Mona Offshore Wind Farm

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Mona Offshore Wind Farm

Received 06 May 2024
From Mooir Vannin Offshore Wind Farm Limited

Representation

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 in 2023 and are preparing to submit an Application for Marine Infrastructure Consent in 2025. Our proximity to Mona Offshore Wind Farm (“MOWF”) can be seen in MOWF’s Environmental Statement (“ES”) (F2.10) Figure 10.4 and Table 10.10. 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 Morgan 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. We note previous consultation responses to MOWF, including from the Isle of Man Government Territorial Sea Committee (E3.1), which refer to our AfL area being omitted from certain maps of neighbouring offshore windfarms. We note that certain Figures and Table within the ES (F2.7) are stated as “excluding Mooir Vannin Offshore Wind Farm”. Our Project’s concerns include: Issue one: The ES highlights potential significant impacts on wildlife, including potential significant project-alone and in-combination impacts on marine mammals (F2.4). We further note in relation to offshore ornithology that Tables 5.49 – 5.50 of the Cumulative Effects Assessment (CEA) refer to our Project but no further consideration is made. A further example is Commercial Fisheries where the MMO specifically requested that our Project is considered within the CEA. We note that our Project is discussed in relation to effects on scallop vessels and offshore static gear vessels during the construction phase and O&M phase. In relation to both receptors the effects are judged to be non-significant. We are not convinced that the baseline and the predicted impacts are robust and align with our understanding of the local environment and we require to analyse this further. 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 and commits to stakeholder engagement (F2.7 7.14.1.2-7.14.1.4). We require to be involved in such engagement to ensure that co-existence can be successfully achieved. The cumulative effect of MOWF, the proposed Morgan offshore windfarm and Morecambe offshore windfarm and our Project is set out in the Navigational Risk Assessment which refers to the fact that “with the addition of Mooir Vannin OWF, there were likely to be further impacts on ferry routes in typical and adverse conditions and unacceptable risk to navigation safety” (F6.7.1 D.5.1.1.8). 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. We require assurance that MOWF has correctly assessed the impact of its windfarm both project alone and on an in-combination basis.