Ecological Management and Monitoring Plan

Clocktower Industrial Estate, Foxdale, Isle of Man

Ecological Management and Monitoring Plan

February 2026

Control sheet

Job number:	25_39
Title:	Clocktower Industrial Estate – EMMP
Client:	Cornerstone Architects
Prepared by:	Adam Denard – Senior Ecologist
Verified by:	Amy Dunderdale - Ecologist
Date of Issue:	February 2026
Version:	2
Revisions:	1
Status:	Final

This report is prepared by Ecology Vannin Consultancy Services for the sole and exclusive use of Cornerstone Architects and their contractors in response to their particular instructions. No liability is accepted for any costs, claims or losses arising from the use of this report or any part thereof for any purpose other than that for which it was specifically prepared or by any party other than Cornerstone Architects. Any biological records for wildlife found in survey will eventually be submitted to Manx Biological Recording Partnership. This report does not prevent MWT pursuing its charitable objectives in relation to planning.

This report has been prepared by an environmental specialist and does not purport to provide legal advice. You may wish to take separate legal advice.

The information which we have prepared and provided is true, and has been prepared and provided in accordance with the BS42020 2013 and Chartered Institute of Ecology and Environmental Management's Code of Professional Conduct and guidelines for preliminary ecological appraisals (CIEEM 2017). We confirm that the opinions expressed are our true and professional bona fide opinions.

Signed (Author) Electronic Signature

Signed (QA) Electronic Signature

Biographies

Amy Dunderdale BSc (Hons) MSc is an ecologist with several years’ experience in baseline ecological survey and assessment, and some specialist protected species surveys including for bats and reptiles. Amy graduated with a First Class Honours degree in Biology bachelor’s degree from the University of Durham and a Master’s degree (achieved with Distinction) in Wildlife Management and Conservation from University of Reading. She has experience working in ecology consultancy in the UK including experience in completing PEAs and BREEAM Land Use and Ecology reports.

Adam Denard BSc (Hons) MCIEEM is Senior Ecologist with Ecology Vannin and has been a professional ecologist for over 15 years, with particular emphasis on recording and assessing habitats in England and the Isle of Man for their potential to support protected species. After graduation with First Class honours in Conservation and Land Management, Adam worked on professional bat surveys for Oxford University before going onto work for ecological consultancies in England 2004 –

1. During this time key skills were surveying for higher plants (site assessment, NVC and aquatic macrophytes), Great Crested Newt, Bats, Birds (Breeding and wintering), Reptiles and Riparian mammals. Adam worked as conservation officer for Manx BirdLife in 2010 (including producing a preliminary Isle of Man Birds of Conservation Concern) and after a career break has been providing consultancy services for Manx Wildlife Trust since 2017. Adam regularly produces professional ecological reports within the Isle of Man planning system including Preliminary Ecological Appraisal Reports (PEARs), Specialist surveys for protected species, mitigation strategies and Ecological Impact Assessment (EcIA).

Glossary

ASSI Areas of Special Scientific Interest ASP Areas of Special Protection BCT Bat Conservation Trust BoCC Birds of Conservation Concern CEMP Construction Environmental Management Plan DBH Diameter at breast height LWS Local Wildlife Site MBG Manx Bat Group MBL Manx Bird Life MBRP Manx Biodiversity Recording Partnership PWMS Precautionary Working Method Statement PRA Preliminary Roost Assessment PRF Potential Roost Feature SAC Special Area of Conservation SPA Special Protection Area SUDS Sustainable Urban Drainage

Ecology Vannin Clocktower Industrial Estate EMMP 3

• 1.0 Introduction
• 1.1 Ecology Vannin were commissioned to produce an Ecological Management and Monitoring Plan for a parcel of land within Clocktower Industrial Estate, Foxdale, Isle of Man (centroid grid reference SC282778). This is in relation to planning conditions 13 and 14 of a permitted decision planning application (reference 24/00314/B).
• 1.2 The conditions state:

