raises the probability of having to break aircraft off or take them on a sub optimal routing. Manston has investigated the possibility of creating a zone of mandatory carriage of a Secondary radar transponder (TMZ) as we have at London and Thannet. This has been ruled out by the regulators due to its close proximity to the final approach track. Also its proximity to the North Kent coast makes it an area easily accessible to light aircraft the owners of which would likely object to being mandated to carry a transponder even though it would enhance flight safety in the vicinity of the windfarm. At this time there are no other technical solutions that are proven and deployable that could mitigate the clutter, however we continue to work with the developer to explore potential mitigation solutions. The visibility of the Kentish Flats clutter on the new Primary radar creates an additional hazard for aircraft operating in the vicinity of Manston. Any extension of the area of clutter would not only exacerbate this problem but will adversely impact the safe operation of flights making an approach to the airport. We must therefore object to the proposed extension to the Kentish Flats windfarm."

London Array Limited
"1. We submitted some comments to Vattenfall the draft ES on 27th July 2011, and note that none of these have been addressed in the final ES. In Appendix 39, The Consultation Report, it states that the ES has been updated with the comments sent by LAL, but this does not appear to be the case, specifically: a. We requested in our response to the draft ES on 27th July, that Vattenfall confirm in paragraph 5.12.2 that they will take account of the additional cables that have been consented for London Array Phase 2 (Phase 2), which may be installed after the planned installation of the KFE cable(s). This has not been addressed. b. We requested that Vattenfall note in paragraph 20.4.3 that export cables from London Array Phase 2, which is consented, may be installed after the planned installation of the KFE cables. This has not been addressed. c. We requested that Vattenfall make reference in paragraphs 20.5.1 to 20.5.4 to London Array Phase 2. This has not been addressed. d. We suggested that whilst the Percival method for assessment is a widely recognised impact assessment tool for offshore wind farms, reference should also be made to specific COWRIE guidance on cumulative impact assessment (King et al. 2009: “Developing Guidance on Ornithological Cumulative Impact Assessment for Offshore Wind Farm Developers”). It may also be worth ensuring impact assessment recommendations from COWRIE are considered alongside the Percival method (Maclean et al. 2009: “A Review of Assessment Methodologies for Offshore Windfarms”). This has not been addressed within chapter 9 as suggested but we do note it’s inclusion within chapter 20. 2. We would like to note that the impact assessment and cumulative impact assessment on ornithology was not available within the draft ES, and this is therefore the first opportunity we have had to comment on this assessment. We have the following comments: a. We welcome the fact that London Array II is recognised as a fundamental part of the assessment and has been classed as a consented project, and that it was agreed that that RSPB and Natural England have recommended that the same disturbance buffers used for London Array have been used to assess displacement for KFE. We also agree with the displacement calculation method used in combination with the disturbance buffers for London Array. b. Table 9.22 gives London Array I as “consented”, this should be “under construction”. c. Please note that London Array Phase II is a consented project, regardless of the Grampian condition. Both Phase I and Phase II therefore need to be considered together and phase I should not be assessed on its own. d. We note that the wrong capacity size has been used for London Array Phase II. The correct capacity is up to 370MW. e. The area given for London Array I in table 9.23 and paragraph 9.11.9 upon which the interaction calculations are based is incorrectly given as 122km2, this should be 100 km2. f. We note that the interaction term does not consider Red Throated Diver mortality. The interaction is in effect displacement. g. We agree with the conclusion in paragraph 1.54 (appendix 9.2) that the impact of displacing divers across the remainder of the SPA would have negligible ecological consequences. 3. We would also like to comment on the HRA report. In para 2.1.4 and 2.1.5 Vattenfall state: “Vattenfall have not been able to obtain any final figures from London Array Ltd(LAL) with regard to London Array displacement and disturbance impacts on red throated diver and it is not clear when these will finally be available”. “If the London Array data becomes available during the examination of the Extension project, Vattenfall will then take a view as to its relevance in understanding and assessing the effects of the Kentish Flats Extension.” As advised by both DECC and DEFRA in 2009, an assessment will need to take place for all consented projects within the Outer Thames SPA. This has yet to be completed and it is our opinion that this assessment needs to be completed before any further project consents can be considered. Once the assessment of consented projects has been completed, which will include London Array Phase 2 as a consented project, we can make available information to inform an Appropriate Assessment for the proposed project. The comments from RSPB and JNCC would also point to there being insufficient evidence for the AA to be concluded."

