“Introduction

NATIONAL TRUST AND PLAS NEWYDD

National Trust is a leading conservation charity with 4 million members. Established over 115 years ago, our primary statutory purpose is to promote the preservation of special places for the benefit of the nation. To achieve this aim we manage over a quarter of a million hectares of land, more than 700 miles of unspoilt coastline and estuary, several hundred historic houses, gardens and parks, and 6 World Heritage Sites. More than 100 million visits are made every year to the properties in our care.
National Trust owns, cares for and provides public access to land and buildings on both sides of the Menai Straits. The Straits have a unique and highly significant combination of historic, scenic and ecological interests. Plas Newydd and Faenol represent a very important part of the tourism offer for North Wales and recognised as a highly significant environmental, heritage and economic asset. Plas Newydd was given to the National Trust by its owner, the 7th Marquis of Anglesey, in 1976, an occupied family home of some four hundred years. Plas Newydd is a special place that has become, and will continue to be, the ‘special place’ of many.

We welcome the opportunity for critical examination and scrutiny of the proposals through the Examination of the submitted Development Consent Order (DCO). National Trust comments are specific to its land ownership interests primarily relating to land in North Anglesey and in the Menai Strait at Plas Newydd and Faenol. The Trust’s concerns are summarised below:

Principle of tunnel for the Menai crossing

The National Trust welcomes the tunnel solution as the preferred technology to cross the Menai Strait. The National Trust recognises the benefits to the landscape and setting of the AONB, and to Plas Newydd and the Faenol estates in bringing forward this solution.

Vibration

The National Trust would note that the mansion at Plas Newydd is 300m horizontal distance from the maximum Limit of Deviation of the proposed tunnel, and in accordance with the submitted assessment, significant vibration is not expected at a distance greater than 100m from the Limit of Deviation.

We would note that whilst an assessment based on distance may be appropriate for ground borne vibration from surface vibration sources, some qualification is required as to why the chosen distances of 50m for a Tunnel Boring Machine or 100m for Drill and Blast methods are appropriate. The National Trust considers that either a quantitative assessment should be carried out which determines the likely range of vibration levels at nearby buildings, or the method of the qualitative method used should be stated and justified. If, as appears to be the case, the assessment has been based purely on distance from the tunnel, then this should be justified by reference to vibration measurements taken during other tunnelling projects carried out in geologically similar areas. It should also be determined whether any buildings within the assessment are structurally unsound, or may be difficult to repair, in which case the vibration damage criteria ought to be reduced on a case-by-case basis (as per BS 5228) to reflect this.
The National Trust thus considers that at the current time, vibration issues associated with tunnel construction are not resolved, and specific issues for Plas Newydd, including the stability of the Whistler painting, remains outstanding.

Construction Transport

The main point of access for all tourism to Plas Newydd is via Brynseincyn Road. Brynsiencyn Road will be used by construction traffic during Enabling and Reinstatement Works at the start and end of the project. Brynsiencyn Road will be used for Abnormal Indivisible Loads (AIL’s).

It is anticipated that the cable for the tunnel would be delivered as AILs to either the T? Fodol or Braint Construction Compound. The Transport Assessment (TA) suggests that there may be 72 cable drum AIL’s. Up to 8 AILs are anticipated to/from Braint Tunnel Head House (THH) for delivery of Tunnel Boring Machine (TBM) in tunnel scenario 1 prior to tunnelling commencing or for extraction of TBM in tunnel scenario 2 following main tunnel drive. The preferred route for TBMs, cable drums and mobile cranes to Braint is via Brynsiencyn Road.

In terms of minimising and managing the impact of construction traffic on Plas Newydd, the use of the primary construction traffic route that avoids Brynsiencyn Road is welcomed by The National Trust.

However, Brynsiencyn Road has been identified as a contingency construction traffic route if the primary route becomes unavailable. The National Trust remains concerned about the implications for Plas Newydd and tourism visitor access should the primary route be unusable. The commitment to onsite storage of excavated material for 4 weeks (or longer) needs to be incorporated into the scheme.

In the event that the contingency access is used construction traffic will not be permitted to use Brynsiencyn Road during peak times. The submitted DCO considers that peak times are limited to 0800-0900 and 1630-1730. Consideration should be given to extending these periods to cover Plas Newydd’s peak periods and any significant events being held at Plas Newydd.

In terms of AIL’s it is recommended that all AIL’s that are able to use the Star Bridge should do so in order to minimise impact on Brynsiencyn Road. The TBM and Cable deliveries cannot cross the Star Bridge and so must use Brynsiencyn Road. With up to 72 Cable deliveries for the scheme there is potential for regular disruption because of this.

The National Trust welcomes the proposal within The Outline Construction Traffic Management Plan for a Transport Review Group being in place and that a Traffic Safety and Control Officer will be appointed. However, National Trust require further assurances in terms of how these movements will be managed so as to avoid conflict with Plas Newydd visitors, and avoidance of traffic disruption.

Tourism

Construction of the overhead line and tunnel could have significant implications for tourism in Anglesey. The combined effect of Wylfa Newydd construction and the associated grid connection construction could have a detrimental effect on tourism and visitor numbers to Anglesey. The National Trust remains concerned about the potential effect of construction workers reducing the availability of tourist accommodation, delays caused by construction traffic and the perception of Anglesey as a tourist destination affected by the construction works.

Potential delays could impact seriously on the National Trust business model with loss of income to the property at Plas Newydd. Income loss and traffic disruption would have a significant impact on the local economy as National Trust employ seasonal staff at the property. Any drop in income, also means less money to spend on conservation at Plas Newydd.

The National Trust thus remains concerned about the tourism implications of the scheme, and the consequent impact on visitor numbers at Plas Newydd.

Conclusion

The National Trust welcomes the opportunity for critical scrutiny of the proposals through the Examination of the DCO. National Trust comments are specific to its land ownership interests primarily affecting land at Plas Newydd and Faenol.
The National Trust welcomes the tunnel solution as the preferred technology to cross the Menai Strait and consequent benefits to the landscape. We have remaining concerns in relation to construction vibration, construction traffic and overarching concerns in relation to tourism from construction of the project.
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