Corporation of Trinity House of Deptford Strond
"Dear Sir / Madam, We refer to the above application for development consent. Trinity House is the General Lighthouse Authority for England, Wales, the Channel Islands and Gibraltar with powers principally derived from the Merchant Shipping Act 1995 (as amended). The role of Trinity House as a General Lighthouse Authority under the Act includes the superintendence and management of all lighthouses, buoys and beacons within its area of jurisdiction. Trinity House wishes to be registered as an interested party due to the impact the development may have on navigation within Trinity House’s area of jurisdiction. Trinity House is likely to have further comments to make on the application and the draft Order throughout the application process. Please address all correspondence regarding this matter to myself at (Redacted)@trinityhouse.co.uk and to Mr Steve Vanstone at [email protected] Yours faithfully, Russell Dunham ACII Legal Advisor"

Gwynedd Archaeological Planning Service
"Gwynedd Archaeological Planning Service is the regional curatorial service responsible for advising on development and the historic environment in north-west Wales, and is a non-statutory consultee. We advise the local planning authorities of Gwynedd, Conwy, Anglesey and Snowdonia National Park. We also comment on applications affecting Registered Historic Landscapes on behalf of NRW. I have been part of the Expert Technical Group (ETG) meetings for Archaeology (Onshore and Offshore) and Seascape, Landscape and Visual Impact Assessment (SLVIA) and Cultural Heritage from the outset. No onshore works fall within our advisory region, therefore my representation will relate primarily to setting impacts. My advice to date has contributed to the respective local authority responses rather than being a separate submission. It is not yet confirmed whether this will be the case for the examination or whether we will be responding separately. I wish to register as an Interested Party to ensure I remain informed as to the progress of the application as well as to allow for the possibility of a separate response."

National Air Traffic Services Ltd
"Awel y Môr Offshore Wind Farm, Irish Sea off the coast of North Wales Dear Sirs, I refer to the Application quoted above, NATS has assessed the application and has identified an unacceptable impact on its infrastructure, specifically the St. Annes and Great Dun Fell Primary Surveillance Radars. No impact is anticipated on NATS’s Clee Hill radar. NATS has been engaged with the Applicant over recent years and following its assessment, has proceeded to investigate mitigation measures. These technical measures are tangible and within NATS’s control; negotiations are currently ongoing with the Applicant in order to secure their funding and implementation. While a formal agreement is not yet in place, NATS has no reason to believe that this will not be forthcoming in the very near future. While its position is that of objecting to the application, NATS is confident that it will soon be in a position to support planning conditions. As soon as formal agreement is reached with the Applicant, NATS will submit a further representation confirming this. Yours faithfully Mr Sacha Rossi For and on behalf of NATS En-Route plc"

Maritime and Coastguard Agency
"MCA will be responding to the ExA on matters concerning the safety of maritime navigation and maritime Search and Rescue. MCA will provide comments on the Navigation Risk Assessment, Shipping & Navigation chapter of the EIA Report, and the content of the DCO and DML. The main issues for MCA are concerning vessel routeing, vessels' ability for continued safe passage, that risks to all vessels and craft are at an acceptable level, and the project is not at the detriment to the provision of Search and Rescue, and other emergency response."

Memoria Ltd
"I represent Memoria Ltd. We are the 3rd largest operator of crematoria in the UK and the owners and operators of Denbighshire crematorium and memorial park. Our site is based near St Asaph, Denbighshire and according to the plans sent to us as part of this consultation process, it appears that the applicant is looking to occupy our site in the construction of this project. Denbighshire Memorial Park and Crematorium is an important public service facility which is carrying out over 1,500 funeral services per annum. We also have over 100 memorials for departed local residents which are visited by bereaved families every day. The use associated with a crematorium is sensitive and requires a peaceful, tranquil environment to operate. The ground around the crematorium is consecrated given that cremated remains are buried across the site. Overall, we have in the region of 150,000 visitors every year. With all of this in mind, it is clear that the route planned for this project should be diverted away from this location. We provided this feedback to the developers during the pre-app process but we are dismayed to see that no adjustments have been made to this application. Given the importance to both the local and wider community, it is critical that our request for a diversion is discussed and actioned asap. We would welcome the opportunity to discuss this further. Best regards, Jamieson Hodgson Deputy CEO Memoria Ltd (Redacted)"

Chris Baines
"I wish to see the proposed array as the physical basis for sea bed ecological restoration and proactive marine nature conservation. I would also like to see this and the other arrays in Liverpool bay as a protected route for seabed transmission cable connections between Anglesey (Wylfa) and Deeside (Connah's Quay. This option would avoid the need for new towers and transmission lines across the Anglesey AONB, the Menai Straights, Snowdonia National Park and the Clwydian Hills AONB"

Conwy County Borough Council
"The Council's response to the pre-application consultation was based on the proposal identified in the Preliminary Environmental Information Report (PEIR) and focused on four main areas of concern: i) Seascape, landscape and visual impacts - The Council disagreed with the level of significance identified in the applicant's Seascape, Landscape and Visual Assessment, including from key settlements, the Wales Coastal Path, Seascape Character Areas and from the A55. Whilst the Council recognised that offshore wind energy would inevitably result in significant changes to coastal seascapes and views, it had concerns over the following impacts: First, the scale of both individual wind turbines and of the extent of the Awel y Mor array as a whole would result in a significantly greater visual impact from a number of viewpoints than views of the existing offshore wind farms. This in turn would cause the offshore wind farms to become the dominant feature in the seascape. Second, the proposed array would lie close to, and affect the setting of, a number of coastal landscape features, including the Great Orme (Heritage Coast and part of a Special Landscape Area and Historic Landscape) and the Little Orme (also part of a Special Landscape Area and Historic Landscape). It would significantly affect the seascape character, and detract from the appreciation of the coastal landscape feature. Third, the proposal would cause both sequential and in-combination cumulative effects with other offshore wind farms, including existing offshore wind farms, and this would increase the dominance and duration of windfarms as a seascape feature. Fourth, in the absence of a cumulative assessment with any future onshore wind farms (including those identified in Future Wales: The National Plan 2040), the SLVIA did not fully evaluate the cumulative effects. ii) Impacts on the tourism economy - It was unclear to what extent the conclusions in the PERI took account of the demographic profile of visitors to Llandudno and the County generally, or to the distinctive heritage and character which are critical in its attractiveness to that visitor profile. As such, the conclusions in relation to the magnitude of the impact were subject to a wide margin and uncertainty. iii) Impacts on the built environment and heritage - including the setting of Llandudno Pier, Llandudno Conservation Area and the Great Orme. It concurred with the conclusions of Gwynedd Archaeological Trust in relation to impacts on these assets. Furthermore, as noted in point iii), the development could potential cause a decline in visitor numbers, and this could in turn lead to a reduction in the frequency and quality of maintenance of the built fabric. Over time, such a deterioration would be detrimental to the character and appearance of the Llandudno Conservation Area and to the special features of interest of the listed buildings. iv) Impacts arising from construction works on the amenity of residents and visitors- only one sensitive noise receptor was identified in the PEIR, and no background noise level surveys had been carried out. The draft Requirement lacked clarity in respect of the maximum noise levels, the periods during which they wold apply, and the location of measurements. The Council will be reviewing its previous representations in the light of amendments to the scheme and the ES, and wishes to reserve the right to amplify or amend its representations."

Denbighshire County Council host authority
"Denbighshire CC as host authority for the onshore works (landfall, cable route and onshore substation) is currently reviewing the extensive application documents and coordinating an internal consultation with relevant technical officers so it is too premature to summarise the nature of the Council's representations at this time. However, for a reference, the Council's formal response to the developer's Pre-Application Consultation concentrated on the impact of the onshore construction works, in particular at the landfall and the interaction with coastal defences and the Rhyl golf course; and the operational impact associated with the onshore substation in terms of impact on visual amenity & landscape character (including cumulative effects) and setting of heritage assets."

Captain Haddock’s Seafood
"I have been fishing in Liverpool Bay and the north Wales Coast for over 30 years, the wind farm will have a massive impact on my business just like the wind farms did in previous years. I need to be kept informed at all times. Regards Kevin Mckie"

Jodi Cook
"I wish to object to this proposal on the grounds of the potential adverse impact it will have on tourism in Llandudno, a vital source of income not just for Llandudno residents but for Conwy County. Llandudno has preserved so much of its Victorian architectural history and because of this, attracts a great many tourists from the UK and beyond. The construction of more wind turbines stretching right across the bay would jar with the town's pride in its preservation of history and make it even more difficult to attract tourists than it presently is. I recognise the need for renewable energy generation but I question why such a picturesque and sensitive location needs has been chosen for this project, and have seen nothing to justify why this location is so perfect for the turbines."

Martyn Hussey
"An Integral part of this development is the requirement to connect to the National Grid. The plan is to do this via National Grid's substation at Boddlewyddan, however, in order to facillitate this, National Grid require enabling works, including extension and new sections of overhead lines. My question therefore is how can this development be objectively considered without knowing the extent of the modifications necessary to the National Grid substation at Boddlewyddan. Secondly I question the size of the proposed onshore substation. The developers alraedy operate a onshore substation in the same area for the Gwynt y Mor wind farm, this is a larger renewable energy source which utilises 6.92 acres of rural land. The Awel y Mor proposal may take up to 12.35 acres of fresh rural land so having a larger environmental impact"

Envirowatch.EU
"1.Replacement of loss of land by sufficient compensatory replacement by tree/ shrub planting, 2.Wildlife, including insect provision, 3. Green connecting corridors, 4. Water bodies for the above"

Ros Griffiths-Williams
"Impact on the environment and wildlife. Number of homes accessing renewable energy generated - effectiveness of proposed turbines in relation to other forms of renewable energy. Impact on target of net zero."

Rostons on behalf of Mr Hugh Wynne-Davies
"We are concerned in principle about the amount of agricultural land being acquired for the scheme and its impacts on food security. principally the amount of land required for contemporary construction compounds and ensuring that the land is returned in a proper and productive condition. We are also concerned about the additional traffic using Dyserth Road and the hazards it will cause for other road users and pedestrians."

Rostons on behalf of Mr Ivor Beech
"We have concerns regarding the following issues: - A significant amount of land occupied and farmed by Mr Beech is to be affected, during and after the works have been completed, this will greatly affect the productive capacity of the land to produce food and is a concern with regards to food security. - The additional traffic accessing the construction compounds on the A547 & Bodelwyddan Road will cause significant congestion as it accesses the A525. - The presence of the construction compounds in close proximity to residential properties has the potential to cause significant stress and health issues to those living at the properties."

Betws yn Rhos and Llanelian yn Rhos Community Council
"The visibility of the windfarm to high ground coastal habitation within the Community Council area due to the size and diameter of the structures. Any compensatory grant available to the Community Council area."

DMPC on behalf of Mr AEM Owen
"Concerns the potential adverse impact of the proposed cabling /ancillary works in respect of land farmed by our client and associated reinstatement standards"

DMPC on behalf of Mr HG & Mrs ME Hughes
"Concerns the adverse impact of the proposed cabling works in respect of our land and associated reinstatement standards."

DMPC on behalf of Mr JB & Mrs E Evans
"Concerns the substantial adverse impact of the proposed scheme acquisition (and ancillary works) on the viability of our client's agricultural enterprise (taking into account the extent of the mitigation area earmarked for the siting of the substation) , together with screening measures proposed and the lasting detrimental effect on the retained property."

Ray Knight
"I would like to support this project because I feel very strongly about renewable energy being produced in the UK. I believe the plans look agreeable and do not detract from an area. I would like to understand how the scheme could benefit local communities."

DMPC on behalf of The Estate of the Late Mr Wynford Davies
"Concerns the potential adverse impact of the proposed cabling /ancillary works in respect of our client's land and associated reinstatement standards."

Flintshire County Council
"The proposal does not appear to involve any land take in Flintshire. The only impacts on Flintshire appear to be related to transport and transportation and seascape/landscape and visual impact. There could also be community benefits that could arise that Flintshire Communities could benefit from which are noted above. The proposed development site is over 20km from Flintshire and only likely to be visible from the very western coastal strip in Flintshire and also from higher ground. Therefore, due to the distance the proposed development is in relation to Flintshire, it is considered that the visual impact on Flintshire and its receptors would not be significant. However, it is noted that the SLVIA does identity significant effects on seascape and landscape and visual receptors throughout the North Wales region. The SLVIA Report confirms that the Awel y Môr proposal at the scale and height proposed would be a major feature and substantial detractor to several special qualities associated with the designated landscapes of North Wales and the National Park. This may, in turn have an indirect negative effect on tourism for the region. Finally, it is noted that there could also be community benefits that could arise that Flintshire Communities could benefit from. The Council would welcome further engagement and consultation with RWE in relation to community benefits and would comment on further details as and when they are provided by the applicant."

