SCEILG MHICHÍL World Heritage Site Report to UNESCO on Film Production Activities Undertaken at the World Heritage Property in September 2015 Contents 1. Introduction3 2. Proposal for Film Production at Sceilg Mhichíl ...................................................................................................3 2.1 Approach by Film Production Company ............................................................................................................3 2.2 Supervision and Monitoring of Production Activities ........................................................................................4 3. Archaeological/Built Heritage Report .................................................................................................................6 3.1 Report on Specific Works and Related Impacts .................................................................................................6 3.1.1 Locations between A and C (See Fig. 1) - Boat Landing to base of South steps to the Monastery ..............6 3.1.2 Location D – Lighthouse .............................................................................................................................7 3.1.3 Locations E –Lighthouse Platform and Wailing Woman................................................................................. 7 3.1.4 Location F - Base of steps to Saddle ..........................................................................................................9 3.1.5 Locations G - Christ’s Saddle ......................................................................................................................9 3.1.6 Locations H - Upper Monks' Garden ...................................................................................................... 110 3.1.7 Locations I – Monastery ........................................................................................................................... 11 3.1.8 Locations J Bedrock Above Monastery ......................................................................................................... 11 3.2 Note on Camera Positions ............................................................................................................................... 12 3.3 Note on maintenance: .................................................................................................................................... 12 3.4 Note on Preparation of Set at Wailing Woman ............................................................................................... 12 3.5 Note on Anchor Points: ................................................................................................................................... 13 4. Natural Heritage Report ................................................................................................................................... 13 4.1 Introduction .................................................................................................................................................... 13 4.2 Report on Specific Works and Related Impacts ............................................................................................... 13 4.2.1 General Impacts .................................................................................................................................... 143 4.2.2 Boat transport to the Island..................................................................................................................... 14 4.2.3 Helipad and Helicopter Usage ....................................................................................................................... 14 4.2.4 Locations C – Base of South Steps; E – Wailing Woman; G - Christ’s Saddle; H – Upper Monks’ Garden; I – Monastery ........................................................................................................................................................ 14 5. Conclusions…………………………………………………………………………………………………………………………………………………...15 Appendix 1 Letter from National Monuments Service Appendix 2 (a) Screening for appropriate assessment submitted by the film company Appendix 2 (b) Ecological and Screening Assessment undertaken by the Department Appendix 2 (c) Consent Appendix 3 Incident Report on Paint Spill Appendix 4 Incident report on minor disturbance to entrance to Upper Monks’ Garden. 2 Appendix 5 Report from National Parks and Wildlife Service on filming activity on Sceilg Mhichíl in September 2015 1. Introduction The Skellig Rocks, Sceilg Mhichíl (also known as Skellig Michael or Great Skellig) and Little Skellig, are sea crags rising from the Atlantic Ocean almost 12 km west of the Iveragh Peninsula in County Kerry. In 1996 UNESCO inscribed the island of Skellig Michael onto the World Heritage List in recognition of its outstanding universal value. The inscription was made on the basis of cultural criteria (iii) and (iv) considering that the site is of outstanding universal value being an exceptional, and in many respects unique, example of an early religious settlement deliberately sited on a pyramidal rock in the ocean, preserved because of a remarkable environment. It illustrates, as no other site can, the extremes of a Christian monasticism characterizing much of North Africa, the Near East and Europe1. 2. Proposal for Film Production at Sceilg Mhichíl 2.1 Approach by Film Production Company Bord Scannán na hÉireann (the Irish Film Board), an agency of the Department of Arts, Heritage and the Gaeltacht, promotes Ireland as a location for international film production and provides support to companies engaged in filming activities on location in Ireland. The Board was contacted earlier this year by representatives of the producers of a major feature film to establish whether the Sceilg Mhichíl world heritage site could be used for certain limited filming activities in 2015 in light of the sensitivity of the site from a cultural and natural heritage perspective. Many world heritage sites have been used as locations for major film and television productions, for example Al Khazneh in Petra, Jordan; Dubrovnik, Croatia; Aït Benhaddou, Morocco and the Redwood National and State Parks, California, USA). , Similar filming work had previously been undertaken by the same producers on Sceilg Mhichíl in 2014 with the necessary statutory consents from the Department of Arts, Heritage and the Gaeltacht (which also owns the island on behalf of the State). The nature, extent and logistics of what was proposed for 2015 was broadly similar to what had previously taken place in 2014. One notable departure, however, was that the 2015 proposals were scheduled for September, rather than July/August as in the previous year. This is a fundamental difference from an ecological perspective as many breeding seabird species have left the island or completed their breeding cycle by September. The proposal was referred to the Department’s: National Monuments Service (NMS), the competent authority in relation to the assessment of impacts on built and cultural heritage, and National Parks and Wildlife Service (NPWS), which is, inter alia, responsible for the assessment of effects on natural heritage in Special Protection Areas (SPA’s) - important sites designated for bird species. A detailed method statement was provided by the producers and a series of protection measures and protocols in relation to the cultural and natural heritage on the island were drawn up and agreed with them by the Department, including full on-site supervision by State personnel of all activities undertaken by the film crew (covering preparatory works, filming and removal). There was extensive interaction with the Department in relation to natural heritage over a number of 1 http://whc.unesco.org/en/list/757 3 months, and particularly with regard to the detailed design of the project and draft proposals. The proposed project, its design, possible impacts and protection measures were the subject of in-depth review by NPWS in respect of both seabird and SPA interests (constituting inter alia a screening assessment), as well as other elements of biodiversity of the Islands. The Department requested the proposers to undertake a detailed counting programme of all seabirds on Skellig Michael in order to collect site specific data which could inform any assessment. The proposal was also referred to the Office of Public Works (OPW), which is statutorily charged with the management, operation and maintenance of all national monument sites (including Ireland’s two world heritage sites) in the ownership of the Minister for Arts, Heritage and the Gaeltacht. The proposal and method statement produced by the film company was approved by the OPW conservation architect responsible for Sceilg Mhichíl and by NPWS on foot of an Ecological Assessment (constituting inter alia a ‘Screening Assessment’). The OPW visitor guides (normally charged with escorting visitors on the island) and NPWS scientific and technical staff were tasked with implementing agreed arrangements for supervising and monitoring the activities of the film crew on the island for the duration of the project. Preparations for filming began on the afternoon of Monday, 7 September 2015, involving the shipping of equipment to the island. Filming proper was commenced on Tuesday, 15 September, and concluded on Thursday, 17 September. All equipment and other material used by the film crew were removed from the island by Friday, 18 September 2015. 