Royal Society for the Protection of Birds
"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 responsibility under the Conservation of Habitats and Species Regulations 2017 (as amended) 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 Morgan Offshore Wind Farm 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. The RSPB have significant methodological concerns with the Applicant’s assessment, despite progress towards resolving a number of issues being made during the pre-application discussions for this project. As such, we are unable reach conclusions with regard to the significance of predicted impacts and have significant concerns relating to the project’s in-combination and cumulative collision risk and displacement impacts. This relevant representation outlines the RSPB’s position on the offshore ornithology impacts of the Morgan application. 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. Project alone – RSPB AEOI conclusions We are unable to reach conclusions with regard to AEOI on Manx shearwater in relation to the following Special Protection Areas: • Irish Sea Front SPA • Copeland Islands 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 • Rum SPA • Isles of Scilly SPA • St Kilda SPA Project in combination with other plans and projects – RSPB AEOI conclusions We conclude there will be an adverse effect on site integrity on the following features of the Isles of Scilly SPA • The impact of collision mortality on the Great Black-backed Gull (GBBG) population 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 due to methodological concerns as to how historical data were incorporated into these. We have also noted that the Morecambe Offshore Wind Farm application documents have been published recently and that they explore the issue of in-combination impacts on, inter alia, the Herring Gull and Lesser Black-backed Gull (LBBG) features of the Morecambe Bay and Duddon Estuary SPA and the LBBG feature of the Ribble and Alt Estuaries SPA. They go on to consider, on a without prejudice basis, possible compensation measures in relation to LBBG for both SPAs. The RSPB will need to consider the Morecambe Offshore Wind Farm application documents in detail and what, if any implications, they may have for the Morgan Offshore Wind Farm. 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. IMPACT ASSESSMENT – METHODOLOGICAL CONCERNS The RSPB’s key concerns with the impact assessment relate to: - Manx Shearwater: Baseline characterisation and Potential Impacts arising through collision - Gannet: the application of a macro-avoidance correction factor to baseline densities for collision risk modelling - Flight speeds used as parameters in collision risk modelling - Methodology for assessment of cumulative/in-combination impacts - Ecosystem impacts - a lack of consideration of impacts compounded by 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. GANNET: THE APPLICATION OF A MACRO-AVOIDANCE CORRECTION FACTOR TO BASELINE DENSITIES FOR COLLISION RISK MODELLING The Applicant has applied a reduction of 70% to the baseline densities inputted into the gannet collision risk modelling in order to account for macro-avoidance, in APP-055. This approach follows suggestions in Cook (2021). The current evidence of a strong macro avoidance of wind farms by gannets, established from observed behaviour, is almost entirely derived from non-breeding birds (Cook 2021). The evidence for macro avoidance during the breeding season is limited with the exception of a study of gannets breeding on Helgoland in the German North Sea. However, it is unclear from this study what the breeding status of the tracked birds was, or how their behaviour differed from what would have been expected pre-construction as two of the three wind farms were already operational during the first year of tracking. What the study does clearly show is that breeding gannets do fly through offshore wind farms, often showing no avoidance behaviour at all. While some tracks show clear avoidance others do not and may even show attraction to the wind farm. In the Cook (2021) report that suggests the application of macro avoidance to baseline densities, the suggestion is based on reviews that do not include this German tracking study, although it does acknowledge that it shows clear differences between individuals in relation to their response to wind farms. The previous gannet recommended avoidance rate was based on ‘all gulls’ data because no gannet data were available. The evidence of macro avoidance of gulls in response to wind farms is equivocal, so this rate was only calculated from ‘within wind farm’ avoidance. As gannets can show macro avoidance it therefore was suggested that this was applied to the baseline densities, and then