Wilson Fearnall on behalf of GBL and IM Kerfoot Discretionary Trust
"The Trustees of the GBL & IM Kerfoot Discretionary Trust wish to make the following representations to RWE’s application for the Awel Y Mor Offshore Wind Farm Order. Inadequate Consultation • The applicant has failed to engage and communicate effectively over key design issues including the cable route, temporary mitigation areas and permanent access rights; • The applicant has not provided sufficient responses to s42 consultation feedback (as referenced in the SoCC) and has failed to fully consider suitable alternative proposals to mitigate; • The material provided for consultation with regard to construction timescales and methodology is inconsistent with land rights being requested; EIA & Designs • The applicant has not fully assessed the impact of their proposals in connection with emerging spatial development requirements of the Denbighshire Replacement Local Development Plan 2018-2033. • Inadequate provision of land rights included for the permanent and temporary diversion of footpaths and utilities. • Rights are being sought via negation that will support and allow development not included with the application. Indicates insufficient design confidence at application stage. Compulsory Acquisition of Land • The applicant has failed to adequately consider reasonable alternatives and suggested modifications to the design; • The applicant is unable to clearly demonstrate that rights sought are proportionate and reasonable for the delivery of the project. Permanent rights are being sought for ‘Temporary Mitigation Areas’ and cable easements with time limited operational periods; • The applicant cannot demonstrate a clear use, or necessary locational requirement for ‘Temporary Mitigation Areas’; • The applicant has not made sufficient attempts to acquire the land required by agreement and the Statement of Reason does not accurately reflect progress and engagement to date; • The applicant has not fully considered the balance between public and private rights and is unable to demonstrate in many cases that there is a compelling case in the public interest for the compulsory acquisition of land."

JNCC
"JNCC would like to be registered as an interested party for the Awel y Mor offshore windfarm DCO application/examination. JNCC are statutory advisors to the UK Government and devolved administrations on issues relating to nature conservation in UK offshore waters (beyond the territorial limit). Our key area of interest is the potential impact of the Awel y Mor development on North Anglesey SAC. This site includes territorial and offshore waters and is jointly managed by JNCC and NRW. The proposed development is approximately 15km from the North Anglesey SAC, designated for harbour porpoise. The design envelope includes mono piles as a foundation option; impact piling has the potential to impact the conservation objectives of this site. Natural England (NE) is authorised to exercise JNCC’s functions as a statutory consultee in respect of certain applications for offshore waters adjacent to England (0-200 nm). As such, we defer to NE to input SNCB views regarding nature conservation advice relating to English offshore waters."

Llandudno Town Council
"The development will have a significant impact on the Town of Llandudno. There are the visual aspects and the potential impacts on the tourism and the SSSI (Great Orme) to be considered. If this does go ahead as seems to be implied by the current situation, Llandudno Town Council wishes to ensure that the maximum benefit for the town and community is achieved. The Town Council would also want assurances about the carbon footprint, operational lifespan and end of life reparation for the development."

Manx Fish Producers Organisation
"The Manx Fish Producers Organisation wishes to remain as an interested party in this development. Our members, which includes scallop fishermen, have interest in the immediate area and specifically the areas around the development which form the regional study area. In the past, Manx vessel data has not been fully included in the presented datasets for other windfarm presentations both within and outside the regional study area, as typically it is Seafish data for over 15m vessels. While we have 11 over 15m vessels in our organisation we also have 24 under 15m vessels which fish for scallops in the regional study area. While the fishing activity of Manx registered may be limited in the commercial fisheries study area it is significant in the regional study area. The issue facing us is one of cumulative impact. It may be only a small percentage of our activity in a specific area but when all of those areas are added together the impact can be high and this is seldom if ever taken into account."

EirGrid
"I am Lead Cable Engineer for the East West Interconnector (EWIC) which is an asset owned by EirGrid and is considered a nationally critical piece of infrastructure. I am registering interest in order to ensure the integrity of the asset is upheld throughout."

Martin Griffiths
"Hi RWE, I submitted a basic response to the Awel Y Mor consultation previously (06/09/21) but upon further reading of the documentation provided I would like to offer some further information from a residents point of view please. (REDACTED) Within the documentation there are several references to the 30mph speed limit along Glascoed Rd B5381. Unfortunately this assumption is incorrect, upon leaving St Asaph Business Park (heading West) the limit changes to a national speed limit (clearly signed) 60mph and remains so beyond the crematorium as well as the houses adjacent to the proposed substation access points. I also note that the detriment to the view from the properties is scored as low because 'high' hedges are alongside the road, this may be the case during the brief period that the hedges are in full leaf (maximum 3 1/2 months per annum) but as they are not evergreen and are also regularly trimmed down to approx 4-5 foot high, therefore the substation shall be much more visible for the majority of the year than is reported. This is also the case with regard properties number 7 & 8, there is very few trees in the garden of the lodge opposite and as they are again only in full leaf for short periods of the year (none are evergreen) this will allow the substation to be seen for a substantial period of the year. Although the report / documentation seems comprehensive much of the information contained could be interpreted as trying to 'pull the wool over peoples eyes' with regard the impact that it will have on our quality of life. Computer generated images of hedgerows are (imo) nowhere near being true representations. Photographs taken of the area have been taken from the lowest possible level (some 2 metres below the doorways of the lowest property in our row) they therefore do not give a true representation of the visual impact which we will be forced to endure. Although we understand devaluing our property is not deemed a legitimate planning concern we believe that the c£50k that we have invested in our property is now wasted. The equity that we have build is lost and the views / vistas from the front of our property (which include a full aspect of the Northern end of The Clwydian Range) will be ruined forever. At present we see mountains, woodland and green farmland (genuine pictures available upon request) which seems soon to be replaced by a monstrous civil engineering project that will result in a constant drone of noise from the transformers as well as high levels of light pollution. The proposed substation will sit almost parallel with the 8ft wall which surrounds Bodelwyddan Castles protected parkland but as we notice the lighting for the new site will be 18mtrs high its safe to say that the features of the new construction will have a significant visual impact on all surroundings. The proposed substation will be a blight on the landscape, the local wildlife and furthermore a blight on our lives, although we understand the need for further transition to renewable energy the significant impact that this chosen location will have on our small residential community is high and seems unacceptable. Kind Regards, MG (REDACTED)"

DLA Piper on behalf of North Hoyle Wind Farm limited
"RELEVANT REPRESENTATION ON BEHALF OF NORTH HOYLE WIND FARM LIMITED 1. North Hoyle Wind Farm Limited (“NHWFL”) operate the North Hoyle wind farm (“NH”) to the south of the proposed Awel Y Mor wind farm (“AYM”). The location of NH can be seen on sheet 2 of the Works Plans. 2. NHWFL raise the following objections to the DCO based on the impact of AYM on the operation of NH- 2.1 The Works Plans shows that Work No.2 crosses the export cable of NH. Whilst an optioneering exercise was conducted in relation to the preferred cable route, there are alternative routes which would avoid the need to cross the North Hoyle cable. The Promoter has not satisfactorily explained why the two shortlisted cable routes (out of three) were rejected since at least one of these does not affect North Hoyle, whilst not affecting Constable Bank. 2.2 The installation of the export cable in terms of Work No.2 has the potential to impact adversely on the export cable for NH. The Promoter has acknowledged the need for a cable crossing agreement but no protective provisions have been included in the DCO to this effect. The DCO should not be made without such provision. 2.3 Work No.2 intrudes into the “Designated Area” for the NH export cable identified in the lease of the NH by the Crown Estate Commissioners to NH for the operation of NH. Within the Designated Area, there is provision in the Crown Estate lease which protects the position of NH. The Crown Estate Commissioners have covenanted with NH not to grant any lease, licence or consent (other than where the lease requires that NH’s consent is obtained) for the construction of any works within the restriction zone without NH’s consent (not to be unreasonably withheld). There is provision in the lease for the Crown Estate Commissioners giving consent for the laying of conduits in the Designated Area but this is subject to agreement with NH on protection for the NH export cable both in relation to the original installation and future inspection, maintenance, repair or renewal work. NH has not been approached to provide such consent. This represents an impediment to delivery of the scheme. 2.4 Protective provisions are required to ensure that the construction of the development, including its cable connection, does not interfere with NH or any planned works which might be required to NH, together with an indemnity for any impacts which are caused. Whilst there are protective provisions in Part 1 of Schedule 9 for electricity undertakers, these do not apply to the offshore works. Appropriate provision must be included in the DCO for the offshore works which may impact on NH. 3. NHWFL would intend to engage with the Promoter with a view to reaching agreement on necessary changes to the DCO, including protective provisions and mitigation measures. However, pending resolution of such matters, development consent should not be granted."

North Wales Wildlife Trust
"I intend to make points relating to potential impacts on marine and terrestrial habitats and species as well as proposed mitigation measures."

Rostons on behalf of Helen Owen Proffitt
"We wish to raise concerns about the following issues: • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of Janet Johnson
"We wish to raise concerns about the following issues: • We are very much against the scheme. • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of Kelly Proffitt
"We wish to raise concerns about the following issues: • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of Rachel Georgina Hughes
"We wish to raise concerns about the following issues: • We are not in favour of the scheme. • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of Richard David Proffitt
"We wish to raise concerns about the following issues: • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of Sandra Archdale
"We wish to raise concerns about the following issues: • We are not in favour of the scheme. • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of The Executor of the Estate of the Late George Edward Brookes
"We wish to raise concerns about the following issues: • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

Rostons on behalf of Toni Mayne
"We wish to raise concerns about the following issues: • There are due be significant vehicle movements and associated traffic measures on Bodelwyddan Road as construction traffic seeks to access the construction compound located at Fferm, off Bodelwyddan Road. This road is notoriously fast and has a number of accidents and near misses, we are concerned that the works will increase the risk of such accidents, particularly when entering and exiting the property. • We gave concerns that the presence of the construction compound, less than 200m from the main dwelling will have on the residents well being in the form of noise, light and dust pollution. • We have concerns that the removal of land from agricultural production, and the time that it take to return to full productivity will have an impact upon food security. • The property is used by the whole family, particularly the children for horse riding and this will not be able to take place during construction for health and safety reasons, causing the family to miss out on opportunities that cannot be repeated. • We are concerned about the impact of the construction compound at Cwybr Fawr on site residents due to noise, dust and light pollution, the most recent letting of a residential property attracted in the region of 60 applicants, highlighting the demand for property in the area and the conditions that applicants would be subjected to for the duration for the works. • Cwybr Fawr is a diversified business and supports a number of local businesses, we are concerned that the presence of the compound and works will have a wider impact on the local economy. • The compound and working areas are accessed off the A525 which is a primary access route between Rhyl and Rhuddlan, the duel carriageway is prone to congestion and it is feared that the works will exacerbate the issue and raise the risk of collisions."

William Beament
"I object to this development on the grounds that Awel-y- mor has not confirmed they will not be using SF6 gas in their instillation. SF6 is is an extremely potent greenhouse gas. Until Awel-y-mor confirm they will not use SF6 , I would like my objection to be registered."

Awdurdod Cynllunio Lleol Cyngor Gwynedd
"Mae Awdurdod Cynllunio Lleol Cyngor Gwynedd o'r farn fod y prif faterion i'w ystyried o ran y datblygiad gerbron yn cynnwys effaith ar ardal a thirwedd yr Awdurdod, ac byddem yn darparu sylwadau pellach ar y materion yma ymhellach ymlaen yn y broses."

North Wales Wildlife Trust
"My representation will raise points with regard to: Impact on marine mammals and other marine/coastal habitats and species Mitigation measures"

