“Mooir Vannin Offshore Wind Farm Limited is the developer of the proposed Mooir Vannin Offshore Wind Farm, which holds a grid connection offer and an Agreement for Lease (AfL) with the Isle of Man Government (“our Project”). We submitted a Scoping Report to the IoM Government in 2023 and are preparing to submit an Application for Marine Infrastructure Consent in 2025. Our proximity to Morgan Offshore Wind Farm (“MOWF”) can be seen in MOWF’s Environmental Statement (“ES”) (F1.4) Section 4.2.2. We do not object to the principle of MOWF. We do, however, wish to participate in the DCO Examination to make representations about the potential impacts on and interactions with our Project and, where appropriate, to secure appropriate mitigations. High-level concerns were previously highlighted to MOWF via a consultation response. Our concerns as raised in the response remain extant and we expect further meaningful engagement to seek to address the issues raised below and previously. We are open to addressing within or outside the Examination process, and have met with representatives of MOWF and Mona Offshore Wind Farm in 2024 to discuss potential mitigations (radar and shipping and navigation) and opportunities (Landfall and Grid connection and Net Gain) for alignment. MOWF should take into account all of our Project’s information and engage appropriately with us as both projects’ applications progress. MOWF must ensure the accuracy of cumulative and in-combination assessments to ensure impacts are properly understood and appropriately mitigated to facilitate effective co-existence. Our Project’s concerns include: Issue one: The ES highlights impacts on wildlife, including potential significant project-alone and in-combination impacts on ornithology (F2.5). We further note in relation to offshore ornithology, that quantifiable impacts on Isle of Man colonies are not presented for project alone or within the Cumulative Effects Assessment (CEA). Assessment is lacking for annual displacement totals - limited information is provided on how impacts are calculated, especially for displacement where annual total is excluded from displacement matrices. This creates uncertainty in relation to the reliability of the assessment outcomes and totals attributable to Morgan Generation Assets, and furthermore, creating difficulties quantifying the impacts for the cumulative EIA and in-combination HRA for Mooir Vannin. The impact of our Project must be accounted for by MOWF and appropriate mechanisms must be put in place to facilitate co-existence and allow co-ordination to reduce potential cumulative or in-combination impacts. Issue two: The ES highlights extensive impacts on shipping and navigation (F2.7). Section 7.11 identifies multiple potential cumulative impacts in-combination with the Mooir Vannin Offshore Wind Farm Project (incl. impacts to commercial operators including strategic routes to lifeline ferries, impact on vessel to vessel collision risk, and impact on allision risk to vessels). For all of these impacts the Applicant does not propose any mitigation and concludes “It is therefore assumed that potential cumulative impacts will be addressed by Mooir Vannin Offshore Wind Farm through the planning process”. Mooir Vannin Offshore Wind Farm does not consider it appropriate to defer all mitigation for cumulative impacts in this way. We would, however welcome the opportunity for meaningful engagement with the Applicant. Issue Three: It is anticipated that there may be a requirement to put in place appropriate mitigation in relation to potential impacts on primary surveillance radar. Chapter F2.11 identifies significant cumulative impacts on aviation PSR systems in-combination with Tier 1, 2 and 3 projects. It is not clear how the mitigation within section 11.9.3 will be applied to reduce cumulative impacts. With regards to Ronaldsway (IoM) Airport specifically, information on the potential mitigation methods refers to the use of additional MultiLAT sensors to reduce project-alone impacts. However, it is not clear how this would be implemented to contribute to mitigation of cumulative impacts.”