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Awel y Môr Offshore Wind Farm
Received 06 July 2022
From Department of Infrastructure, Isle of Man Government on behalf of Mrs Emily Curphey, Chair, Territorial Sea Committee
“The Territorial Seas Committee (TSC) has previously submitted comments on this project, but comments in respect of offshore ornithology and commercial fisheries need to be raised again. Concern remains with regards the cumulative impact of all the proposed offshore windfarms within the Irish Sea area and the impact they could have on shipping and navigation. Offshore ornithology has been screened in within the transboundary screening report, however consideration of Manx conservation features has been inconsistent across the chapters of the Environmental Statement. The Isle of Man view on the ornithology scoping has been included, in full, within the revised Scoping Report, but the applicant’s responses are not stated. We have previously noted the lack of reference to Manx sites that are likely to relate to this study area, specifically the Manx shearwater and the comments of the JNCC relating to remaining flight height risks and the possible need for CRM assessment, and we have requested evidence of the specific consideration of the Isle of Man in such respects. We note that no ‘significant effects’ were found in the ornithological assessments, and therefore site attribution was not undertaken. Nevertheless, site related considerations have arisen in the process, but we have not found any comment on the Manx seabird colonies or Manx sources of migrant birds, lying within range on the Isle of Man, where they are a feature of a number of designated sites. In the offshore ornithology sections, despite the presence of relevant species of seabird on the Isle of Man, including regionally-relevant, breeding colonies and recovery programmes, there are only three, non-specific references to Isle of Man in the main chapter. With no references, or acknowledgement of the Manx protected sites, it is difficult to confirm that adequate consideration of Manx ornithological interest have been considered. Commercial fisheries has been screened in as a transboundary impact assessment. As noted in the Isle of Man Government’s response to the PEIR, and comments within ‘Annex 8.2: commercial Fisheries Consultation Record’, there are still only 3 non-specific references to the Isle of Man in Volume 4, Annex 8.1 Commercial Fisheries Baseline Final, and 5 non-specific references in Volume 2, Chapter 8 Commercial Fisheries v Final. Given the overlap of the Fisheries Regional Study Area within Manx waters (ie. 36E5), the non-specific references make it difficult to determine whether the Isle of Man commercial fishing interests have been adequately considered. The responses outlined in the Consultation Record are typically generic, and not apparent that further attempts to quantify the fisheries baseline have been made by engagement with relevant Manx data sources nor specifically for any potential impact on the Isle of Man fleet. These examples do not provide reassurance that Manx commercial fishing interests have yet been adequately considered, regardless of the eventual conclusion of the assessment. The TSC has a reasonable expectation of demonstrable consideration within the ES of issues relevant to Isle of Man interests, and this is not yet apparent within the Ornithological or Commercial Fisheries assessments.”