SP Energy Networks
"Thank you for the opportunity to comment on the above recently accepted DCO. I have reviewed the submission and on the basis of my review to date, I have the following comments. Please note that the general point to these comments is as I have previously commented (see attached), to avoid SPM assets and to engage as much as possible where this is unavoidable. For this current consultation response, I have grouped my comments into key areas of the DCO submission as below: General These comments are made by SP Energy Networks which acts on behalf of SP Manweb, the licenced Distribution Network Operator (DNO) for the area covered by the onshore elements of the proposed scheme. SP Energy Networks operate and manage the electricity network up to 132kV. This electricity network in the area of the proposed development is shown on the attached plans. In general, SP Energy Networks has no objection in principle to the proposed renewable energy scheme, however, it must ensure the avoidance of any adverse impact on its network as we all drive to maintain a network that is capable of meeting the increase in demand from an all-electric economy. SP Energy Networks has started a process of developing investment targets from 2023 to 2028 to meet the UK and devolved Governments ambitious decarbonisation targets for Net Zero. The next decade will be crucial in preparing the grid for these changes and this is why we are very interested in being able to comment on the proposals which may undermine maintaining and developing a suitable future grid network. In relation to this scheme, to date, SP Energy Networks has initiated engagement on various matters relating to the impact of the proposals on its network assets including the s42 stage and so considers to be at the early stages of working with the applicant to avoid impacts on its network. This engagement is helpfully recorded in the Consultation Report in para 385 (where reference is made to SP Energy rather than SP Energy Networks). SP Energy Networks commented on the scoping report in 2020 and these comments are repeated in the Scoping Opinion. However, SP Energy Networks requests the applicant to engage further to agree as much as possible at these earlier stages of the DCO process. SPM Network assets SP Energy Networks has over the course of the past year or so sought to obtain from the applicant detailed plans showing where crossover points are between the existing SPM assets and the proposed AyM development. Whilst the applicant has provided a plan showing crossover points, it is unclear to SPM what these crossover points are and if they are all points of contact where there will be an impact on SPM assets. The current position is that SP Energy Networks has recently asked the applicant to provide an overlay plan showing SPM assets and the proposed DCO limits. which seems the clearest way of showing these crossover points with a schedule explaining what the crossover is, and is seeking detailed discussion on the information included in the DCO (Figures 5 to 14 in Chapter 1 of Vol 3 of the EDS and the Crossings Schedule in Vol 3 Annex 1.1) to better understand the referencing system and identify crossover points. It is unclear from the information presented in these references to the ES as to what the reference in the legend ‘Crossing Schedule (excluding utilities)’ means and what the obstacle ID refers to as there are some differences between SPM assets listed in the schedule and what is shown in the figures, and whether the schedule includes all the SPM assets affected. In addition, it is not clear how the obstacles might be affected. It would help if there is an assumed centre line that indicates the likely route of the proposed cable installation. Having reviewed the submitted plans, the key pinch points are south of B5119, A547, River Clywd, north of A55, Glascoed Road and south of Glascoed Road. SP Energy Networks would like to resolve matters as much as possible and would like to see clarification on the crossover points/SPM assets as soon as further details can be provided. Noting the reference to SP Energy Networks network assets in the scoping opinion and the crossover schedule, no regard is given in the Environmental Statement to the impact of the AyM scheme on existing electricity network assets. Therefore it is identified what environmental impacts there might be where network has to be diverted and whether any required consents and further environmental assessment for diverted network is needed. This matter should be resolved and included in the AyM scheme. SPM does not want to be left with having to consent and assess environmental impacts for network diverted outside of the order limits or not included in the order limits. Impacts and consenting SP Energy Networks needs assurances that any affected network requiring to be diverted is, once identified, included in the EIA and properly assessed and reported. Where necessary, any related consents for diverting network is included in the DCO. It is noted no reference is made to such consents in the Other Consents and Licences Report. The applicant should clarify these matters as soon as possible. Grid Connection No reference is made in the Grid Connection statement to impacts on the existing electricity network and how proposed measures for working with SPM assets will ensure the existing network is able to operate and deliver the power that the proposed AyM scheme will provide. Measures for agreed working (DCO) Having carried out an initial review of the draft protective provisions in Schedule 9 of the draft DCO, these are not consistent with the provisions SP Energy Networks has provided to the applicant. As such, the applicant is asked to continue to work with SP Energy Networks and agree as many areas of possible through the application stages. Land Rights SP Energy Networks will require all SPM land rights affected by the AyM scheme that need to be amended to be agreed in full agreement with SPM. Reference is made to the Book of Reference where SP Manweb interests are included. Reviewing the BoR and confirming existing and proposed rights is likely to be an expansive task and the applicant is asked to engage with SPM regarding a timetable and cost undertakings to support working with SP Energy Networks in this regard. There are a number of key areas to resolve in relation to SPM network, which is critical to protect as it is this network that will be relied upon to distribute the generation into local homes and businesses. Any adverse impacts on the SPM network that need to be resolved by SPM would impact on the benefits of delivering this proposed scheme. The applicant should discuss the above with SP Energy Networks as soon as possible as they have been requested to do for over the past year but without making much progress. Given the extent of the information prepared and submitted, it is a reasonable expectation for there to be a plan produced showing the SPM asset as likely to be most affected and how, and an SPM network diversions worksheet that outlines how this network will be managed within the proposed development. SP Energy Networks will continue to review the DCO application and may wish to raise further matters in due course. Lastly, on an administrative note, please note that in order to assist in mail outs, you can delete SP Distribution Plc from the database as this is the SP Energy Networks distribution licence holder in southern Scotland and the entry for SP Manweb Plc, as this is covered by the ‘S Edwards, :and Land Planning SP Energy Networks’ entry."

Cadw - Welsh Government
"Cadw has serious concerns about the Environmental Impact Assessment (EIA) which we note is incomplete. In particular, we note that 30% of the proposed walkover survey for terrestrial archaeology has not been completed and the survey on the intertidal area is also incomplete. The geophysical survey has also only been undertaken on some 65% of the area required. However, the results of this work are essential if any sub-surface archaeological sites are to be identified and the need for further investigative work, including archaeological evaluation, carried out. The failure to complete these aspects is contrary to section 5.8.10 of National Policy Statement EN-1 which states that any application should contain sufficient information to allow heritage significance to be understood. The surveys must therefore be completed so that the impact of the proposed development on the historic environment can be understood. The proposed development will have an impact on (i) the settings of Beaumaris and Conwy Castles, which are both nationally important scheduled monuments and part of the Castles and Town Walls of King Edward in Gwynedd World Heritage Site and (ii) Penrhyn Castle which is a grade I listed building set in a Grade II* registered historic park and garden and part of the Slate Industry of Northwest Wales World Heritage Site. The proposed windfarm will be seen in identified significant views from all of these designated historic assets. Whilst these significant views are acknowledged in the respective assessments there is no explanation about the reasons why these views have been identified as significant and no full analysis of the impact of the windfarm in these views has been made. This failure appears to be due to the assessor considering that as the windfarm is some distance from the castles, their setting does not extend that far. This is incorrect as explained in Welsh Government TAN 24 Section 1.25 - the setting of an historic asset includes the surroundings in which it is understood, experienced and appreciated, embracing present and past relationships to the surrounding landscape. Its extent is not fixed and may change as the asset and its surroundings evolve. Therefore, we consider that the full impact of the proposed development on the settings of these very highly significant historic assets has not been fully assessed leading to the effect being understated in the EIA. Consequently, the assessment of the impact of the proposed development on these historic assets along with the impact on the World Heritage Sites should be redone before the EIA is submitted with any application."

Dr Jonathan F Dean
"I am broadly in support of Awel y Môr offshore wind farm. My concern is about how it will connect to the grid Using subsea cables and buried cables to the substation is excellent, taken in isolation, but the wider impacts on the grid are not fully considered The Ofgem Offshore Transmission Network Review is not yet published, and the impact of this offshore generating asset on the onshore transmission network not fully understood. There are many changes to the north Wales generation and transmission landscape, either “in flight” or in discussion, that may render a shore connection in north Wales inappropriate. The following are all likely to happen within the next decade: Mona and Morgan offshore wind farms, Môrlais tidal off Ynys Cybi, multiple solar farms on Ynys Môn, SMR nuclear at Trawsfynydd, large nuclear or several SMRs at Wylfa plus further offshore potential west of Ynys Môn. This mix of offshore and onshore may mean the better route for Awel y Môr is via an offshore grid rather than use the constrained onshore grid. Committing to an onshore connection “locks in” that capacity making it unavailable to onshore generation. This in turn would create additional cost and disturbance onshore that could be avoided by early commitment to an offshore route"

Genesis Town Planning on behalf of Memoria Ltd
"We act on behalf of Memoria Ltd who own and operate the Denbighshire Memorial Park and Crematorium, Glascoed Road, Saint Asaph, LL17 0LG. The crematorium and memorial park is directly impacted by the proposed development which would cause substantial harm to the operation of the facility resulting in the complete loss of the quiet and tranquil setting necessary for funerals to take place. Construction Traffic Temporary Access: Of particular concern is the routing of construction traffic to the proposed site of the sub station along Glascoed Road, passed the crematorium. The introduction of heavy vehicles and constant construction traffic movements within such close proximity to a sensitive receptor, such as a crematorium, would have a significant impact on the operation of the facility. The site of the crematorium was chosen because of its tranquil and peaceful setting, which is a necessary requirement to assist the bereaved in coming to terms with the loss of their loved ones. The proximity of Glascoed road and the use of it by construction traffic, would result in harm to this tranquil setting No amount of noise mitigation or landscaping would overcome the harm identified. Whilst the routing of construction traffic along Glascoed Road may have been the subject of detailed assessment and analysis we suggest that there has been no regard for the impact on the operation of the crematorium that would arise as a result. The most sensible solution would be to utilise a construction and haul road serving the sub station site either from the north, close to interchange with the North Wales Expressway (A55), or alternatively from the east through St Asaph Business Park where existing commercial activities exist. It makes no sense to bring traffic along Glascoed Road when suitable access could be achieved from Llys Edmund Prys or from Carlton Close across open fields to the site. Here the road widths are adequate, and the junction designed to accommodate large articulated vehicles associated with the commercial use of the business park. The existing commercial occupiers of the business park are not as noise sensitive when compared to a crematorium use. This approach would also encourage construction and associated traffic to utilise the A55 rather than the narrower country lanes to the south. In addition, scope to access the proposed sub station from the south of the A55 interchange along Ffordd William Morgan should also be explored further. This would avoid any construction traffic impacting on St Asaph Business Park, Glascoed Road, or the crematorium. We therefore request that further consideration be given to the location and routing of the construction access to the proposed sub station. Maintenance Access to the East of the Crematorium: We note that the submitted details indicate the introduction of a maintenance access to serve the cable route. This access is located immediately to the west boundary of the site, adjacent to the existing crematorium and memorial gardens. This access follows a hedge line, utilising existing field gates into the field to the land to the south along the alignment of the cable route. We see no reason why this maintenance access cannot be repositioned to the western boundary of the same field. There is simply no necessity for it to 'hug' the crematorium boundary. Whilst we note that the use of this access may be infrequent, any activity of that nature along the route and in proximity to the building would impact on the quiet enjoyment of the facility by mourners. The crematorium is in constant use, and undertakes over 1,500 cremations per annum, in addition to bereaved families visiting the gardens of remembrance. To have vehicles operating so close to the site, with the associated, noise, activity and visual disruption would be harmful to the operation of the crematorium."

National Trust
"The National Trust owns a diverse range of property along the North Wales coast that will have views to the proposed wind farm. This includes coastal property in North Anglesey to the west, Penrhyn Castle, the Carneddau in Snowdonia, and Graig Fawr in the east. National Trust also owns Parc Farm near the summit of Pen y Gogarth/the Great Orme. The Trust has a statutory duty to promote the permanent preservation of these properties for benefit of the nation-for ever for everyone. The Trust does not object to the principle of Awel y Mor. Climate change is one of our key priorities, and we recognise the need to bring forward renewable energy generation at larger scale: including that at Awel y Mor. We welcome the opportunity for critical examination and scrutiny of the proposals. National Trust staff, visitors, and tenants will see the proposed scheme from our properties and future visitor experience will include this significant new feature of the landscape and seascape. The key element for National Trust is the significance of change to the landscape and seascape. Our properties at Great Orme and Penrhyn Castle will be impacted most by the scheme-the most significant change in view for our visitors to consider. The nature of change and harm to the wider setting of the Great Orme Heritage Coast is a factor in our deliberations. Night lighting adds further to our consideration of landscape and seascape change from National Trust property. The identified residual effect during operation of the windfarm is the key concern from NT land ownership but given the length of construction our considerations also include the timelines relating to the latter end of construction and the decommissioning impacts. National Trust note the very limited approach to offshore landscape mitigation, with one line (line 1 page 20 of 23 pages) given to the issue. National Trust consider that further mitigation from the scheme can be achieved to reduce the identified harm from land in our ownership. We hope the night-time lighting issue can be examined in detail with further options explored on reducing harm. We also consider there are opportunities to enhance designated landscapes as offset mitigation. No enhancement or landscape/visual compensation programme is identified within the submitted scheme. The submitted Outline Landscape and Ecology Management Plan should be examined in the wider context of offshore residual effects, rather than its current scope and definition with a limitation to onshore construction and operation. The project submission identifies the significance of the Great Orme in its impact on tourism and recreation. Para 301 within Chapter 10 (Tourism and Recreation) of the ES states “there are opportunities for AyM to manage the risks of a negative short-term impact on tourism due to construction activity and to potentially deliver a positive benefit to the tourism sector within Llandudno and Great Orme area, which will be explored with local stakeholders”. No specific implementation mechanisms appear to be brought forward within the submission, nor the extension of this commitment to operational impacts, nor detailed exploration of this potential benefit. The project submission recognises in its Planning Balance conclusion (para 888) the significance of the landscape and seascape impact. Para 890 of the Planning Statement indicates “It is also noted that all predicted significant effects have been mitigated as far as practicable”. National Trust consider that the Planning Balance needs the further consideration of offshore landscape with a redefined Landscape Management Plan including a wider and specific package of offset mitigation and enhancement measures. National Trust wish to see consideration of this issue through Examination and potentially a Section 106 Agreement to secure the wider landscape enhancement alongside the management of tourism risk: both identified as key issues within the submitted scheme."

UK Chamber of Shipping
"The UK Chamber of Shipping is the trade association for the UK shipping industry, representing some 200 members, operating 900 vessels equalling 18 million GT in capacity, trading around the UK and globally. The Chamber represents the full breadth of the industry, including dry and wet trades, passenger transport (cruise & ferry), offshore supply and construction, towage and specialist, as well as professional service providers with shipping interests. The Chamber fully supports the Government’s obligations to achieve Net Zero and welcomes the development of offshore renewable energy as a means to achieve. The ports and shipping industries play an essential role in enabling those targets to be achieved by providing bases and vessels for construction, operation & maintenance, and decommissioning. The Chamber also asserts that the planning process and framework must support both the UK’s offshore renewable goals for decarbonisation and the wider shipping industry to ensure that navigational safety is not compromised nor economic contribution from the shipping industry jeopardised, in accordance with the National Planning Statements. The Chamber seeks to ensure navigational safety is upheld and that developments are appropropriately positioned to enable existing commercial navigation to continue safely and efficiently. Shipping is the greenest form of cargo transport and proposed offshore renewable developments must take fully into consideration the routeing and operations of commercial shipping to enable this to continue. The Chamber has been closely involved in the planning process for Awel y Mor prior to DCO application, through PEIR, Hazard Workshops and the NRA, advocating for full considration for navigation safety and environmental efficiency of commercial shipping. The Chamber wishes to have opportunity to provide further representation on navigation, where necessary."