2.2 Supervision and Monitoring of Production Activities All works on Sceilg Mhichíl were monitored by Grellan D Rourke, Senior Conservation Architect, National Monuments Service (OPW), and Bob Harris, Head Guide (OPW). Mr Rourke was directly responsible for all cultural heritage on the island. Declan O' Donnell, Clare Heardman, Michael O’Sullivan, David Tierney and Philip Buckley of the Department’s NPWS monitored the works throughout, including during filming: to ensure that the conditions and Protection Protocols incorporated into the design of the proposal and the consent granted were adhered to, and with a view to avoiding any potential impacts on the breeding birds of the island. An ornithologist and ecologist employed by the film producers were also in full-time attendance. OPW’s Head Guide, who remained on the island throughout the entirety of the project, was tasked with direct liaison with the film crew, in consultation with other OPW and NPWS personnel on site, to ensure that any potential impacts to either the cultural or natural heritage were avoided. NPWS personnel similarly monitored all activities on the island throughout (and inspected biosecurity arrangements, including on the mainland). NPWS officers had the authority to halt or modify any of the filming or any activities at any stage (this was a condition of the Consent). No archaeological consent was required under the legislation governing the protection of archaeological heritage, the National Monuments Acts 1930 – 2004, as no works were contemplated or carried out that would have come within the scope of the consent framework. A copy of the letter to that effect issued to the producers is included as Appendix 1. Consent was, however, needed and granted under the European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. 477 of 2011) and the European Communities (Conservation of Wild Birds (Skelligs Special Area of Conservation 004007)) Regulations 2010 (S.I. 74 of 2010). A copy of (a) Screening of appropriate assessment submitted by the film company; (b) the Ecological and Screening Assessment undertaken by the Department and (c) the Consent issued is attached at Appendix 2a, Appendix 2b and Appendix 2c. 4 Figure 1 pinpoints the main areas of activity in relation to the film production on Sceilg Mhichíl. The areas of activity are designated A – J and these locations are referenced in the main sections of the report dealing with archaeological/built heritage and natural heritage. 5 3. Archaeological & Built Heritage Report Following receipt of the Natura Impact Statement and method statement from the film company the Department’s NMS, in conjunction with the OPW managers of the world heritage site, undertook a full review of the proposals with a view to identifying and eliminating any potential negative impacts on the archaeological monuments on Sceilg Mhichíl. The OPW personnel responsible for managing the world heritage site accompanied the film crew when they visited the island on Tuesday, 1 September, to discuss logistics and the proposed locations for the filming. The professional ornithologist engaged to advise on the film production was also in attendance. The proposals focused on the following locations - the Wailing Woman, the base of the long flight of steps to the Christ's Saddle, the Saddle itself, the flight of steps above the Saddle and a location above the Monastery. No filming was proposed in the vicinity of any of the monastic structures other than the steps. Discussions also took place in relation to the appropriate number of film crew required to be on site and the position of any temporary structures, as in the previous year. Subsequent to this meeting, OPW manager met film representatives on the mainland on Friday, 4 September, to discuss any outstanding issues, including: Inspection arrangements for cargo being taken out to the island, safety set-up, separation from historic structures, removal and reinstatement of fencing on the Saddle, issues of marshalling, activities on the Saddle. The final method statement accommodated the Department’s and OPW's observations in relation to crew and temporary structures. The producers also undertook to be bound by the directions of OPW and Departmental personnel in relation to the location of temporary structures and the minimising of the impact of camera positions, etc. 3.1 Report on Specific Works and Related Impacts 3.1.1 Locations between A and C - Boat Landing to base of South Steps All loads were brought by cargo boat to the landing pier (point A) and all cargo was transported by hand by rope access specialists to point C (the base of the South Steps). Some material was stored at point B (lighthouse store by helipad) and on the lighthouse road. Two portaloos were set up just west of the landing on a rock surface. There was temporary storage at point C. Any material left overnight was stored more than 1.2m away from any built structure to avoid damage and to allow the ingress and egress of night birds nesting in the walls. Duration: 7 days Impact: None 6 Storage of material on the lighthouse road before filming. On three days a small area (point C) was set aside to handle catering. Catering area at point C 3.1.2 Location D - Lighthouse Loads were brought by hand by rope access specialists and stored in the Lighthouse (point D). Material included cameras, lights, film and some catering supplies. Security was dealt with by the Commissioners of Irish Lights. A brief period of filming (without actors) took place on Thursday, 17 September, from this area looking up towards the Upper Lighthouse Road. Duration: 8 Days and a number of hours for the filming. Impact: None 3.1.3 Location E - Lighthouse Platform & Wailing Woman Material was carried up to a camp area on the Lighthouse Platform across from the Wailing Woman. All loads were carried by rope access specialists. Duration: 3 days Impact: None 7 Left: The Lighthouse Platform showing light tent and equipment stored thereon and tape marking out access areas. Right: Visitors to the platform on Friday, 18 September, after removal of film material (lhs). The Wailing Woman is an iconic natural rock formation located at the Lighthouse Flagstaff platform where there are remains of a concrete pad and some fixings for metal stays. This flat location was used for filming and the storage of two large props. Storage of materials not being used in filming was located at the aforementioned Lighthouse Platform. Filming took place over a 2-day period at this location. Duration: 6 days Impact: Low in relation to the ground but see report of minor incident below. The Wailing Woman platform area showing protection of prop prior to filming and delineated access areas to avoid any nests and fragile surfaces with little or no vegetation. The Wailing Woman platform area after removal of all props and equipment. 8 Incident Report: In late afternoon, Wednesday, 16 September, a small volume of diluted water-based paint was spilled on adjacent rocks. Highly-absorbent spill pads were used to immediately mop up the spill. Clean water was also applied to further dilute and eliminate the effects of the spill. Used spill pads were double bagged for off-island disposal. An ecologist and ornithologist were present and nests were not compromised in any way. Any remaining light rock discolouration will be monitored and is expected to quickly disappear through weathering. See Appendix 3 for a more detailed account. 