4. Dunbar Castle Wardening Role

4.1. Introduction

  1. The third compensatory measure to be implemented by The Applicant is wardening of kittiwake colonies on the mainland site of Dunbar Castle. The wardening position is provided as an umbrella role to implement a series of sub-measures to reduce human disturbance and improve nesting habitat for Kittiwakes in Dunbar Castle.
  2. The objectives of the wardening role are to identify limiting factors to the colony and implement solutions to improve both the number of birds nesting at Dunbar and their breeding success. These objectives will be measured through a conservation target of approximately 400 pairs (800 birds) to bring the colony back to numbers observed in 2020 (this was before the avian influenza outbreak experienced in 2022) with the aim of this compensatory measure to put the colony on a trajectory towards recovery to 2020 levels. The explanation and justification of this conservation target is provided within the CCM Evidence Report.
  3. The warden will also be employed to investigate a range of colony-based issues that may be contributing to the decline of this locally significant Kittiwake colony. The results of these studies will inform the design of each sub-measure on an iterative basis.
  4. Further information regarding this compensatory measure is provided in Section 4 of the CCM Evidence report submitted as part of the Derogation Case.

4.2. Securing and Implementing the Compensatory Measure

  1. As part of the Section 36 consent for the Proposed Development, licences will be issued by Scottish Ministers which will detail conditions which the Applicant must adhere to, or discharge. It is anticipated that a condition will be included by the Scottish Ministers with regards to securing compensatory measures. A draft condition has been provided by the Applicant in section 6.5.
  2. The proposal is for the warden to be employed by East Lothian Council (ELC) and this position would be fully funded by the Applicant. Agreement in principle on this approach has been reached with ELC that the Applicant will provide appropriate funding to pay for the employment of the warden and the associated implementation of the various compensatory measures for a period of at least five years. Heads of Terms regarding this have been agreed and signed between the Applicant and ELC.
  3. Dunbar Castle was formerly owned by ELC, and ownership was transferred in 2004 to the Dunbar Harbour Trust (DHT), a charity set up by a number of harbour users with the aim of improving the harbour facilities for the professional and leisure users. The Board’s mission statement is to ‘run a safe, efficient and welcoming harbour that caters for the needs of all the harbour users, visitors and the local community as well as the environment’. One of the strategic objectives identified by the Board is improvement of the environment within the harbour.
  4. Access requirements and landowner agreement, to allow the warden to undertake monitoring and implement the compensatory measures, will be secured through Heads of Terms between the Applicant and DHT. As ELC already have an agreement with DHT to carry out works, as they carry some of this work already, the warden would work under this agreement. DHT has also offered the warden the use of a room within the Harbour Office.
  5. Dunbar Castle is a Scheduled Monument, and Dunbar Harbour is a historic conservation area. However, with careful design and the use of non-invasive installation techniques, the Applicant does not anticipate a requirement for consent under s. 2 Ancient Monuments and Archaeological Areas Act 1979. If consent is required, an application would be made to Historic Environment Scotland (HES). As non-invasive installation techniques would be used to avoid any structural change to the scheduled monument, the Applicant does not foresee any impediments to gaining such permission.
  6. The above information provides evidence that The Applicant is committed to and has made substantial progress towards delivering the compensatory measure.

4.3. Implementation Mechanisms

Baseline Data Collection

  1. Although there is good information available about the Kittiwake colony at Dunbar Castle, further studies are planned in advance of implementation to either identify or confirm the actions required in order to achieve the objectives of the compensatory measures
  2. As such, the collection of baseline data from one breeding season (in advance of implementing any compensatory measures) is required to enable the most appropriate measures to be implemented and to gather baseline data on the colony as it stands, so that this can be compared with data gathered in the post-implementation period. This allows the warden the opportunity to gather a season’s data which would then be used to develop an Operational Kittiwake Management Plan.
  3. The baseline data collection is likely to focus on understanding three main objectives as outlined below.
  • Kittiwake Colony

–      Baseline data on the extent and productivity of the current kittiwake colony is required to inform the development of an Operational Kittiwake Management Plan. The approach to collecting the data may involve collecting information on the number of nests, location of nests, attendance rates, check feeds and productivity in different nesting areas. This data collection would be undertaken by the warden. 