Carl Davies
"Charter Skipper/Commercial fisherman Conwy based. Our sector was included in the scoping process during a few meetings with RWE, Gobi Consultants and the Fishery Liason Officer, which was much appreciated. Many concerns were flagged, concerning the effects Awel y Mor construction and post construction on finfish and shellfish, after reading the scoping report and PIER. The charter vessel industry along the North Wales coast has extensive experience of the effects of other wind farms on finfish. However, I am concerned to note that in the EIS many of these concerns have not been addressed. Best Regards, Carl Davies REDACTED"

Diamond Transmission Corporation
"As an owner of assets that will be crossed or affected through proximity of potential works both onshore and offshore, it is important for us to be consulted and be involved in the matter as an interested party."

Glyndwr University on behalf of Glyndwr Innovations Limited
"This Relevant Representation is made by Glyndwr University (“Respondent”) as interested party and leaseholder of the building and land known as Optic Technology Centre (“Centre”) located at Ffordd William, St Asaph Business Park, St Asaph, LL11 0JD. The Respondent has previously engaged with the Applicant providing a section 42 response to the earlier statutory consultation concerning the Project in 2021. It follows that as part of this process, the Respondent raised a number of concerns with the Applicant regarding both short and long-term adverse impact to the Respondent and its business operations from the noise and vibration implications arising from the proposed Project and identified within the Applicant’s Preliminary Environmental Information Report. The nature of the Respondent and Centre’s business operations predominantly consist of precision optical systems, including optical fabrication and surface metrology which relies on vibration-sensitive machinery. The Respondent’s primary concern is and remains to be that low ground-born low frequency (sub-micron level) vibrations which are likely to arise out of the Project (including but not limited to the development of an onshore substation and corridor in close proximity to the Centre) would render machinery used by the Respondent for its processes unusable and substantially and detrimentally effect its undertakings at the Centre without reasonable and appropriate mitigation. The Respondent has reviewed the Applicant’s Application together with accompanying documents including the Environmental Impact Assessment, Consultation Report and Noise and Vibration Mitigation Plan and remains concerned that these do not appropriately consider the nature of the area for which the proposed on-shore element of the development concerns such as St Asaph Business Park which consists of a high proportion of businesses similar to that of the Respondent who operate during the days and timings proposed by the Applicant with respect to the Applicant to undertake Project construction nor appropriately addresses the Respondent’s earlier concerns outlined within its earlier section 42 response and possible options for mitigation for the Project as discussed between the Applicant and Respondent in October 2021 including consideration of such days and times the development could be undertaken in order that the impact on the Respondent, as a commercial enterprise, arising from any subsequent development by the Applicant could be reasonably and proportionately reduced."

Isle of Anglesey County Council
"Awel Y Mor Offshore Wind Farm Planning Inspectorate Reference: EN010112 Isle of Anglesey County Council Written Representation Thank you for the invitation to become an Interest Party with respect to the Awel y Mor (AyM) Offshore Wind Farm application for Development Consent Order (DCO).This representation by the Isle of Anglesey County Council (IACC) includes an outline of the principle submission we wish to make in relation to the application as submitted. The IACC acknowledges that there is a recognised need and support for renewable energy technology through UK, Welsh and Local Planning policy and this development would contribute towards the targets set for both the UK and Wales's greenhouse gas emission reduction and increasing the country's energy supply from renewable sources. Landscape and Visual Impacts The IACC have assessed the Environmental Statement Report Volume 2, Landscape and Visual Impact Assessment which presents the Landscape and Visual Impact Assessment (LVIA) for the onshore elements of the proposed development. It is considered that the development will have a significant adverse impacts on views of the seascape from the Ynys Môn Area of Outstanding Natural Beauty (AONB) and a harmful effect on a number of AONB special qualities. It is not considered that the development would be consistent with the conservation and enhancement of natural beauty. Adverse effects on the designated landscape and seascape as a setting and feature of the Ynys Môn AONB, relate to the likely visibility of the proposed Offshore Wind Farm (OWF) alone and cumulatively with other OWFs. The introduction following pre-application consultation of design mitigation to reduce the extent of the horizontal and vertical field of view and number of turbines has reduced the area and number of receptors from which significant adverse effects would be experienced; however, significant effects are predicted for a substantial portion of the east coast, recreational routes within such as the Wales Coast Path and properties within coastal communities. Archaeology & Heritage Assets: The Council has consulted with Gwynedd Archaeological Planning Service (GAPS) the regional curator with regulatory and advisory functions and the Council’s advisor with regards to matters concerning archaeology. It is considered that the archaeological impacts of the proposal relevant to the Isle of Anglesey are confined to the possible loss of significance to terrestrial historic assets, due to change in their setting. These historic assets include Listed Buildings, Scheduled Monuments, Penmon Registered Landscape of Outstanding Historic Interest and most importantly Beaumaris Castle World Heritage Site. Visual and physical connection to the sea is an important aspect of many of these sites. Visual intrusion of the new turbines may impair this connection and unacceptably reduce the significance of one or more assets. It would appear that the impacts the proposed wind farm would have on the setting of some Listed Building’s have been under assessed. These include the Grade II* Trwyn Du, or Black Point, Lighthouse (CADW Record No. 21615) and the Grade II Telegraph Station (former) (5529). Additionally, the impacts upon the setting of the Grade II listed Pilot's Cottage (former) No 1 & 2 and Enclosure walls at former pilots' cottages for Trwyn Du, or Black Point, Lighthouse (CADW Record No.’s 5515, 26757 and 21616) have not been assessed. The proposed development could damage the important visual and physical connection between many of the above heritage assets and the sea and by doing so lessen their significance. The IACC also refers PINS to the comments received by CADW in relation to Beaumaris Castle World Heritage Site and the Menai Suspension Bridge, which are considered of high historical architectural value and are popular tourism attractions on Anglesey. Socio-Economic: The IOCC have assessed the Environmental Statement Report Volume 3, Chapter 3: Socio –economics which presents the result of the assessment of the likely significant effect of the development with respect to socio-economic including jobs and economic output. - Local Employment & Supply Chain Opportunities Future Wales acknowledges that large-scale renewable and low carbon energy schemes can generate direct social and economic benefit to local communities and that developers should explore how infrastructure improvements associated with a development be utilised by the host communities to bring additional, non-planning related benefits. The Council notes the confirmation that the opportunity to maximise local socio-economic benefits will be explored and presented in more detail post- consent. It is noted that this includes the requirement under requirement of any DCO given for the development to submit for approval a ‘Skills and Employment Strategy’. Similarly, local companies need to be made aware of the potential supply chain opportunities that will be made available during all stages of the project to allow them to plan accordingly and ensure that they can capitalise on the opportunities presented. The Council would also promote the development of a Supply Chain Action Plan’. It appears that the DCO Requirements as currently drafted does not include a suitable worded requirement that requires the approval of a ‘Skills and Employment Strategy’. It is best practice to prepare and submit an outline of such plans as part of the DCO application documentation in order to ensure that such discussions take place early and during the consenting process, with engagement taking place with key stakeholders and that the final plans to be approved under condition is based on the outline plans. Key stakeholders including Welsh Government, North Wales Regional Skills Partnership, Ambition North Wales, M-Sparc, local education providers (including Bangor University and Group Llandrillo Menai) and relevant Local Authorities (including Economic Development Teams). It is noted from the assessment that the jobs which are likely to be generated include port related activities, charted and operation of non-specialist vessels and civil works related to installation of onshore infrastructure. The Council would encourage RWE to consider these opportunities now and to identify how much of these skills are available locally in order to enable local people and companies to train or upskill to capitalise on these opportunities. Given the potential for other major offshore wind projects to take place in North Wales such as the Mona Offshore Wind Farm, the Council very much considers that there is potential for collaboration in order to ensure that the potential socio-economic benefits are maximised for the region. - Potential of Holyhead Port and Amlwch Port It is noted that the submission does not specify either a construction or operational port that will facilitate the project. The Council understands that the port development will not be part of either the DCO or marine licence application and that any port upgrade works would be delivered through separate requests for consents. It is noted and welcomed that Holyhead Port is included on the long list of ports that have been identified as part of the EIA process. Other ports on Anglesey which could support the delivery of the project include Amlwch Port. We are aware that you have undertaken a port study and have already commenced engagement with Stena Line Ports. IACC would recommend for this engagement to continue in particular to gain an up to date understanding of the proposed future investment for the Port. The Council notes that the ES assessment splits the construction phase into scenarios which is dependent on the proposed port locations – a ‘no local construction port scenario’ and a ‘local port construction scenario’. This approach provides a clear indication that in the event that a local construction port is located on Anglesey, it would have greater impact upon the local economy by increasing local sourcing and employment. Even with the port being located locally, the magnitude of impact upon the economy together with employment opportunities for North Wales has been assessed as ‘negligible’ and that the residual effects as ‘minor beneficial’ during both the construction and operational phase. The Council confirms the port selection has the potential to offer socio-economic benefits for the region at all project phases and that use of a port local to the development should be fully explored. Furthermore, the Council believes that suitable land located close to the port could be available to support the construction and operation of the AyM project. The IACC is happy to discuss this further with the developer in order to understand their requirements as the project develops. - Marine Licence The IACC notes that a separate Marine Licence application has been submitted to Natural Resources Wales (NRW). The IACC confirms that it will be making separate submissions to NRW."

Llanddulas and Rhyd Y Foel Community Council
"I have been asked by the Community Council to register our interest for the following reasons. 1. Although the Project is centered on the Rhyl area a significant number of the turbines will be built off the coast of Llanddulas village 2. The Project involves construction work along the A55 which is the main route for tourism into the area"

Department of Infrastructure, Isle of Man Government on behalf of Mrs Emily Curphey, Chair, Territorial Sea Committee
"The Territorial Seas Committee (TSC) has previously submitted comments on this project, but comments in respect of offshore ornithology and commercial fisheries need to be raised again. Concern remains with regards the cumulative impact of all the proposed offshore windfarms within the Irish Sea area and the impact they could have on shipping and navigation. Offshore ornithology has been screened in within the transboundary screening report, however consideration of Manx conservation features has been inconsistent across the chapters of the Environmental Statement. The Isle of Man view on the ornithology scoping has been included, in full, within the revised Scoping Report, but the applicant’s responses are not stated. We have previously noted the lack of reference to Manx sites that are likely to relate to this study area, specifically the Manx shearwater and the comments of the JNCC relating to remaining flight height risks and the possible need for CRM assessment, and we have requested evidence of the specific consideration of the Isle of Man in such respects. We note that no ‘significant effects’ were found in the ornithological assessments, and therefore site attribution was not undertaken. Nevertheless, site related considerations have arisen in the process, but we have not found any comment on the Manx seabird colonies or Manx sources of migrant birds, lying within range on the Isle of Man, where they are a feature of a number of designated sites. In the offshore ornithology sections, despite the presence of relevant species of seabird on the Isle of Man, including regionally-relevant, breeding colonies and recovery programmes, there are only three, non-specific references to Isle of Man in the main chapter. With no references, or acknowledgement of the Manx protected sites, it is difficult to confirm that adequate consideration of Manx ornithological interest have been considered. Commercial fisheries has been screened in as a transboundary impact assessment. As noted in the Isle of Man Government’s response to the PEIR, and comments within ‘Annex 8.2: commercial Fisheries Consultation Record’, there are still only 3 non-specific references to the Isle of Man in Volume 4, Annex 8.1 Commercial Fisheries Baseline Final, and 5 non-specific references in Volume 2, Chapter 8 Commercial Fisheries v Final. Given the overlap of the Fisheries Regional Study Area within Manx waters (ie. 36E5), the non-specific references make it difficult to determine whether the Isle of Man commercial fishing interests have been adequately considered. The responses outlined in the Consultation Record are typically generic, and not apparent that further attempts to quantify the fisheries baseline have been made by engagement with relevant Manx data sources nor specifically for any potential impact on the Isle of Man fleet. These examples do not provide reassurance that Manx commercial fishing interests have yet been adequately considered, regardless of the eventual conclusion of the assessment. The TSC has a reasonable expectation of demonstrable consideration within the ES of issues relevant to Isle of Man interests, and this is not yet apparent within the Ornithological or Commercial Fisheries assessments."

National Grid
"APPLICATION BY AWEL Y MÔR OFFSHORE WIND FARM LIMITED FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE AWEL Y MÔR OFFSHORE WIND FARM PLANNING INSPECTORATE REFERENCE: EN010112 RELEVANT REPRESENTATION BY NATIONAL GRID ELECTRICITY TRANSMISSION This relevant representation is submitted on behalf of National Grid Electricity Transmission Plc (“NGET”) in respect of Awel Y Môr Offshore Wind Farm Limited's ("Promoter") application for a development consent order ("DCO") seeking powers for an offshore wind farm ("Project"). NGET has a substation, high voltage electricity overhead transmission lines and underground cables within or in close proximity to the proposed Order Limits. The substation, overhead line and underground cables form an essential part of the electricity transmission network in England and Wales. The details of the electricity assets are as follows: Substation • Bodelwyddan 400kV Sub Station. • Associated overhead and underground apparatus including cables. Overhead Lines • 4ZB 400kV OHL - Bodelwyddan - Deeside - Pentir 1 o Bodelwyddan - Deeside - Pentir 2 • GM Route 400kV OHL Bodelwyddan - Deeside - Pentir 2 Cable Apparatus • Pentre-Mawr Cable Compound • Deeside - Pentir 1 Cable • Bodelwyddan4 St Asaph 132kv Cable Sections 01 And 02 NGET will require appropriate protection for retained apparatus including compliance with relevant standards for works proposed within close proximity of its apparatus. NGET's rights of access to inspect, maintain, renew and repair such apparatus must also be maintained at all times and access to inspect and maintain such apparatus must not be restricted. Further, where the Promoter intends to acquire land or rights, or interfere with any of NGET’s interests in land or apparatus, NGET will require appropriate protection. Further discussion is required between NGET and the Promoter to ascertain the impact to NGET's apparatus and rights. Protective Provisions NGET requires protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET is working with the Promoter in relation to the protective provisions for inclusion within the DCO, along with any supplementary agreements which may be required. NGET and the Promoter will keep the Examining Authority updated in relation to these discussions. Summary As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. NGET reserves the right to make further representations as part of the examination process but in the meantime will continue to work with the Promoter with a view to reaching a satisfactory agreement on all matters."

