Glyn Rhonwy Pumped Storage

Representations received regarding Glyn Rhonwy Pumped Storage

The list below includes all those who registered to put their case on Glyn Rhonwy Pumped Storage and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Blue Peris Mountain Centre
"We are primarily concerned about the disruption to the area known as the lagoons and the water area surrounding this venue. Outdoor recreation users frequent this area on a large basis, as well as children and adults visiting local outdoor education centers. Also the possibility of entrapment/snagging in the rea in which the abstraction of water will take place by swimmers,canoeists etc. There is also concern with the possible pollution to the lake environment from the dumping of access water and the associated temperature differential from the normal value found in the lake ( algal blooms) and also any sedimentary material being transported from the quarry area. "
Members of the Public/Businesses
Daniel Jackson
"My greatest worry as a local resident is the visual impact of connection to grid. There is a stated recognition that the intention is to connect to the grid through underground cables. However, I note that the offer from SP Manweb is a proposed one and that it is un-finalised. The concern is that there is no definitive assurance and therefore my worry is that there is no-one to hold Manweb to account should they decide, once the development is underway or nearing completion, that the connection is to be made above ground with associated visual impact to the area. This is a particular concern due to the fact that SPH consider the matter to be outside their proposal and therefore not their concern."
Members of the Public/Businesses
Lledr Hall Outdoor Education Centre
"As the manager of a local education authority run outdoor education Centre in North West Wales I have a vested interest in what happens at Llyn Padarn in Llanberis. We regularly use Llyn Padarn to introduce young people to the sport of canoeing. We visit the lake sometimes 5 days of the week but often 3 days a week and stay there for the whole day. Over a calendar year we will take approximtely 900 young people to this venue. We use canoeing to teach a wide range of life skills to school pupils aged from 9 - 16 years of age. We drive to the car park, by the area known locally as the lagoons, in our minibus towing a canoe trailer. Llyn Padarn is a very special site that has unique advantages for this kind of work due to the extremely sheltered nature of the lagoons. Inevitably with this sort of activity children end up at times swimming in the lake so the qality of the water is extemely important to our organisation. There is no alternative site in the region that offers this type of environment which means that if it is lost or altered in any significant way we will be deprived of a unique teaching environment. The proposed development of the site by Snowdonia Pumped Hydro has the potential to cause all sorts of problems both short and long term to our use of this fantastic resource. I believe these repercussions should be clearly explained to the Planning Inspectorate during their deliberations."
Members of the Public/Businesses
Plas Gwynant OEC
"Main points of concern: Visual impact of connection to grid. There is a recognition that the intention is to connect through underground cables however it is noted that the offer from SP Manweb is a proposed one and that it is un-finalised. The concern is that there is no definitive assurance and overarching 'holding to account' of SP Manweb should they decide, once the development is underway or nearing completion, that the connection is to be made above ground with associated visual impact to the area. This is a particular concern due to the fact that SPH consider the matter to be outside their proposal and therefore not their concern. Disturbance to lagoons during construction phase. In particular impact on the resource in regard to term time use by outdoor providers. ES states that there will be a reduction in construction during key school holidays. However, the majority of outdoor providers, particularly the centres, operate during school term time periods with school groups."
Members of the Public/Businesses
Cyngor Gwynedd Council
"Trwy gofrestru diddordeb yn y cais hwn, dymuna Cyngor Gwynedd gael y cyfle i gyflwyno barn ar yr ystyriaethau perthnasol oddimewn y wybodaeth a gyflwynir yn y Datganiad Amgylcheddol gan gynnwys cymeryd rhan yn y trafodaethau a gynhelir ynglyn ag unrhyw amodau neu fesurau lliniaru perthnasol. Cynhelir trafodaeth ynglyn a'r cais gan gabinet y Cyngor yn ystod mis Ionawr 2016, ag er na ellir rhagdybio beth fydd canlyniad y cyfarfod yma, ystyrir y bydd y canlynol yn debygol o fod yn berthnasol: - cydymffurfiaeth gyda pholisiau cynllunio - cyfnod adeiladu - effaith gweledol/tirlun - hawliau tramwy - trafnidiaeth - cyswllt grid - ardrawiad cymdeithasol ag economaidd - treftadaeth diwylliannol/hanesyddol - swn a dirgryniad - bioamrywiaeth - hydroleg, hydroddaeareg, daeareg - risg llifogydd - llygredd - effaith ar ardaloedd wedi eu gwrachod Mae'n debygol y bydd y Cyngor yn cyflwyno barn gyffredinol am y bwriad gan ategu fod datblygiad ar gyfer bwriad i greu cynllun 49.9MW eisioes wedi ei ystyried a'i ganiatau o dan y Ddeddf Cynllunio Gwlad a Thref gan Gyngor Gwynedd. Fe all ystyriaethau ychwanegol i'r uchod gael eu ategu o ganlyniad i gyfarfod y Cabinet ag yn ystod y cyfnod archwilio. Mae Cyngor Gwynedd yn ystyried effaith y datblygiad arfaethedig ar sail y wybodaeth a gyflwynwyd ag fe gyhoeddir ganlyniadau'r ystyriaethau hyn yn yr Adroddiad Effaith Lleol (LIR) ag mewn unrhyw sylwadau a gyflwynir yn ystod y cyfnod archwilio."
