“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.”