Renewable generation

AuthorityDepartment of Infrastructure
Date received2025-05-14
OutcomeNot upheld
Outcome date2026-01-12
Case ID4654247

Summary

A request for information regarding renewable generation and the Future Energy Delivery Strategy was made to the Department of Infrastructure, resulting in a decision not to uphold the request due to extensive redactions.

Key Facts

  • The request was received on 2025-05-14 and the outcome was determined on 2026-01-12.
  • The response included 117 pages across 6 documents, primarily consisting of email chains.
  • Manx Utilities aims for a planning submission for an onshore windfarm in January 2025.
  • Construction for the onshore windfarm is targeted to start in early 2026.
  • The Department of Infrastructure and Attorney General's Chambers were key correspondents.

Data Disclosed

  • 2025-05-14
  • 2026-01-12
  • 117
  • 6
  • Jan 2025
  • early 2026
  • 27 January 2023
  • 08 March 2023
  • 27 February 2023
  • 05 November 2024
  • 04 November 2024

Exemptions Cited

  • Section 25
  • Section 35
  • Section 40

Original Request

 

Data Tables (34)

Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
ection 25 Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25
Section 25 >; Section 25
Section 25
Section 25
Section 25
Section 25
ection 25
Risk Potential Barriers
Project delays - critical path milestones not delivered to plan (also see planning and structure assumptions below) Project requires execution of a coordinated work programme across public and private sector. Critical path milestones include permissions, licences, access, surveys and supply chain requirements (e.g. design, procure, installation, commissioning and maintenance). Potential barriers may include resource capacity, priorities and allocation. Project Boards require membership from building owners/users. Ownership boundaries around projects unclear – agreement required to ensure appropriate management of safety at sites.
Funding - not received or when required (scarce capital resources, with multiple competing priorities) Provisional funding will be required to carry out structural/electrical survey and preliminary design work before individual business cases can be presented with accurate costs for approval.
Planning permissions delay projects Risk is limited to car park installations as rooftop projects are permitted developments. Car park projects have the greatest solar potential but are not permitted developments. Planning process timing assumptions in respect of car park solar could be incorrect.
Deficiency in structural integrity of buildings identified Risk is largely unknown until completion of structural surveys. Existing survey data indicates differences across public buildings. Funding requirements currently assume roofs can accommodate solar installations and asbestos is not present. Unknown risk has potential to increase costs and timescales due to structural deficiency.
Risk Potential Barriers
Planning Approval must be obtained by December 2025 Onshore windfarm planning application untested. Planning inspector will ultimately rule on suitability. Planning policy requires use of UK legislation as best practice. Strategic planning policy not clearly supportive of developments in countryside: GP3 offers Resource & National Need provisions. EIA must demonstrate selected site is most suitable on Island. Tynwald approval likely required. EIA and design completion required for planning application. Final design requires commitment to a manufacturer. Planning required before site preparation. Construction window constrained by bird breeding season. Local stakeholders expressing strong concerns about the project.
Funding - not received or when required (scarce capital resources, with multiple competing priorities) Funding commitments likely to be needed (manufacturer and construction) before planning permission obtained (i.e. capital at risk). Funding requires Tynwald approval.
Manufacturing Lead Times and high competition for supply chain Final contract will need to be placed in January 2026. Supply chain constraints and competition for net zero technology.
Risk Barriers
Funding Since initial estimates by Arup and WSP, costs are projected to be significantly higher; primarily due to supply chain challenges, limited GB route options (see below), and competing net zero projects. Project costs will require significant funding and will likely be considered as ‘exceptional’ levels of capital spending; likely influencing political and public support. Up front commitment will be required for substantial survey work and to secure delivery dates. Programme management, ownership and commercial delivery mechanisms to be determined.
GB Network Capacity is saturated Connection agreement is ultimately dependent on UK stakeholders, including GB network asset owners and operators. Limited options for connection is increasing the route length and overall project cost
Possible Changes to Marine Planning Rules Feasibility studies and EIA to current regulations (Submarine Cables Act, 2003). EIA requires minimum two years to account for migratory bird and marine life surveys. Residual EIA repeat risk.
Risk Potential Barriers
Key stakeholder acceptability of technology Project considered essential to maintain security of supply and some level of energy independence (post fossil fuel electricity generation ban in 2030) Limited understanding of sustainability of fuels and potential benefits to the Island. Biofuels remain contentious which is likely to present challenges in respect of key stakeholder support.
Fuel Route A reliable and secure carbon neutral fuel feedstock, processing, transport and storage system will be required by 2029. Compromise in food security vs. energy independence.
Funding not received or when required (scarce capital resources with multiple competing projects) Initial investment required to seed fund project development High capital cost for technology
Section 30
Section 30
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 25
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35
Section 35