collision risk modelling was carried out using the ‘all gull’ avoidance rate, so effectively applying avoidance twice. Notwithstanding the above, the RSPB does not agree with the approach for two reasons. Firstly, it does not take into account the likely seasonal variation in macro avoidance as described above. Secondly, by basing the ‘within wind farm’ avoidance rate on the ‘all gull’ rate, it assumes that gannets will have the same ‘within wind farm’ reactive flight response as gulls. This assumption is very unlikely to be met, as gannets have much lower flight manoeuvrability than gulls. This will result in a lesser ability to make rapid reactions and consequently have a greater risk of collision. This should be reflected in the ‘within wind farm’ avoidance rate if any further changes are to be made. Any evidence of macro avoidance should also be seen in the context of recent work in Belgian offshore windfarms that has shown potential habituation to the presence of turbines. This effectively results in lower macro avoidance and so an elevated risk of collision. It is also important to acknowledge that corpses of Northern Gannets with injuries consistent with collisions with offshore wind farms have been recovered (Rothery et al., 2009), and the imperfect detection of these corpses indicate that there may be many more. Due to these concerns with the Applicants application of additional macro-avoidance the RSPB are concerned that the predicted Gannet mortalities arising from collision are not robust, and therefore cannot come to any conclusions with regard to any adverse effects on site integrity. FLIGHT SPEEDS USED AS PARAMETERS IN COLLISION RISK MODELLING The Band Collision Risk Model requires parameterisation with the characteristics of potentially impacted birds and of the turbines. The bird characteristics include flight speed, and the model has been shown to be highly sensitive to variation in this parameter (Masden et al., 2021). Flight speed will be influenced by a wide range of variables including time of year, sex, age, weather, and behaviour and therefore also vary with location. This means that models using a single generic value for flight height and speed incorporate errors associated with variability and uncertainty. In the assessment of impacts arising from direct mortality through collision with the rotating turbine blades, the Applicant has gone against the advice of Natural England, as well as other SNCBs and the RSPB, and parameterised the collision risk model with flight speeds obtained from Skov et al. (2018). This reported on a study which estimated flight speed for some species through the manual use of rangefinders by observers on turbine platforms of an operational wind farm. The study was hampered by being carried out only at two turbines at a single site, observations were skewed toward the non-breeding season and the study did not include consideration of the potential biases arising from the use of rangefinders. These include selection bias of the observers’ picking targets, bias toward good weather conditions, (both to access the turbines and to operate the rangefinder), bias arising through difficulties in target locking in the view finder and lack of calibration and validation in an offshore environment. The results of the study have not succeeded in being published in a peer reviewed scientific journal. Furthermore, the Applicant has used these flight speed without amending the avoidance rate used in the collision model. This is problematic for two reasons. Estimates of avoidance rates are sensitive to many of the parameters that CRMs are sensitive to, including flight speed. The avoidance rates presented by Ozsanlav-Harris et al. (2023) calculated avoidance rates using the Band collision risk model, parameterised with the SNCB recommended flight speed. As a consequence, those Avoidance Rates are only specific to modelling carried out using the same flight speed parameter. If different flight speed are to be used, the calculations of avoidance rate would need to be re-run using the different flight speeds. Secondly, Avoidance Rate is not simply a quantification of avoidance behaviour in the vicinity of turbines. They are a correction factor which refers, in part, to the avoidance behaviour of a bird but that also includes general elements of error (both in terms of errors in the model itself and in relation to the input parameters). As such, any change in the model parameters, such as flight speed, will require amendment of the Avoidance Rate. While the Applicant has presented results using model parameterised with both the SNCB recommended flight speeds and their own in the Collision Risk Modelling Technical Report, it is unclear whether this the SNCB recommendation have been followed in the predicted mortalities taken forward to the Information to Support and Appropriate Assessment. For these reasons, the RSPB does not have confidence in the predicted mortalities arising through collision for Gannet, Kittiwake, Lesser Black-backed Gull, Herring Gull and Great Black backed-Gull. 