3.1.4 Location F – Base of flight of steps to Saddle There was a brief film shoot at the base of this long flight of steps. A small platform was set up under supervision. Duration: 2 days [small platform in place 2 days; filming a few hours] Impact: None Platform in place (lhs) and being removed after filming. 3.1.5 Location G – Christ's Saddle Material was carried up to a camp area at Christ's Saddle. All loads were carried by rope access specialists. Material was kept to a minimum and, as in 2014, there were no heavy loads. The camp area included one tent and an area designated for storage. Materials stored included tools, track, water, props, small generators, etc. All archaeological features and nesting areas were fenced off with hazard tape to confine activities to non-sensitive locations. The central part of the fence on the north side of the Saddle was taken down to allow filming northwards. This was identical to what happened on site in 2014 and the work was supervised. The fence was reinstated by Friday, 18 September, the day the island re-opened to visitors. Saddle showing detail of tape to mark exclusion zones, location of tent and storage area for equipment. 9 A short period of filming (of terrain only), with one cameraman and 2 safety specialists, was permitted on Thursday, 17 September, on an upper section of the North Steps. There was also a brief amount filming from the steps above Christ's Saddle looking down onto the Saddle. Saddle after removal of tent and equipment and reinstatement of fencing on 18 September 2015. Section of fencing removed to facilitate filming on 15 September. 3.1.6 Location H - Upper Monks' Garden Material was carried up to a small camp in the Upper Monks' Garden (point G). All loads were carried by rope access specialists and the camp consisted of two tents. The two tents were located on the remnants of an archaeological spoil heap. All temporary structures were located more than 1.2m away from walls and were also fenced off with hazard tape to isolate the area from nesting birds at the west end of the Garden. Material stored at the site included water, camera equipment, medical equipment and small generators. Duration: 5 days Impact: None in relation to the ground but see report of minor incident below. Two tents were located in the Upper Monks' Garden. These were used for storage including some small generators. Very few of the film crew accessed this area. Incident Report: On the morning of Thursday, 17 September, when materials were being removed from the garden area, a small part of the dry stonework forming part of the inner jamb of the entrance to the Upper Monks' Garden was partially disturbed. The opening was immediately propped by OPW masons and the minor drystone repair effected; the entrance was opened again immediately afterwards. This incident mirrored a similar occurrence in mid-June when the same section of stone was displaced by a visitor to the island, possibly through contact with his/her rucksack. Similar remedial action was taken by OPW masons at that time. See Appendix 4 for a more detailed account. 10 Doorway into Upper Monks' Garden from inside showing partial dislocation of stonework to the interior south jamb and immediate repair by OPW masons. 3.1.7 Location I – Monastery Enclosure: A tent was set up to the west of Cell A at the monastery. All loads were transported by safety specialists to this area. A self-sealed toilet unit was located in the tent. Very few people used this, as they were encouraged to use the toilets below. Duration: A few hours on 2 days – to erect and remove it. Impact: None Storage tent at H to the west of Cell A. This area was not accessed in the end. 3.1.8 Location J - Bedrock above Monastery Ropes were attached to give safe access to this rock area and a safety line was set out, back from the face of the lighthouse wall at the rear of the cells to facilitate access. Duration: A few hours Impact: None 11 Safety line above lighthouse wall en route to an area of rocky outcrop above the Monastery, one of the locations for a shoot. Very few personnel were allowed into this area which was fully supervised. 3.2 Note on Camera Positions Precise details of camera positions are not provided in this report because of commercial considerations. However all positions were recorded both prior to and during filming. All surfaces, particularly paving, were insulated against contact by camera and other tripods by various means, including laying down heavy layers of cloth and use of other protective materials. All camera tracks were levelled using light wooden boxes and wedges. There was no ground disturbance and no cameras were placed on walls. Duration: 3 days Impact: None 3.3 Note on maintenance: As is the case during normal visiting times, the steps were monitored regularly in the course of the filming. The ongoing maintenance required by OPW masons, who are on site throughout the visitor season, i.e. tightening of some individual steps, was consistent with that required on a normal week when visitors are on the island. Duration: 7 days Impact: Consistent with normal visitor numbers 3.4 Note on preparation of set at Wailing Woman It was necessary to dress the set for filming at the Wailing Woman. Small amounts of sea campion (taken from the lighthouse compound area) were used in addition to very small stones (scree – taken from the vicinity of the platform); the stones were put back in their original location after the filming. Duration: 2 days Impact: None 12 3.5 Note on Anchor Points: No new anchor points were drilled. There is an existing network of anchor points for fixing ropes to facilitate the removal of injured personnel or visitors. These have easily removable attachments and, where advised by safety personnel, were utilised by the film crew. Duration: 3 days Impact: None 4. Natural Heritage Report 4.1 Introduction All issues relating to natural heritage impacts were covered in a Ministerial Consent, which related to a proposal and method statement supplied by the film company (see Appendix 2c). Michael O’Sullivan, Clare Heardman, Declan O’Donnell, Dr David Tierney and Dr Philip Buckley of the National Parks and Wildlife Service (DAHG) monitored the works throughout, including during filming, to ensure that the conditions and Protection Protocols were adhered to and to avoid any possible impacts on the birds or their habitats on the island. One, usually two (sometimes more), NPWS officers were present on the island at all times monitoring the activities and with the authority to halt or modify any activities at any stage (this was a condition of the Consent). 4.2 Report on Specific Works and Related Impacts 4.2.1 General Impacts The Skelligs is important for and designated a Special Protection Area for populations of specified breeding seabirds, namely: Storm-petrel, Puffin, Guillemot, Kittiwake, Fulmar, Manx Shearwater and Gannet (latter nesting on nearby Little Skellig, but not nesting on Skellig Michael). The most notable other elements of biodiversity on Skellig Michael are the lichens. The project involved three broad categories of activities in terms of any possible impacts on the biodiversity, namely (1) activities undertaken on the island itself, (2) boat transport to the island, and (3) helicopter usage. Possible impacts were: 1) Transfer of animals/other biota to the island from the mainland (especially potential predators of seabirds e.g. rats); 2) ‘On the ground’ disturbance of birds, particularly at breeding sites; 3) Disturbance of birds by helicopters; 4) Damage to or destruction of birds borrows or breeding habitats; 5) Physical damage to lichens. The final project incorporated a comprehensive range of measures to address potential ecological issues. The main protection measures included: 1) Limiting the seasonal timing of the film project to September. 2) Limiting the daily timing of the filming to avoid overlap with the activity of any remaining nocturnal seabird species. 3) Stringent biosecurity. 13 4) Confining activities to limited and specified areas (and in the main, to areas usually frequented by tourists) and limiting the numbers of persons on the island (did not exceed normal tourist numbers). 5) Identification, marking and avoidance of any sensitive areas for nesting seabirds at the specific location/habitat level; 6) Various Protocols and Controls for movement of film crew and equipment; for storage or placing of equipment; for waste and food; for dusk filming; for helicopter usage; for protection of lichens. 