Members of the Public/Businesses
Ceris Meredith
"We are just 60 metres from the lower zone of this project and as residents as well as guest house owners our concerns include: Noise and pollution levels of construction traffic passing our property at all hours of the day. They will be working from 7am to 7pm Monday to Friday and 7am to 12 noon on Saturdays which will have adverse affects on our business. Noise, pollution (including dust) and vibration levels of the construction process which will involve drilling and blasting. Presence of a large volume of water held behind a 15 metre high dam just 60 metres from our boundary and above our property. The effects of blasting and drilling on the land surrounding the site and on our and our neighbours properties - vibration damage, land slides etc Presence of large volumes of water in an earthquake zone - there was an earthquake here just this year, albeit a small one! Water seepage and a change in the water table. Flooding caused by run off from the Tarmac areas of the site as we have already suffered from this. Taking water from Llyn Padarn and more particularly, discharging water to the lake from the quarries as they have been used as ammunition dumps in the past and contain pollutants that will be of great harm to the flora and fauna of the lake as well as to those who use the lake for swimming, kayaking etc. "
Members of the Public/Businesses
Patrick Gunning
"The following is a summary outline of the main issues that I intend to address in relation to the application: - • Technical (Head & Energy Storage Potential) • Capital Cost • Environmental Sensitivity (Designations etc) • Proximity to the Grid • Site Access and Land Ownership "
Members of the Public/Businesses
Neale Lewis-Jones
"My major concerns are regarding the potential for the contamination of Llyn Padarn through the disturbance of the waters contained in the quarries, previously utilised for the storage of chemical and conventional weapons and referred to in the survey document entitled 'Glyn Rhonwy Pumped Storage Development Consent Order Appendix 8.5 Zetica (2015) UXO Desk Study Report'. There is massive potential for contamination of the water through natural seepage. The report highlights the following and quotes recently released documents from the Ministry of Defence documentation. I quote from same:....... 1) 'it was temporarily used as a storage facility for 14,000 tons of bombs filled with Tabun, a toxic nerve gas which had been seized from German ammunitions dumps..' 2) 'Records indicate that this disposal was not always successful..." 3) 'Disposal activities at RAF Llanberis are considered to provide a source of UXO hazard within the quarry pits on the site' 4) The details of pit locations are marked incorrectly on the photographs giving extreme concern should we agree with the location of ammunition on site at the present time 5) 'It should be noted that the RAF was unwilling to certify the quarries completely free of explosives despite rendering safe each disposal area. 6) In 2015 'During recent Site walkovers, the Client has encountered potential items of UXO........ These discoveries indicate that, despite the extensive EOD operation, not all items of ordnance within the quarry pits were accounted for’. Biggest concern....'the decomposition products of these materials, especially Mercury and Lead can be highly toxic’. These are just a few of many major concerns that if not addressed, surveyed, risk assessed and indeed monitored may have a catastrophic affect on the lives and health of residents, workers and indeed the wildlife and water contained in LLyn Padarn. How can the developers possibly ensure that the site and its contents will not : 1) Explode 2) Permit contaminated water potentially containing Mercury (fatal if swallowed bearing in mind the amount of swimmers using the lake) and Lead, from naturally making its way through underground faults once it is disturbed. I cannot find any reference in the documentation as to how the developers plan to deal with UXO should it be encountered. Have the developers budgeted for the cost of the disposal of any UXO, surely the cost would be prohibitive? With the potential for such eventualities, surely the process should be considered at the highest level, given the extraordinary site circumstances involving the storage of chemical and conventional weapons. Surely, the document I have referred to gives rise to many, many questions that need thorough investigation to ensure public safety and environmental sustainability. Submitted for consideration: "
Members of the Public/Businesses
Arfon Swimming Club
"I’d like to register as an interested party in regard to the Glyn Rhonwy Development as the Chair of Arfon Swimming Club. The Club has around 60 members and, as Chair, I am expressing our concerns particularly to the impact of the development of the Lagoons area of Llyn Padarn and the potential harm to water quality following the planned discharge into Llyn Padarn. During the months of April to October, many Members use the Lagoons area and Llyn Padarn at least twice per week for open water swimming and social activities (BBQs etc). We are concerned with the location of pumping station for water abstraction particularly 1. disruption to access during construction 2. damage to trees along the shoreline 3. impact on the amenity (which is heavily used by many locals) in terms of noise and light pollution. ? We would also like to make representation about the permanent loss of the Llyn Padarn amenity due to water pollution following the planned discharge from the development. Glyn Rhonwy quarries were used to store 14,000 tons of bombs filled with tabun (a toxic nerve gas). Surplus and faulty ordnance was also disposed of in the quarries. The site survey document by Zetica (“SITESAFE UXO DESK STUDY” - extracts quoted below) highlights a number of extremely worrying points including (and not restricted to): 1. “Records indicate that this disposal was not always successful. Firstly ordnance would often get lodged on rock shelves, in slate piles or within crevices when tipped into the quarry, never making it into the burning pit”. 2. “Given the volume of ordnance that required clearance, and the working practices of the period, it is possible that some explosive items were inadvertently disposed of in Pit2B and residues may have remained within some of the casings” In relation to encountering live ordnance during clearing processes… 3. ”This means that there are still live ordnance items within the remained of the [slate] pile, constituting a significant source of UXO hazard.” In relation to the 1972 clearing process: 4. “During clearance of the slag heap it was discovered that the previous disposal process had been inefficient and was incomplete, with live and semi-destroyed material still in place. Unburnt magnesium powder was interspersed with live detonators and other explosives.” 5. “It should be noted that the RAF was unwilling to certify the quarries completely free of explosives, despite rendering safe each disposal area.” 6. “During recent Site walkovers [in 2015] , the Client has encountered potential items of UXO on the access path to Pit 2A…..These discoveries indicate that, despite the extensive EOD operation undertaken, not all items of ordnance within the quarry pits were accounted for.” These points (and many others in the document) indicate, at the very least, a considerable risk of contamination of any water discharged from the development into Llyn Padarn. "
Members of the Public/Businesses
Lynne Pugh
"I have concerns about the possible damage to the lake and shore during the construction period and after. This is a beautiful lake and surrounding area which is used by many walkers, boat users and swimmers. It is a great asset to the local town and if there was any toxic discharge into the lake could destroy a beautiful lake and loose all the revenue from tourists and locals who come to the are. I have concerns also about the possible destruction to the fish that are in the lake. "
Members of the Public/Businesses
Ramblers.