Alan Gibson on behalf of Marine Management Organisation
"KENTISH FLATS OFFSHORE WIND FARM EXTENSION PROJECT BY VATTENFALL WIND POWER LIMITED IPC APPLICATION AND ASSOCIATED DOCUMENTS The MMO is an interested party for the examination of DCO applications for nationally significant infrastructure projects in the marine area. The MMO has received notice of such an application for Kentish Flats Extension (IPC ref: EN010036,). Please find below the MMO’s initial comments on this application. Please note these are only initial comments and the MMO reserves the right to make further comment on this application throughout the examination process. The MMO is interested in this project because it involves installing up to17 wind turbines, associated developments and cabling within the marine area. The MMO has made an initial assessment of the draft DCO and has the following comments on Schedule 2 for your consideration: 1. Page 19, paragraph 5(4). The MMO requests that the last line of this condition is amended to state: If the disposal of the arisings has not been assessed within the environmental statement a separate marine licence will also be required. 2. Page 19, paragraph 5(7). The MMO requests that this condition is amended to state that the audit sheet must be submitted for approval of the MMO at least one month prior to construction. Also to state that construction cannot commence until the MMO has provided written approval. 3. Page 20, paragraph 5(9). The MMO requests that this condition is amended to clearly state that the side scan sonar survey will cover the order limits and the transport routes of any vessel involved in the transportation of material which cannot be accounted for. 4. Page 22, paragraph 11(2). The MMO requests that this condition is amended to state that the pre-construction baseline report is submitted to the MMO for approval at least 4 months prior to the start of any licensed activities. It should also state that construction must not commence until the MMO provides written approval of the baseline monitoring report. 5. The MMO requests that the following condition be added to Schedule 2 of the DCO: The undertaker must submit a Decommissioning Plan at least 3 months prior to any planned decommissioning works. This plan must be approved in writing by the MMO prior to the commencement of any decommissioning works. The MMO has made an initial assessment of the Environmental Statement(ES) and the report to inform the Habitats Regulations Assessment. In the opinion of the MMO the ES identified and assessed all potential impacts. The ES document is comprehensive, and the Environmental Impact Assessment (EIA) included all the relevant receptors, pathways and potential impacts arising from the construction, operation and decommissioning of Kentish Flats Extension, alone and in combination to other developments. Yours sincerely Alan Gibson Marine Environment Team Marine Management Organisation"

Kent Wildlife Trust
"Impacts on the Red Throated Diver within the Outer Thames Estuary SPA due to disturbance and displacement Kent Wildlife Trust does not agree that the Kentish Flats Extension would not adversely affect the ecological integrity of the Outer Thames Estuary SPA either alone or in-combination with other plans and projects within the area. Post construction monitoring for the Kentish Flats Wind Farm shows there may be a significant displacement of birds within the site (94%), 500m, (83%) 1km (77%) and 2km (61%) if peak counts are used. This could signify an impact on 2.3% of the population. We do not feel that evidence has been provided to substantiate the conclusion that impact will be negligible. a) Although the surveys generally recorded small numbers of red throated divers, peak counts of 174 individuals were observed. Using peak counts 2.3% of the population would be impacted by the extension. b) Kent Wildlife Trust does not agree that the importance of this area relative to the SPA is low. Peak counts show that 2.3% of the recognised population were recorded within the study zone. We acknowledge that areas containing higher densities of red throated diver exist but the application site is part of the SPA and impact should be fully mitigated. c) Kent Wildlife Trust welcomes the appraisal of carrying capacity of surrounding habitat within Appendix 9.2 of the ES. However there is no analysis of in-combination impacts in relation to habitat availability and densities as a result of disturbance from all wind farms within the area. We do not agree that it has been proved that there will be no in-combination impact on the red throated diver from the proposed extension and other wind farms within the area. Analysis of the figures provided using the buffer model show that there will be an in-combination impact on 23.9% of the red throated diver SPA population within 1km of the wind farms with an in-combination impact of 20.9% within 2km. At present it is our view that there could be a significant impact if displacement over all wind farms is viewed in-combination. Due to the above concerns and the lack of mitigation in place to alleviate impacts Kent Wildlife Trust objects to the application. It is our view that disturbance has occurred within the Kentish Flats wind farm and is likely to occur in the Kentish Flats Extension. When viewed in-combination with other wind farms within the SPA it is possible that a significant overall impact on the SPA population will occur. Kent Wildlife Trust feels that a precautionary approach regarding in-combination impacts should be taken until such time as the London Array data is available. Impacts on Thornback Rays due to piling and electromagnetic fields We are concerned that no mitigation is proposed for the Elasmobranchs found within the development area. Of particular note is the presence of Thornback Ray for which the Outer Thames Estuary is of regional importance Rays have low fecundity and are slow to mature therefore any impact on these species spawning and nursery grounds should be mitigated. We note that further information has been provided within the final ES however due to the regional importance of Thornback Rays within the Outer Thames Estuary we feel mitigation for these species is essential. Spawning times should be avoided for piling activities and measures to reduce the magnetic fields wherever possible incorporated. Response to the Draft Habitats Regulations Assessment Kent Wildlife Trust wishes to clarify that contrary to the statements within the reports we did respond to the Draft Habitats Regulations Assessment on the 3rd August 2011 and our response can be found in Appendix 3 of the HRA Report."