Natural Resources Wales
"PROPOSED AWEL Y MÔR OFFSHORE WINDFARM PLANNING INSPECTORATE REFERENCE: EN010112 RELEVANT REPRESENTATION FROM NATURAL RESOURCES WALES (NRW) 1. INTRODUCTION 1.1. NRW have identified key concerns relating to the following matters, which have been split into offshore and onshore as set out in the Environmental Statement (ES): - OFFSHORE • Marine mammals - ONSHORE • Flood Risk (Flood Risk Activity Permit) • Designated Landscapes The above matters are those that require amendments to the scheme, substantial additional information, or a revised Development Consent Order (‘DCO’). The topic heading for these matters are marked “Key Concern” in the relevant sections below. We also provide comments below on matters that may need minor amendments and / or clarification. These are matters that we can provide further details on in our Written Representations and / or can be addressed in our on-going dialogue with the Applicant in the preparation of our Statement of Common Ground (SoCG). 1.2. NRW shall continue to provide advice to the Applicant on all the required matters, through correspondence and meetings, with the aim of reaching as many positions of agreement and common ground as possible prior to the examination of the proposals. Our Relevant Representation is based solely on the information provided within the application documents. Any changes in our position will be reflected in our full Written Representation and SoCG. 1.3. NRW has reviewed the DCO submission and, notwithstanding our key concerns and other issues raised in this representation, consider the submission, on balance, to be comprehensive and of a good quality. NRW is pleased to note that many of our previous concerns, as raised during the pre-application process, have been appropriately addressed. 1.4. Our comments are made without prejudice to any further comments NRW may wish to make in relation to this application and examination whether in relation to the ES, provisions of the draft DCO and its Requirements, SoCG or other evidence and documents provided by RWE and their consultants (‘the Applicant’), the Examining Authority or other interested parties. The following paragraphs comprise our Relevant Representation as a Statutory Party under the Planning Act 2008 and Infrastructure Planning (Interested Parties) Regulations 2015 and as an ‘interested party’ under s102(1) of the Planning Act 2008. 1.5. In addition to being an interested party under the Planning Act 2008, NRW exercises functions under distinct legislation including (but not limited to) the Environmental Permitting (England and Wales) Regulations (EPR) 2016 (as amended) and the Marine and Coastal Access Act (MACAA) 2009. NRW has received applications for a Marine Licence under the MACAA 2009. For the purpose of clarity, comments from NRW Regulation and Permitting Service are titled as such, and include comments in Annex A. We provide a comment on NRW’s general purpose in section 4. 2. OFFSHORE 2.1. Marine Mammals – KEY CONCERN 2.1.1. The proposal has the potential to impact marine mammal Annex II and European Protected Species (EPS) and we consider that impacts such as auditory injury and associated disturbance have not been adequately assessed. 2.1.2. NRW considers that the assessment of impacts of underwater noise on marine mammals is inadequate. I. There is inadequate justification for the absence of assessment of cumulative Permanent Threshold Shift (PTS) in the Habitats Regulations Assessment (HRA); as such we consider that the assessment is incomplete. II. There are insufficient grounds to conclude that PTS-onset risk has a negligible impact on harbour porpoise when cumulative PTS-onset has been excluded from the Marine Mammal Mitigation Protocol (MMMP) (APP-107); III. In order to allow a more comprehensive analysis of PTS and disturbance, NRW considers that additional modelling should be carried out and additional model details provided in order to inform assessments of underwater noise and PTS onset. This includes carrying out Interim Population Consequences of Disturbance (iPCoD) modelling for harbour porpoise disturbance and PTS injury, including modelling parameters used. IV. NRW does not recommend the use of dose/response curves to conduct an area-based assessment to estimate area of harbour porpoise habitat disturbed. Given that disturbance for harbour porpoise Special Area of Conservation (SACs) is defined through spatial and temporal thresholds of 20% daily and 10% seasonal disturbance, as set out in the supporting advice for the disturbance conservation objective (CO2) for porpoise sites, we advise that an area-based assessment should be carried out where the extent of habitat that is insonified to a level that might produce significant disturbance is determined. Although there is a strong link between area lost and numbers disturbed, directly equating the probability of population response to loss of habitat / loss of habitat quality (i.e. using a dose response curve to calculate habitat loss) is currently not possible. 2.1.3. There is insufficient justification to support a conclusion of no Likely Significant Effect from vessel collision for bottlenose dolphin, grey seal or harbour porpoise features of relevant SACs. 2.1.4. A number of figures in the revised marine mammal Chapter 7 (AS-026) appear to be incorrect. For example, Figure 21 is supplied in place of Figure 19, and Figure 21 does not contain all the necessary data layers either time it is presented. Corrected figures should be supplied alongside confirmation of the nature of any revisions from the original version (APP-053). 2.2. Marine Ornithology 2.2.1. NRW advises that a detailed assessment of the potential impacts of the project on the breeding seabird features of Pen-y-Gogarth / Great Orme’s Head Site of Special Scientific Interest (SSSI) (guillemots, razorbills and kittiwakes) should be undertaken, as currently this has not been done sufficiently to assess effects on these features. 2.2.2. From the evidence provided, it does appear that the extent of the supporting habitat for red-throated diver (RTD) within the Liverpool Bay Special Protection Area (SPA) will be maintained if the project is constructed and therefore there will be no adverse effect on the RTD feature of Liverpool Bay SPA from loss of habitat. 2.2.3. However, we note that the displacement of RTD in this part of Liverpool Bay SPA is not consistent with what has been observed in other areas of Liverpool Bay SPA, as well as in other areas of the UK and Europe. 2.2.4. Given this anomaly in observation, NRW advises that comprehensive validation monitoring before, during, and after construction is needed to confirm that it is the case that supporting habitat (as identified in the sites conservation objectives) has not been lost. 2.2.5. NRW agrees that a vessel traffic management plan, using measures such as, but not limited to, restricting vessel movements to existing navigation routes, is necessary in order to avoid or reduce disturbance, and therefore displacement. As requested by the Applicant, we will work with the Applicant to produce and implement the plan. NRW considers that a vessel traffic management plan could be secured as a condition in the marine licence. 2.2.6. NRW notes that the Furness et al (2015) stable age structure assessment method has been applied. Whilst NRW would have preferred that stable age structure is calculated from the local surveys, or, by adopting a precautionary approach by counting all birds as adults, we do not consider that this impacts the final assessments. Therefore, NRW agree with the conclusions presented. 2.2.7. By looking at the range of figures presented for displacement and mortality, NRW were able to make an assessment (on a precautionary level) at higher levels of displacement and mortality than were chosen by the Applicant. By looking at the full range of variability of displacement and mortality, we do not consider this to be an issue. 2.3. Physical Processes 2.3.1. NRW agrees with the baseline description, numerical modelling approaches, assessment methodology, and the assessment conclusions with respect to the potential impacts of the Awel-y-Môr project on physical processes, as outlined in the ES. 2.3.2. NRW notes that the local dimensions of secondary scour are highly dependent upon the specific shape, design and placement of the scour protection. These parameters are highly variable and so there is no clear quantitative method or evidence base for accurately predicting the dimensions of secondary scour. Given the uncertainty regarding the spatial extent and volume of secondary scour, we therefore advise that post-construction monitoring should be considered. Clarity is required on the most appropriate regulatory mechanism needed to secure it. We acknowledge that the assessment of primary scour has been undertaken using recognised empirical equations supported by knowledge of the foundation design dimensions, and we agree with the assessment as presented. 2.4. Benthic Subtidal and Intertidal Ecology 2.4.1. NRW agrees that the data collected through the site-specific surveys, through the desktop review of existing literature, and data sources are sufficient to appropriately characterise the benthic ecology throughout the array and export cable corridor (ECC). We also agree with the assessment methodology and the assessment conclusions with respect to the potential impacts of the project on benthic receptors, as outlined in the ES. 2.4.2. We agree with the conclusion of the Report to Inform Appropriate Assessment (RIAA) that, provided the mitigation measures outlined are adhered to, the project will not have an adverse effect on site integrity (AEOSI) and therefore will not undermine the conservation objectives of the benthic designated features of the Dee Estuary SAC and the Menai Strait and Conwy Bay SAC. 2.4.3. From the evidence presented, the areas of low resemblance stony reef do not meet the strong justification criteria in terms of biological communities that NRW would expect within an Annex I feature. NRW therefore agrees with the conclusion presented that the discrete patches of stony habitats found in the ECC area do not qualify as Annex I stony reef. 2.4.4. NRW considers that the magnitude of impact from the potential introduction of marine invasive non-native species (mINNS) should be presented as Low (and not negligible) as there is a continuous risk of mINNS being introduced. Notwithstanding this, we consider that the significance of the impact would still be minor and therefore not significant in EIA terms. 2.4.5. We acknowledge the commitment of the Applicant to produce a biosecurity risk assessment to be conditioned within the marine licence, as outlined in the Schedule of Mitigation (APP-310) and the Marine Licence Principles document (AS-023). NRW recommends that the marine biosecurity plan is a free-standing document kept separate to the terrestrial plan provided in the Outline INNS Management Plan (APP-323). NRW should be consulted on the suitability of a marine biosecurity risk assessment and plan ahead of commencement of activities. Clarity is required on the most appropriate regulatory mechanism needed to secure it. 2.5. Saltmarsh - Clwyd Estuary 2.5.1. We note that the onshore cable will intersect Atlantic salt meadow at the Clwyd Estuary. Whilst the Clwyd Estuary is not a SAC or SSSI, saltmarsh is a section 7 habitat under the Environment (Wales) Act 2016. We note that there is a commitment in the Crossing Schedule (APP-121) for the use of trenchless techniques (for example, Horizontal Directional Drilling (HDD)) underneath the Clwyd Estuary. However, we require confirmation regarding how the cable will cross the river if it is undergrounded, that the techniques employed will be deep enough to avoid the saltmarsh and minimise cable exposure, and that appropriate entry and exit sites (pits) are identified. Such detail should be specified in the Outline Construction Method Statement (APP-313). 2.6. Fish and Shellfish Ecology 2.6.1. NRW considers that a robust assessment has been carried out to support the overall conclusions of no significant impacts on fish and shellfish receptors. 2.6.2. NRW agrees that the data collected through the site-specific surveys, through the desktop review of existing literature, and data sources are sufficient to appropriately characterise the fish and shellfish ecology throughout the array and export cable corridor. 2.6.3. NRW agrees with the conclusion of the RIAA that the project will not undermine the conservation objectives of the designated migratory fish features of the River Dee and Bala Lake SAC and Dee Estuary SAC. 2.6.4. The assessment asserts that Atlantic salmon do not pass through the array area and are therefore unlikely to be exposed to potential impacts from noise. However, we note that evidence supporting this assertion is not available. Nonetheless, NRW agrees that Atlantic salmon are not considered to be very sensitive to underwater noise impacts and furthermore, will only be transient in the array area. Therefore, NRW agrees with the overall conclusion of no AEOSI on the River Dee and Bala Lake SAC. 2.6.5. NRW agrees with the assessment methodology and the assessment conclusions of the potential impacts on fish and shellfish receptors. There are, however, some inaccuracies in the assessment, for example: there appears to be an error used in the calculation of affected spawning area for sandeel (Table 18, in Chapter 6: (APP-052)), where the figure from Worst Case Scenario (WCS) monopile piling NW location scenario has been adopted, rather than temporal Maximum Design Scenario (MDS) for multi-leg foundation modelling at the NW location. Furthermore, we do not consider that the assumptions used when modelling spawning fish as fleeing receptors are realistic, for example, we do not consider a sustained swim speed of 1.5m/s-1 is realistic for spawning sole. Consequently, it is our view that the figures presented for the Valued Ecological Receptor (VER) affected spawning potential do not represent realistic scenarios for some fish receptors, such as sole, plaice, cod and whiting. Nonetheless, NRW recognises that regardless of this, the resulting area impacted by noise from piling activities remains minor, when compared to the wide available spawning habitat in the region. NRW agrees that the significance of effect on VERs remain ‘minor adverse’ and are therefore not significant in EIA terms. 2.6.6. NRW notes the cumulative environmental assessment (CEA) undertaken for fish receptors and requires further information on how the cumulative impacts to fish populations over multiple spawning seasons from underwater noise arising from consecutive construction activity from several offshore windfarm projects in Liverpool Bay has been considered. 2.6.7. NRW agrees with the conclusions that the project will not impact Water Framework Directive (WFD) fish status in the affected Transitional waterbodies. 2.7. Marine Water and Sediment Quality (MW&SQ) 2.7.1. NRW agrees that there is no impact on Bathing Waters from elevated suspended sediment, during the construction phase. 2.7.2. We do not agree with the conclusions made in relation to sediment bound contaminants, as further information is required to support the conclusion. Where data is available, the Applicant should report all data in the context of Centre for the Environment, Fisheries and Aquaculture Sciences (CEFAS) Action Levels. Once the above information has been updated and provided, we advise that the RIAA is updated to reflect this new information. 2.7.3. We do not agree with the approach to assessing impacts to phytoplankton, as the assessment is focussed on nutrients rather than light limitation caused by elevated suspended sediments in the water column. We therefore disagree with the conclusion presented. The main impact pathway arising from the construction phase to phytoplankton is elevated suspended sediment and therefore this is what the assessment should focus on. 2.7.4. We do not agree with the approach to assessing Dissolved oxygen (DO) as the assessment is focussed on nutrients rather than suspended sediments. DO can be impacted by the remobilisation of anoxic sediments or sediments with organic content and associated bacteria. We therefore disagree with the conclusion presented, and we recommend that this is clarified. 2.7.5. We disagree with the Applicant’s conclusion that potential spills will only cause temporary issues as these chemicals can persist in the environment for long periods. We consider that the impact should be ‘medium adverse’ rather than ‘negligible adverse’ as presented in the ES, as the ability to meet Environmental Quality Standards (EQS) could be compromised (Table 6, Page 59: Chapter 3 (APP- 049)). However, we note the mitigation commitments presented to produce a Project Environment Management Plan (PEMP) and Marine Pollution Contingency Plan (MPCP) as part of the marine licence condition. Providing these conditions are secured and delivered, we can agree that the risk is mitigated to an acceptable level. 2.7.6. A number of inter-relationships between MW&SQ and other receptors have been overlooked, including but not limited to elevated bacterial counts and their ability to impact human health, which would be of relevance under the Bathing Waters Directive. 2.7.7. We agree with the conclusions in the ES with respect to suspended sediment in Water Framework Directive (WFD) water bodies (Chapter 3 Para 129 & 132 (APP-049)). However, for the purposes of the WFD Compliance Assessment (CA), please see comment below (comment 2.8.3). 2.7.8. We consider that the relationships between marine water quality and the onshore works have been considered appropriately and therefore agree with the conclusions and mitigation suggested. 2.8. Water Framework Directive (WFD) (Coastal and Transitional Water Bodies) - North Wales Coastal Water Body 2.8.1. NRW agrees with the assessment of the potential impacts upon the hydromorphology resulting from the presence of physical structures as provided in Volume 2, Chapter 2: Marine Geology, Oceanography and Physical Processes (APP-048). We therefore agree with the conclusion of the WFD CA (APP-094) for the hydromorphology element – that the proposed activities will not result in deterioration of status of the water body or jeopardise the attainment of its objectives. 2.8.2. NRW agrees with the characterisation of the biology, assessment methodology and the assessment conclusions of the potential impacts on benthic receptors as outlined in Volume 2, Chapter 5: Benthic Subtidal and Intertidal Ecology (APP-051). NRW therefore agrees with the conclusions of the WFD CA for biology: habitats within the water body - that the biological elements associated with this would not be at risk of deterioration as a result of the project. 2.8.3. In relation to water quality, we note that the information presented in the MW&SQ chapter has not been transposed into the WFD CA with respect to water clarity (suspended sediment) and contaminated sediment, and as such, we cannot agree with the conclusions of the CA with respect to those aspects of the assessment at present. 2.8.4. In relation to water quality, we do not agree with the conclusions with respect to phytoplankton and dissolved oxygen (DO) as the assessment focusses on nutrients rather than water clarity (please see comments 2.7.3 and 2.7.4 above). Water clarity is the main impact pathway arising from the proposed works which could affect the phytoplankton and DO status of the North Wales water body and therefore the assessment should focus on this. - Clwyd Transitional Water body 2.8.5. Based on the statement made at para 128 and in Table 9 of Volume 4 - Annex 3.1 (APP-094) that “there are no current intentions to install structures which may alter the hydromorphology of the Clwyd transitional waterbody”, NRW agrees with the conclusions of the WFD CA for the hydromorphology element within the Clwyd water body. 2.8.6. NRW agrees with the WFD CA conclusions for biology – habitats within the water body, that provided that no direct interaction with the biological habitats in the Clwyd transitional waterbody will occur due to the proposed trenchless techniques, the project will not cause deterioration to the biological elements within the water body, or jeopardise the attainment of Good Ecological Potential. 2.8.7. NRW agrees with the WFD CA conclusions for water quality within the water body, that due to the trenchless techniques proposed, the project will not cause deterioration to the water quality within the water body or jeopardise the attainment of Good Ecological Potential. 2.8.8. We note that there is a commitment in the Crossing Schedule (APP-121) for the use of trenchless technique (e.g. HDD) underneath the Clwyd. However, we seek confirmation regarding how the cable will be brought across the river if it is undergrounded; that the techniques employed will be deep enough to avoid the saltmarsh and minimise cable exposure, and that appropriate entry and exit sites (pits) are identified. We advise that this information should be included in the Outline Construction Method Statement (APP-313). We advise that if the proposal to employ trenchless techniques changes, then the WFD CA will need to be revisited and any impacts properly assessed. 2.8.9. NRW agrees with the proposal to produce a biosecurity risk assessment and for it to be secured as a condition of the marine licence. 2.9. Decommissioning - Offshore 2.9.1. We acknowledge the commitment to produce a Decommissioning Plan under section 105 of the Energy Act 2004 and as identified under Requirement 20 of the draft DCO (AS-014) and in the Marine Licence Principles (AS-023). 2.9.2. We note, from the ES, the intention to completely remove all infrastructure at the end of the operational lifetime of the project, unless, closer to the time of decommissioning it is decided that removal would lead to a greater environmental impact than leaving some components in situ. 2.9.3. NRW considers that offshore renewable projects should produce decommissioning plans that retain all decommissioning options (maintain, full removal and partial removal); the options for which can be assessed and refined closer to the time of decommissioning itself in consultation with NRW. NRW reserves its position until a draft plan is submitted at which point we will provide further advice. 2.9.4. NRW advises that the Applicant will need to submit a marine licence application at the point of decommissioning to remove infrastructure. 2.9.5. We advise that the Applicant follows the industry decommissioning guidance produced by BEIS. - Draft Development Consent Order: Requirements 2.9.6. There are notable differences between the proposed timings of submission for the offshore and onshore decommissioning plans, as drafted in the DCO (Requirements 20 and 21 respectively) (AS-014)) and associated parts of the ES. For example, we note that an onshore plan is to be submitted at least 6 months prior to any decommissioning works commencing, and an offshore plan is to be submitted 4 months prior to commencement of construction. We recommend that the reasons for such discrepancies are clarified. In addition, it would be prudent to understand how decommissioning plans for both the offshore and onshore aspects of this project will be dealt with. Clarity is required on what the appropriate regulatory mechanism would be to secure decommissioning plans, unless it is considered that the DCO needs to address both aspects because the consent is ultimately for the project which includes both offshore and onshore elements. 2.10. Schedule of Mitigation and the Marine Licence Principles 2.10.1. There are a number of inconsistencies between the Schedule of Mitigation (APP-310) and the Marine Licence Principles document (AS-023) that require clarification. For example, the Schedule of Mitigation refers to a Cable Specification and Installation Plan to be secured as part of the marine licence, but which is not recognised in the Marine Licence Principles document as a specific document (albeit cable management plans are noted). This potentially results in confusion as to the exact measures that are to be secured as part of the project mitigation. 3. ONSHORE 3.1. Designated Landscapes – KEY CONCERN 3.1.1. The ES chapter Seascape, Landscape and Visual Impact Assessment (AS-027) acknowledges that the proposal will have significant effects on a number of viewpoints. Based on the ES and supporting ES Appendices, NRW advises that the offshore works are likely to have numerous and extensive significant adverse effects on seascape, landscape and visual receptors within the Isle of Anglesey Area of Outstanding Natural Beauty (AONB) and Snowdonia National Park (NP) and within their settings. Special Qualities set out in the respective management plans for the areas which support the designations, would be adversely affected. These concerns relate to all Maximum Design Scenarios (MDS) i.e. those relating to MDS of the smaller number of Wind Turbine Generators (WTGs) and the MDS relating to the larger number of WTGs as detailed in the offshore project descriptions (APP-047) 3.1.2. NRW are concerned that the proposal will result in unacceptable adverse effects on the Isle of Anglesey AONB and Snowdonia NP designated landscapes through conflict with the purpose of conservation and enhancement of natural beauty, which is enshrined in the purposes of these designated landscapes. 3.1.3. In addition, NRW considers that there would be non-significant, but adverse effects on the Clwydian Range and Dee Valley AONB as well as other non-significant but adverse effects on the Isle of Anglesey AONB and Snowdonia NP. 3.1.4. NRW considers that there has been an under-estimation of some seascape, landscape and visual effects on designated landscape receptors within the Seascape Landscape and Visual Impact Assessment (SLVIA). 3.1.5. Whilst we acknowledge the embedded mitigation of the reduced western extent of the array, and that a reduction in the number of WTGs has been applied, we do not consider it sufficient to reduce the likely significant effects at the numerous viewpoints within Isle of Anglesey AONB and Snowdonia NP. The visual impacts will lead to significant adverse effects on landscape character within these Nationally Designated Landscapes and within their seascape settings. 3.1.6. In terms of mitigation, a further substantial reduction in array area and/or scale or number of turbines would be required to minimise adverse effects on the Isle of Anglesey AONB and Snowdonia NP. Further consideration of NRW’s evidence base “Seascape & visual sensitivity to offshore wind farms in Wales: Strategic assessment and guidance” would assist in informing an appropriate reduction. 3.1.7. NRW advises that opportunities for enhancement of the designated landscapes should be considered in accordance with Welsh National Marine Plan Policy SOC_06: Designated Landscapes. NRW considers enhancements represent compensation and/or offsetting and not mitigation for adverse effects, as any enhancements would not be directly related to the impacts. 3.1.8. Whilst NRW considers that the landscape and visual effects of the onshore substation on the Clwydian Range and Dee Valley AONB are unlikely to be significant, adverse effects should nevertheless be minimised and the materials and colours of the proposed buildings and infrastructure should be designed to minimise visual impacts. We note the intention to secure such detail under DCO Requirement 6, but advise that this also needs to be considered from a landscape and visual perspective. 3.1.9. The proposals are likely to have adverse night-time visual effects on the Isle of Anglesey AONB and Snowdonia NP. Dark skies are a noted feature of the Peace & Tranquillity Special Quality within the Anglesey AONB. 3.1.10. NRW are concerned that adverse incremental, combined cumulative seascape, landscape and visual effects may arise on the Isle of Anglesey AONB and Snowdonia NP because of plan and projects both offshore and onshore. 3.2. Flood Risk - Flood Risk Activity Permit – KEY CONCERN 3.2.1. NRW does not consent to the Applicant’s request for the DCO to include a provision to remove the requirement for a prescribed consent to be granted (namely Flood Risk Activity Permits (FRAP) (as detailed in the Consents and Licences Required Under Other Legislation document (APP-037)) under s150 Planning Act 2008. NRW considers that a FRAP application should be made for each main river crossing (and associated flood defences) in accordance with the Environmental Permitting Regulations 2016 (EPR 2016). 3.2.2. The Outline Construction Method Statement (APP-313) advises (paragraph 69) that “….the depth of each cable at every watercourse or flood defence crossing will be determined through the Crossing Schedule in consultation and agreement with the relevant authority on a case-by case basis in collaboration with the respective…”. It also advises in the same document (paragraph 70) that “….Options for open cut or trenchless crossing of watercourses will be finalised following ground investigation…”. For a number of crossings, it has not been confirmed which crossings will be open cut and whilst accepting that they are likely to be on the smaller watercourses it should be ensured that open cut crossings of main rivers be subject to a bespoke application. 3.2.3. A bespoke FRAP application would usually be required for each new crossing beneath a main river which includes both the permanent works and the temporary works. A permanent application would include details such as depth of cover beneath the bed of the main river and level of pipe/cable within an 8m/16m distance from the banks of the main river/toe of any associated flood defence structures. A temporary works application would consider the cable’s installation method be it open cut or trenchless crossing. 3.2.4. It should be noted that service crossings below the bed of a main river (by trenchless techniques) can be registered as an exempt flood risk activity under the Regulations provided that certain key conditions can be met as per part 4 of Schedule 3 of the EPR 2016. - Flood Consequence Assessments 3.2.5. The Export Cable Corridor is located within zone C1 of the Development Advice Map (DAM) contained in Technical Advice Note (TAN)15, along with minor works in C2. The Flood Consequence Assessment refers to the Flood Risk Assessment Wales maps. The Flood Risk Assessment Wales maps should not be used for planning purposes; NRW advises the Flood Map for Planning (FMfP) represents more up-to-date information for assessing flood risk. However, in view of the works proposed, and as a final Construction Method Statement will be approved by the Local Planning Authority (LPA) (Requirement 10), NRW considers that flood risk can be appropriately/adequately mitigated. However, whilst consultation with NRW is specifically stated for the discharge of some Requirements (e.g. Requirement 7, 13 and 14), we note that this is not included for Requirement 10. For the avoidance of doubt, we recommend that the Draft DCO (AS-014) is updated to ensure that NRW should be consulted by the LPA prior to the discharge of Requirement 10. 3.2.6. NRW also notes that there are works in C2 which are not assessed in the Flood Consequence Assessment (APP-137). The works include an operational access track and a temporary mitigation area. It should be ensured that any tracks or temporary mitigation areas within zones C1/C2 or within 8m of a designated main river does not interfere with access to maintain the watercourse or impact on flood risk. Such proposals would be subject to a bespoke FRAP from NRW. 3.2.7. With regard to the Onshore Sub-Station, the supporting Flood Consequence Assessment has not referred to the FMfP. However, NRW is satisfied that the FMfP/DAM shows that the site is not at risk of flooding from the sea or fluvially. Some parts of the site is at risk from flooding surface water and small watercourses according to the FMfP. The Lead Local Flood Authority (Denbighshire County Council) is the appropriate body to advise with regard to the acceptability of surface water flood risk. 3.3. Protected Species (Terrestrial) 3.3.1. NRW considers the survey and assessment to be satisfactory in respect of great crested newts (GCNs), bats, otters, dormice, water voles and barn owls. Water voles and barn owls are protected under the Wildlife and Countryside Act 1981 (as amended). GCNs, bats, otters and dormice are also European Protected Species which are protected under the Conservation of Habitats and Species Regulations 2017 (as amended). 3.3.2. NRW agrees with the conclusions in the ES and the recommendations and proposed principles for mitigation in the Outline Landscape and Ecology Management Plan (LEMP) (APP-305). We also note that the final LEMP will be approved by the LPA following consultation with NRW. NRW agrees with this approach. However, NRW considers that amendments to the Outline LEMP should be made to ensure that the final LEMP is based on a more robust Outline LEMP (e.g. the need for an external Ecological Compliance Audit, revised details regarding long-term monitoring and management). 3.4. Fish (Freshwater) 3.4.1. We note that mitigation for fish (eels) is included in the Outline LEMP and that the final version will be approved by the LPA, in consultation with NRW. We agree with this approach. 3.4.2. NRW also notes the ES chapter Onshore Biodiversity and Nature Conservation (APP-066) discusses the declining trend of salmonids within the river Clwyd. Whilst the statement is true, the conclusions of “Not Significant” should not be based on the fact that populations are declining and numbers are low. However, NRW can agree with the conclusion based on the developer undertaking HDD under the river Clwyd which mitigate disturbance to fish. 3.5. Invasive Non-Native Species (INNS) (Terrestrial) 3.5.1. NRW notes that the final (terrestrial) INNS Management Plan will be approved by the LPA (Requirement 10). NRW agrees with this approach and consider that INNS will be appropriately managed. However, as highlighted above (comment 3.2.5) we advise that NRW is consulted prior to the discharge of Requirement 10. NRW also considers that minor amendments to the Outline INNS Management Plan (APP-323) should be made in order to ensure that the final version of the plan is based on a more robust Outline version (e.g. the need for the Plan to consider landscape planting, diseases that may affect protected species, and preventive techniques). In addition, although the Outline version refers to species listed under the provisions of the Wildlife and Countryside Act 1981 (as amended), NRW advises that it should also refer to the provisions under the Invasive Alien Species (Enforcement and Permitting) Order 2019. 3.6. Water Quality (Freshwater) 3.6.1. NRW notes that the final Code of Construction Practice and the underpinning Method Statements and Management Plans must be submitted to and approved by the LPA (Requirement 10). NRW agrees with this approach and consider that impacts on water quality (both surface and groundwater) will be appropriately managed. However, as highlighted above (comment 3.2.5) we advise that NRW is consulted prior to the discharge of Requirement 10. 3.6.2. NRW also considers that minor amendments to the Outline Pollution Prevention and Emergency Incident Response Plan (APP-318) be made in order to ensure that the final version of the plan is based on a more robust Outline version (e.g. confirmation that no discharge of contaminated water occurs (including contamination with sediments) without the relevant exemption or Permit, not refuelling within 10m of a watercourse rather than the 5m stated). 3.7. Air Quality 3.7.1. NRW agrees with the conclusions in the ES (Chapter 11) (AS-030) that construction and operational onshore traffic is unlikely to have significant effects on any designated nature conservation site (SSSI, SAC, SPA and Ramsar site). 3.7.2. NRW notes that the works will be within the proximity of Ancient Woodland. Planning Policy Wales recognises the significant value of ancient woodlands and makes provision for their protection against damage or loss. Our standing advice to all planning proposals that may affect (directly or indirectly) ancient woodland can be found at Natural Resources Wales / Advice to planning authorities considering proposals affecting ancient woodland. The LPA will be able to advise with respect to the acceptability of the proposals in terms of Ancient Woodland. 3.7.3. However, we note that there is no assessment of any air quality impacts arising from marine vessel emissions. It is unclear whether marine vessels will operate within proximity to sensitive coastal onshore habitat (that may support features of SSSIs/SACs/Ramsar). We advise the Applicant provides additional information to demonstrate that there will not be significant impacts from marine vessel emissions. 3.8. Water Framework Directive (WFD) (Freshwater) 3.8.1. The conclusions of the WFD Compliance Assessment will be reliant on securing appropriate mitigation, including the final Code of Construction Practice and the underpinning Method Statements and Management Plans which must be submitted to and approved by the LPA. We agree with this approach. 3.8.2. We note that there are matters that will be confirmed following detailed design (e.g. as to specifically which watercourses that trenchless or trenching techniques will be employed, and exact haul road crossings). As highlighted above (comment 3.2.5), NRW should be consulted on the final Method Statements and Management Plans prior to discharge of Requirement 10. 3.8.3. We also have minor comments regarding the methodology/scoping undertaken. As an example, we consider that INNS should have been scoped into the impact assessment stage as there is a risk of introduction of INNS. However, as stated above (comment 3.5.1), we are satisfied that INNS will be appropriately managed as the final (terrestrial) INNS Management Plan will be approved by the LPA. 3.8.4. We also note that the WFD CA is based on the 2015 Western Wales River Basin Management Plan however the Applicant has been able to incorporate 2021 classification data published earlier this year into the assessment. The Examining Authority should be aware that the updated Western Wales River Basin Management Plan 2021-2027 will be published on 18th July 2022 and will be available on the NRW website here. 3.9. Materials and Waste 3.9.1. We note that the final Site Waste Management Plan will be approved by the LPA. We agree with this approach and consider that waste will be appropriately managed. As highlighted above (comment 3.2.5), NRW should be consulted on the final Site Waste Management Plan prior to discharge of Requirement 10. 4. NRW’S GENERAL PUPROSE 4.1. NRW is satisfied that this advice is consistent with its general purpose of pursuing the sustainable management of natural resources in relation to Wales, and applying the principles of sustainable management of natural resources. In particular, NRW acknowledges that the principles of sustainable management include taking account of all relevant evidence and gathering evidence in respect of uncertainties, and taking account of the short, medium and long term consequences of actions. NRW further acknowledges that it is an objective of sustainable management to maintain and enhance the resilience of ecosystems and the benefits they provide and, in so doing meet the needs of present generations of people without compromising the ability of future generations to meet their needs, and contribute to the achievement of the well-being goals in section 4 of the Well-being of Future Generations (Wales) Act 2015. --- CONTINUED --- ? ANNEX A – NRW Regulation and Permitting Services 1. Marine Licensing: Regulatory Response 1.1 The works proposed under the DCO that are within Welsh Waters require a marine licence under the Marine and Coastal Access Act 2009, for which NRW is the licensing authority. An application for a marine licence was submitted by the developer on 30 May 2022 to NRW Permitting Service (NRW PS). The application was validated on 20 June 2022. We commenced consultation with relevant consultation bodies who have until the 3 August to provide any comment. The public will also be consulted on the application in due course. Should PINS require copies of the consultation responses these can be made available on request. It is anticipated that the marine licence application will be determined concurrently with the DCO examination, although it is currently not possible to provide an indicative timescale in respect of the determination. Although there are issues that substantively overlap between the determination of the DCO and Marine Licence, it should be noted that the respective consents are determined under separate and distinct legislative processes. 1.2 It is stated in the Explanatory Memorandum, that the draft DCO submitted in support of the application ‘does not contain powers or controls which sit within the marine licencing regime’. NRW PS endorses this approach and considers that the DCO should not seek to duplicate controls within the DCO which can be placed within the Marine Licence, to avoid regulatory overlap. 1.3 NRW PS, acting in its marine licensing function, has determined that an environmental impact assessment is not required in relation to the marine licence in reliance on Regulation 10 of the Marine Works (Environmental Impact Assessment) Regulations 2007 (as amended). This is on the basis that NRW PS is satisfied that an EIA assessment in respect of the project is to be carried out by the Secretary of State and that such assessment will be sufficient to meet the requirements of the EIA Directive. 1.4 The above comments are made without prejudice to any further comments that NRW PS, acting in its marine licensing function, may wish to make during the DCO examination."

