“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.”