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. The Applicant has not included these recent counts in their assessment and for reason given above, we cannot rely on their estimates for collision mortality and for cumulative impacts. However, their own calculations indicate that the impacts arising from collision associated with the Morgan Wind Farm in-combination with other projects are predicted to result in the annual population growth rate of Great Black-backed Gull at the Isles of Scilly SPA declining, with a ratio of impacted to unimpacted population growth rate of between 0.906 and 0.908. This means that after the 35-year lifetime of the Wind Farm, the population size of the SPA is expected to be between 2.8-3.1% of what it would have been in the absence of the development in-combination with other projects, representing a 97% decline in the population. While, as described, there are likely errors in the assessment, these results can be considered indicative of the scale of impact and are clearly unacceptable. ECOSYSTEM IMPACTS The RSPB would welcome an inclusion consideration of the potential wider ecosystem impacts that may arise through the construction and operation of the wind farm (Isaksson et al, 2023). 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 (Burnell et al, 2023). 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. REFERENCES Archer, M., Jones, P. H., & Stansfield, S. D. (2015) Departure of Manx Shearwater Puffinus puffinus fledglings from Bardsey, Gwynedd, Wales, 1998 to 2013 Seabird, 48 43-47 Burnell, D., Perkins, A.J., Newton, S.F., Bolton, M, Tierney, T.D. & Dunn, T.D. 2023. Seabirds Count, A census of breeding seabirds in Britain and Ireland (2015–2021). Lynx Nature Books, Barcelona Cook (2021) Additional analysis to inform SNCB recommendations regarding collision risk modelling. BTO Research Report 739. Deakin, Z., Cook, A., Daunt, F., McCluskie, A., Morley, N., Witcutt, E., Wright, L. and Bolton, M., 2022. A review to inform the assessment of the risk of collision and displacement in petrels and shearwaters from offshore wind developments in Scotland. Report to Marine Scotland Science Guilford, T., Padget, O., Bond, S., & Syposz, M. M. (2019). Light pollution causes object collisions during local nocturnal manoeuvring flight by adult Manx Shearwaters Puffinus puffinus.?Seabird,?31 Isaksson, N., Scott, B.E., Hunt, G.L., Benninghaus, E., Declerck, M., Gormley, K., Harris, C., Sjöstrand, S., Trifonova, N.I., Waggitt, J.J. and Wihsgott, J.U., 2023. A paradigm for understanding whole ecosystem effects of offshore wind farms in shelf seas. ICES Journal of Marine Science, p.fsad194. Kane, A., Pirotta, E., Wischnewski, S., Critchley, E. J., Bennison, A., Jessopp, M., & Quinn, J. L. (2020). Spatio-temporal patterns of foraging behaviour in a wide-ranging seabird reveal the role of primary productivity in locating prey.?Marine Ecology Progress Series,?646, 175-188 Miles, W., Money, S., Luxmoore, R., & Furness, R. W. (2010). Effects of artificial lights and moonlight on petrels at St Kilda.?Bird Study,?57(2), 244-251 Ozsanlav-Harris, L., Inger, R., & Sherley, R. (2023). Review of data used to calculate avoidance rates for collision risk modelling of seabirds. JNCC Report 732 (Research & review report), JNCC, Peterborough, ISSN 0963-8091. https://hub.jncc.gov.uk/assets/de5903fe-81c5-4a37-a5bc-387cf704924d Rothery, P., Newton, I., & Little, B. (2009). Observations of seabirds at offshore wind turbines near Blyth in northeast England. Bird Study, 56(1), 1-14. Searle, K. R., S. H. O'Brien, E. L. Jones, A. S. C. P. Cook, M. N. Trinder, R. M. McGregor, C. Donovan, A. McCluskie, F. Daunt, and A. Butler. "A framework for improving treatment of uncertainty in offshore wind assessments for protected marine birds." ICES Journal of Marine Science (2023): fsad025. Shoji, A., Dean, B., Kirk, H., Freeman, R., Perrins, C. M., & Guilford, T. (2016). The diving behaviour of the Manx Shearwater Puffinus puffinus.?Ibis,?158(3), 598-606 Skov, H., Heinänen, S., Norman, T., Ward, R., & Méndez, S. (2018). ORJIP Bird avoidance behaviour and collision impact monitoring at offshore wind farms. The Carbon Trust: London, UK. Tremlett, C.J., Morley, N., and Wilson, L.J. (2024). UK seabird colony counts in 2023 following the 2021- 22 outbreak of Highly Pathogenic Avian Influenza. RSPB Research Report 76. RSPB Centre for Conservation Science, RSPB, The Lodge, Sandy, Bedfordshire, SG19 2DL."