"Wherever there is an affected Public Right of Way this ROW must be protected in accordance with all legal requirements. Should there be a temporary closure of a PROW during construction application must be made for a Temporary Prohibition of Use Order. A notice of any temporary closure or diversion must be clearly displayed. Our Public Rights of Way must be protected at all costs, and this is particularly of the utmost importance in the National Park. Safety in all aspects must be considered before any construction in the area of the PROW must receive the utmost consideration for the protection of the many visitors to the area using these footpaths."
Members of the Public/Businesses
Tom Hutton
"I am a local resident and run a business based on tourism in the area (mountain biking and walking guiding). I am worried about this development on a number of levels, the biggest being the impact it will have on the natural environment in the area. The hill of Cefn Du is much-loved by locals. It is riddles with tracks and trails that provides accessible breathing space for all kinds of people, unlike much of the national park, where the mountainous nature of the ground makes many areas inaccessible. The hill will be effectively out of bounds during the construction period and then less accessible afterwards. The works will be a blot on the landscape, and will adversely affect access and enjoyment of people who climb nearby Moel Eilio – widely thought of as one of the best view points in Wales. The traffic that will need to access the development will make life a misery for Waunfawr residents, in a village which has incredibly narrow roads. And the increased noise will affect all residents during construction and potentially afterwards too. There are also rare, protected bird species nesting in the area including peregrine falcons and choughs, and I have always thought that there was a duty to protect the known breeding sites of these birds? Lower down, in Llanberis, there is potential that a local beauty spot will be spoiled forever, with a huge risk of pollution from ammunition stored in the area. This would have a catastrophic effect on the local people and the economy. Llyn Padarn is used by people of all ages, both locals and visitors, for swimming, boating of various types and just for socialising in the summer. This is like a beach for Llanberis and vital to the economy. This could be out of bounds during construction, potentially adversely affecting tourism. And could potentially be lost for good if there is a pollution problem caused by the munition store. And last but not least, I am suspicious of the ability of the developer to carry out the work in line with its own policies or the planning permission it receives. It seems slightly disingenuous to apply to our local council for permission for a small scheme, one so small in fact that most locals felt it would never be financially viable so didn't worry too much about, and then once approved, to suggest the capacity can be doubled to a size where it would be viable and one that locals would have spoken out against. The work carried out so far has flown in the face of the company’s own environmental policies, including drilling work outside the dates agreed to protect nesting birds and closing off public rights of way without permission. If they have been incapable of sticking to the letter of their own policies so far, what are they going to be like if and when real work starts? This is a deprived area that relies on tourism, particularly outdoor tourism, for most of its income. There are many ways that this scheme could damage the local environment and the tourism that depends upon it. And if it did so, it would have a huge economic impact that would far outweigh any jobs created by it, either in construction or long term. I personally would urge you to consider this too big a risk and to refuse permission for the scheme. "
Members of the Public/Businesses
Chloe Rafferty
"1. As a regular swimmer in Llyn Padarn I am concerned about the effects of the scheme on the lake and shores regarding both access in the Y Glyn (Lagoons) area and the effect on the quality of the water. 2. I have concers about the overall effect to the environment of Llyn Padarn due to the potential leaking of dumped military waste in the proposed sites. 3. I am an organiser of an SwimRun event that takes place in Y Glyn in late June (www.loveswimrun.co.uk). As well as my points from 1. I am concerned that the building of the pump house will cause a loss of access to this area for swimming and running along the shores which will prevent this event from taking place. This is my business so I have a vested interest in the area and it's access through Padarn Country Park Authorities. "
Members of the Public/Businesses
Cymdeithas Eryri the Snowdonia Society
"The main areas of concern which we will address are: 1. Landscape and visual impacts of the development in its entirety 2. Sensitivity of upland landscape close to National Park boundary 3. Impacts on public access and enjoyment 4. Common land exchange 5. Impacts on ecology of freshwater, including designated sites and their qualifying features "
Members of the Public/Businesses
Derek Summers
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW)will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health and safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. SECONDARY CONCERNS ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds."
Members of the Public/Businesses
Tammy Lewis-Jones
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW)will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health and safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. SECONDARY CONCERNS ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds."
Members of the Public/Businesses
Thomas Jones
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW)will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health and safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. SECONDARY CONCERNS ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds."
