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Response to the Ramsey South Bay Consultation Submission from Manx Wild Life Trust

Ramsey Marina Limited (RML) have received a copy of the Manx Wild Life Trust’s (MWLT) response to the Planning Consultation for the North/West. It has now had the chance to review the contents of that response and would have the following comments:

A.    RML had very cordial relations with Dr Tim Graham, the previous CEO of MWLT. It is therefore with much disappointment that RML have heard of this sudden change in approach. RML reached out to MWLT over three years ago and were assured that MWLT would conduct a professional dialogue with RML at all stages of the marina project. Indeed, Dr Graham agreed that, with care and attention, there was a very real opportunity to improve the ecosystem in the Bay with the marina and they were excited to support that.

B.     Since the arrival of Leigh Morris as CEO last year, RML have had one meeting with MWLT which lasted for just over an hour. RML can’t agree with the MWLT statement that RML have met “at length” with MWLT. During that one hour meeting the main talking points were around what the project consisted of physically, and very little discussion about the marine ecology.

C.     At that single meeting, Mr Morris repeated his suggestion that RML employ MWLT to undertake some of the work associated with the RML Environmental Impact Assessment. On 6th November 2021 RML chased Mr Morris for his staff’s credentials, as nothing had been heard from them on this proposal.

D. Referring to the numbered points in their response:

1.     MWLT have presented no scientific basis on which to state that the development would have negative ecological effect. Based on RML discussions with UK experts in marina biology, they agree that, with careful thought, the marina could enhance the marine ecology. In 2019, the MWLT posted: “Hopefully Ramsey Marina Ltd will take our environmental concerns seriously and aim for a real quality assessment with BREEM or CEEQUAL. We hope to be involved in a full Environmental Impact Assessment before any decisions are made.

It is not clear why MWLT have now reneged on their earlier desire to work with RML on a really worthwhile project.

2.     MWLT have not made it clear or provided any evidence as to why the repurposing of 350m of beach would “undo all of the protection for important species…” nor have they illustrated how this would “undermine the legally-protected wildlife habitats on the Isle of Man and in our territorial waters.” MWLT’s points appear to be a complete exaggeration with no proof or evidence provided by MWLT to support their claims.

3.     There is no reference on the DEFA website to any “policy” on an Area of Ecological Importance but there is a strategy. As such, MWLT’s comments are completely misleading in that respect.

4. There is a possibility that the marina will alter certain natural aspects of the Ramsey Bay and this is why an Environmental Impact Assessment is vital in order that both RML as developer and MWLT can understand the position and to mitigate against any red flags raised by such an assessment.

MWLT have provided no scientific evidence or rationale to support the statement that the development will negatively impact the eelgrass near to the development area. RML has already engaged with experts in the UK and have been provided with advice that the mechanism, that allowed the eelgrass to colonise the iron Pier legs and dolphin, will be naturally replicated along the toe of the breakwater.

MWLT provide no scientific basis or rationale to support their statement that that the marina might affect the ASSI. The ASSI is on the other side of the harbour entrance to the development. Scientific evidence (as enshrined in the Manx Maritime Environmental Assessment – published by DEFA) shows that there almost no littoral/longshore drift from the South Beach and northwards along the coast to the Point of Ayre. This lack of littoral drift is evidenced by there being no sand banking up against the south side of the south stone pier.

Having reviewed existing studies, which are publicly available, it appears that MWLT’s statement can only be one of conjecture in that MWLT appear not to have familiarised themselves with existing studies and scientific evaluation and have formed an opinion contrary to those studies.

5.     RML’s plans are fully aimed at ENHANCING the enjoyment of the beach, so it is unclear why MWLT think a major leisure facility will prevent the Island residents from enjoying the physical and mental health benefits of South Bay. The whole ethos of the marina is outdoor physical sport and activities for people from every walk of life.

6.     RML are fully aware of the threat of invasive species. The suggestion that by adding a breakwater, in addition to the huge volume of marine structures on the Island will greatly increase the volume of invasive species, appears to be a complete exaggeration and, to put it bluntly, comes across as simply an attempt to scaremonger. RML, in line with DEFA guidelines, will undertake periodic checks on the marina structures to ensure that invasive species are not given the opportunity to colonise the development. Furthermore, RML plan to encourage native species to thrive.

This statement would to be at odds with what MWLT’s colleagues in the UK believe. According to the North West Wild Life Trust in their report to Natural England in December 2016, entitled “Monitoring Invasive Non-Natural Species (INNS) in Marinas in North West of England”, they stated, inter alia: “The North West has a relatively low number of INNS overall….”

7.     The two key statements by MWLT are incorrect. These are:

a) It would appear that the Biosphere team are unaware of any “Core Area” in Ramsey Bay.

b) The site is NOT the highest protected area. Referring to the MWLT’s own website:

It should be noted that the marina is in Zone 1, the lowest denomination of the 5 zones.

8.     It appears that, at the instigation of the Save the Bay team, who are now Ramsey Town Commissioners, the area of the beach, where the plovers and oystercatchers nest, has been removed and disposed of at an unknown location. In the last 6 weeks the beach has been lowered, mechanically, by around 2m. So the nesting site no longer exists.

MWLT do not seem to have considered that rock armour on breakwaters provide a perfect habitat for sea birds, as evidenced by many scientific papers.

Referring to the last paragraph of their submission, RML would comment:

i)     MWLT have absolutely no evidence that the marina will increase the risk of flooding. Whereas the breakwater will prevent wave action on the Queen’s Promenade, and the development itself will protect some 65% of the Queen’s Promenade from tidal surge and rising sea levels.

ii)     By careful building design, generating power from renewables and enhancing the eelgrass growth (as have been achieved in Plymouth and other South Coast locations), the marina will have very little, if any, carbon footprint. RML are currently considering how we can mirror some of the net carbon negative projects currently being established around the UK.

iii)     MWLT have not defined how many pollution incidents there have been in UK marinas in the last 10 years. RML will be seeking accreditation under the Blue Flag marina programme together with the British Marine Federation’s Gold Anchor scheme, which detail how such pollution risks should be addressed.

E. Summary

RML would propose that their Environmental Impact Assessment should be allowed to quantify, if any, the ecological issues. When complete, the Environmental Impact Assessment report will be publicly available.

The MWLT submission is a mixture of exaggeration, misleading statements and statements on which no scientific basis or rationale has been presented to justify them. The residents of the Island therefore should treat the MWLT submission with much circumspection.

F. PERSONAL CONFLICTS

We have noted that a senior member of the MWLT team posted the MWLT response on the social media, and, in particular, the Save the Bay Facebook page. RML are aware that a second member of the MWLT has also posted strongly negative views on the marina proposals in the past. Not only is this unprofessional, but it must remove any suggestion that MWLT are an impartial authority on the environmental aspects of the marina.

RML will be bringing in world class experts on marine ecology and, in particular, eelgrass propagation. RML hope to be in a position to announce further details within the next few weeks.

RML had hoped it would not be become necessary to address the personal conflicts and agendas, that have become glaringly apparent. RML has always been open and available to engage in a mutually respectful and objective manner. We are saddened this is not the case and that we are therefore forced into addressing these directly to ensure that the public are aware of the apparent bias in the information being presented to them.

RH Bromley-Martin
Director