Full Response Text

From: Smith, Elizabeth

Sent: 27 January 2023 17:41 To: Dobbins, Adrian

Cc: MU Executive ; Riley, Lizzie (MUA) ; Watson, Simon

Subject: RE:

Hello Adrian,

Many thanks Liz Elizabeth Smith Executive Director of Legal Services

Attorney General's Chambers Ground Floor, Belgravia House 34/44 Circular Road, Douglas Tel:

Isle of Man, IM1 1AE

IMPORTANT PLEASE NOTE: - Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 40 Section 40 Section 40 Section 40 Section 40 3. Any legal advice contained in this communication may be subject to Attorney General's privilege, in which case neither the fact of consultation nor the opinion or advice given herein may be disclosed outside Government without the express consent of the Attorney General. 4. Whilst the legal advice privilege attaching to this communication is always ultimately the privilege of the recipient, the contents are not to be forwarded or quoted in whole or in part without the express consent of the sender. From: Dobbins, Adrian

Sent: 27 January 2023 16:12 To: Smith, Elizabeth

Cc: MU Executive ; Riley, Lizzie (MUA)

Subject:

Importance: High Dear Liz

Regards Adrian Dobbins
Executive Director SUSTAINAB LIFE’S ESSE FOR O Section 25 Section 25 Section 25 Section 25 Section 35 Section 40 Section 40 Section 40 Section 40 Respect | Integrit t: e:

m: w: www.manxutilities.im 687687 Section 25 Section 25 Section 25 From:

To:

Sent: Mon Mar 13 2023 08:20:30 GMT Subject: FW: Future Energy Delivery Strategy Slides & WSP Report (Attachments:) FW:

Kind regards Andrew From: Riley, Lizzie (MUA)

Sent: 08 March 2023 17:25 To: Fretwell, Helen

Cc: Dobbins, Adrian McGhee, Steve Watson, Simon

Sidebottom, Andrew (DOI) Clague, Simon (MU) King, Philip

Subject: RE: Future Energy Delivery Strategy Slides & WSP Report Dear Helen,

Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 40 Section 40 Section 40 Section 40 Section 40 Section 35

Section 40 Section 40 Section 40 Section 40 Section 40 Section 40 Section 40 Section 40 Section 40 Section 40

Section 40 Section 40 Section 40 Section 40 Section 40 Section 40 Section 40

Best Regards, Lizzie From: Fretwell, Helen

Sent: 08 March 2023 09:10 To: Riley, Lizzie (MUA)

Cc: Dobbins, Adrian McGhee, Steve Watson, Simon

Sidebottom, Andrew (DOI)

Subject: RE: Future Energy Delivery Strategy Slides & WSP Report Dear Lizzie

Kind regards Helen
Helen Fretwell Senior Legal Practitioner – Commercial Commercial Division Attorney General’s Chambers Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 40 Section 40 Section 40 Section 40 Section 40 Ground Floor, Belgravia House Direct Tel No.:

34-44 Circular Road, Douglas General Office Tel No.: 01624 685452 Isle of Man, IM1 1AE

IMPORTANT PLEASE NOTE: - 1. Any legal advice contained in this communication may be subject to Attorney General's privilege, in which case neither the fact of consultation nor the opinion or advice given herein may be disclosed outside Government without the express consent of the Attorney General. 2. Whilst the legal advice privilege attaching to this communication is always ultimately the privilege of the recipient, the contents are not to be forwarded or quoted in whole or in part without the express consent of the sender. From: Riley, Lizzie (MUA)

Sent: 27 February 2023 14:01 To: Watson, Simon Fretwell, Helen Sidebottom, Andrew (DOI)

Cc: Dobbins, Adrian McGhee, Steve

Subject: Future Energy Delivery Strategy Slides & WSP Report Dear all,

Best Regards, Lizzie Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 40 Section 40 Section 40 Section 40 Lizzie Riley
Energy Transition Lead & Transition Programme Manager Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellence t:

e:

w: www.manxutilities.im 687687 Section 25 Section 25 From:

To:

CC:

Sent: Tue Nov 05 2024 09:23:13 GMT Subject: RE: IOM onshore windfarm Hi Mark,

Many thanks, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 05 November 2024 09:17 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Good morning Emma, Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 We are currently aiming for a planning submission for Jan 2025, with construction starting early 2026.
Kind regards Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 04 November 2024 10:07 To: Inman, Mark

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Hi Mark,

Many thanks, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 01 November 2024 08:02 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Thank you Emma,
That would be much apricated. Kind regards
Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 01 November 2024 07:58 To: Inman, Mark

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Good morning Mark, Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25

Best wishes, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 01 November 2024 07:37 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: IOM onshore windfarm

Kind regards Mark
Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 Section 35 Section 35 Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 Section 25 Section 25 Section 25 From:

To:

CC:

Sent: Wed Dec 04 2024 11:20:57 GMT Subject: RE: IOM onshore windfarm Hi Mark,

Best wishes, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 04 December 2024 11:19 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Good Morning Emma, Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35

Kind regards Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 05 November 2024 13:10 To: Inman, Mark

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Hi Mark,

Best wishes, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 05 November 2024 10:54 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Hi Emma,

Kind regards
Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 05 November 2024 09:23 To: Inman, Mark

Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 From:

To:

CC:

Sent: Tue Nov 05 2024 13:09:45 GMT Subject: RE: IOM onshore windfarm Hi Mark,

Best wishes, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 05 November 2024 10:54 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Hi Emma,

Section 25 Section 25 S Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35

Kind regards
Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 05 November 2024 09:23 To: Inman, Mark

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Hi Mark,

Many thanks, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 05 November 2024 09:17 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Good morning Emma, We are currently aiming for a planning submission for Jan 2025, with construction starting early 2026.
Kind regards Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 04 November 2024 10:07 To: Inman, Mark

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Hi Mark,

Many thanks, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 01 November 2024 08:02 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm

Kind regards
Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 From:

To:

Sent: Fri Nov 01 2024 09:01:55 GMT Subject: RE: IOM onshore windfarm Hi Lizzie,

Best wishes, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

P Consider the environment, please don't print this e-mail unless you really need to From: Riley, Lizzie (MUA)

Sent: 01 November 2024 09:00 To: Rowan, Emma

Subject: RE: IOM onshore windfarm
Thanks Emma, Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35

Best Wishes, Lizzie Lizzie Riley
Energy Transition Programme Manager Energy Transition SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellence t:

e:

w: www.manxutilities.im 687687 From: Rowan, Emma

Sent: 01 November 2024 07:58 To: Inman, Mark

Cc: Riley, Lizzie (MUA)

Subject: RE: IOM onshore windfarm
Good morning Mark,

Best wishes, Emma Emma Rowan MA MSc PhD MRTPI Senior Infrastructure Policy Officer Central Support and Change Division Department of Infrastructure Sea Terminal Building Douglas Isle of Man
IM1 2RF Email:

Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 Section 35 Section 35 P Consider the environment, please don't print this e-mail unless you really need to From: Inman, Mark

Sent: 01 November 2024 07:37 To: Rowan, Emma

Cc: Riley, Lizzie (MUA)

Subject: IOM onshore windfarm

Kind regards Mark
Mark Inman
Project Manager - Onshore Wind Manx Utilities Transition Programme SUSTAINABLY DELIVERING LIFE’S ESSENTIAL SERVICE FOR OUR ISLAND Respect | Integrity | Teamwork | Excellenc t: e:

m: w: www.manxutilities.im 687687 Section 25 Section 25 Section 25 Section 25 Section 25 Section 25 Section 35 From:

To:

Sent: Wed Jul 27 2022 10:49:20 BST Subject: RE: Orsted AfL / NDA Hi Lizzie

Kind regards

Commercial Asset Manager Public Estates and Housing Division | Department of Infrastructure | Isle of Man Government | Sea Terminal| Douglas | Isle of Man | IM1 2RF Commercial Section Tel:

Email:

Web: www.gov.im/infrastructure
Social: www.twitter.com/iominfra and www.facebook.com/iominfr

[Response truncated — full text is 96,833 characters]