Members of the Public/Businesses
Kent County Council
"This Scheme has potential for a negative impact on the long established educational recreational and leisure usage of Llyn Padarn and the area immediately adjacent to it, an outstanding Nationally Valued natural environment. This Negative impact has potential to adversely affect more widely existing commercial leisure and tourism providers in the region. It is not clear that the benefits claimed for the scheme justify or have been balanced against the irreversible losses that may result."
Members of the Public/Businesses
Siobhan Evans
"PRIMARY CONCERNS REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW)will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health and safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. SECONDARY CONCERNS ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds."
Members of the Public/Businesses
Ann Lawton
"I am extremely concerned regarding the potential for the contamination of Llyn Padarn through the disturbance of the waters contained in the quarries. Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. Large volumes of water will be discharged from the quarries and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate. Public safety and environmental sustainability are paramount. Chemical and other weapons were stored in the quarries. (Reference: document entitled 'Glyn Rhonwy Pumped Storage Development Consent Order Appendix 8.5 Zetica (2015) UXO Desk Study Report'). There are many worrying quotes in the report, mainly: * 'temporarily used as a storage facility for 14,000 tons of bombs filled with Tabun, a toxic nerve gas' *'Records indicate that this disposal was not always successful..." *'Disposal activities at RAF Llanberis are considered to provide a source of UXO hazard within the quarry pits on the site' *I notice that pit locations are marked incorrectly on some photographs giving extreme concern should we agree with the location of ammunition on site at the present time * the RAF was unwilling to certify the quarries completely free of explosives despite rendering safe each disposal area. * In 2015 'During recent Site walkovers, the Client has encountered potential items of UXO. These discoveries indicate that, despite the extensive EOD operation, not all items of ordnance within the quarry pits were accounted for’. *'the decomposition products of these materials, especially Mercury and Lead can be highly toxic’. Should these points not be addressed, they could possibly lead to terrible effects on the lives and health of local people, workers and the wildlife and water contained in Llyn Padarn. The possible catastrophic effects could lead to losing 100s of jobs too. I have written to the MOD who are yet to be able to state that the site and it's contents are safe. In view of this, how can the developers possibly ensure that the site and its contents are safe!!...and if anything was to happen, how would the developer deal with it? This matter surely needs to be considered at the highest level, given the extraordinary site circumstances involving the storage of chemical and conventional weapons. Public safety and environmental sustainability are paramount. "
Members of the Public/Businesses
Dean Lawton
"My main concern is the potential damage to Public Health and Llanberis, particularly Llyn Padarn with the spill off from the quarries, knowing that chemical and other ordinance have been stored there. Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. My other concerns are: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. "
Members of the Public/Businesses
Emily Wood
"I am concerned with regard to the electrical connection to the national grid. Chapter 3 states that the SPH (Snowdonia Pumped Hydro) expects the grid connection to be underground however has no direct control over the electrical connection as it is Associated Development and therefore can provide no assurance on the connection. Chapter 17 Cumulative Impact Assessment considers the inter-related impacts from the grid connection and the Project but no visual assessment is undertaken as the electrical connection is assumed to be underground. This assessment is therefore invalid. The assessment of the worst case visual impact of the overground electrical connection with the Glyn Rhonwy development will be a major adverse significant impact throughout the project life on the visual amenity of the area. I am concerned by the proposed location of the pumping station within the lagoons area of Llyn Padarn – in regard to: • Safety to recreational users; • Potential restriction on recreational use of the lagoons area; • damage to the visual amenity of the area; • damage to established trees on the Llyn Padarn shoreline; and • loss of recreational amenity due to noise and light pollution. Chapter 4 states it was agreed with National Resources Wales that the approved scheme would be of sufficient depth (5 m) that adverse effects to recreational users in Llyn Padarn would be avoided. The potential effects are not identified - what depth is actually considered safe and whether seasonal variation in water depth is considered. Contaminated water has the potential to enter the lake from disturbance of the quarry housing old ammunitions containing TNT etc. Any contamination will pose a safety risk to recreational users. Chapter 4 states the pumping station will be in a vegetated area by the car park.This area is not a car park but a grass picnic area with picnic tables, mature trees and enclosed shallow lagoons for safe sheltered swimming, and as advised by Country Council For Wales, February 2013, “The proposed pump house is to be built on the shores of Llyn Padarn, within the area locally known as the lagoons ... a very important recreational resource for local people and tourists”. There is no clear rationale for considering the location of the pumping station directly in the middle of the lagoons.The impacts from the pump station with regard to loss of trees, light pollution, noise, and disturbance during construction are all identified in the Draft ES and would be minimised by moving the location outside of this key area. Chapter 12 states the pumps are not inherently noisy. What does this mean in way of background humming? The noise assessment is incorrect as does not consider the nearest NSR, recreational users, “directly adjacent” and high sensitivity. Chapter 15 Socioeconomics advises that the location of the pumping station has been moved from the lagoon area and so has not been assessed. This is not the case as it remains one of only two options being presented. This assessment is therefore incorrect. "
Members of the Public/Businesses
Dr Jane Huuse
