The following is a letter submitted for publication in Media Isle of Man’s newspapers. To submit your own, write to [email protected]

The Isle of Man will see some big changes over the coming years if the proposed large onshore wind farm set to be constructed at Earystane as part of the MUAs net zero plans gets the go-ahead.

The Earystane development will have a substantial negative impact on our natural heritage, because – among other things – it will involve the destruction of registered heathland, peat habitat in pristine natural condition and a plantation with temperate rain forest conditions, with all the consequences for wildlife that that entails. There are several other potential negative environmental impacts that could be very serious, alongside some issues in carbon accounting in relation to these developments.

Healthy functioning peatland is the best land-based carbon sink in the world. The formation of peatland requires a damp climate retaining a waterlogged soil and hard acidic underlying geology. In the Southern uplands, conditions are ideal for peat-forming blanket bog. Many plants find such conditions difficult, but species of Sphagnum moss are very well adapted for them. The Sphagnum consists of two kinds of cell – living green cells which contain chlorophyl and do the photosynthesis, and hyaline cells. The hyaline cells are much bigger than the living green cells and are used for storing water; they allow the Sphagnum to hold many times its own weight in water and hold the majority of rain where it falls. This explains why we have completely saturated ground halfway up or on tops of hills – The sphagnum holds vast amounts of rainwater in place. Growth of Sphagnum is slow, and decomposition does not occur at anywhere near the same rate (if at all) as in other habitats, because of the lack of oxygen associated with this saturated habitat. The dead remains of the previous year’s growth thus slowly accumulates below the living layer of Sphagnum at a rate of about 1mm per year.

Blanket bog formation began when the climate was substantially warmer and wetter than today and the policy of neolithic humans to clear areas of much of their woodland resulted in the ecological balance tipping towards peat formation. Today, blanket bog is a rare, vulnerable, highly sensitive habitat with its own ecology and is home to a number of specialist species. Many of these species are globally threatened. Internationally, the UK holds 10-15% of all blanket bog.

Correct hydrology is essential for the maintenance of healthy bogs, the water tables at or just below the surface in winter and no more than 10cm below the surface in summer. Any modification of this bog structure will affect its water balance and, consequently, its soil structure. If the peat containing dead plant material underneath the surface layer dries out, the bog may slump and crack; this will supress the growth of sphagnum moss and release both methane and carbon dioxide (methane is approximately 25x more efficient as a greenhouse gas (GHG) than carbon dioxide). Indeed, any modification of the bog structure will affect its water balance and, accordingly, its soil structure with negative impacts in terms of GHG emissions and the bog’s associated ecology.

Such negative influences on bog hydrology need to be prevented, which in practice means preventing any unnecessary disturbance to the bog. It also needs to be understood that disturbance to a peat bog can be caused by activities elsewhere – in particular by dust from road building blowing onto otherwise undisturbed bog, pollutants released by concreting and similar, alongside any activities that will influence water-table level. These water-table levels can be influenced from some distance away. The developments at Earystane & Scard will certainly have such effects, there is a complex system of springs in the area feeding not only the garees and bogs but local farmland and the reason why our forefathers chose it for the site of the original Rushen waterworks reservoirs at Scard.

Many species of plants and animals depend for their existence on this unique habitat. A notable list of either Annex 1 or Red listed species (meaning that there exists the threat of extinction of these species at either a national or global level) nest at the site and the surrounding area and it is part of an important migration route. The recent problems that birds have encountered with avian flu means that it is imperative that any further pressures on their populations are removed.  It is an offence to intentionally or recklessly (a) disturb any wild bird included in Schedule 1 while it is building a nest or is in, or near a nest containing eggs or young; or (b) disturb the dependent young of such a bird. Unfortunately, this only covers birds during the breeding season. It does not prevent measures to deter birds from returning to their traditional sites in spring. This means that it is perfectly legal to use bird scarers to frighten birds from their breeding sites before the nesting season has begun; a common mitigation method employed by wind farm developers!

The International Union for Conservation of Nature (IUCN) stresses the importance of recognising that peatland restoration cannot bring back all values lost as a result of peatland destruction or degradation, which reinforces the primary importance of peatland in pristine or near-natural condition. Indeed, it is a well-known ecological principle that bog regeneration should never be used or accepted as an excuse for the destruction of pristine sites, or the exploitation of others. This is because re-wetting of bogs has recently been recognised (by the IUCN) as controversial for two reasons: 1. Whilst re-wetting reduces CO2 emissions it greatly increases emission of methane in the short term before it starts to be reabsorbed. 2. Re-wetting and restoration in no way guarantees restoration of invertebrate fauna which in turn, is connected to the recovery (or lack of recovery) of the avifauna. If the food supply is not available to birds, they will not return to breed.

It is surprising, therefore, that the MUA appears to claim that the climate crisis is more serious than the biodiversity crisis. This claim is ridiculous. The two are interdependent; climate change will have an impact on biodiversity and changing biodiversity will have an impact on climate.

There is also the matter of the proposed 7.7km of underground cabling (at a cost of over £1.5million) required to connect the Earystane site to the MUA substation at Ballamodha, we were sold the idea that the Earystane site was close to the network - turns out not close at all!  This route cuts through the southern uplands and South Barrule plantation impacting further on the biodiversity of the area.

Finally, there is increasing evidence that both acute and chronic exposure to operating turbines can cause serious problems within a 2km area of residences. A report from NHS Scotland concluded that, “A number of countries including Scotland are now setting setback limits of 2km to reduce risks, though these are mostly guidelines for best practice rather than legal requirements.”  So, we should all be concerned that the Isle of Man Government is settling for a 500m setback, a quarter of the distance that other more experienced wind farm jurisdictions are following. Let’s hope this doesn’t come back to bite the tax payers in years to come… I fear it most certainly will.

 Name and address supplied