  • Sources of disturbance

–      Community engagement will be central to the success of these compensatory measures, and an approach which seeks to understand why people are visiting Dunbar Harbour and that takes their needs into account (alongside those of the Kittiwakes) is considered more likely to result in long-term success. This approach would also accommodate the goals of DHT (as discussed in section 4.2), who are an engaged stakeholder in this work.

–      The warden will engage with both fishermen and other users of the harbour as well as the general public to identify sources of human disturbance noting publicly accessible areas and proximity to nests, offshore recreational use of the harbour and surrounding waters, vessel movements in harbour as well as identifying sources of litter in both castle area and within the harbour. This information will be needed to determine how various types of disturbance may be impacting birds, and to establish how these may be tackled.

  • Constraints to kittiwake habitat

–      A better understanding of productivity across the different sub-colonies in Dunbar Castle will be needed to understand how successful each of the sub-sites are before habitat enhancement could be considered. Productivity data from other locations such as the rocky outcrops, the magazine and the cliffs are needed to assess whether similar problems occur and whether habitat enhancement in the form of more ledges higher up would be of benefit in these specific areas.

–      Collecting information under the above two workstreams will help to identify constraints to kittiwake habitat (be it through proximity to sources of disturbance or use of litter within nests for example), potential habitat areas which could be enhanced and potential further nesting spaces.

–      The warden will identify currently used nesting areas as well and potential nesting areas and the suitability of these for enhancement.

Kittiwake Management Plan

  1. In advance of baseline data collection, a Kittiwake Management Plan will be prepared. This will outline the measures to be implemented, the actions to manage human disturbance, the actions to enhance habitats and the protocols to follow to monitor the kittiwake colony. The Kittiwake Management Plan will set out how the success of each element will be monitored and measured themselves so that the benefits of the compensation can be quantified. This Kittiwake Management Plan will be consulted on with NatureScot, RSPB, ELC, HES and DHT to ensure all proposed management measures can be feasibly implemented and monitored.
  2. Once the warden has undertaken baseline data collection they will prepare an Operational Kittiwake Management Plan, based on the approved Kittiwake Management Plan. As shown in Figure 3   Open ▸ , the Operational Kittiwake Management Plan will be updated during the operation phase of the Proposed Development (currently expected to be annually, based on the outcomes of monitoring (as discussed in section 4.4) and produced following analysis of baseline data so that effort can be targeted strategically. This process helps ensure that the concept of adaptive management is central to the design and evolution of the project. Any actions taken would be transparent and made available to other Harbour users. Further details on the approach to monitoring and reporting is provided in section 4.4.
Figure 3 :
Adaptive Approach to Implementing Compensatory Measures at Dunbar Castle

Figure 3 Adaptive Approach to Implementing Compensatory Measures at Dunbar Castle

 

  1. Subject to the collection of baseline data, the Operational Kittiwake Management Plan may include the following measures to manage human disturbance as well as actions to enhance kittiwake habitat:
  • Actions to manage disturbance

–      The warden will engage with both the harbour users (including fishermen and recreational users) as well as the general public. One of the umbrella roles of the warden will be providing education to the general public and liaison with fishermen. This will be carried out to address both human disturbance and marine litter, with an aim to engender a sense of connection to and ownership / conservation of the Kittiwake colony. Education/liaison may include:

  • Visits to local schools;
  • Provision of tours to the colony;
  • Information provision to tourists;
  • Improving public awareness of the colony through social media (led by ELC with input from the warden);
  • Warden to be on site at the Castle Battery in the tourist season at specific times with a telescope to provide opportunities for both visitors and members of the local community to see the birds and learn more about them;
  • Liaison with fishermen and a representative of the fishing community to be kept aware of what is happening within the harbour, have a clearer understanding of what the issues are, and also what will be expected from them and why; and
  • Codes of conduct could be developed with local groups if required.

–      The warden will reduce human disturbance at Dunbar castle through the following mechanisms:

  • Restricting access to the front face and entrance stepway on the south side of the harbour;
  • Fencing off the green in front of the steps to add a buffer between the kittiwakes and the public;
  • Keeping watch and stopping children throwing stones at the kittiwakes nesting;
  • Education and liaison (as above).
  • Actions to manage kittiwake habitat

–      The warden will reduce fishing litter / debris from nests at Dunbar castle through the following mechanisms:

  • Removal of plastic from nest sites over the winter (i.e. outside the breeding season), clipping any trailing net or rope and removal of small pieces of plastic (complete removal is not possible as the nests are used annually) – this would include liaising with ELC and the Conservation Officer to handle the building’s historic status, and support from a climber for hard to access areas (if required).