• 13.Prior to the commencement of any works details of an ecological management and monitoring plan shall be submitted to the Department and approved in writing. The plan will need to incorporate the measures detailed in Table 1, 2 and 3 of the Curragh Environmental Consultancy's Constraints and Opportunities Plan (as amended November 2023), Cornerstone Architect's Ecological Plan (Drawing No. 004 REV A) and the creation of a new lizard hibernaculum. The plan will need to be secured for at least 5 years post construction and the approved details shall be fully adhered to. Reason: In the interest of biodiversity of the site.
• 14.Prior to the commencement of any development a detailed habitat protection plan demonstration how the areas identified on the submitted ecological plan are to be protected/preserved during the construction period and post construction shall be submitted to the Department and approved in writing and the approved details shall be fully adhered to. Reason: In the interest of biodiversity of the site.

• 1.3 Previous ecological reports that formed part of the application and utilised for the following management plan include:

•  Preliminary Ecological Appraisal Report (PEAR) (Curragh Environmental

Consultants, 2022)

•  Ecological Constraints and Opportunities Plan (ECOP) (Curragh Consultants, 2023)

•  Phase 2 special surveys for Bats (Manx Bat Group, 2022) Invertebrates (Hawkins.

2023) and Common Lizard (Ecology Vannin, 2023).

• 2.0 Site Overview/Ecological Baseline
• 2.1 The survey site is a former industrial site that has been colonised and impacted by various human interference e.g. previous vegetation clearance to produce a typical ‘brownfield site’ habitat type and structure. Habitats are a mosaic of bare open metalliferous substrate, short ephemeral, tall ruderal, grassland patches and scrub. The unusual soil chemistry supports the rare vascular plant Petite-leaved Hawkweed Hieracium daedalolopioideswhich is a red list ‘high’ conservation species in the Isle of Man (Bellamy & Dubbeldam, 2023). The site also supports five Schedule 8 legally controlled invasive plant species (Japanese Knotweed Reynoutria japonica, Himalayan Balsam Impatiens glandulifera, Montbretia Crocosmia x crocosmiiflora, New Zealand Broadleaf Griselinia littoralisand a Cotoneasterspecies).
• 2.2 In terms of fauna, there is suitable habitat for Common Lizard Zootoca vivipara(a fully protected Schedule 5 species), and foraging and commuting Bats (Schedule 5 – all species) were confirmed as present during specialist survey. Invertebrate communities present were not considered particularly high value but the habitats present provide a range of habitat structure and niches for a relatively diverse number of species for a site of this size.

Ecology Vannin Clocktower Industrial Estate EMMP 4

3.0 Ecological Objectives

Area	Habitat/species aim	Methods and treatments
A	• Development of scrub and succession to woodland. • Stabilisation of the mine deads on the bund, in the wood at the southern tip and on the steep slope alongside the stream.	• This area to be left undisturbed with the exception of JK/HB treatment. • Remove other Schedule 8 species on the northern boundary of the site. If replacement is possible, please use native, fruit or berry bearing species. • Any dead trees should be left to provide habitat for insects and fungi. • No vegetation should be uprooted. • Some cutting back of gorse may be necessary on the inner boundary of area A. • If any tree planting or seeding is required for stabilisation, locally grown native stock of birch and oak should be used.
Ai	Maintaining open areas on the deads for bryophytes and insects	• The area shown with orange stripes will need regular control of gorse and broom. • Divide this area into 5 parts and cut one part each year in rotation. • Start this cycle before construction. • Ensure there is access to this area for machinery that might be used for gorse cutting

3.1 The ecological objectives for the site were provided in Table 1 of the ECOP report and are provided below to cross reference with the 'Ecological Plan –Drawing 004' in Appendix I.

