Verbatim copy of oral submission to public hearing about Sealink plan
Kent Wildlife Trust is one of several landowners at Sandwich and Pegwell Bay, having bought and managed the site since 1987. The mosaic of habitats from saltmarsh, mudflats, sand dune systems and grazing marsh sits at the heart of the nominated World Heritage Site, the East Atlantic Flyway, supporting the millions of migratory birds that visit the site each year. Home to Kent’s largest seal population, it is quite simply, one of the most sensitive and ecologically valuable coastal systems in the county.
The beating heart of an internationally protected ecosystem
Given this significance, it is deeply concerning how Pegwell Bay and Minster Marshes have been selected for Sea Link. They are the beating heart of an internationally protected ecosystem. An ecosystem that naturally stores carbon, absorbs floodwaters and buffers the coast, yet these habitats now face irreversible harm in the name of addressing the very crisis they help us withstand.
Reasonable alternatives dismissed early
Overall, the DCO documents present what is, in effect, a retrospective justification for a pre-determined decision to select Pegwell Bay and Minster Marshes. Reasonable alternatives were dismissed early, and crucially, were never put before the public. This is a procedural failing, but it is also a strategic one: the project is being forced into the most environmentally sensitive location because the Applicant did not allow the process to genuinely consider anything else.
Relies on incomplete species data
That failure is made even more serious by the fact that the environmental baseline the project relies upon is incomplete. Almost every protected species assessment is based on a single survey season, with some relying entirely on desk-based data. No baseline habitat assessment has been conducted for the proposed golden plover mitigation site, meaning the Applicant cannot guarantee that it is even suitable. What we do know is that the site sits only a stone’s throw from where we are sitting now, directly beside the A256 , a road identified in the Applicant’s own Noise Chapter as one of the most dominant and persistent noise sources in the area.
Previous cabling damaged the saltmarsh
We also cannot ignore the history of the site. With National Grid’s previous cable, Nemo Link, trenchless techniques were promised and then abandoned, causing catastrophic and long-lasting damage to the saltmarsh, damage that has still not recovered and can be seen today. Sea Link’s DCO acknowledges open-cut trenching may be required – including preferred open-cut trenching through intertidal mudflats, a Priority Habitat and foundation of the SPA’s qualifying bird assemblages. Therefore, it is concerning that the Applicant is not taking the same caution at the Kent landfall site, as they are at Suffolk, where trenchless techniques will be used to avoid all intertidal habitats.
A third interconnector from Scotland’s windfarms
Crucially, Sea Link is not the last proposed project to effect Sandwich and Pegwell Bay. National Grid’s Beyond 2030 Strategy already identifies Pegwell Bay as the preferred landfall for a third interconnector project to connect Scotland windfarms to Kent – a project that has been omitted from Sea Link’s cumulative impact assessment despite its clear relevance as a foreseeable project with overlapping environmental pathways. We are witnessing the gradual transformation of an internationally protected ecosystem into a default landing point for high-voltage infrastructure. As with the Suffolk side, the Kent coastline is being treated as a “zone of sacrifice” simply because of its geographical convenience.
This is not strategic planning. It is incremental erosion of a designated site – death by a thousand cuts, delivered through separate projects that are chipping away at the habitats this ecosystem depends on.
There are alternative landfall options
Kent Wildlife Trust fully supports the transition to clean energy – but you cannot destroy the environment to save the environment. Climate change is the defining challenge of our time, but the solution cannot be to erode the very ecosystems that protect us from its impacts. There are alternative landfall options. There are alternative converter station sites. And there are alternative strategic approaches that could avoid this internationally protected landscape entirely.
Pegwell Bay and Minster marshes are not suitable locations for this project
The Examining Authority is being asked to accept a project whose risks remain unclear because the evidence base remains incomplete. We will provide the technical detail in our Written Reps, but here today our message is simple: the risks are too great, the evidence too thin, and the consequences irreversible. Pegwell Bay and Minster Marshes are not suitable locations for this project. They are too important, too fragile, and too integral to Kent’s ecological and climate resilience to be treated as expendable.
In closing, Kent Wildlife Trust urges the Examining Authority to scrutinise this application with the utmost rigour. We ask you to ensure that alternatives are properly explored, that environmental risks are fully evidenced, and that no project proceeds unless it can be shown, beyond reasonable scientific doubt, that the integrity of these protected sites will be preserved.”