Dover District Council
"I refer to the request for comments in respect of the adequacy of the consultation and publicity undertaken by the developer at the pre-application stage. I note that we are outside the response date, and apologise for the delay, but hope that our comments cam be noted. I can confirm that Vattenfall did consult with us on 20th January 2011, providing a copy of the notice of the proposed development. On 20th April 2011, a further letter was received accompanied by a hard copy of the non-technical summary of the ES and a cd containing the fully draft ES. It is considered that the consultation carried out by Vattenfall on these occasions met the requirements set out in Sections 42, 47 and 48 of the Planning Act 2008. Whilst the Local Planning Authority did not respond to the consultations, as it was not considered necessary, we trust that our comments to the IPC in our letter dated 24th November 2011 in respect of locations within the Dover District which should be included in any Landscape and Visual Impact Assessment will be taken into account in the forthcoming application."

The Environment Agency
"The Environment Agency has reviewed the above application and accompanying documentation submitted with Vattenfall’s letter of 28 November 2011. The matter that initially concerned us – the potential impact on bathing water quality during construction works – is addressed to our satisfaction within the environmental statement supporting this application. Provided that appropriate conditions are imposed on the development consent order to ensure measures are taken to prevent an unacceptably adverse effect on bathing water quality as outlined in the environmental statement, we do not expect to have any objections to the proposal. We will consider further the nature of the conditions that we would suggest should be imposed on the development consent order and advise the Infrastructure Planning Commission of our views in due course. (It may be that an overarching condition requiring the works to be carried out in accordance with the submitted application and supporting documentation would be sufficient). We reserve the right to add any further comments at the written representation stage. Informatives: 1. We have been previously advised the applicant that the onshore works associated with this scheme will be dealt with under a separate application to Canterbury City Council. 2. The ‘West Brook’ flows in a generally Northerly direction in the vicinity of these proposed works; this is a designated ‘main river’ and under our jurisdiction for the purposes of its land drainage functions. Written consent from us is required under the Water Resources Act 1991 and associated Byelaws prior to the carrying out of any works whatsoever in, over, or under the channel of the watercourse, on its banks or within eight metres of the top of the bank (or within eight metres of the landward toe of any flood defence, where one exists). For maintenance reasons, we will not normally consent works which obstruct the eight metre Byelaw Margin. 3. Any other watercourse or drainage ditch along the existing/proposed cabling route would be classified as an ‘ordinary watercourse’ and would not be maintained by us or by an Internal Drainage Board. In the absence of any express agreement to the contrary, maintenance is the responsibility of the riparian owners. However, any culvert, diversion, weir, dam, or like obstruction to the flow of the watercourse requires our consent and/or Internal Drainage Board, under the Land Drainage Act 1991. For nature conservation reasons, we seek to avoid culverting and will not normally consent such works except for access. If you have any queries concerning our response, please do not hesitate to contact me"