–      Kittiwake habitat enhancement will be undertaken using the following mechanisms

  • This measure may include adding artificial ledges and overhangs in certain areas (in winter), ensuring these are the correct size to prevent access from herring gulls; and carried out through liaison with stakeholders. After the Castle and Inner Castle, the Magazine is considered the next best nesting area. It should be noted that any habitat enhancement will be undertaken outside of the breeding season to avoid further disturbance.
  • In view of the historic value of the site, further liaison would be required involving the local Conservation Officer to agree an acceptable plan for the work. These areas are also challenging to access, so skilled contractors would be required. These details will be discussed with the relevant stakeholders post-consent to inform the detailed plan.

4.4. Monitoring and Reporting

Approach to Monitoring

  1. Successful implementation of the compensatory measures will contribute to improving both the number of birds nesting at Dunbar and their breeding success. Monitoring of the colony will be undertaken to show whether the various compensatory measures outlined in section 4.3 have been successfully implemented and progress is being made towards reaching the conservation target (as outlined in section 4.1).
  2. Alongside the production of the Kittiwake Management Plan a Monitoring Plan will be developed. This will outline how the warden will monitor both the kittiwakes and their nests, as well as activities causing pressure to the birds. Progress indicators will be included in the Monitoring Plan to allow the warden to determine the success of each compensatory measure.
  3. The list below details the type of approach that could be undertaken as part of the Monitoring Plan to assess and quantify the benefits of both the proposed compensatory measures. This list provides some detail on the monitoring principles and approach that could be adopted and tailored as the project progresses. Examples include:

 

  • Monitoring kittiwake colony (these align with the disturbance monitoring proposed below)

–      Annual colony counts

–      Mapping of nest locations

  • Mapping exercise to look at the spatial distribution of different types of disturbance around the harbour in relation to nesting areas
  • Identify overlap areas and investigate potential solutions e.g. relocation of activities if possible

–      Productivity monitoring

–      Chick provisioning, this could be monitored effectively using cameras (see below), which could be positioned to cover several nests

–      Monitor presence of litter within kittiwake nests

  • Monitoring disturbance

–      Monitor activities and their frequency of occurrence

  • Look for whether there are more nests and/or more successful nests in less disturbed areas. Look at whether specific activities elicit responses from the birds.

–      Monitor number of disturbance events with and without warden present (model experiment design on Liley and Panter 2017)

  • Assess and quantify the extent to which warden presence is effective in reducing disturbance. (If warden presence is not effective, then the reasons for this need to be evaluated as a part of the adaptive management procedures, as discussed in section 4.6).

–      Monitor response of birds to different activities

  • Test whether specific activities are more disturbing and then investigate why (e.g. is it because they are loud, or because they are conducted close the colony?

–      Monitor number of nests and nest productivity in disturbed and less disturbed areas

  • Test whether there are more nests in less disturbed areas.
  • Test whether productivity is higher in less disturbed areas.

–      Monitor effectiveness of fencing/restricting access to problem footpaths in reducing disturbance

  • Restrict access to one of the key footpaths and monitor number of nests and productivity
  • Test whether productivity improves using existing data as a baseline.
  • Look at whether the number of nests increase in areas where access has been restricted.

–      Monitor number of disturbance events from local children

–      Test whether disturbance events from local children reduce as the project progresses

  • Arrange school visits and continue to monitor during the project lifetime

–      Count visitor numbers at public engagement initiatives

  • Test whether visitor numbers at engagement events increase

–      Undertake social media campaign and surveys of visitors ask them to score their interest in the Kittiwake colony (along with other potential reasons for visit).

  • Look at the level of interest people express in the Kittiwakes during surveys and test whether this increases as the project develops over time.

