NRW admits no EIA on Hinkley mud dumping, against rules

The NRW up to recently stated the EIA for dumping had been covered in the EIA for the Power Station and Jetty development in Somerset, which England's Environment Agency covered, but this was contradicted by CEFAS’s statement of 2013**. 

Nevertheless the NRW (wrongly) issued the 2014 license. Now they rely on a CEFAS officer's opinion that "an EIA was not required" . NRW's own rules say that an EIA is always required for projects within an European conservation site, as is the Severn Estuary.”

The NRW's change of EIA excuse is in the Chairman's letter to FOE of 29 August, extract here:

Ein cyf/Our ref: CH18-043
Ty Cambria / Cambria House
29 Heol Casnewydd / 29 Newport Road
Caerdydd / Cardiff
CF24 0TP

29 August 2018
Marine Licence 12/45/ML
Thank you for your letter dated 14th August 2018, regarding the licence to dispose of marine sediment into the Cardiff Grounds disposal site. You raise various concerns which I have responded to in turn, as follows:

1. Neither EIA or HRA were carried out of dumping this ‘capital dredging’ material in the estuary. NRW officers in 2013 believed EIA+HRA had been covered by the developer’s power station EIA, but CEFAS’s report says explicitly not**.

The Cefas experts which you quote at the bottom of your letter explicitly state that an HRA would not be expected, although Cefas would defer to NRW’s opinion, and an EIA was not required for these works. However, we did undertake an HRA as part of this licence determination.

** The Centre for Environment, Fisheries and Aquaculture Science (CEFAS) were consultants for Natural Resource Wales, for assessing the radioactivity in samples

Their 2013 assessment (Shelley Vince) MCU12/45  23 April 2013, said

 Requirement for EIA26. An Environmental Statement was produced for the Hinkley Point C Nuclear Power Station IPC application. This ES has been provided with the disposal application however this does not specifically cover the disposal of material to Cardiff Grounds but does provide some useful information to support the application. I am of the opinion that an Environmental Impact Assessment is not required for these disposal works. 

The "opinion" given in the final sentence was not a decision by a competent authority and not backed by the full CEFAS report.  But NRW now rely on this opinion for exempting the project from EIA.