"Objection to the QBC Glyn Rhonwy development 1. Footprint: The huge environmental/physical footprint created by the scheme in order to potentially produce only 2.8% of the UK’s 2025 pump storage needs. If approved this could create a precedent for degrading beautiful upland landscapes across the UK for private profit. Why not get companies, either private and/or public, to co-ordinate and economise on scale, ruining only a few sites of beauty, and agree to use profits for example to fund research in to improving energy efficiency for future generations? 2. With rapidly evolving battery technology (for example use of Vanadium batteries to balance the grid), it may be the case that the QBC type of pump storage is soon considered exceptionally inefficient. A landscape ruined in vain? 3. The Environmental Impact Assessment is not accurate on a number of points, some of which I would like to discuss in more detail. Incidentally all reports provided for previous planning permission consideration by Gwynedd Council had been commissioned by QBC with some start up funds from Gwynedd Council to develop the site. . Will a balanced view of the facts (also made by qualified environmental personnel (without the huge financial incentives)) be taken in to account if presented to this panel? 4. The construction phase of this development will have a severe impact on those living along the access route (particularly those located in upper Waunfawr) and those in Llanberis. Many of the > 200 year old houses are within a few meters of access route (presently a narrow rural lane). Heavy goods vehicles using this route are likely to pose significant danger to school children, local children walking between houses (no pavement), buildings and walls. Some houses show strong potential for collapse. If this project gets the green light, then QBC proposes against the resident’s will, to use this route for its heavy goods vehicles and their associated site personnel at any time from 7 am to 7 pm, putting a lot of current road users at avoidable risk. 5. I also contest the conclusion of the EIA’s traffic section that concludes there will be insignificant disturbance from their heavy machinery and/or workers’/service vehicles using this access route. Pilot drilling on the development site resulted in vastly increased traffic counts around the clock and a strong increase in heavy noisy vehicles. Monitoring equipment was set up after site establishment and taken down before site abandonment and did thus not capture the most significant traffic increases. Thus there are major queries about the validity of the vibration and noise monitoring the company has carried out. "
Members of the Public/Businesses
Garry Smith
"Here are my concerns about the proposal NOISE - During the construction phase blasting may be necessary and a continuous conveyor belt has been proposed to move excess material uphill. The impact of this noise has not been adequately addressed. During actual operation, the potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. During the autumn of 2015, the noise from test drilling far exceed the developers anticipated levels. It was most audible by households on the opposite side of the valley, a distance of 2 km away. Despite complaints to Gwynedd Council the developres continued to drill, often outside of the permitted times (e.g. Saturday evenings). The Developer's estimation of contruction noise levels are grossly inaccurate, particulary concerning the accustics (sound directions) of the valley. CONSULTATION - The developer’s consultation efforts have been inadequate and not a recognised consultation with any two way exchange of views. The main benifits of the scheme pushed by the developer during the consultation show were 'local jobs' and 'energy security for Llanberis', the latter being completely misleading and infact untrue. Elected representatives at local and county level are whole heartedly in favour of this scheme and did not engage with any local residents who objected to the scheme. The consultation process has been inadequate. WATER MONITORING - Large volumes of water will be discharged from the quarries during both construction and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate. The immediate area is very popular for outdoor recreation, especially watersports for local people and visitors (recently awarded safe bathing water staus by the Welsh Govt). Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. PROCEDURAL IRREGULARITY - The Developer has gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. REGULATION - Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective (recent revelations through an FOI request have demonstrated NRW's inaction on monitoring abstraction licences on nearby hydro schemes). Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSIDERATION OF ALTERNATIVES - The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. FLOOD RISK - Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. Recent December rainfall levels were at the highest ever recorded in the valley. All pools (pits) on the Glyn Rhonwy site were at their maximum level with seemiingly no capacity to absorb further water. If two of these pools are to be made effectively 'water tight' there is nothing within the developer's flood risk assessment that deals with the now not-so-unthinkable even higher-level of monthly rainfall than that experienced in December."
Members of the Public/Businesses
Lowri Roberts
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. "
Members of the Public/Businesses
Mads Huuse
"Objection to the Glyn Rhonwy development by QBC 1. Environmental concerns: • The proposed scheme will have an output of 100 MW. The UK need for pumped storage of energy is projected to rise by 3.5 GW by 2025. The proposed development would only provide 2.8% of this. If UK demand is to be met by such small-scale plants it would need 35 such developments in pristine highland areas around the UK. Moreover, the revised Glyn Rhonwy scheme is designed to maximize profit from price fluctuations linked with balancing of the grid and intended to be emptied every day, generating a 20% net energy loss every day. • The areal footprint is the size of Llanberis and only 30% within the brownfield site of Glyn Rhonwy. The rest is in an area designated Area of Outstanding Natural Beauty, right on the border with Snowdonia National Park and the head pond and other installations will be clearly visible from Snowdon and other areas within the park, in contrast to the views and conclusions given in the EIA. • The Environmental Impact Assessment grossly mis-represents the impact on the local community along the upper access road through Waunfawr which will be adversely affected by traffic and noise. This is in direct contrast to the EIA which states that no significant increase in traffic or nuisance is projected. Recent pilot drilling on a much smaller scale than the development highlighted the general traffic increase and the increase in abnormal loads and abnormally noisy machinery along the peaceful mountain road, both during works hours and out of hours including early mornings and evenings. 2. Health and safety concerns: • The traffic up the unnamed road to Cefn Du is going to be severely increased with abnormal loads and multiple HGV trips daily and a large numbers of vehicles trasnporting workers up and down each day. HGV trips represent an increase of 300-900%, exceeding the limit for ‘substantial’ adverse effect. The traffic taking workers up and down each day will be a very significant increase at times when hardly any vehicles use the road. The traffic statement concludes the impact will be ‘minor adverse’, which conflicts with their own definitions. Only if traffic numbers are averaged over the day can the commuter traffic be considered incremental, but such an approach does not adequately capture the impact on local residents who are due to be woken up each day by a cortege of vehicles taking workers up the mountain. • School children, walkers, bikers, equestrians and residents will all be severely impacted by increased traffic for up to 3 years. As there are no pavements and the road is single track. In particular school children will be at risk in early morning and afternoons. • Numerous houses along the road are within a few metres of the road and situated on adverse slopes (up to 25% gradient), beneath the road level. These properties would suffer significant risk of collapse when subject to abnormal loads and vibrations from repeated 40 ton trucks passing. "
Members of the Public/Businesses
Mark Lynden
