The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.
Awel y Môr Offshore Wind Farm
Received 06 July 2022
From 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.”