“Planning Inspectorate Reference: EN010137 Text of Relevant Representation from the Royal Society for the Protection of Birds (RSPB) 6 May 2024 INTRODUCTION The UK is of outstanding international importance for its breeding seabirds and wintering marine birds. As with all Annex I and regularly migratory species, the UK has a particular responsibility under the Birds Directive to secure their conservation. Their survival and productivity rates can be impacted by offshore windfarms directly (i.e. collision) and indirectly (e.g. displacement from foraging areas, additional energy expenditure, potential impacts on forage fish and wider ecosystem impacts such as changes in stratification).   The RSPB supports the deployment of renewable energy projects, providing that they are sited in appropriate places and designed to avoid potential adverse impacts on wildlife. We are grateful for the constructive pre-application discussions that have taken place with Mona Offshore Wind Farm Limited in respect of this proposal, particularly through the Evidence Plan process. As set out in Searle et al (2023), assessing impacts of offshore windfarms and other renewables developments is inherently uncertain. This uncertainty is propagated throughout the impact assessments, as there are not only direct impacts, but ecosystem wide impacts that can change, for example, the abundance and availability of prey. Multiple data sources and modelling techniques are used to capture a simplified version of reality. They do not fully capture the complexity of seabird behavioural or demographic processes in a dynamic marine environment.   Not recognising these uncertainties risks poorly informed decisions being made. Furthermore an underestimation of impacts will have repercussions when consenting later offshore wind development. If a precautionary approach is taken from the beginning, the likelihood of irreversible damage occurring is reduced even whilst our knowledge base is incomplete, and modelling improves.   The precautionary principle requires the Applicant to demonstrate with scientific certainty that something would not be harmful. The concept of something being overly precautionary dismisses the inherent uncertainty in modelling and overlooks the simplistic version of reality that the modelling captures.   While methodological concerns remain, progress towards resolving a number of issues was made during the pre-application discussions for this project. We continue to have significant concerns relating to the project’s in-combination and cumulative collision risk and displacement impacts including their assessment. The RSPB has engaged with the Applicant throughout the pre-application stage to provide our constructive advice as the Applicant has developed its project. We will continue, as far as practicable, to seek to engage with the Applicant throughout the Examination period. However due to the number of offshore wind farm project applications coming forward during 2024 we will face significant demands on our limited capacity. As a consequence, we will not be able to engage with any hearings associated with this application and will engage through written communications only and limited to when capacity allows. OFFSHORE ORNITHOLOGY IMPACTS - SUMMARY OF RSPB POSITION We have significant concerns regarding the findings of some of the impact assessments. As a result of the methodological concerns, set out below, the RSPB considers that the impacts have not been adequately assessed and, as such consider Adverse Effect on Integrity (AEOI) cannot be ruled out beyond reasonable scientific doubt for collision impacts arising through the project alone and in combination with other projects for Manx shearwater at the following Special Protected Areas: - Copeland Islands SPA - Irish Sea Front SPA - Rum SPA - St Kilda SPA - Glannau Aberdaron ac Ynys Enlli/Aberdaron Coast and Bardsey Island SPA  - Skomer, Skokholm and the Seas off Pembrokeshire/Sgomer, Sgogwm a Moroedd Penfro SPA AEOI cannot be ruled out beyond reasonable scientific doubt for impacts arising through collision and distributional change arising through the project in combination with other projects on a range of species/SPA combinations We also consider that the Assessment has not fully considered Ecosystem impacts arising from the proposed development and has not properly accounted for potential for population scale impacts to be magnified through effects of Highly Pathogenic Avian Influenza. MANX SHEARWATER BASELINE CHARACTERISATION Manx shearwater can be active throughout the day and night, with different levels of activity at different times. Such activity is variable, for example, for birds tracked from Skomer, diving occurred during the day and peaked in the evening (Shoji et al., 2016), while nocturnal foraging was observed from tracking of birds from High Island, Ireland (Kane et al., 2020). These diel variations in activity mean that the somewhat limited amount of time digital aerial surveys (DAS) were carried out is unlikely to properly characterise the activity of Manx shearwater at the Application site, (only one of the 24 survey flights for the baseline characterisation started before 0700). For these reasons the RSPB does not have confidence in the baseline densities of Manx shearwater presented, and therefore it is impossible to make any conclusions as to the significance of impacts. Issues of detectability are not only whether the nocturnal and crepuscular nature of some of the at-sea behaviours means that they are not captured by the survey flights but also whether the size and flight characteristics of the species make them harder to detect. Evidence