Executive summary
Energy UK warmly welcomes the updated HRA guidance. This new guidance is a welcome move towards more proportional implementation of the Habitats Regulation, based on solid ecological evidence. However, this guidance is not without gaps in certain areas and requires greater definitions in others. A critical issue is on how various bodies will implement this guidance on the ground, including SNCBs. Key questions such as de minimis thresholds need further resolution, and a big question mark remains over the rollout of this guidance to offshore waters beyond 12 nautical miles. This area remains a priority for Energy UK going forward.
If you would like to discuss this response in further detail with Energy UK and its members, we would welcome further engagement.
Chris Friedler
Policy Manager (Environment and Planning)
chris.friedler@energy-uk.org.uk