DLA Piper on behalf of Rhyl Flats Wind Farm limited
"RELEVANT REPRESENTATION ON BEHALF OF RHYL FLATS WIND FARM LIMITED 1. Rhyl Flats Wind Farm Limited (“RFWFL”) operate the Rhyl Flats wind farm (“RF”) to the south of the proposed Awel Y Mor wind farm (“AYM”). The location of RF can be seen on sheet 2 of the Works Plans. 2. RFWFL raise the following objections to the DCO based on the impact of AYM on the operation of RF:- 2.1 The Works Plans show that Work No.2 intrudes into the area of the sea bed which is leased by the Crown Estate Commissioners to RFWFL for the operation of RF. RFWFL had understood that the rights sought by the promoter for cable installation would avoid the area leased to RFWFL. This is Crown Land over which RFWFL have an exclusive lease. Without prejudice to the other points in this submission, the area within the RF Crown Estate lease should be excluded from the proposed development. 2.2 The work plans show that Work No.2 also intrudes into the 250m restriction zone around the perimeter of the areas leased by the Crown Estate Commissioners to RFWFL for the operation of RF. The restriction zone exists to ensure that other proposed developments do not adversely affect the operation of RF. The Crown Estate Commissioners have covenanted with RF not to grant any lease, licence or consent (other than where the lease requires that RF’s consent is obtained) for the construction of any works within the restriction zone. RF has not been approached to provide such consent, representing an impediment to delivery of the scheme. 2.3 Work No. 2 would permit construction activities in close proximity to the eastern-most RF turbine. Although AYM has indicated that best practice will be used during cable laying, this is not secured by the DCO. There are protective provisions in Part 1 of Schedule 9 for electricity undertakers but these do not apply to the offshore works. It is essential that the DCO provides protective provisions for the benefit of RFWFL. These require to include a mechanism for RFWFL approving the installation activities and the timing of the installation so as to avoid conflict with any maintenance activities which may be required on the RF turbines. An indemnity is also required for any impacts which are caused by the installation process. 2.4 The AYM turbines would lie to the north of the existing RF turbines. There is the potential for the AYM turbines to interfere with wind speed or wind direction and thus cause a reduction in energy output from the RF turbines. This requires to be assessed and mitigation proposed for any impact. 3. RFWFL would intend to engage with the Promoter with a view to reaching agreement on necessary changes to the DCO, including protective provisions and mitigation measures. However, pending resolution of such matters, development consent should not be granted."