 

  1. The Applicant is committed to digital transformation and where appropriate applying innovative approaches to implement and monitor compensatory measures. One such opportunity for digital innovation for the measure proposed to be implemented at Dunbar Castle is with regards to monitoring the kittiwake colony. The Applicant has held discussions with the Scottish Seabird Centre, East Lothian Council, Dunbar Harbour Trust and FSG about installation of monitoring equipment at key nesting locations within Dunbar Castle and providing a live feed to within the Seabird Centre. The cameras would record footage throughout the day, and use a new technique to count birds using artificial intelligence (AI) and image-recognition technology. This would help minimise disruption to birds’ breeding and feeding habits as this is less invasive than traditional monitoring approaches and is more efficient and accurate, saving the warden many hours physically watching nests.
  2. The data would collect information on nest residency time and how often there is disturbance for example. It should be noted that camera installation would be undertaken in the winter period following best practice guidance. This builds upon a successful trial of this technology between SSE Renewables, Microsoft, Avanade and NatureScot whereby the AI was used to count puffins in the Isle of May. The Applicant will continue discussions with their partners and other stakeholders in 2023 and implement a trial of the technology in advance of baseline data collection to ensure the technology is in place and running in time for undertaking the first year of monitoring, as outlined in section 4.5.

Approach to Reporting

  1. The monitoring outlined above should be considered as progress indicators to be used to measure the implementation of measures against the outcomes of monitoring and this will be detailed in annual monitoring reports.
  2. It is inevitable that the list of compensatory measures required will vary somewhat between years: for example, removal of plastic from nests may not always be required annually, and therefore could be carried out less frequently. Therefore, at the end of each year an annual report will be produced. The annual monitoring report is likely to follow this structure:
  • Overview of the results from monitoring each compensatory measure

–      Colony counts

–      Mapping nest locations

–      Productivity monitoring

–      Chick provisioning

  • Actions delivered

–      Actions to manage human disturbance

–      Actions to manage kittiwake habitat

  • Identification of emerging issues
  • Approach to implementation for the following year
  • Approach to monitoring for the following year 
  1. The annual monitoring reports and data collected will be shared with key stakeholders including ELC, DHT, NatureScot, RSPB, Scottish Seabird centre and FSG and all data collected made publicly available where appropriate. The results of the monitoring report will be used to update the Operational Kittiwake Management Plan and subsequent implementation of measures on an annual basis as shown in Figure 3   Open ▸ .

4.5. Programme for Implementation and Delivery

  1. Programme 3 below presents the indicative programme for the implementation and delivery of the Dunbar Castle wardening role compensatory measure. This programme provides a timetable for implementation and delivery of the compensatory measures, as well as a monitoring and reporting schedule.
  2. The objective of the compensatory measures is to put the colony on a trajectory towards recovery to 2020 levels. The success of this measure will be reviewed on an ongoing basis and will be continued if it is demonstrated to be effective. Should monitoring show the measures do not deliver as expected then various adaptive management approaches (as outlined in section 5) will be considered.

4.6. Adaptive Management

  1. It is recognised that the issues facing kittiwakes at Dunbar Castle may change over the lifetime of the project and the Applicant is committed to take appropriate action should measures fail to work as expected.
  2. In the event that monitoring shows that the compensatory measures have not reached their objectives new measures would be developed or adaptions made to each proposed measure. Key to the success of this approach is for the warden to identify emerging issues, and where necessary gather data and develop adaptive management solutions and corrective measures. These corrective measures would be developed as a result of monitoring (as outlined within each annual Monitoring Report), included within the annual update of the Operational Kittiwake Management Plan, and subsequently be implemented and then monitored. This approach is shown graphically in Figure 3   Open ▸ . These corrective measures could include increasing intensity of visitor/public engagement, changing warden watch hours to stop significant disturbance events at different times of day, provision of additional nesting habitat in more favourable locations than currently used by kittiwake, closure or diversion of different footpaths / accessible areas in proximity of nesting areas or additional signage to inform visitors, for example.
  3. This iterative and adaptive approach to implementation and monitoring is key to achieving the objectives of the compensatory measures at Dunbar Castle.
  4. In addition to adaptive management measures which are specific to kittiwake management in Dunbar Castle, the Applicant has also taken a tiered approach to adaptive management measures considering the package of compensatory measures proposed within this document. Consideration of tiered approach to adaptive management is presented in section 5.


5. Adaptive Management

  1. Whilst the Applicant is confident all compensatory measures can be successfully implemented, and achieve their conservation targets to increase seabird populations (for which significant evidence has been collated to support this (CCM FCM Evidence Reports)), three approaches to adaptive management have been developed by the Applicant so appropriate action can be taken in the event that monitoring shows the compensatory measures are not progressing towards their conservation targets. These three approaches are:
  • Built in adaptive management;
  • Secondary compensatory measures; and
  • Strategic adaptive management.

