“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.”