St. Mary’s Seal Watch (SMSW) welcomes the restoration and renovation of St. Mary’s Lighthouse and Former Keepers Cottage and supports sensitive improvement to the visitor’s centre and educational facility.
However, St. Mary’s Island is first and foremost a nature reserve and a site with statutory ecological designations and should therefore offer protection and respect for all the wildlife that makes use of it.
Certain aspects of the proposed development will see an increase in wildlife disturbance and have long-term implications on the welfare of the wildlife, the functional biodiversity capacity of the site and learning experience of visitors and therefore is of grave concern to us. Our concerns are as follows:
1) The viewing platforms
The new structure (see Development plans) will result in an increase in visual and audible disturbance to the wildlife through the presence of visitors using the two new first floor, open top glass surround (1.35m) viewing platforms. All disturbance cues generated from the new structure will be in addition to existing disturbance levels from within the lighthouse compound wall and likely to be of a higher magnitude because of the projection of sound and increased visibility of the visitors elevated position.
The applicant claims there have been numerous design alterations for the viewing platforms. However, there is no evidence of any consideration to reduce the visual and audible output from the viewing platforms.
The viewing platforms should be constructed in a sympathetic manner, including using opaque glass (or something similar) to obscure the appearance and movement of visitors, as well as be enclosed or high sided and/or have a design similar to a wildlife hide with long, narrow viewing windows. Creatively and aesthetically designed viewing ‘peep’ holes might hugely improve the visitor experience from an enjoyment perspective and encourage them to think more about conservation. Interpretation information inside the centre explaining why the viewing areas were designed to be fit for purpose to enhance the visitor experience whilst at the same time protecting the seals and birds from unsustainable disturbance levels. It is our opinion that if a wildlife friendly design is not achievable, the viewing platforms should not be built at all.
2) Increased disturbance levels
a) The 25% increase in footfall due to improvement of facilities will see the same relative increase upon existing disturbance levels.
b) The raising of the causeway – proposed repairs and improvements to the causeway will result in an unspecified height increase. This means that the island will be accessible for longer periods, reducing the time that wildlife will be able to use their habitat undisturbed. This increase in footfall will result in a further increase in disturbance levels and a reduction in the conservational value of the island.
For the repair work to be carried out on the causeway a Marine License must be granted to North Tyneside Council by the Marine Management Organisation (MMO). This process is now open to public consultation where you can make a comment to the MMO on their Public Register (deadline 26th October).
Over 70 days from April to August 2016, SMSW recorded a total of 1574 incidents where seals were flushed from the rocks (see Impact of disturbance). Over half (830) of these incidents were caused by the visiting public and nearly a third (485) of these were caused by visitors within the lighthouse perimeter wall. The elevated viewing platforms offer no improvement to the already existing viewing areas and therefore there will be an increase in disturbances to all the wildlife using the island.
The Environmental Statement and “mitigation”
North Tyneside Council is obliged to carry out an Environmental Impact Assessment (EIA) and an Environmental Statement (ES) must accompany this planning application.
The ES acknowledges the importance of the St Mary’s site, nationally, district wide and locally. It acknowledges the detrimental impact that both the proposed viewing platforms and the 25% increased footfall will have upon the seals and the birds that use the island.
Despite this acknowledgement, the ES concludes that all impacts upon the wildlife are to be dealt with through “mitigation”. This is a set of management implications to offset the expected detrimental impact the development will have.
A summary of the mitigation measures proposed are:
1. Increased warden/voluntary warden presence
2. Increased education to deter visitors using certain areas of the island at peak/sensitive times
3. Restricted access to the viewing platforms at the discretion of the lighthouse manager/wardens/voluntary wardens
It is SMSW’s informed opinion that the mitigation and monitoring measures proposed within the Environmental Statement are inadequate and will not prevent an increase in disturbances to the wildlife because:
- It fails to address the full scale of the existing problems of disturbance levels on St. Mary’s Island.
- It puts an unrealistic and unachievable level of responsibility on the lighthouse duty manager.
- It refers to resources that North Tyneside Council does not have i.e. warden/volunteer wardens.
- The viewing platforms will be part of the paying visitor experience. The need to generate revenue does not fit with restricting access to the viewing platforms.
- Information, advice and wildlife protection is already offered by St. Mary’s Seal Watch and additional signs by North Tyneside Council requesting people avoid the wildlife sensitive areas of the island. There are no details as what is to be offered beyond what is already in place that will deter visitors using of site where disturbance occurs.
- There is no detail of how the effectiveness of the mitigation will be monitored, who will monitor it and what will be done if disturbance to the wildlife increases.
Additionally, North Tyneside Council claims that “the viewing platforms will discourage visitors from accessing the area where animals are sensitive to disturbance.” (i.e. the rocks) There is no evidence to support this claim, particularly as it is proposed the viewing platforms will be part of the paying visitor experience.
A claim is made within the ES “that it is likely that the seals will habituate to a degree to the increased visitor presence atop of the platforms as … [they] become accustomed to their presence”. There is no evidence to support this and the writers of the ES acknowledge that it is based only on assumption. We can categorically say that this statement is wrong. The majority of the seals that use the island are juvenile and using it in their first year. They do not have the time to “become accustomed”. Therefore the statement is incorrect and misleading.
The ES acknowledges:
- In the absence of mitigation, it is predicted that there will be a proportional increase in seal disturbance as a result of increased footfall (25%)
- Additional visitor number may also increase disturbances to seals caused by dogs
- Such disturbances (visual, audible and physical) can lead to physical harm of seals as they are flushed into the sea
- Such disturbances (visual, audible and physical) also lead to a wide range of welfare issues to seals due to an unnecessary expenditure of energy and increased stress
- Increased disturbance events may lead to the abandonment by seals of the haul out site.
- Increased disturbance and ‘flushing events’ may affect the population at a regional scale due to the sites intrinsic link to the Farne Islands natal population.
- An increase in footfall could result in potential displacement of birds.
- Without suitable mitigation, an increase in human and dog disturbance to birds would increase.
- Fleeing birds suffer as they are expending energy to fly and because they may be interrupted from activities that enhance their survival and/or reproduction.
- Disturbances that has a negative effect on energy stores can have a population level effect on bird species.
Our objection to this planning application
Without appropriate or effective mitigation, the proposal will have significant residual impacts on the environment once the Development is completed. It must therefore be concluded that the proposed development (as it stands) is unacceptable.
The ES states: If significant harm from a development cannot be prevented, adequately mitigated against, or compensated for, then planning permission should be refused.
We therefore have no other choice but to object to this planning application due to the addition of the two inappropriately designed viewing platforms, the proposed unspecified height increases of the causeway and a failure to provide effective mitigation to prevent further disturbance to the wildlife of St. Mary’s Island Nature Reserve which will in our opinion result in significant suffering for individual animals and have a detrimental impact on the wildlife habitats.
The delicate balance between humans and wildlife is always a precarious one, but on a wildlife-sensitive site the wellbeing of the wildlife should be at the forefront of every decision.
Our natural heritage
When we look back and realise that we made a mistake, why and how we could have prevented it, it is learning.
When we allow something to happen knowing what will go wrong, why and how we could prevent it happening, it is reckless and irresponsible.
When that irresponsibility is at the hands of those with a duty to care, it is negligence.
We believe that it is our duty to take responsibility and ensure our natural heritage and the wildlife within it does not fall victim to inappropriate, unfit and unnecessary development.