7) Presence of NPWS personnel (and also a Supervising Ecologist and a seabird surveyor (who has been monitoring birds on the island over the breeding season)) - with the authority to stop or modify any filming or other activity. Duration: 9 Days Impact: None 4.2.2 – Boat Transport to the Island Most personnel and equipment involved with the filming were brought to the island by boat (using normal licensed ferries & ports). Any transfer of animals (especially potential predators of seabirds such as rats) from the mainland to a seabird colony would be a significant ecological issue. The consent required that specific and stringent biosecurity protocols were in place. These were adhered to at all times. All equipment and material being transported to the island was inspected before loading/departure from the mainland. Boat transport did not have potential to cause disturbance to the breeding birds or their habitats or other biodiversity. Duration: 9 Days Impact: None 4.2.3 Location B – Helipad and Helicopter Usage The majority of the film crew accessed the island by boat. A limited number of helicopter trips to and from the helipad to transport some of the film crew occurred. The helipad is situated close to an active seabird breeding colony. A helicopter was also used to take film shots on occasion over the course of the 3 days of filming (and under conditions specified in the consent). Breeding activity by all species was completed by the time of the filming. A small number of Fulmars (adult or fledged) were in attendance in the area of the helipad. The reactions of seabirds to the helicopter touchdowns at the helipad and to helicopter usage for filming generally were monitored. The study birds generally remained on the breeding ledges. Any that did take wing returned shortly afterwards. There was no adverse impact on the breeding seabirds. Duration: 3 Days Impact: None 4.2.4 Locations C - Base of South Steps; E - Wailing Woman; G - Christ’s Saddle; H - Upper Monk’s Garden; I – Monastery With the exception of Manx Shearwater and Storm Petrel, all other seabird species had completed their breeding cycle and the majority of these birds had left the island before filming activity commenced. 14 Terrestrial based filming was limited to defined areas. Most, though not all, areas are normally accessible to tourists. All areas were all treated as potential breeding seabird habitats/nest sites, or as having active breeding Manx Shearwater or Storm Petrel (unless there was specific data showing otherwise). In order to prevent damage to the potential breeding habitat and to minimise direct disturbance to any actively breeding seabirds that might be present, protocols for the identification, marking, cordoning off and avoidance of any Shearwater or Petrel nesting sites were followed. Both Manx Shearwater and Storm Petrel are nocturnal at breeding colonies. No filming activity took place after dark, and all film crew had left the island by then. The temporary structures (e.g. tents, equipment) associated with the filming were sited at particular locations that would not impede access from or egress to the breeding sites. Duration: 9 Days Impact: None The design of the project and the Protection Measures and Protocols it incorporated were worked out to explicitly address and avoid any significant damage to the breeding seabirds, the SPA or other biodiversity. NPWS monitored the filming activities throughout. NPWS is satisfied that all conditions and Protection measures were followed in full (and indeed that the project was generally conducted in an exemplary manner). NPWS is satisfied that this filming had no adverse impact on the seabirds or other biodiversity of Sceilg Mhichíl. 5. Conclusions Any potential impacts on the cultural and built heritage of Sceilg Mhichíl by the film production were fully addressed and the Department is entirely satisfied that the activities undertaken had no implications for the Outstanding Universal Value of the World Heritage Property. The natural heritage value of Sceilg Mhichíl is very rich and the island is fully protected by relevant Irish and EU legislation. However, the Department notes that the island’s flora and fauna, while important, are not central to its inclusion on the world heritage list. Notwithstanding the foregoing, the Department is entirely satisfied that no impact was made on the natural heritage of the island, or on any of the approaches to it, and that the activities undertaken as part of the film production avoided any significant damage to the populations of breeding birds present, or any other biodiversity on the island. Ed Bourke ____________ Edward Bourke, Senior Archaeologist, World Heritage Unit, Department of Arts, Heritage and the Gaeltacht, G49, Custom House, Dublin 1 15th October 2015. 15 Philip Buckley _________________ Philip Buckley, Divisional Manager, National Parks & Wildlife Service, Department of Arts, Heritage and the Gaeltacht, Custom House, Flood Street, Galway 16 Appendix 1 Letter of 7 September 2015 from National Monuments Service, DAHG, to Lucasfilm regarding Consent under Section 14 of National Monuments Act 1930 (as amended) Appendix 2a Screening for appropriate assessment as submitted by the film company Appendix 2b Ecological and Screening Assessment of proposed film work undertaken by the Department Skelligs Islands, Co Kerry Ecological and Screening Assessment of proposed film work September 2015 1. Skelligs Islands The Skelligs are two islands that lie about 13km of Valentia Island, Co Kerry. They are red sandstone & slate. Skellig Michael is the larger island (48ha) and the Little Skellig is 7ha. They hold important seabird breeding colonies. Indeed they are recognised as being internationally important for breeding seabirds. Skellig Michael supports several thousand pairs of Storm-petrels (c. 10,000) and Puffin (c. 4,000 pairs), and smaller numbers of Guillemot, Kittiwake, Fulmar, Manx Shearwater and Razorbill, as well as some other seabird species. Little Skellig supports nearly 35,000 pairs of Gannets (one of 6 colonies in Ireland). No Gannets occur on Skellig Michael. The Skelligs are an established Nature Reserve. They are also designated as a Special Protection Area (SPA). The number of other species, and habitats is generally limited as it is an island. The breeding biology (and status, ecology, etc) of seabird species in Ireland and Britain is generally well known and documented. Skellig Michael is also a National Monument and a UNESCO World Heritage Site. 2. Proposed Film Project There is a proposal to undertake filming work on Skellig Michael in September 2015. The Department has now received a formal application (accompanied by an Assessment and Screening Report). There have been meetings and communications with the Department (and others) in regard to this proposed project for a number of months, and particularly in relation to the detailed design of the project and drafts of an ecological and screening report over the last two months or more. The Department requested the proposers to undertake a detailed counting and monitoring programme of all seabirds (not just limited to those for which the islands are designated as an SPA) on Skellig Michael in order to collect site specific, comprehensive & up-to-date data which could inform any report and assessment. Previously in 2014, similar filming work was undertaken on Skellig Michael (having obtained consent from this Department). The nature, extent and design of that film project is broadly, but not exactly similar, to that in the current application. A notable difference is that the work in 2014 was undertaken in July/August, whereas the 2015 request is for September. Ecologically, this is a fundamental difference, as several, but not all, of the breeding seabird species of the Skelligs have left the island or completed their breeding cycle by September. 