RSPB
"Awel y Môr Offshore Wind Farm Development Consent Order Application Planning Inspectorate Reference: EN010112 Text of Relevant Representation from the Royal Society for the Protection of Birds (RSPB) 6 July 2022 INTRODUCTION The RSPB supports the deployment of renewable energy projects, providing that they are sited in appropriate places and designed to avoid potential adverse impacts on wildlife. We are grateful for the constructive pre-application discussions that have taken place with Awel y Môr Offshore Wind Farm Limited in respect of this proposal, particularly through the Evidence Plan process. While methodological concerns remain, progress towards resolving a number of issues was made during the pre-application discussions for this project. We continue to have significant concerns relating to the project’s in-combination and cumulative collision risk and displacement impacts including their assessment. OFFSHORE ORNITHOLOGY IMPACTS - SUMMARY OF RSPB POSITION We have significant concerns regarding the findings of some of the impact assessments. As a result of the methodological concerns, set out below, the RSPB considers that the impacts have not been adequately assessed and, as such consider that an adverse effect on the integrity (AEOI) on the following qualifying feature of the Liverpool Bay Special Protection Area (SPA) cannot be ruled out: Project alone – RSPB AEOI conclusions Impact on the following feature of the Liverpool Bay SPA: - The impact of displacement on the red throated diver population Project in combination with other plans and projects – RSPB AEOI conclusions In-combination impacts on the following feature of the Liverpool Bay SPA: - The impact of displacement on the red throated diver population We also have methodological concerns and consider that it is not currently possible to rule out adverse impacts upon other SPA species occurring within the study area, in particular: - Manx shearwater - Gannet RED THROATED DIVER DISPLACEMENT The conservation objectives for the Liverpool Bay SPA are: Ensure that the integrity of the site is maintained or restored as appropriate, and ensure that the site contributes to achieving the aims of the Wild Birds Directive, by maintaining or restoring: - The extent and distribution of the habitats of the qualifying features - The structure and function of the habitats of the qualifying features - The supporting processes on which the habitats of the qualifying features rely - The population of each of the qualifying features, and, - The distribution of the qualifying features within the site. There is clear evidence of the displacement of red-throated diver from offshore wind farms (e.g. Furness et al. 2013, Mendel et al., 2019) with a significant effect detectable 10-15km from the wind farm (Heinänen et al. 2020). The Awel y Mor proposed development directly abuts the Liverpool Bay SPA. The numbers of red throated diver, their distribution within the SPA and their ability to use all suitable habitat contained in the SPA are relevant to the SPA conservation objectives but are not considered by the Applicant. If red throated diver are displaced from part of the SPA which would otherwise be suitable for them the effect is to reduce the functional size of the SPA, contravening the conservation objectives. The RSPB therefore cannot rule the impact of displacement on the integrity of the Liverpool Bay SPA, arising through the project alone and in combination. Other SPA species of concern present on site Manx shearwater are BoCC5 Amber listed (Stanbury et al., 2021) and are a Birds Directive Migratory Species. Awel y Mor is within the mean-max foraging range (1,347 km, Woodward et al., 2019) of seven SPAs of which they are a qualifying feature (Copeland Islands, Irish Sea Front, Rum, St Kilda, Outer Firth of Forth and St Andrews Bay Complex, Glannau Aberdaron ac Ynys Enlli/ Aberdaron Coast and Bardsey Island, and Skomer, Skokholm and the Seas off Pembrokeshire/ Sgomer, Sgogwm a Moroedd Penfro). Gannet is Amber listed in BoCC5 (Stanbury et al., 2021). Gannet is a qualifying feature of Grassholm SPA and also known to breed in Ireland’s Eye SPA and Lambay Island SPA, all of which are within mean-max foraging range of Awel y Mor (Woodward et al., 2019). IMPACT ASSESSMENT – METHODOLOGICAL CONCERNS The RSPB’s key concerns are with the baseline survey methodology, the scoping out of collision impacts for Manx shearwater, the use of avoidance rates in gannet collision risk modelling, lack of consideration of impacts compounded by HPAI Baseline surveys The RSPB are content that digital aerial surveys can provide useful data in order to provide baseline characterisation of an offshore wind farm footprint. However full methodological detail needs to be provided alongside the outputs and the details the Applicant has provided are scant. In particular, but not exclusively there is - insufficient consideration of potential biases in the survey and analysis methods - there is no consideration of potential response of birds to disturbance arising from the survey e.g. from aircraft shadow - there is no detail provided as to how autocorrelation has been evaluated and if necessary accounted for, - there is no rationale provided as to why a grid rather than transect survey design has been used - there is no detail given of any independent validation of identification and detection rates Manx shearwater: The Applicant has scoped out Manx Shearwater as being a receptor at risk of collision impacts. We disagree with this approach and consider there to be risk of collision. Fundamental to the consideration of collision risk for this species is the extent to which nocturnally active seabirds, such as Manx shearwaters, may be attracted to the illuminations required for turbines, support vessels and the construction or expansion of ports. Such attraction will cause behaviour change, which could in turn increase collision risk, for example if birds fly higher when attracted to lights. There is also abundant evidence of light-induced disorientation of Manx shearwaters. This evidence includes the grounding of fledglings in lit areas (Miles et al., 2010) and collision with lighthouses and other illuminated structures (Guilford et al., 2019, Archer et al., 2015). If light-induced disorientation leads to individual birds circling the navigation lights on the nacelle or tower of turbines for protracted periods (as has been reported for birds disorientated by lighthouses or gas flares) the probability of collision with turbine blades or other surfaces is vastly increased. Manx shearwater can be active throughout the day and night and with different levels of activity at different times. For example for birds tracked from Skomer, diving occurred during the day and peaked in the evening (Shoji et al., 2016), while nocturnal foraging was observed from tracking of birds from High Island, Ireland (Kane et al., 2020). These diel variations in activity mean that the somewhat limited amount of time aerial surveys were carried out, restricted to the hours of full light are unlikely to properly characterise the activity of Manx shearwater at the Application site. these have generally taken place between mid-morning and mid-afternoon. For these reasons the RSPB does not have confidence in the baseline densities of Manx shearwater presented, and therefore it is impossible to make any conclusions as to the significance of impacts. Gannet: Avoidance Rates For collision risk modelling, the Applicant has presented Avoidance Rates as recommended by the SNCBs (JNCC et al, 2014) Whilst the RSPB agrees with almost all of the SNCB’s recommended rates, we differ with regard to gannet. We are content that 98.9% is suitable for non?breeding birds, but do not agree that this figure should be applied to the breeding season due to the lack of available evidence relating to breeding birds. Furthermore, GPS tracking of gannets breeding on the Bass Rock between has shown variation in the two?dimensional foraging behaviour of birds across the breeding season (prior to chick?rearing, and during chick?rearing), between sexes, and between years (Cleasby et al. 2015a, Lane et al. 2020, Lane and Hamer 2021). Three?dimensional tracking of gannets during chick?rearing has revealed that flight height and flight speed both vary according to behaviour, sex and wind conditions (Cleasby et al. 2015b, Lane et al. 2019, Lane et al. 2020,) and similar patterns have been recorded in other seabirds (Masden et al. 2021). As the misspecification of these parameters contributes to the model error component of avoidance rate (Johnston et al., 2021) such variability should result in differential avoidance rates. As such we recommend the use of the default seabird avoidance rate of 98% for gannet during the breeding season. The Applicant has also, in Appendix 4 of Volume 4, Annex 4.3: Offshore Ornithology Collision Risk Modelling reduced the density of birds inputted into collision risk modelling by 70% to take into account macro avoidance. This approach follows suggestions in Cook (2021), the recommendations from which have not yet been adopted by the SNCBs. Cook (2021) is currently being reviewed and revised by two projects, one funded by JNCC and one by Natural England. Until these projects have reported, the RSPB do not accept this approach. Population Viability Analysis The Applicant did not carry out Population Viability Analysis for gannet. The RSPB would prefer that this was now carried out, to take into account the likely mortality arising from the outbreak of Highly Pathogenic Avian Influenza o the local and regional populations Finally, the RSPB reserves the right to add to and/or amend its position in light of changes to or any new information submitted by the Applicant. REFERENCES ARCHER, M., JONES, P. H. & STANSFIELD, S. D. 2015. Departure of Manx Shearwater Puffinus puffinus fledglings from Bardsey, Gwynedd, Wales, 1998 to 2013. Seabird, 28, 43-47 Cleasby, I.R., Wakefield, E.D., Bodey, T.W., Davies, R.D., Patrick, S.C., Newton, J., Votier, S.C., Bearhop, S., Hamer, K.C. 2015a. Sexual segregation in a wide-ranging marine predator is a consequence of habitat selection. Marine Ecology Progress Series, 518, 1-12 Cleasby, I.R., Wakefield, E.D., Bearhop, S., Bodey, T.W., Votier, S.C., Hamer, K.C., 2015b. Three-dimensional tracking of a wide-ranging marine predator: flight heights and vulnerability to offshore wind farms. Journal of Applied Ecology, 52, 1474–1482. Cook A.S.C.P. (2021) Additional analysis to inform SNCB recommendations regarding collision risk modelling. BTO research report 739 Furness, R. W., Wade, H. M., & Masden, E. A. (2013). Assessing vulnerability of marine bird populations to offshore wind farms. Journal of environmental management, 119, 56-66. Guilford, T., Padget, O., Bond, S. & Syposz, M. 2019. Light pollution causes object collisions during local nocturnal manoeuvring flight by adult Manx Shearwaters Puffinus puffinus. Seabird, 31, 48-55 Heinänen, S., Žydelis, R., Kleinschmidt, B., Dorsch, M., Burger, C., Mork?nas, J., Quillfeldt, P. and Nehls, G., 2020. Satellite telemetry and digital aerial surveys show strong displacement of red-throated divers (Gavia stellata) from offshore wind farms. Marine environmental research, 160, p.104989. Johnston, D.T., Thaxter, C.B., Boersch-Supan, P.H., Humphreys, E.M., Bouten, W., Clewley, G.D., Scragg, E.S., Masden, E.A., Barber, L.B., Conway, G.J., Clark, N.A., Burton, N.H.K., Cook, A.S.C.P. (2021) Investigating avoidance and attraction responses in lesser black-backed gulls Larus fuscus to offshore wind farms. Marine Ecology Progress Series, prepress online Joint Nature Conservation Committee (JNCC), Natural England (NE), Natural Resource Wales (NRW), Northern Ireland Environment Agency (NIEA), Scottish Natural Heritage (SNH) 2014, Joint Response from the Statutory Nature Conservation Bodies to the Marine Scotland Science Avoidance Rate Review Lane, J.V., Spracklen, D.V., Hamer, K.C., 2019. Effects of windscape on three-dimensional foraging behaviour in a wide-ranging marine predator, the northern gannet. Marine Ecology Progress Series, 628, 183–193. Lane, J.V., Jeavons, R., Deakin, Z., Sherley, R.B., Pollock, C.J., Wanless, R.J., Hamer, K. C., 2020. Vulnerability of northern gannets to offshore wind farms; seasonal and sex-specific collision risk and demographic consequences. Marine Environmental Research. 162 Lane, J.V. and Hamer, K.C. 2021. Annual adult survival and foraging of gannets at Bass Rock, Scotland: Report to the Ornithology subgroup of the Forth and Tay Regional Advisory Group (FTRAG-O) – October 2021 Masden, E. A., Cook, A. S., McCluskie, A., Bouten, W., Burton, N. H., & Thaxter, C. B. (2021). When speed matters: The importance of flight speed in an avian collision risk model. Environmental Impact Assessment Review, 90, 106622. Mendel, B., Schwemmer, P., Peschko, V., Müller, S., Schwemmer, H., Mercker, M., & Garthe, S. (2019). Operational offshore wind farms and associated ship traffic cause profound changes in distribution patterns of Loons (Gavia spp.). Journal of environmental management, 231, 429-438 Miles, W., Money, S., LUXMOORE, R. & FURNESS, R. W. 2010. Effects of artificial lights and moonlight on petrels at St Kilda. Bird Study, 57, 244-251."