Built-in Adaptive Management

  1. The Applicant has outlined adaptive management measures through this document (which are specific to each compensatory measure) to be implemented if monitoring demonstrates that the proposed measures have not delivered the required amount of compensation. The approaches to this form of adaptive management are built into each compensatory measure.

Secondary Compensatory Measures

  1. A list of secondary measures proposed as adaptive management are presented on a highly precautionary basis. The secondary measures comprise measures that have been developed as part of the compensatory measure selection process undertaken by the Applicant in addition to a range of measures that are currently being developed in collaboration with other groups within strategic forums. The Colony Compensatory Measures Evidence Report outlined a ‘long list’ of potential compensatory measures, divided into three Tiers:
  • Tier I: Measures that are agreed to be beneficial, were generally viewed positively, and which can be implemented within the short term
  • Tier II: Measures that are agreed to be beneficial, but which are difficult to quantify, or which would require a further data-gathering stage prior to implementation.
  • Tier III: Measures which were discussed as a part of the consultation process, but which were not progressed due to lack of support from SNCBs and/or regulators, but which may still have the potential to deliver some compensation benefit.
  1. Should any of the Tier I measures demonstrate no compensation benefit the Applicant will explore the Tier II measures further as they are considered to be beneficial and of potential value as compensation but have not been developed at this time. If these measures were to be progressed an updated version of the implementation and monitoring plan would be produced.
  2. Another secondary measure has been developed by the Applicant to a highly advanced stage, Rat Eradication and Biosecurity at Inchcolm. A complete account of this measure is provided within section 5.1, although it should be noted that further stakeholder consultation would be required before this specific measure could be secured and the intention would only be to take this measure forward as a secondary, adaptive management compensatory measure if required.

Strategic Adaptive Management

  1. The Applicant recognises the importance of strategic compensation and adaptive management to ensure overall coherence of the national site network, particularly in the Forth and Tay region. A strategic approach is particularly important in the marine environment due to the connectivity of marine ecosystems, as well as spatial pressures from climate change and other marine industries.
  2. SSE Renewables (which wholly owns the Applicant) is a member of the Offshore Wind Industry Council’s Derogation Subgroup (OWIC DS) and has already contributed to the knowledge base on which the OWIC-led strategic pilots will be based. The Applicant will continue to support and contribute to the knowledge base for any OWIC projects at an appropriate level to offset any impacts from the Proposed Development.
  3. It is understood that a Marine Recovery Fund (MRF), will be set up by Defra’s Offshore Wind Environmental Improvement Package. which will be fully functional and available to offshore wind developers in late 2023. The MRF is operated by Defra pursuant to the Offshore Wind Environmental Improvement Package of the British Energy Security Strategy (April 2022) for the implementation of strategic compensation for the offshore wind industry. The Applicant will contribute to this as appropriate throughout the lifespan of the Proposed Development if further compensation is required.

5.1. Secondary Compensation: Rat Eradication Inchcolm

  1. This compensatory measure proposes to eradicate the black rat Rattus rattus, and undertake biosecurity measures and seabird management at the island of Inchcolm. The objective of this measure is to increase kittiwake Rissa tridactyla, Atlantic puffin Fratercula arctica, guillemot Uria aalge and razorbill Alca torda populations on the island through the removal of this predation pressure.
  2. Inchcolm was chosen based on delivery and connectivity of the seabird populations within a wider island site network within the Firth of Forth. Inchcolm has been recognised as a priority island for restoration (Ratcliffe et al. 2009). With the removal of black rats on Inchcolm, biosecurity measures and monitoring must be implemented to prevent re-invasion as part of this compensation package. The eradication at Inchcolm will involve several stages; pre-eradication preparation (field studies, operational planning and biosecurity planning) eradication and intensive monitoring, improvements to seabird nesting habitat (where required), monitoring, reporting and adaptive management.
  3. The number of birds present on Inchcolm is extremely low both relative to other unmanaged non-SPA islands, such as Inchkeith, and relative to the other rodent-free Forth Islands, and it is likely that this could be due to the presence of black rat. Information on the ecology and seabird populations of Inchcolm has been collected for a long period by the Forth Seabird Group (FSG), Forth Islands Heritage Group (FIHG), and various individuals. This compensatory measure will provide the opportunity to measure the rate of seabird recovery after the eradication of black rats. The opportunity for seabird restoration on Inchcolm post-eradication is likely to be successful; current seabirds (such as puffins, razorbills, and guillemots) could expand their range density and therefore prospecting species could establish on Inchcolm.
  4. The Applicant has undertaken a nesting habitat assessment to determine the quantity of available habitat for each of the key species, this provides a starting point to establish the number of birds that could theoretically nest on Inchcolm. The habitat assessment currently represents the best available information on the restoration potential of Inchcolm, and for this reason these numbers have been used to generate conservation targets. The conservation target of this compensatory measure is to increase kittiwake, Atlantic puffin, guillemot and razorbill populations on Inchcolm to 478, 510, 258, and 186 adult birds respectively throughout the operational lifetime of the Proposed Development.
  5. Further information regarding this compensatory measure is provided in section 2 of the CCM Evidence Report.