3. Assessment 3.1 Background As mentioned, there was considerable interaction with this Department (NPWS) re the design of the proposal and the preparation of draft and final Ecological and Screening Reports. The draft proposals and reports were subject to detailed review and comment by scientific and technical staff in NPWS. This included Head of Birds Unit; staff familiar with the island; other NPWS scientific staff; Divisional Manager for Southern Division (an ornithologist; previously Head of Birds Unit). The application now lodged is accompanied by a report. It may be noted that that document not only addresses the SPA (and Article 6(3) Assessment) requirements, but considers other important biodiversity elements also. The Department asked the proposers to follow this ‘best-practice’ approach, and not limit their consideration solely to legal requirements. The proposed project, its design, possible impacts and protection measures has been the subject of in-depth review by us in respect of both seabird & SPA interests (constituting inter alia a screening assessment), as well as other elements of biodiversity of the Islands. 3.2 Biodiversity The Skelligs is designated an SPA for populations of specified breeding seabirds, namely: Storm-petrel. Puffin. Guiilemot. Kittiwake. Fulmar. Manx Shearwater. Gannet (not nesting on Skellig Michael). A number of other species of seabird and terrestrial bird species also occur. The most notable other elements of biodiversity on Skellig Michael are the lichens. The island is considered to be a nationally and internationally important site for lichens. 3.3 Main elements of project The project involves filming on Skellig Michael in specific and defined areas, and generally those areas are used by tourists. Filming is proposed to take place over about a week in mid-September 2015. Preparatory work will take place the week before and removal work the week after. Up to 100 persons may be involved at peak periods (up to 40 during preparatory & demobilisation periods). They, and the equipment, will be transported to the island by boat (most) or helicopter. A helicopter will also be employed during filming. Filming and other activities will take place during daylight hours, or at dusk on occasion. The project involves three broad categories of activities in terms of any possible impacts on the SPA and bird species and other biodiversity, namely (1) activities undertaken on the island itself, (2) boat transport to the island, & (3) helicopter usage. 3.4 Potential Impacts Possible impacts are: 1) Transfer of animals/other biota to the island from the mainland (especially potential predators of seabirds e.g. rats); 2) ‘On the ground’ disturbance of birds, particularly at breeding sites; 3) Disturbance of birds by helicopters; 4) Damage to or destruction of birds borrows or breeding habitats; 5) Physical damage to lichens. 3.5 Protection Measures The proposal in terms of design and execution have at this stage incorporated many measures – both at the overall and a detailed level – to address a comprehensive ranges of potential ecological issues (including, but not limited to, the SPA/SCI interests). The main protection measures include: 1) Limiting the seasonal timing of the film project to September. 2) Limiting the daily timing of the film/other activity so that there is no or very little overlap between filming and that of any remaining seabird species still engaged in breeding activity (i.e. species are nocturnal; filming is during the day or dusk). 3) Stringent biosecurity. 4) Confining the on the ground activities to limited and specified areas. 5) Ensuring, that in the main, film activities, etc are limited to areas usually frequented by tourists. 6) Ensuring that the numbers of persons on the island will not exceed, and indeed will generally be less, than the normal tourist number using the island. 7) Protocols for storage and movement of film crew and equipment. 8) Identification, marking and avoidance of any sensitive areas at the specific location/habitat level; 9) Protocols for storage or placing of equipment (e.g. specified distance from any potential nest sites in walls). 10) Protocols for waste and food. 11) Controls for dusk filming. 12) Controls for helicopter usage. 13) Controls for protection of lichens. 14) Presence of seabird surveyor (who has been monitoring birds on the island over the breeding season) - available to provide advice in relation to location, movements etc of seabirds at the micro or island level. 15) Presence of a Supervising Ecologist – available for any detailed ecological checking, and with the authority to stop or modify any filming or other activity. 16) Presence of NPWS personnel, with the authority to stop or modify any filming or other activity 3.6 Assessment of significance of potential Impacts The potential impacts and their significance on each of the qualifying seabird species for the SPA (and Razorbill) are outlined below. Gannet No Gannets occur on Skellig Michael. No activities will take place on Little Skellig (the Gannet colony) & no direct impacts on the breeding site are possible. The helicopter will maintain a minimum distance of 1km from Little Skellig at all times and therefore is unlikely to cause any significant disturbance to the remaining Gannets. Storm-petrel Given the Ecological Protection Protocols (protocols for identification, marking and avoidance of any petrel nest sites), it is unlikely that there will be any significant loss or damage to petrel nest sites. The species is nocturnal at breeding colonies. Observed activity patterns on the island, recorded no birds flying within one hour of sunset. This relates to adult birds. Even if there were some temporal overlap with fledging birds, it is unlikely that the dusk filming activities will result in any significant disturbance given limited artificial lighting in the area, reduced crew and on the spot DAHG supervision to halt film related activity if deemed excessive. Guillemot Based on on-site observations, Guillemots have now all finished breeding on Skellig Michael and generally have departed the island. Direct disturbance is therefore not an issue at breeding site. No ground-based activities will take place on or near any Guillemot breeding ledges and there can be no adverse impacts on these. Razorbill Based on on-site observations, Razorbills have now all finished breeding on Skellig Michael and generally have departed the island. Direct disturbance is therefore not an issue at the breeding site. No ground-based activities will take place on or near any Razorbill breeding sites and there can be no adverse impacts on these. Puffin Based on on-site observations, Puffins have now all finished breeding on Skellig Michael and generally have departed the island. Direct disturbance is therefore not an issue. Given the Ecological Protection Protocols (especially protocols for identification, marking and avoidance of any Puffin burrows & nesting habitats), it is unlikely that there will be any loss or damage to Puffin breeding habitats. Kittiwake Based on on-site observations, the majority of Kittiwakes have finished breeding on Skellig Michael and generally have departed the island. Therefore there is unlikely to be any significant disturbance of breeding Kittiwake when filming begins. No ground-based activities will take place on or near any Kittiwake breeding sites and therefore unlikely to result in any significant damage. Fulmar Count data and age profile data indicate that all Fulmar chicks will have fledged by mid-September (which is in accord with scientific literature (Snow & Perrins 1998). It is therefore unlikely that any significant disturbance will arise. No ground-based activities are to take place on or near Fulmar breeding ledges and therefore no adverse impacts on these are foreseen. Manx Shearwater Given the Ecological Protection Protocols (protocols for identification, marking and avoidance of any Shearwater burrows & nesting habitats), it is unlikely that there will be any loss or damage to Shearwater burrows or breeding habitats. The likelihood is that there will be little or no disturbance of Shearwaters. The species is nocturnal at breeding colonies. Given observed activity patterns on the island, there is no overlap in time between shearwater activity in the open & filming activity (even at dusk). Even if there were some overlap, it is unlikely that the dusk filming activities will result in any significant disturbance given limited artificial lighting in the area, reduced crew and on the spot DAHG supervision to halt film related activity if deemed excessive. 