Snowdonia National Park
"We as Snowdonia National Park intend to make representations, both on an individual basis, and as part of a wider north Wales Local Planning Authorities group basis. As part of the wider north Wales LPA group (and other NW LPAs will also raise their own points), we intend to raise points such as; • The under-reporting of significant effects, in terms of sensitivity of the landscape and magnitude of change • Lack of mitigation in terms of turbine height, array extent (although this has been reduced) etc • The project cannot be described as an extension due to the vast difference between it and the current wind farms (Gwynt y Mor, Rhyl Flats) in the bay. Gwynt y Mor for example consists of 160 turbines with a 133m blade tip height – vastly different from the project proposed under Awel y Mor • Concerns regarding the impact of the proposal on the regional interests particularly associated with the landscape and visual impact of the proposal which may have an indirect negative impact on tourism for the region and associated socio-economic impacts. • The size and scale of the overall project As an individual local planning authority, we as Snowdonia National Park intend to raise further, area specific points. These will include; • Visual impacts from specific points within the National Park, such as from Carnedd Llywelyn and the Carneddau as a whole • Adverse effects on landscape character areas within the National Park • The general specifics of the project – i.e. the heights of turbines and cumulative effect due to the presence of offshore wind farms already • In terms of cumulative effects, from a National Park point of view there are concerns about the cumulative impact of turbines in the area and the increased disruption to the ‘cone of view’ from viewpoints within the Park. From certain areas it is likely that the sea horizon will be dominated by wind turbines adding to the growing cumulative effect and it could be asked at what point does the accumulation of turbines/cumulative effect become excessive. As a general principle the National Park is supportive of a renewable energy project, which is crucial in the current climate emergency, however as noted there are numerous concerns with the project in its current form."

Sustainable Cymru
"Denbighshire Residents Health - Large Asbestos Water pipe adjacent to the development. Should it be replaced at a cost to RWE safely before the start construction? Who will manage / monitor the disturbance and water testing of the Asbestos Water pipe during construction/ ground works (vibrations etc.) and any future interference via electric magnet. Denbighshire Residents Consultation was conducted during Covid (restricting information access to important community stakeholders, such as the Vulnerable and the Elderly). - Majority of Denbighshire Vulnerable/Elderly residents were not able to go to a group setting to view plans and ask questions - Many not able to use computers to access/view documents online Denbighshire Natural Environmental Impact • St Asaph nature Bridle path access to Resident will be blocked • Established hedgerows will be destroyed to make way for lines and construction access. • Rare Welsh “Ridge and furrow Fields” site will be destroyed • Proposed concrete site abuts a Public Nature Reserve that houses rare and protected Newts, Voles, Bats, Owls, and many other wildlife and fauna. • The other side abuts to Bodelwyddan Castle estate that consist of large ponds and established woods where birds and wildlife breed. • The proposed site is currently on food producing agricultural green land. • Noise pollution: Electric Humming of the transformers and magnetic nuisance impact on wildlife breeding. Future Economic impact to St Asaph Business Park • Regionally significant enterprise site in an area of outstanding natural beauty, offering work life balance and economic, environmental, social and cultural well-being – NOT AN INDUSTRIAL POWER STATION HUB! What will happen to current and future tenants? Expansion to the site will be restricted by a one substation to the East – two to the south and now a proposed super substation to the West. • Substation will take 2 years to build, after which access to the site will be severely restricted."

The Crown Estate
"The Crown Estate requests to be registered as an Interested Party in the examination of the Awel y Môr Offshore Windfarm. Our interest in the project is that Awel y Môr Offshore Wind Farm Ltd holds an Agreement for Lease from The Crown Estate."