Securing and Implementing the Compensatory Measure

  1. ed The Applicant has undertaken engagement with HES, who have indicated if eradication was to progress on Inchcolm both internal and external consultation would be required in advance of implementing any compensatory measure. If this secondary compensatory measure was required to be implemented as a result of adaptive management, the Applicant would facilitate this engagement as part of a communications and stakeholder engagement strategy (as detailed below).
  2. This secondary compensatory measure would involve various stages comprising pre-eradication monitoring, eradication, implementing biosecurity, post-eradication monitoring (both in the immediate term and long term), seabird monitoring, seabird habitat management and implementing an incursion response plan in case of re-incursion. As such there different approaches would be required to secure and implement the various stages. It should be noted that the Applicant will fund this compensatory measure, including continued management of biosecurity, and any eradication associated with re-incursion events during the operational lifetime of the Proposed Development.
  3. Inchcolm Island is a Scheduled Monument. The monument consists of the whole island of Inchcolm, comprising the following principal elements: the remains of the Augustinian Abbey of Inchcolm, a hermit's cell, and the remains of World War I and World War II defences, together with miscellaneous associated remains. However, with careful design and the use of non-invasive installation techniques, the Applicant does not anticipate a requirement for consent under s. 2 Ancient Monuments and Archaeological Areas Act 1979. If consent is required, an application would be made to Historic environment Scotland (HES). As non-invasive installation techniques would be used to avoid any structural change to the scheduled monument, the Applicant does not foresee any impediments to gaining such permission.

Implementation Mechanisms

  1. Rat eradication at Inchcolm will be implemented in four stages. Each stage is comprised of several sub-tasks, as outlined below. It should be noted that all stages will be designed to be compatible with the Biosecurity for LIFE guidance[3]. The Applicant will develop, manage and implement each of these stages with input from specialist eradication experts and HES as required.
  • Pre-eradication stage

–      Communications and Engagement Strategy

–      Habitat Assessment

–      Feasibility Study

–      Operational Plan

  • Health and Safety Plan
  • Non Target Species Management Plan
  • Waste Management Procedures

–      Pre-eradication Field Studies

  • Eradication Preparation
  • Seabird Census
  • Vegetation Assessment
  • Predation Monitoring

–      Mitigation for loss of black rats (if required)

–      Establish Biosecurity Plan

  • Eradication and intensive monitoring

–      Establishment of rodenticide grid

–      Rodenticide baiting

  • Improvements to seabird nesting habitat (where required)
  • Monitoring, reporting and adaptive management