4. Decision I am satisfied that what is proposed will not adversely affect the integrity of the SPA, nor have a significant adverse effect on the biodiversity of the site. The site is an SPA and the application has to be assessed further to the requirements of Statutory Instrument 477 of 2011 and Statutory Instrument 74 of 2010, which designates the Skelligs as a Special Protection Area (SPA) for Birds. This proposal and application for consent requires the Minister to satisfy herself, beyond reasonable scientific doubt, that what is proposed will not adversely affect the integrity of the site, within the meaning of Article 6(3) of the Habitats Directive. I have undertaken the screening for appropriate assessment pursuant to the European Communities (Birds and Habitats) Regulations 2011. I have taken into account expert advice from NPWS staff, including in particular Head of Birds Unit, scientific knowledge and the screening report that accompanied the application. Having undertaken this review (including the screening for an Appropriate Assessment), my view and recommendation is that there is no ecological reason why this application cannot be granted. I would recommend that it would be prudent to include in any consent explicit conditions that the applicant has to adhere to. These could be a modification of those required last year (I set these out in the Appendix here). Appendix Special Conditions 1. A Department of Arts, Heritage and the Gaeltacht (DAHG) representative will be present on the island during the project. The DAHG representative will have full discretion to modify any aspect of this consent or to revoke it at any time. The applicant will comply with any direction given by the DAHG representative. REASON – To protect the SPA, to ensure that protection and avoidance measures are complied with in full and to address unforeseen issues. 2. All avoidance and protection measures proposed in the application document to be undertaken in full and to the satisfaction of the DAHG representative on-site. REASON – to ensure that there is no significant disturbance to species or damage to habitats. 3. The applicant shall ensure to the satisfaction of the on-site DAHG representative that nest sites are not damaged or access to and from them impeded in the course of this project. REASON – to ensure that there is no significant disturbance to species or damage to habitats. 4. Helicopter landings on the Island to be limited to the existing helipad and restricted to 16 returns in total over the three weeks and no more than four return flights in any one day. A maximum of four additional contingency flights, if required, may be requested but must be agreed by DAHG representative in advance. REASON – to avoid any significant disturbance to species 5. Helicopter presence on helipad to be limited to disembarking and boarding of passengers only and immediate turnaround to be undertaken. REASON – To avoid any prolonged disturbance at helipad site. 6. Personnel on the island to be limited to maximum numbers set out in Appendix 1 Paragraph 4.7 of proposal and combined film-related personnel (incl. OPW and DAHG officials) and tourists on the island shall not exceed 180 at any time. REASON – to avoid any increase of numbers of people at the site at one time beyond those permitted in Site Management Plan. 7. Consent is confined to 7th September 2015 to 25th September 2015 inclusive. REASON – to ensure project is limited to proposed dates 8. No personnel to arrive on the island before 07:00. All personnel to have quit the island each day by 20:00, except for the dusk filming crew (maximum 15 persons) 21:00 on the XXXX to XXXX September, save with express consent of DAHG representative. REASON – to ensure that the island is vacated when nocturnal birds emerge from or enter their nests. 9. The applicant will strictly adhere to biosecurity protocols for the control of alien species as set out in 4.2.6.2.Resonsibility for ensuring biosecurity must be assigned to a specified person and a record kept of same. REASON – To ensure that no alien species of plants or animals are introduced to the Island. 10. Daily transport to and from the Island for the DAHG representatives to be provided by the applicant. REASON – To ensure DAHG representative’s presence on-site 11. The salary and expenses (at standard civil service rates) of the DAHG representatives to be met by the applicant (subject to a maximum of €12000). REASON – Applicant to meet tax-payers’ costs incurred. 12. The applicant accepts that the Department is not liable for any losses or costs incurred by the applicant in regard to restrictions or directions given in the course of the project pursuant to this consent and to the protection of the site as a Special Protection Area and otherwise. REASON – Project risk to be borne by applicant. 13. For the production of aerial filming (other than that subject to condition 15) the helicopter will take a standby position outside of the SPA boundary (or a minimum of 500m from the Great Skellig or 1km from Little Skellig) and only enter to undertake 15 passes of no more than 180 seconds each (this gives the requested 120 seconds of filming and 30 seconds to enter and 30 to leave). The approaching flight path will be a distance of more than 100m above the cliffs. REASON – to avoid significant disturbance of cliff-nesting birds. 14. For the production of tile shots the hovering helicopter must not take a position closer than 300m from the Great Skellig. When not actively filming, the helicopter should position itself outside of the SPA or not within 500m of Great or 1km of Little Skellig. Any variation of this condition must be approved by the on-site DAHG representative in advance. REASON – to avoid significant disturbance of cliff-nesting birds. 15. The Department retains the right to extend the restrictions or to impose further restrictions if adverse reactions by the breeding seabirds are observed. Philip Buckley 5th September 2015 Appendix 2c Consent issued by the Department in respect of Wildlife Issues Muckross House Killarney National Park Killarney Co. Kerry 7th September 2015 Mr Martin Joy Production Manager Ireland Dear Mr Joy, I refer to your application of 4th September to undertake filming on Skellig Michael in September 2015. The Department acknowledges the considerable interaction with its technical and scientific staff regarding the design of the proposal, including the habitat and species issues to be addressed, and the preparation of draft and final Ecological and Screening Reports. The proposal in terms of its design and execution has at this stage incorporated many protection measures to address ecological issues, and the Department underlines the importance of same. The proposed project, its design, possible impacts and protection measures has been the subject of in-depth review by the Department in respect of both seabird and SPA interests (constituting inter alia a screening assessment), as well as other elements of biodiversity of the Islands. The Department has taken into account expert advice from specialist NPWS staff, scientific knowledge and the screening report that accompanied the application. The site is an SPA and the application has been assessed further to the requirements of Statutory Instrument 477 of 2011 and Statutory Instrument 74 of 2010, which designates the Skelligs as a Special Protection Area (SPA) for Birds. Your proposal and application for consent requires the Minister to satisfy herself, beyond reasonable scientific doubt, that what is proposed will not adversely affect the integrity of the site, within the meaning of Article 6(3) of the Habitats Directive. The Department has undertaken the screening for appropriate assessment pursuant to the European Communities (Birds and Habitats) Regulations 2011. Having examined your proposal, the Department has concluded that, provided the protection measures set out therein, and the special conditions outlined below, are adhered to in full, what is proposed will not adversely affect the integrity of the SPA, nor have a significant adverse effect on the biodiversity of the site. Special Conditions 1. A Department of Arts, Heritage and the Gaeltacht (DAHG) representative will be present on the island during the project. The DAHG representative will have full discretion to modify any aspect of this consent or to revoke it at any time. The applicant will comply with any direction given by the DAHG representative. REASON – To protect the SPA, to ensure that protection and avoidance measures are complied with in full and to address unforeseen issues. 2. All avoidance and protection measures proposed in the application document to be undertaken in full and to the satisfaction of the DAHG representative on-site. REASON – to ensure that there is no significant disturbance to species or damage to habitats. 