Table 1: Ecological aims and methods

B	Creation of calcareous/Calaminarian grassland habitat. Zone of non-disturbance	• Treat the gorse in this area well in advance by cutting the stems just above the surface and treating with an appropriate herbicide. • Remove sycamore and willow seedlings/saplings • Crush the piles of concrete to between 6mm and 8mm. Use this material to spread as a thick layer in the area shown in blue ensuring a minimum thickness of 100mm, with minimum compaction. • No soil or grass seed should be applied without seeking ecological advice. • Create lizard hibernaculars
C	Development of calcareous and bare/disturbed ground species including the Hawkweed (Hieracium daedalolopioides).	• Leave the area and soil undisturbed. • Any protection measures put in place during the construction works should also be applied to this area. • Concrete surfaces should be left in place and the vegetation surrounding them preserved • The grass bank where the Hawkweed now grows should be clearly marked and protected during the works.
Di	Conservation of mine deads moss species. Developing bare ground for insects, mosses and lichens.	• Gorse to be removed by cutting off at ground level and treating stumps with herbicide. • Avoid disturbance
Dii	Bare ground and impermanent pools. For birds, insects and plant species diversity.	• Gorse to be removed by cutting off at ground level and treating with herbicide. • Leave this area undisturbed to maintain bare mine deads which has surface, impeded drainage. • Ensure the surface water is prevented from running off into proposed drainage systems, using mine spoil material excavated from the attenuation void to create a low bund around this area.
E	Brownfield/ waste ground habitat creation	• After the drainage works are complete the surface should be finished with existing materials and rubble • No soil or grass seed should be applied without seeking ecological advice.

4.0 Management Prescriptions

Area	Proposed treatments and management
All	• Continue monitoring and treatment of JK and HB for as long as necessary. • Remove any other non-native invasive schedule 8 species that appear, as appropriate (with advice from DEFA).
A	• Cut back or trim gorse and broom along the inside edge of area A when it spreads onto areas B, C, or D.
Ai	• Continue the control of gorse, as above
B	• Mowing/strimming regime: as required with ecological advice • Only between September and March and not in period of prolonged wet weather • As needed
C	• Mowing/strimming regime, if needed. Parts of this area might be treated differently. • Only between September and March and not in period of prolonged wet weather • Annual
Di	• Annual gorse removal • Monitoring of potential moss species
Dii	• Bi-annual mowing or strimming as needed
E	• Minimal management in this area • Mowing/strimming regime, if needed. Parts of this area might need to be treated differently. • Only between September and March and not in period of prolonged wet weather
All	Arisings from gorse clearance and mowing should be removed well away from the areas of habitat creation and bare ground for onsite composting or if necessary remove for incineration at the energy from waste plant. The area for onsite composting to be agreed by a competent ecologist.

Habitat Management

4.1 Habitat Management Prescriptions were provided in Table 2 of the ECOP report and are provided below. These have been reviewed with some additional instruction for site management/contractors. Areas are to be cross referenced with the Ecological Plan in Appendix I.

Table 2: Long-term management prescriptions Key: JK = Japanese Knotweed / HB = Himalayan Balsam

• 4.2 Additional recommendations are:

•  Area C should be included in the bi-annual (twice per year –before and after

main flowering period April to August) mowing to promote open grassland structure including rare Hawkweed species.

•  Area Dii should be included in the annual mowing/strimming regime.

•  Area E should remain unmanaged.

•  Arisings from gorse clearance works could be chipped on site and used as a

mulch in ecologically low value areas as directed by an ecologist.

•  Tree and shrub removal should be undertaken outside of the main breeding

period (typically March to August) wherever practically possible. Should clearance be required during the breeding season, a pre-clearance nesting check should be undertaken and any nests safeguarded until all young have fledged and are independent of the nest. Checks are to be no more than 5 days prior to works continuing. (NOTE –nests are also protected whilst in the process of being built). Ideally this should be by an experienced Ecologist but can be undertaken by site operatives. If in any doubt all work should be temporarily suspended and advice sought by DEFA Ecosystem Policy Team

(651577).

•  As birds can potentially nest at any time of year site workers must be vigilant

for the presence of nesting activity at all times. Evidence includes (but not exclusively) agitated calling adult birds, distraction displays by adults, adult birds carrying nesting material and/or food for young, a fresh nest, eggs and sounds of calling young.