that the surveys are recording Manx Shearwaters should not be taken as evidence that all of this species occurrence within the footprint during surveys has been detected. Deakin et al., 2023 highlight a need for experimental validation of these potential biases in aerial survey methods, including detectability, identification and diel variation. Without addressing these concerns, we are unable to rely on the densities of Manx Shearwater presented in the assessment and therefore unable to reach conclusions as to the significance of adverse impacts. POTENTIAL IMPACTS ARISING THROUGH COLLISION In respect of Manx shearwater, the Applicant has concluded no adverse impact arising through collision with rotating turbines. We disagree that such a conclusion can be reached because the manner in which the calculations have been carried out do not reflect potential behaviour in the vicinity of turbines. Fundamental to the consideration of collision risk for this species is the extent to which nocturnally active seabirds, such as Manx shearwaters, may be attracted to the illuminations required for turbines, support vessels and the construction or expansion of ports. Such attraction will cause behaviour change, which could in turn increase collision risk, for example if birds fly higher when attracted to lights. There is abundant evidence of light-induced disorientation of Manx shearwaters. This evidence includes the grounding of fledglings in lit areas (Miles et al., 2010) and collision with lighthouses and other illuminated structures (Guilford et al., 2019, Archer et al., 2015). If light-induced disorientation leads to individual birds circling the navigation lights on the nacelle or tower of turbines for protracted periods (as has been reported for birds disorientated by lighthouses or gas flares) the probability of collision with turbine blades or other surfaces is vastly increased. Alongside this increased collision risk, the energetic costs of attraction and disorientation may be sufficient to impact on long term survival and the ability to successfully rear young. METHODOLOGY FOR ASSESSMENT OF CUMULATIVE/IN-COMBINATION IMPACTS The RSPB recognise the difficulties with carrying out a full in combination assessment for a number of species SPA combinations because of the difficulties in obtaining historical data and the limitations in how it was collected and analyses. Regardless of these difficulties, it is important that such an assessment is carried out with consideration of these sites and Natural England have produced what we consider to be a practical and pragmatic solution, while fully acknowledging that it is imperfect; less so for displacement than collision risk but both are to a greater or lesser extent indicative of the potential scale rather than absolute quantification of impact. While it is acceptable for the Applicant to present alternative methodologies, it would be preferable for the outputs to be presented alongside those obtained following the recommendations of the Statutory Agencies. The RSPB are particularly concerned in regard to in combination impacts in relation to Great Black-backed Gull at the Isles of Scilly SPA. Great Black-backed Gull breeding numbers (AON) declined by 52% in the UK between the Seabirds 2000 and Seabirds Count censuses (Lewis, 2023), although the majority of decline happened in Scottish colonies. However, a further decline was recorded by surveys carried out in response to the outbreak of Highly Pathogenic Avian Influenza (HPAI) Tremlett, et al., 2024. The total number of Great Black-backed Gull AONs recorded across all sites surveyed in 2023 decreased by 20% compared with the pre-HPAI baseline count for these sites, and a 32% decline was recorded in the Isles of Scilly SPA. ECOSYSTEM IMPACTS RSPB Cymru would welcome an inclusion consideration of the potential wider ecosystem impacts that may arise through the construction and operation of the wind farm. These could occur, for example, through changes in water column stratification arising from the presence of the wind farm ultimately altering the availability of prey to seabirds. HIGHLY PATHOGENIC AVIAN INFLUENZA The current H5N1 strain of Highly Pathogenic Avian Influenza (HPAI) has affected UK wild bird populations on an unprecedented scale since it was first recorded in the country in Great Skuas in summer 2021, with seabirds and waterfowl particularly affected. The extent of reported mortalities attributed to HPAI in the UK and across Europe in 2022 demonstrated that HPAI had become one of the biggest immediate conservation threats faced by multiple seabird species, including some for which the UK population is of global importance. Many species impacted by HPAI are of conservation concern in the UK, and the outbreak comes on top of widespread declines reported by the latest seabird census. It is currently unclear what the population scale impacts of the outbreak will be, but it is likely that they will be severe. This scale of impact means that seabird populations will be much less robust to any additional mortality arising from offshore wind farm developments. It also means that there may need to be a reassessment of whether SPA populations are in Favourable Conservation Status. With such uncertainty as to the future of these populations, there is the need for a high level of precaution to be included in examination of impacts arising from the proposed development.  The RSPB do not consider that these concerns have been adequately considered in the Assessment. Finally, the RSPB reserves the right to add to and/or amend its position in light of changes to or any new information submitted by the Applicant. ”