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by NRW will be effective. CONSULTATION: The developer has misrepresented several aspect of the development which renders the consultation process invalid. The consultation has seemed more like a public relations exercise. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: There is an apparant degree of risk associated with the amount of explosive and chemical munitions potentially remaining on the site. Further information is required to understand the implication of this to public health and the environment, particularly with respect to the activities proposed by the developer. WATER MONITORING: Proposals for monitoring and controlling discharge from the quarries in both constructional and operational phases are inadequate. Harmful chemicals could have a profound effect on downstream water catchment areas. GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground but this is misleading as the connection to the grid is influenced by other factors. There should be an obligation to make the connection underground to the existing pylons/Pentir sub station. RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Degradation of the environment arising from this scheme could have a negative effect on this important part of the local economy. ACCESS: The “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documented information about the number of "local jobs" is different to the larger numbers being circulated during consultation. NOISE: During construction: The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: There are serious questions regarding the accountability of the development procedures to date. The preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body, then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less additional risk to the local environment. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Assurance that the local water table will not be raised by seepage from the and that rapid river level changes from unnanounced releases of water is required. These risks are not adequately addressed by SPH "
Members of the Public/Businesses
Stephanie Duits
"I’d like to register as an interested party in regard to the Glyn Rhonwy Development. I belong to a swimming club of around 60 members and I am expressing my concerns particularly to the impact of the development of the Lagoons area of Llyn Padarn and the potential harm to water quality following the planned discharge into Llyn Padarn. During the months of April to October, many members of my swimming club use the Lagoons area and Llyn Padarn at least twice per week for open water swimming and social activities (BBQs etc). We are concerned with the location of pumping station for water abstraction particularly: 1. disruption to access during construction 2. damage to trees along the shoreline 3. impact on the amenity (which is heavily used by many locals) in terms of noise and light pollution. ?We would also like to make representation about the permanent loss of the Llyn Padarn amenity due to water pollution following the planned discharge from the development. Glyn Rhonwy quarries were used to store 14,000 tons of bombs filled with tabun (a toxic nerve gas). Surplus and faulty ordnance was also disposed of in the quarries. The site survey document by Zetica (“SITESAFE UXO DESK STUDY” - extracts quoted below) highlights a number of extremely worrying points including (and not restricted to): 1. “Records indicate that this disposal was not always successful. Firstly ordnance would often get lodged on rock shelves, in slate piles or within crevices when tipped into the quarry, never making it into the burning pit”. 2. “Given the volume of ordnance that required clearance, and the working practices of the period, it is possible that some explosive items were inadvertently disposed of in Pit2B and residues may have remained within some of the casings” In relation to encountering live ordnance during clearing processes… 3. ”This means that there are still live ordnance items within the remained of the [slate] pile, constituting a significant source of UXO hazard.” In relation to the 1972 clearing process: 4. “During clearance of the slag heap it was discovered that the previous disposal process had been inefficient and was incomplete, with live and semi-destroyed material still in place. Unburnt magnesium powder was interspersed with live detonators and other explosives.” 5. “It should be noted that the RAF was unwilling to certify the quarries completely free of explosives, despite rendering safe each disposal area.” 6. “During recent Site walkovers [in 2015] , the Client has encountered potential items of UXO on the access path to Pit 2A…..These discoveries indicate that, despite the extensive EOD operation undertaken, not all items of ordnance within the quarry pits were accounted for.” These points (and many others in the document) indicate, at the very least, a considerable risk of contamination of any water discharged from the development into Llyn Padarn. "
Members of the Public/Businesses
Christine Jordan
"I am registering as an interested party in regard to this developement as a local resident who will be impacted by the proposed scheme. I have previously submitted my concerns several times to the Developer at consulation stage ,but these concerns have not been adequately addressed and I wish to make reprensentation to see that the impacts on myself and my neighbours are refuced or sufficiently mitigated. I AM CONCERNED ABOUT SAFETY ON MANY ASPECTS. 1.The proposal to ose our small lane as access for all construction traffic for the building of the Dam and resevoir is totally unsuitable and the lane ,even with some added passing places is not fit for purpose.This phase will go on for several years, during which time we shall have our safety compromised,our house devalued or damagedand feel at risk every time we venture out of our homes.The applicant has no intention of being the developer,but will sell the project and promises made may never be fulfilled.We shall in practice have to actively police and try to enforce any conditions meant to ensure our safety. 2.The previous use of Glyn Rhonwy as a disposal location for bombs, nerve gas and other ordanance makes it totally unsafe and unacceptable as a site through which there will be tunnels drilled.What could happen if these old and unstable items are disturbed?The Zetica report makes chilling reading and highlights the real dangers we could all face. 3.The use of Llyn Padarn as the water supply and for discharge is putting in danger the unique qualities of this iconic lake.The water sports enjoyed by locals and tourists safely throughout the year is at risk ,we cannot allow this natural resource to be destroyed. 4.The development of much more sophisticated and self contained electricity storage facilities are becoming a reality,Bill Gates has made this one of his missions.This will make pumped storage uneconomic and unviable,when this happens and the managing company goes out of business who will maintain the dam and protect the village of Waunfawr below?This would be a permanent structure that will change the landscape forever but could hold financial and hidden dangers for the local council in the future. I conclude that this development is unneccessary,enhancing the existing connection from Dinorwigto the Grid enanbling it to run at full capacity is surely more sensible. This profit making scheme for Snowdownia Pumped Hydro is compromising safety for local residents on many aspects,please listen to our concerns. So "
Members of the Public/Businesses
Ms K S Potter
"I have been following this process very closely and have many and varied concerns. The following itemises them: PRIMARY CONCERNS REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW)will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health and safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. SECONDARY CONCERNS ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds."