Natural England
"This letter contains Natural England’s initial representations on the above documents submitted to and accepted by the IPC for the Kentish Flats OWF extension. These comments reflect our pre-application discussions with the developers and Natural England acknowledges the time and effort taken by them to incorporate our comments and the various opportunities for feedback they have provided. In regards to the Environmental Statement, NE feel that our concerns on the draft ES were discussed at length with the developer and we have no comments to make at this time. We do however note the revisions within the final submitted documents. The aim of this letter is to draw your attention to the HRA and our continuing concerns. Natural England have no outstanding concerns with the main body of the HRA Report or Appendix 1: No Significant Effects Report, as our previous comments appear to have been incorporated within the revised document. As discussed during our telephone conversation in December, our main concerns lay with Appendix 2 and as requested this letter lays out those concerns. This letter is intended to provide more clarity on our position and hopefully help inform you of the background prior to further examination of the application. Overall comments on revised Appendix 2. At present Natural England are still unable to sign off this Appendix of the HRA report as supplying sufficient (clarity of) information to inform an AA. We do note the revisions to the document in line with ours and the RSPB’s comments, however there are several outstanding points that we feel still need to be addressed. Overall our position that we consider the conclusion that the Kentish Flats windfarm extension would not adversely affect the ecological integrity of the Outer Thames Estuary SPA, either alone or in combination may be correct, still holds. However, Natural England considers that the evidence provided in the draft HRA we commented on was not sufficient to support that conclusion. In particular, evidence regarding the magnitude of displacement needed to be re-examined and figures for collision mortality needed to be provided. The comments below reflect our pre-consultation advice. • NE felt there needed to be greater clarity on how the displacement figures have been calculated using the JNCC data. The alternative means of calculating displacement using the actual survey data from KF1 and the extension (as in the earlier draft) ought to be presented too for comparison subject to re-calculation in line with the observed percentage density reduction figures around KF1 (as recommended before). Although we acknowledge that cumulative collision is unlikely to give rise to an adverse impact, an assessment should ideally be informed by the actual numbers of predicted collisions at each windfarm. • There also needs to be much greater clarity on how any displacement interaction figures have been calculated, as it is not clear how reliable this new figure is. • Thus, in addition to providing these new JNCC database derived figures, the report should also present figures based on the pre-construction KF1 survey data and the observed post-construction reductions in densities at varying distances out to 1km (and acknowledge that use of 1km is for comparative purposes only and likely to underestimate displacement out to 2km and perhaps beyond). • On the basis of the information provided there are a range of possible displacement interaction percentage values for the Kentish Flats extension alone: o ranging from 0.4% (using JNCC database and 100% and 50% displacement figures within the OWF and 1km ) through 0.5% - 1.4% (mean winter counts at KF extension and 2km buffer), 1.5% - 2.3% (peak winter numbers at KF extension and 2km buffer) to 2.7% (peak winter number within 2km of KF extension and assuming 100% displacement out to 2km). o Given that the quoted SPA population is an estimate based on the mean of the peak estimate of numbers of birds within the boundary for each winter, the use of peak numbers recorded within the Kentish Flats extension may be the most appropriate way to calculate the percentage interaction. • Therefore, the figures are 1.5% - 2.3%, against an impacted baseline as some birds will already have been displaced in 2009-2011 from parts of this survey area due to the existence of KF1. While this is lower than the 3.1 – 3.4% that was deemed acceptable at London Array Phase 1 alone, we are now dealing with an in combination situation where the KF extension impact will be on top of that which will arise from LA Phase 1. o 12.6% was deemed unacceptably risky in the London Array AA. With the figures currently given in Table 4, excluding Greater Gabbard and Galloper and Thanet (as outside the SPA and LA Phase 2 due to Grampian conditions preventing its construction unless no adverse impact is established) we have an in combination figure of 8.2%, of which the Kentish Flats extension accounts for 0.4% (c 5% of the total). This may constitute a likely adverse in-combination impact (albeit largely due to LA Phase 1). In conclusion, whilst we believe that this proposal is unlikely to have an adverse effect on the SPA alone (or in combination (with the London Array caveat above) we do need to have the evidence to fully support this before we can sign off Table 2 in the HRA Report. I hope that this letter has provided more clarity in regards our concerns and we will be happy to discuss the points raised within this letter."

SSE Pipelines Ltd
"I am writing to confirm that SSE Pipelines Ltd do not have any comments to make regarding the above proposal."

Andrew Riches
"Whitstable is famous for the native oyster. When the original windfarm was proposed, the site was moved further north so as to avoid building on prime oyster grounds. The proposed extension is now to be on this ground. Since the original wind farm (Kentish Flats) was built the ground within its area has become infested with starfish. The starfish kills all types of shellfish including small oysters. To make matters worse when starfish numbers build up on the sea bed the ground becomes unworkable (unfishable). The wind farm power cables appear to attract star fish to the area. Although there is no scientific evidence to support this claim. The fear is that starfish will spread further south when the extension is built and prime oyster ground will be lost. Also in the future fishing within the windfarm boundaries would be stopped, meaning a loss of fishing ground, regardless of the fishing method. As the extra cables will have to cross the London Array cables at certain points this means that rock dumping will be used to cover the cables at these points amounting to the loss of more fishing ground. Oyster fishing in the winter is an important part of the small boat fishery at Whitstable."