Invasive Plant Species

• 4.3 Table 3 of the ECOP report (shown below) provides project advice on the control and eradication of legally controlled Schedule 8 species. The EMMP has reviewed this and provided additional clarity for the client.

Ecology Vannin Clocktower Industrial Estate EMMP 8

Additional comment re Invasive Plant Species

• 4.4 For effective treatment by a watercourse, Japanese Knotweed and Himalayan Balsam should be treated by herbicide stem injection. Late summer August/September is the best period of treatment. Treatment should occur as soon as possible given the time elapsed since baseline ecological surveys.
• 5.0 Protection Measures

5.1 Table 4 of the ECOP report (provided overleaf ) outlines the key protection measures required. These have been reviewed and extra instruction for site managers and contractor provided.

Ecology Vannin Clocktower Industrial Estate EMMP 9

• 5.2 Additional recommendations:

•  A copy of this report is to be held on site by the site manager and used to ensure

protection measures are adhered to. In addition, site induction should include ecological information on sensitive areas and species.

•  Before works commence, the plant refuge area and location of Japanese Knotweed

and Himalayan Balsam avoidance areas are to be staked out to prevent incursion by site traffic and operatives.

•  Management of site run-off and drainage must prevent sedimentation and,

particularly, soils containing heavy metals entering the catchment. Methods such as sedi-mats and straw bales are typically deployed. Additional advice from DEFA Inland Fisheries is strongly recommended to ensure best practice is followed.

•  The project should engage an Ecological Clerk of Works for site checks and

compliance with the 5-year post-construction period stated in Condition 13.

•  Site works should follow precautionary Reasonable Avoidance Measures (RAMs) for

Common Lizard and Common Frog Rana temporaria(see Appendix II).

• 6.0 Habitat Creation

• 6.1 Habitat creation is limited to Area ‘A’. along the northern boundary of the development. Screening tree cover is to include Manx native tree species with known ecological benefit and with suitability for site soils e.g. Downy Birch Betula pubescens, Grey Willow Salix cinereaand Common Alder Alnus glutinosa(see Appendix I (ii)).
• 6.2 Area B in the Ecological Plan is to receive crushed concrete from the spoil heaps to be cleared to make way from development. This should be left to colonise naturally from neighbouring plants already adapted to calcareous soil conditions.
• 6.3 A reptile hibernaculum (hibernation area) is to be sited in a sunny aspect within Area ‘B’. This is to be created from concrete slab and stone recycled waste from the development footprint. An example construction drawing is provided in Figure 1 below. Key features are to ensure that it is free draining and likely to protect from frost.

Figure 1 Example reptile hibernacula

Ecology Vannin Clocktower Industrial Estate EMMP 10

• 7.0 Monitoring
• 7.1 The project should appoint an Ecological Clerk of Works (ECoW) to ensure site compliance with the EMMP in terms of species and habitat protection and management.
• 7.2 Monitoring recommendations within the 5 year post-completion period are:

•  Annual check to confirm continued presence and health of Petite-leaved

Hawkweed Hieracium daedalolopioidesin plant refuge area at a favourable status (i.e. no reduction in number of flower spikes from baseline survey).

•  Annual check of effectiveness of invasive plant species control programme to

prevent further spread in the wider countryside. Successful control will be no further expansion in distribution from baseline surveys and likely significant reduction from successful treatment options provided.

•  Single visit to confirm installation of suitably constructed Lizard hibernaculum

and advise on any alterations as required.

•  Year 2 check on habitat management to assess desired outcomes and any

beneficial changes required. Habitats should be of expected species composition, area and structure for optimal ecological functionality.

•  Year 3 check on plant health of proposed tree planting zone and advise on

any changes/replacements as necessary.

•  Annual summary report to DEFA and Planning authority to confirm

compliance with planning conditions as specified.