Other Statutory Consultees
Public Health England
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on the proposals and Environmental Statement (ES) at this stage of the project. Our response focuses on health protection issues relating to chemicals and radiation. Advice offered by PHE is impartial and independent. PHE, including PHE’s Centre for Radiation, Chemical and Environmental Hazards (Wales), has considered the submitted documentation. Whilst we are broadly satisfied with the conclusions drawn within the ES, we note however, that our previous request (dated 5th March 2015) in considering the potential health impact associated with electric and magnetic fields (EMF) has not been specifically addressed. It is important that all aspects of the development are considered at this stage and would request this aspect be undertaken for PHE to consider. Should the applicant seek any specific advice prior to the submission, PHE of course would be pleased to assist. "
Members of the Public/Businesses
Snowdonia Wildlife Tours
"1 My concern about the 2 species of scheduled 1 birds in the quarries. The Chough and Peregrine falcon which the latter failed to breed this Spring due to disturbance by boring holes so near the nest. Yes boring holes in the second week of May ??? As I and others have been watching this pair for over a decade,its so sad to see the regeneration of wildlife trampled by big machinery in just a few weeks. 2 The tabun bombs left in the quarry then just burried with slate to cover up. Emptying the quarry could risk poisoning the water system Do Llanberis need another dead lake like Llyn Peris"
Members of the Public/Businesses
Cherry Bartlett
"The proposal from Snowdonia Pumped Hydro (the company) makes no sense in energy terms. The amount of energy that will be generated even from the enlarged scheme will be a drop in the energy ocean. The existing Dinorwic system is, according to those who conduct tours around it, rarely used to its full capacity. Utilising an existing facility is a much more sensible approach. The company proposals involve a major impact on the local communities of Waunfawr and LLanberis. Both these places are reliant on tourism for the majority of their income and the disruption that will be involved in creating this facility will create a long term downturn in this industry. The proposed access route for construction through Waunfawr and Groeslon is totally unsuitable for the heavy traffic that will be required. The road can never be brought up to the standard required and represents considerable safety and sanity threats to those who live along it. A number of properties actually abut the road and will be particularly threatened. There have been no tangible answers provided by the company when these concerns have been raised in the past. If the company receive planning permission they will undoubtedly then sell the project on, possibly to overseas investors and any profits will disappear from Wales - indeed they would never come to Wales as the company is based in England. Few long term jobs will be delivered and the communities most affected can only lose from the development. "
Members of the Public/Businesses
Mr Neville E. Gray-Parry
"Our property is served by a private water supply, our concern is therefore any effect on the local water table and continued supply of water to our property which is a grade 2 star listed property with grade 2 registered gardens which contain a series of waterfalls and features which also use the water gained from our own reservoir which is served by springs from Cefn Du. There is no borehole to supply this water only a private reservoir."
Members of the Public/Businesses
Dr David Bellamy on behalf of Mrs Claire Bellamy
"3 years of large trucks going up and down 1 vehicle wide roads is going to be a logistic and safety disaster for walkers and car users. Will the trucks reverse when encountering a car (I think not) or will the car have to find the nearest ditch, and will walkers simply abandon visiting the area? For many walkers "the journey" is as important as "the destination" and if they are going to be exposed to continual vehicle pollution they are simply going to deem the area a no-go zone despite the impressive destination. Similarly, people want to see 360 degrees of beauty when they visit Snowdon; we don't want to visualise what it will be like once the construction is finished. Can Wales afford to have droves of people delaying their visit until they can have the truly panoramic vision promised? Will the expected light pollution further demerit Snowdon and the surrounding hills - will the phrase "it used to be beautiful" stick? Given that no real evaluation of the physical impact the trucks will have on the houses that are only a few feet from the roads being used, is there any certainty that serious structural damage will not eventually occur? Will the cottages that play an integral part in the giving Wales its heritage and beauty be destroyed (never mind the legal issues that will ensue if structural damage occurs to cottages that have stood firmly for centuries)? These are questions about long-term issues and also takes into account that tourists (those who bring needed money into the area) are quite picky. They are on the net and will know if it is worth visiting Snowdon and the surrounding area. Facebook users and Tweeters will have a lot to say. The impact of many tweets talking about noise pollution from trucks and how walkers were forever watching out for huge vehicles as they trudged up narrow roads could be horrific on the economy. "
Members of the Public/Businesses
Peter Frost
"I am concerned about the potential danger to health posed by the noise of the Glyn Rhonwy pumped storage scheme whilst it is operating. The similar, existing pumped storage scheme at Dinorwig creates a loud, low frequency noise when operating, and this is audible over a long distance. There is considerable, peer-reviewed scientific evidence about the danger to human health posed by man made noise, and with the village of Llanberis so close to the Glyn Rhonwy site, the potential for harm over the operating lifetime of this scheme is considerable. I would like to raise these serious health concerns, and provide details of the science behind them. In the interim, I refer the Inspectorate to Section 6 of the Welsh Government's Noise Action Plan for Wales 2013 - 2018."
