| From: | Costain, Sophie (DEFA) | | --- | --- | | Sent: | 11 March 2020 14:48 | | To: | DEFA, Planning; Callow, Jo (DEFA) | | Cc: | Samson, Louise; Thomas, Aline | | Subject: | PA 20/00115/B - Erection of an illuminated sculpture, The Smelt, Derbyhaven |

Good Afternoon

RE: PA 20/00115/B - Erection of an illuminated sculpture, The Smelt, Derbyhaven

The Ecosystem Policy team do not agree with, what we see as, unnecessary lighting of this area, which is within Langness, Sandwick and Derbyhaven Areas of Special Scientific Interest (ASSI) and Bird Sanctuary. We would prefer it if the lighting element of this application was removed, to keep the area unlit.

If the applicants feel like lighting is a necessary feature then liaison with the DEFA, Ecosystem Policy team over the type, strength, duration and direction of the lighting will be required, as well as an assessment into the impact of the light spill into the surrounding area. Updated plans for the sculpture will then need to be submitted to the Planning Directorate in order for the applicants to evidence that the development will not adversely affect species and habitats of importance as per Environment Policy 4 of the Isle of Man Strategic Plan.

Even if planning permission were to be given, an ASSI consent will be required prior to the erection of the sculpture, and the Ecosystem Policy Team will not give ASSI consent before all of these elements have been considered and we are confident species and habitats will not be negatively affected.

The lighting assessment will need to be undertaken by a suitably qualified ecological consultancy and should be submitted to planning for approval prior to determination of this application. The assessment will need to consider at least the following elements:

• Derbyhaven beach, which is only 30 m to the east of the proposed sculpture and which is home to roosting, feeding and nesting birds.
• The potential impact on bats. The assessment will need to determine the presence of roosting, commuting and foraging bats, evaluate the importance of this area for those activities, determine the key habitat features which should be kept unlit, and propose any suitable mitigation, as per the Bat Conservation Trust, Guidance Note on Bats and artificial lighting in the UK. A suitability survey of the old smelt for roosting bats should also form part of this assessment. All surveys should be done in line with the Bat Conservation Trusts Bat Surveys for Professional Ecologists - Good Practice Guidelines ( 3^{\text {rd }} Edition 2016).

Please note that the direction of the light is of particular concern to us, as up-lighting is considered much more disturbing to wildlife because of the light spill above and into the surrounding area. Some form of directional down-lighting where the light spill is limited would be of less concern to us, however, no lighting at all is still the preferred option.

Also for consideration alongside this application should be the registered Dark Sky Discovery Site at Fort Island, and the potential implications to this status from lighting in the area.

Best wishes

Sophie

Miss S Costain, Ecosystem Policy Officer

Department of Environment, Food & Agriculture, Thie Slieau Whallian, Foxdale Road, St John's, Isle of Man, IM4 3AS

Tel +44 (0)1624 685963 Fax +44 (0)1624 685851 Email [email protected] Website: www.gov.im/defa

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