Ecology Vannin Clocktower Industrial Estate EMMP 11

APPENDIX I – Ecological Mitigation Plan and Soft Landscaping

(i) Ecological Mitigation Plan

KEY A AREA OF ECOLOGICAL VALUE Ai ROTATIONAL GORSE MANAGEMENT B ZONE OF NON-DISTURBANCE C PLANT REFUGE D LEAVE UNDISTURBED BUT MANAGE GORSE E WASTE GROUND

SPECIAL TREATMENT AREAS

1. HAWKWEED - PROTECTED BY FENCING DURING THE WORKS
2. BOUNDARY WITH MINE DEADS - MINIMISE DISTURBANCE IN THIS AREA DURING WORKS, ON SITE ECOLOGIST TO SUPERVISE
3. LEAVE BARE AND NO DISTURBANCE WHERE THE SURFACE WATER COLLECTS - THESE AREAS TO BE MARKED OUT / PROTECTED BY FENCING DURING WORKS

CONCRETE RUBBLE / SPOIL HEAPS a) RETAIN AS WILDLIFE REFUGIA b-f) CRUSH AND USE FOR SURFACING AREA B g) USE CONCRETE AS a) ABOVE USE STONE TO BUILD LIZARD HIBERNACULUM / REFUGIA

PLEASE USE THIS PLAN IN CONJUNCTION WITH THE ACCOMPANYING REPORT: CLOCK TOWER INDUSTRIAL ESTATE - PROPOSED EXTENSION ECOLOGICAL CONSTRAINTS AND OPPORTUNITIES PLAN, CURRAGH ENVIRONMENTAL CONSULTANCY, AUGUST 2023, PART 2. TABLES 1-4.

APPENDIX II –Common Lizard/Common Frog RAMs

Working methods for enabling and construction work should include the following Reasonable Avoidance Measures (RAMs):

Site information

 Protected species information sheet to be provided in site briefing of all operatives for due

consideration of Common Frog and Common Lizard presence and potential for injury and mortality. To be supplemented by ‘toolbox talks’ on site if considered necessary. This should be done prior to the commencement of work.

Vegetation management

•  Minimisation of disturbance boundary hedgerows / trees and scrub

•  For removal of, any stone/rubble areas that could provide sheltering or hibernation habitat,

clearance is recommended to be undertaken by hand, or proceed with caution for the protection presence of lizards and frogs.

•  Vegetation clearance ideally to be undertaken during the lowest risk period (November to

February). Outside this period clearance should be undertaken in a one-way direction to enable any frogs/lizards that may be active to move out of the way into adjacent habitat ahead of machinery.

•  If vegetation cutting is required outside of this period:

• o Vegetation should be cut slowly in one direction, no shorter than 10cm, to allow any lizards or frogs to relocate to adjacent habitat. The direction of cut will depend on which area is being cut. Cutting should start at the existing levelled footprint area and move towards the boundary of the field.
• o Vegetation should then be left for 24-48 hours, to allow frogs and lizards to relocate, before removal of the remaining grass sward.
• o It should be completed on warm sunny days 120C+ ambient temperature.
• o If there is any significant delay (greater than 2 weeks) that enables the sward to become attractive to use by lizards and frogs the vegetation height will need to be managed by regular use of the above methods.

General construction phase

•  Construction materials should be stored on existing levelled areas / areas of hardstanding,

rather than on remaining grassland areas. If this is not possible, materials must be kept off the ground in a compact, defined area to minimise disturbance and avoid protected species using them for shelter.

•  Any trenches should have suitable escape ladders (e.g. planks) or be covered at the end of

each working day.

•  If any lizards or frogs (or anything suspected of being a lizard or a frog) are found during

operations, work must stop immediately, and advice sought from Ecology Vannin (844432) or DEFA (651577). Licences may be required to undertake translocation into neighbouring habitat.

•  Site vehicles and heavy plant should adhere to an on-site 10mph speed limit to avoid injury

and mortality of frogs and lizards.

Ecology Vannin Clocktower Industrial Estate EMMP 14