Mooir Vannin responds to concerns raised by Manx Wildlife Trust

1. Several of the baseline ecological assessments are inadequate and do not allow for an appropriate assessment of potential ecological impacts (most notably the benthic and marine mammal assessments).

Baseline ecological assessments are adequate, follow industry standard best practice methodology and have been consulted on extensively with MWT and other key stakeholders for almost three years. As part of the assessment, the Applicant has sought to apply embedded mitigation in the initial design – such as committing to piling mitigation in the forms of soft start and noise abatement technologies where necessary – to ensure significant impacts are not likely. We will continue to work with both Defa and MWT to ensure potential impacts are mitigated appropriately before construction begins should the wind farm be consented.

1. Contrary to the “uniquely Manx” approach originally proposed by the Applicant, ecological impacts have often only been assessed at a very broad scale, including the use of international scale biogeographical regions. This dilutes the local-level impacts. Explicit conclusions of impact assessments at the Manx national level are therefore required throughout:

The Applicant has carried out its ecological assessments with appropriate consideration of the Manx jurisdiction and scale of impact, where it is relevant to do so. In some instances, however, it is simply not possible or aligned with ecological best practice to suggest there is a distinct Manx population made up of wide ranging and mobile receptors. This does not align with the scientific evidence base which must underpin the assessments. Where it has been possible, the Applicant has presented the potential impacts to more localised populations. For instance, the ornithological assessments are undertaken at a wide population scale, but the impacts are then assigned to specific Isle of Man colonies where these exist.

2a) Government policy is that adverse ecological impacts need to be mitigated. This can only be achieved through an Environmental Impact Assessment at the national Manx scale. However, a robust framework of Manx-specific guidance for ecological assessments currently does not exist, and much of the current legislation broadly appropriates British environmental regulations without taking into account the Manx context. Such a framework would have made this process more straightforward and effective.

The Applicant has consistently applied the mitigation hierarchy since the outset of its development of Mooir Vannin. All parties agree that there is no directly applicable Manx-specific guidance for ecological assessments for an offshore wind farm. As such, the Applicant has adopted best practice from the UK (an established offshore wind market). This accords with the Isle of Man Strategic Plan 2016, which expressly confirms current practice from England and Wales will be used for EIA, and that where novel or unusual matters arise it will often be appropriate and helpful to have regard to legal judgments or advice published in the UK.

2b) The issue of evaluating how something is going to affect wildlife populations specifically in the Isle of Man is important. We believe that the Manx ecological impacts have to date been understated by the Applicant. By way of example, the Applicant’s annual expected number of bird deaths is 660 individual birds per year, including the modelled deaths of 466 auks (the seabird group which includes locally amber-listed Guillemot, red-listed Razorbill and redlisted Puffin). In a Manx context, for Guillemot, the modelled 309 annual deaths represent around 21% of the known Manx over-wintering population. For Razorbill, the modelled 149.5 annual deaths is actually significantly greater than the entire Manx over-wintering population. We therefore do not agree that such mortality can be insignificant in a Manx context.

The Applicant does not agree that ecological impacts have been understated. A precautionary approach to the presentation of results and the resultant assessment has been applied throughout. In setting out MWT’s view on bird impacts, MWT have focussed on the upper end of the spectrum without reference to the lower values, when Statutory Nature Conservation Bodies (SNCBs) in other jurisdictions refer to the range. It is not appropriate to consider the numbers quoted against a Manx population because they represent regional population numbers and colonies outside the Isle of Man, only present a worse case and ignore the range of evidence-led numbers.

To use the guillemot example given by MWT, the 309 displacement mortalities were derived using the worst-case 70% displacement/10% mortality estimate. However, when using the 50% displacement/1% evidence-led estimate favoured by the Applicant. this reduces to 22 annual mortalities, an increase in baseline mortality of just 0.004% when considered in the context of the biogeographic population size of 4,125,000 individuals. The Applicant has presented these impacts apportioned to Isle of Man colonies in APP-087, following the NatureScot apportioning tool, which is recommended by English, Welsh and Scottish SNCBs. Using the 70% displacement/10% mortality estimate, the total annual guillemot mortalities in the Isle of Man is 15.5. Using the more appropriate 10% displacement/1% mortality estimate, this reduces to 1.1 individuals per year.

1. By stating only insignificant impacts across all areas of ecology, the Applicant has avoided the requirement to suggest suitable mitigation. This is still required under several Manx policies, including Environment Policy 4 of the Strategic Plan (which sets planning policy best practice in the absence of specific marine frameworks), the Island’s Biodiversity Strategy and the Climate Change Act 2021.

Overarching response

The Applicant has embedded mitigation into the design of the project and committed to other mitigations via a series of secured and detailed management plans (for example soft start and ramp-up procedures which limit noise generation and reduce impacts upon marine mammals (see Outline Underwater Noise Mitigation Strategy for embedded mitigation measures)). The ecological assessments consider the embedded mitigation in the assessment methodology, which leads to a conclusion of non-significant effects. This demonstrates the mitigation identified is appropriate, robust and effective.

Notwithstanding the Applicant’s conclusion of non-significant impacts for ecological receptors, the MIC application currently being examined includes a commitment to a Biodiversity Strategy. This secured Management Plan sets out the approach to provide additional pre-, during and post-construction monitoring across a range of species and habitats, in addition to a significant commitment to deliver meaningful, positive biodiversity initiatives in conjunction with key Isle of Man environmental and biodiversity organisations. Should the project be granted consent we look forward to working with those organisations to ensure the project delivers positive biodiversity net impact on the island and in the surrounding waters.