3. The applicant shall ensure to the satisfaction of the on-site DAHG representative that nest sites are not damaged or access to and from them impeded in the course of this project. REASON – to ensure that there is no significant disturbance to species or damage to habitats. 4. Helicopter landings on the Island to be limited to the existing helipad and restricted to 16 returns in total over the three weeks and no more than four return flights in any one day. A maximum of four additional contingency flights, if required, may be requested but must be agreed by DAHG representative in advance. REASON – to avoid any significant disturbance to species 5. Helicopter presence on helipad to be limited to disembarking and boarding of passengers only and immediate turnaround to be undertaken. REASON – To avoid any prolonged disturbance at helipad site. 6. Personnel on the island to be limited to maximum numbers set out in Appendix 1 Paragraph 4.7 of proposal and combined film-related personnel (incl. OPW and DAHG officials) and tourists on the island shall not exceed 180 at any time. REASON – to avoid any increase of numbers of people at the site at one time beyond those permitted in Site Management Plan. 7. Consent is confined to 7th September 2015 to 25th September 2015 inclusive. REASON – to ensure project is limited to proposed dates 8. No personnel to arrive on the island before 07:00. All personnel to have quit the island each day by 20:00, except for the dusk filming crew (maximum 15 persons) 21:00 on the XXXX to XXXX September, save with express consent of DAHG representative. REASON – to ensure that the island is vacated when nocturnal birds emerge from or enter their nests. 9. The applicant will strictly adhere to biosecurity protocols for the control of alien species as set out in 4.2.6.2. Responsibility for ensuring biosecurity must be assigned to a specified person and a record kept of same. REASON – To ensure that no alien species of plants or animals are introduced to the Island. 10. Daily transport to and from the Island for the DAHG representatives to be provided by the applicant. REASON – To ensure DAHG representative’s presence on-site 11. The salary and expenses (at standard civil service rates) of the DAHG representatives to be met by the applicant (subject to a maximum of €12000). REASON – Applicant to meet tax-payers’ costs incurred. 12. The applicant accepts that the Department is not liable for any losses or costs incurred by the applicant in regard to restrictions or directions given in the course of the project pursuant to this consent and to the protection of the site as a Special Protection Area and otherwise. REASON – Project risk to be borne by applicant. 13. For the production of aerial filming (other than that subject to condition 14) the helicopter will take a standby position outside of the SPA boundary (or a minimum of 500m from the Great Skellig or 1km from Little Skellig) and only enter daily to undertake passes of no more than 90 to 180 seconds each). In any event, aggregated aerial filming will not exceed 45 minutes per day of filming activity. The approaching flight path will be a distance of more than 100m above the cliffs. REASON – to avoid significant disturbance of cliff-nesting birds. 14. For the production of tile shots the hovering helicopter must not take a position closer than 100m from the Great Skellig. When not actively filming, the helicopter should position itself outside of the SPA or not within 500m of Great Skellig or 1km of Little Skellig. Any variation of this condition must be approved by the on-site DAHG representative in advance. REASON – to avoid significant disturbance of cliff-nesting birds. 15. The Department retains the right to extend the restrictions or to impose further restrictions if adverse reactions by the breeding seabirds are observed. I am directed by the Minister for Arts, Heritage and the Gaeltacht to provide consent to you on the basis of your proposal, as submitted, on condition that all protection measures are implemented in full and that all Special Conditions are adhered to in full. Yours sincerely Philip Buckley Divisional Manager Appendix 3 Incident report on Paint Spill at Wailing Woman issued by Space Bear Ltd. Wailing Woman Incident Report 16/09/15 At approx. 15:00 the Standby Art Director started to move painting materials from a safe area behind a rock near the set piece platform to a position further down the slope towards the Lighthouse Road, so they would be clear for an upcoming aerial shot. All materials had been removed safely except for 2 part filled kettles of diluted, water based emulsion paint and 2 kettles containing texturing saw dust. The paint was picked up and placed on the broad, stable top of the rock whilst the saw dust pots were lifted for transit. As the (far lighter) saw dust pots were lifted onto the rock, one swung on its handle and impacted the paint containers, causing some of their contents to be spilled over onto the adjacent rocks. There was water and a Spill Kit containing pads, rolls and sheets of high absorbency material (previously placed here by the Locations Dept) to hand. The Spill Kit rolls were immediately deployed to create a bund, containing and limiting the affected area. Water was used to further dilute the paint with this solution then being thoroughly mopped up using the Spill Kit pads & sheets. Regrettably, it is likely that some paint may have been absorbed into the rock, although having appropriate treatment material on standby and the quick action of crew effectively minimised this effect. The contaminated spills pads, sheets & rolls were double bagged for off island disposal. Inspection by Simon Nobes and John Murphy confirmed that neither any potential Petrel nesting features beneath the rocks, the local vegetation in the form of a patch of Sea Spurrey, nor an adjacent Puffin burrow, marked by a yellow ground tag were compromised. Further examination of the rocks showed that there was no significant impact on the lichen resource. With the inherently mottled hued nature of the lichen covered rocks creating a variably toned surface colouration, the visual effects of the incident are virtually undetectable. Rock subject to minor paint spill, post incident clear up. Appendix 4 Incident report on minor disturbance to entrance to Upper Monks Garden issued by Space Bear Ltd. 1 Monastery Incident Report 17/09/15 At approximately 08:45 a member of Crew snagged their right jacket sleeve on the edge of a stone internal to the feature as they passed in a low crouch position through the first entrance to the monastery complex. Their momentum caused the large stone to rotate through approximately 40 degrees and move out of alignment with the vertical elevation. This motion also drew smaller stones out of alignment from the courses immediately above and below, ‘though to a lesser degree (see below). A safety marshal immediately stopped any further use of the entrance and notified Simon Nobes from the film company’s Location Dept. Recognising the potential risks and lacking the appropriate skills, no attempt was made to effect repairs. On attending the scene Simon Nobes discussed the situation with Bob Harris (OPW) and under his advice it was decided to permit three crew members to pass through the entrance to join the shooting crew already in place on the rocky outcrop above the monastery. These individuals removed all loose clothing, hats, radios etc to create a smooth body profile. They were then instructed to ‘crab’ through the entrance sideways, avoid all contact with the stonework whilst facing the damaged area in order to keep it in clear view at all times. SN denied access to one member on the grounds of their size. Via radio coms, OPW foreman Tom Kerrisk and stonemason Eamonn McCarthy were asked to attend. By approximately 09:40 they fitted temporary horizontal bracing boards and proceeded to remove loose stone for assessment (see below). Inspection by the Production Ecologist failed to reveal any evidence of the affected area being used by Storm Petrels. 