–      Monitoring and Evaluation Plan

Pre-Eradication

Communication and Engagement Strategy
  1. Extensive consultation has already been undertaken by the Applicant as part of the habitat assessment and feasibility studies, however it is recognised if this secondary compensatory measure was to be implemented further consultation would be required, particularly with HES, which the Applicant would facilitate.
  2. Once plans and further studies are undertaken, as described below, key stakeholders would have the opportunity to comment on the planning and requirements of the eradication and ongoing biosecurity and be engaged throughout the operation of the compensatory measure.
  3. Stakeholders would be informed about all aspects and stages of the compensatory measure and engaged throughout the implementation, and monitoring stages of the project. To facilitate this, a Communication and Engagement Strategy would be prepared to ensure stakeholders are kept engaged and informed.
  4. This strategy would outline the approach to communicating and engaging with stakeholders, members of the public, users of Inchcolm and the media regarding the eradication, biosecurity, monitoring and subsequent biosecurity measures. Some examples of information that this could include are:
  • Using key applicable information from the Campaign for Responsible Rodenticide Use (CRRU) which have developed a good practice leaflet on the use of rat poison and the threats to wildlife (CRRU 2021). This leaflet outlines methods to prevent rodent infestations, methods to control rats, information on trapping, rodenticides and resistance and the dangers to wildlife (particularly raptors and other birds of prey) for the general public.
  • Strategy to engage with the ferry service and visitors to the site regarding the purpose of eradication and the implementation of biosecurity measures
  • The erection of information boards and notices on Inchcolm to notify people of the programme and provide warnings and risk information regarding the bait stations and the presence of rodenticides.
  • Clear warning signs (detailing the eradication, bait station design and danger from bait) would be placed on Inchcolm at all suitable landing beaches. Warning labels would be placed on all bait stations advising visitors not to touch the stations or bait.
  1. Whilst the Communication and Engagement Strategy would be developed at the outset of the project, it would be updated and adapted during the lifetime of the measure, depending on outcomes of the eradication programme and the implementation of biosecurity measures.
Habitat Assessment
  1. The Applicant has undertaken trapping to confirm the presence of black rats on Inchcolm and to establish whether there are any other invasive mammalian predators. The Habitat Assessment assesses the numbers and distribution of rats on the island, the accessibility of the cliff faces, confirmed the abundance of black rats on Inchcolm, and also the extent to which black rats are likely to be impacting key bird species. An assessment of nesting habitat available to key species as well as a seabird colony assessment has also been undertaken.
  2. Each of these initial habitat assessments have confirmed that eradication of black rats is a feasible option to increase seabird numbers on Inchcolm and therefore a Feasibility Study was undertaken to inform the production of a more detailed project plan, as discussed below.
Feasibility Study
  1. A Feasibility Study has been undertaken against the following seven key feasibility criteria described in the UK Rodent Eradication Best Practice Toolkit (Thomas, Varnham, and Havery, 2017):
  • Technically feasible
  • Sustainable
  • Socially acceptable
  • Politically and legally acceptable
  • Environmentally acceptable
  • Have capacity (requirements to carry out eradication), and be
  • Affordable (estimate costs for full eradication).
  1. The Feasibility Study identified good opportunities for the target seabird species (kittiwake, razorbill, guillemot, and puffin) to breed more successfully on Inchcolm following an eradication of predatory black rats. Information from this study would inform the preparation of an Operational Plan to deliver and implement the eradication programme, and the associated monitoring, reporting and adaptive management required both for the eradication programme and seabird habitat enhancement.
Operational Plan
  1. In advance of commencing an eradication programme an Operational Plan would be developed. The Operational Plan may include the following information
  • Scope and method statements
  • Approach to permitting
  • Organisational arrangements
  • Health and Safety Plan

–      A detailed information sheet outlining the hazards associated with the proposed rodenticide would be prepared for the eradication team as part of the Health and Safety plan prior to operation

  • Requirements of Control of Pesticides Regulations 1986
  • Safe working procedures
  • Emergency preparedness
  • Waste management.(It is important that alternative food is not available to rats on Inchcolm during the eradication. Waste would be collected by the eradication team and transported back to the mainland for disposal. Waste bait, rat carcasses and used monitoring tools should be disposed of at a registered landfill or incineration facility).
  • Specialist subcontractor engagement (rope access and horticultural services),
  • Mitigation planning
  • Non-target species management plan
  • Approach to adhering to Communication and Engagement Strategy
  • Long term monitoring and biosecurity planning.
  1. A number of Health, Safety and Environmental requirements would need to be met prior to the operational phase of the proposed eradication. These include, but are not limited to, Animal Ethics approval to undertake key species research and monitoring, training of operational staff in rodent control (as required), and confirmation the operation is valid under the Control of Pesticides Regulations 1986. The Applicant would ensure these requirements are adhered to in advance of commencing eradication and does not consider there would be any impediment to obtaining these approvals due to the proposed approach following the Biosecurity for LIFE guidance which has been successfully implemented in other islands.
  2. As part of the Feasibility Study the proposed rat eradication operation on Inchcolm was assessed using the internationally recognised ethical principles of Humane Vertebrate Pest Control developed by the Royal Society for the Prevention of Cruelty to Animals (RSPCA) Australia (Humane Vertebrate Pest Control Working Group, 2004). The proposed eradication operation satisfies all the criteria of the Humane Vertebrate Pest Control principles.
  3. The subsections below provide more detailed information on some of the above aspects which could be included within the Operational Plan.