“Thank you for the opportunity for giving my views on the National Grid Electricity Transmission plc (NGET) proposal for the North Wales Connection (NWC). I apologise for the length of this Relevant Representation so have provided key themes below

Key themes: impact on tourism, impact on farming, impact on house valuation, flawed “consultation”, failure to follow Government Policy, failure to the follow the Holford Rules, historically and culturally inappropriate

My views on the Wylfa Newydd DCO are irrelevant for this proposal, but it goes without saying that any generator needs to be connected to the demand, so I fully agree with a connection existing, however, I totally disagree with all other aspects of this proposal

The current line of pylons was built in 1963-66, just before the Anglesey Area of Outstanding Beauty (AONB) was designated in 1967 (and coincidentally when I came to Anglesey as a child so my late father could run Wylfa). Had the designation been in place earlier, it is unlikely that significant portions of this line could have used pylons, but would have been placed underground/under the Menai. I urge you to stand on the shore of Menai, or the summit of Mynydd Bodafon, both popular with residents and tourists and see for yourselves. Opposition to the line in 1962/3 is documented in the Anglesey Archives. This line is now largely redundant, so should not be used for the Wylfa Newydd export, should not be significantly modified to facilitate the new line and should not be used to justify a second (third or fourth) line. I hated pylons as a child, and still hate them now. Don’t believe the myth that people get used to them

NGET will tell you that there are very few studies into the effect of high voltage overhead transmission lines on tourism, and state that the impact of this proposal will be minimal. However, only a few minutes of on-line searching yields multiple, peer-reviewed studies in respected journals showing that this is simply not true. Anglesey, designated by the Office of National Statistics as a “holiday hotspot”, is hugely dependant on the tourism economy. This proposal, both during construction and operation, will deprive the local tourism industry of revenue, market share and growth. Only a few minutes more of on-line searching will provide further evidence that agriculture and housing will be similarly impacted. The socio-economic evaluation provided in the DCO is simply inadequate, primarily as the economic/financial impact (via NGET’s flawed methodology) has not been estimated. The “social costs” of this proposal, estimated at £500 million, outweigh the additional cost of undergrounding

Wales is unique in having a Wellbeing of Future Generations Act, and a vehicle for putting this into practice is the tenth edition of Planning Policy Wales (PPW10). Should this proposal be granted, it would be in direct contravention of Welsh planning policy (as well as Ofgem’s principal objective “… to protect the interests of existing and future electricity … consumers”). PPW10 is clear in that new grid connections should be placed underground, allowing for cost considerations if this would jeopardise the viability of an otherwise feasible development. With the current regulatory and price control regime, where the power station developer cannot invest in a grid connection, and NGET pass all costs on to consumers, the additional cost of undergrounding this connection cannot impact the viability of the power station. The additional costs are estimated at some 11p/year on an average UK electricity bill of £554 – an increase of 0.02%, affordable even to those vulnerable households suffering fuel poverty

The so called “consultation” that preceded the application contained significant flaws – NGET had published details and costs of their desired solution a full three years before the “consultation”, which claimed to look at options such as underground and subsea, commenced. While claiming to consult on a subsea option in 2012, no consultation was conducted on the Wirral or in Pembrokeshire, the destinations of the subsea options. At no point was a “cumulative consultation” (for the entire power station/grid connection development, as suggested by The Planning Act 2008) conducted, and the cumulative impact assessment in the DCO is severely lacking

Of the seven “Holford Rules”, NGET ignore all of them for the modifications to the existing line, and follow only one of them for the new line. NGET’s CEO John Pettigrew told me at the National Grid AGM in 2017 “… they are only guidelines, we don’t have to follow them”, although the principles of the rules are enshrined in UK Government Policy (EN-5). There are numerous other examples where Government Policy has been simply swept aside, such as rationalisation of existing assets. To be fair to NGET, many of the rules are difficult to follow on Anglesey due to the underlying geology and geomorphology, resulting from glacial flow in the last ice age (and recognised by UNESCO). The residential settlement pattern on Anglesey, which NGET could easily have used as justification for undergrounding, are in part due to the ninth century inheritance laws of Hywel Dda. In such an ancient landscape, that is simply “at odds” with the “rules”, the case for undergrounding becomes overwhelming

I am sure you have heard the saying Môn, Mam Cymru (Anglesey, the mother of Wales), first documented in the 1100’s by Gerald of Wales, who recounts the tale of Anglesey being able to feed all of Wales due to the fertile land. Gerald states this only shortly after saying much of the land is marshy, rocky and poor. It was probably Gerald who created this “Christian propaganda” to hide the fact that the locals used the pre-Christian name. Mon/Mona was a female Celtic deity, and mona is still used in Irish Gaelic to denote “the earth”. It would simply be culturally/historically/spiritually wrong to decorate/desecrate this “sacred” landscape with a second line of pylons, destroying the ample visual amenity, enjoyed by many, for generations to come

In closing, I would urge the Examining Authority to visit Star, Rhosybol, Rhosgoch, Capel Coch, Cemaes, or even my garden in Bachau, to see for themselves the current blight
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