1 2 Immediately prior to the installation of bracing boards, two key members of crew (cast double and wardrobe assistant) were allowed to leave in the controlled manner previously described. Meanwhile, Mally Chung (Supervising Locations Manager) informed Grellan Rourke (OPW) of the situation and sent him photos of the scene. Bob Harris also spoke to Grellan. Under Grellan’s instruction, relayed to Simon Nobes by Bob Harris, no further foot traffic was permitted to pass through the entrance until the feature had been made completely secure. By approximately 10:20 after additional required materials had been brought up from the Lighthouse Road, the entrance had been fitted with supporting wooden sleeving. Under the assurance of Eamonn and Tom that with the support boarding in place, a short delay in undertaking full repair would not be detrimental, Crew and OPW staff (21 in total) remained in the Monks Garden area whilst a helicopter filmed a shot of a single member of cast moving up the stairs from The Saddle towards the monastery. By 10:58 the helicopter filming was completed and by 11:14 Crew and OPW guides had left the monastery under the supervision and direction of Bob Harris. Larger items of equipment were left in the monastery garden. Full repair then commenced with Eamonn and Tom completing the work by approximately 12:45 (see below). In conversation with Eamon and Tom it became apparent that this same area of stone work has been subject to two similar such incidences of damage in the past 18months which they repaired. This is the narrowest passing place on the island. 2 3 Rather than being carried, the remaining kit was then moved through the entrance by being passed between two Sherpas. This protocol was also applied to elements of a storm tent which was dismantled and removed from the monastery garden later in the day. 3 Appendix 5 Report from National Parks and Wildlife Service on filming activity on Sceilg Mhichíl in September 2015 Skelligs Islands, Co Kerry Assessment and Report of film work September 2015 1. Background Filming work took place on Sceilg Mhichíl in September 2015. This was carried out between the 7th September and 18th September 2015. Specifically, preparation and transport of equipment to the island took place on 7th, 8th, 11th, 12th, 13th; filming activities (both on the ground and helicopter) took place on 15th, 16th and 17th; and removal of equipment and final inspection on 18th September. Consent had been granted for this work by the Department of Arts, Heritage and the Gaeltacht further inter alia to an Ecological (including a ‘Natura screening’) Assessment. Similar filming work was previously undertaken by the same producers on Sceilg Mhichíl in 2014 The nature, extent and logistics of the 2015 filming activities was broadly similar to what had previously taken place in 2014. A significant difference ecologically was that the 2015 activities took place in September, rather than July/August as in the previous year. This is a fundamental difference from an ecological perspective as many breeding seabird species have left the island or completed their breeding cycle by September. Information on the project itself, and particularly on ecological issues and assessments undertaken prior to approval being given for this project, are set out elsewhere (e.g. the Ecological and Screening Assessment undertaken by the Department, the letter of consent (and also the proposals and screening reports submitted by the applicants)). This document is a report on, and assessment from the ecological perspective of, the activities carried out in September 2015. The proposal in terms of its design and execution incorporated many protection measures to address ecological issues. The Department further attached conditions to the consent to ensure the activities would not adversely affect the integrity of the SPA, nor have a significant adverse effect on the biodiversity of the site. 2. NPWS Supervision and Monitoring of Activities NPWS monitored all activities on the island (and inspected biosecurity arrangements, including on the mainland). NPWS officers had the authority to halt or modify any of the filming or any activities at any stage (this was a condition of the Consent). Michael O’Sullivan, Declan O’Donnell, Dr David Tierney, Dr Clare Heardman and Dr Philip Buckley of the Department’s NPWS monitored the works: - to ensure that the conditions and Protection Measures incorporated into the design of the proposal and the consent granted were adhered to, and with a view to detecting and avoiding any potential impacts on the breeding birds, their habitats and other biodiversity of the island. An ecologist and an ornithologist employed by the film producers were also in full-time attendance. On the island, the NPWS staff monitored the filming and other activities. Staff also carried out observations on the birds. Staff ensured they were in attendance at all specific ‘filming events’. The filming itself and other activities were scrutinised to detect and avoid any potential ecological issues. NPWS staff undertook observations of the birds present and their responses to activities and in particular to helicopter work. NPWS staff who were present have submitted their own logs on what they observed. (The Film Company has also submitted a report, including observations and data from the Consulting Ecologist.) 3. Observations Adherence to Protection Measures and Conditions Staff were satisfied that the film crew and activities followed in full the ecological protection measures and procedures as set out in proposal submitted (which in turn were cited as a requirement in the consent granted). Staff were also satisfied that the Conditions the Department attached to the consent were adhered to (one condition - to have left the island by 2100 was technically over ran as the boat departed the quay at 2110. This was of no consequence ecologically). Observations on the ecological effects of the activities NPWS staff closely monitored activities, including all filming events. No incidences of any adverse effects on the birds, their habitats or other ecological interests were observed. Observations on disturbance & the response of the birds present (including to helicopter work) NPWS staff made specific observations of the effects and responses of the birds that were present to the helicopter work, covering both (a) direct drop off and pick up landing flights (to and from the helipad), and (b) filming work per se where the helicopter was either static or made slow passes off some cliff areas. The Consultant Ecologist also provided observational data/reports on this. Helicopter drop off and pick up landings at the helipad were observed. Small numbers of birds were present in the vicinity (most having departed the island given the stage of the breeding cycle), mostly Fulmars. Generally, the birds showed no observable response and did not take flight. On one occasion, some Fulmar were seen to depart in advance of the helicopter touch down. Most of the helicopter filming activity (‘static or passes’) was also observed by NPWS staff (and Consultant Ecologist). Again only small numbers of birds (mostly Fulmars, a few Laridae) were present in the vicinity of these activities. Generally the birds under observation did not take flight nor even become agitated. On one occasion two Fulmars took flight (and returned within five minutes), and on two other occasions, a few Fulmar assumed an ‘alert’ posture. Such behavioural responses, and affecting such limited numbers of birds, and particularly at this time of year are of no ecological significance. Biosecurity NPWS staff inspected and observed bio-security arrangements and procedures. NPWS staff were satisfied that all bio-security protocols and procedures were followed in full. Incidents There were two ‘incidents’ reported. These related to spillage of a diluted water-based paint and sleeve- snag dislodgement of stones in a Monastery gateway. NPWS staff attended on both occasions and observed and specifically examined the areas to see if seabirds were present or if there were any ecological issues. There were none, and both incidents were resolved and of no ecological consequence. 4. Conclusion There was close and continuous monitoring of these activities by NPWS personnel throughout. The activities themselves were monitored and supervised, and observations were made of the responses of the seabirds and any impacts on them or their habitats, or on other biodiversity. Based upon the observations and reports of NPWS staff, and my own observations, we are satisfied that the conditions of the consent were adhered to fully, these activities had no adverse ecological impacts, and did not adversely affect the integrity of the SPA, nor have a significant adverse effect on the biodiversity of the site. Philip Buckley 15th October 2015