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