Other Statutory Consultees
Public Health Wales
" Dear Sir / Madam Re: NSIP Application by Snowdonia Pumped Hydro Ltd for an Order Granting Development Consent for the Glyn Rhonwy Pumped Storage Project In Wales, the statutory function for public health is delivered through Health Boards with specialist support from Public Health Wales as necessary. We have consulted our technical advisors within Public Health Wales as well as Public Health England PHE CRCE – Wales. Our comments are based on the information contained within the application documentation to date. We have divided our comments to cover both the operational and construction phases. Note: In this context we consider off-site sensitive human receptors may include people living in residential premises; people working in commercial, and industrial premises and people using transport infrastructure (such as roads and railways), recreational areas, and publicly-accessible land. Consideration should also be given to environmental receptors such as the surrounding land, watercourses, surface and groundwater, and drinking water supplies such as wells, boreholes and water abstraction points. Overall the submitted Environmental Impact Assessment (EIA) has acknowledged public health risks. Operational Phase It will be vital to mitigate from the outset, impacts from noise and vibration that may arise from surface, underground operations and nighttime water pumping. The final project designs and operational plans to protect sensitive human receptors from noise and vibration should be agreed in conjunction with the local authority. Advice on mitigation of any possible health effects associated with the electric and magnetic fields around substations and the connecting cables or lines has been previously supplied by PHE – we have however supplied again for the attention of the developer in Appendix 1. Subject to the above impacts from the operational phase as described, do not present a concern for public health. Construction Phase We understand that the construction phase may last circa 5 years. We appreciate this phase will comprise a number of individual elements ultimately linked by underground water pipelines / tunnels. Potential impacts upon health are possible during this phase unless they are avoided or mitigated. Impacts from construction and material handling include dust and invisible particulates (point source, fugitive and traffic-related), noise and vibration (including from rock blasting). We therefore recommend that the developer 1. Agrees to and operates a Construction Environmental Management Plan (CEMP) which outlines mechanisms to respond to any complaints during construction. 2. Liaises with • the local authority for matters relating to noise, vibration, odour, and dust nuisance. • the local authority regarding any impacts on existing or proposed activities on local air quality. • the local authority to agree mechanisms to respond to any complaints from the community during construction, operational and any decommissioning phases. 3. Has regard to any cumulative impacts, including those arising from associated development, other existing and proposed development in the local area and new vehicle movements associated with the proposed development We hope that the above is useful but should you have any questions or concerns please do not hesitate to contact us. Yours sincerely ? Appendix 1: Electromagnetic fields (EMF) There is a potential health impact associated with the electric and magnetic fields around substations and the connecting cables or lines. The following information provides a framework for considering the potential health impact. In March 2004, the National Radiological Protection Board, NRPB (now part of Public Health England), published advice on limiting public exposure to electromagnetic fields. The advice was based on an extensive review of the science and a public consultation on its website, and recommended the adoption in the UK of the EMF exposure guidelines published by the International Commission on Non-ionizing Radiation Protection (ICNIRP):- http://www.hpa.org.uk/Publications/Radiation/NPRBArchive/DocumentsOfTheNRPB/Absd1502/ The ICNIRP guidelines are based on the avoidance of known adverse effects of exposure to electromagnetic fields (EMF) at frequencies up to 300 GHz (gigahertz), which includes static magnetic fields and 50 Hz electric and magnetic fields associated with electricity transmission. PHW notes the current Government policy is that the ICNIRP guidelines are implemented in line with the terms of the EU Council Recommendation on limiting exposure of the general public (1999/519/EC): http://www.dh.gov.uk/en/Publichealth/Healthprotection/DH_4089500 For static magnetic fields, the latest ICNIRP guidelines (2009) recommend that acute exposure of the general public should not exceed 400 mT (millitesla), for any part of the body, although the previously recommended value of 40 mT is the value used in the Council Recommendation. However, because of potential indirect adverse effects, ICNIRP recognises that practical policies need to be implemented to prevent inadvertent harmful exposure of people with implanted electronic medical devices and implants containing ferromagnetic materials, and injuries due to flying ferromagnetic objects, and these considerations can lead to much lower restrictions, such as 0.5 mT as advised by the International Electrotechnical Commission. At 50 Hz, the known direct effects include those of induced currents in the body on the central nervous system (CNS) and indirect effects include the risk of painful spark discharge on contact with metal objects exposed to the field. The ICNIRP guidelines give reference levels for public exposure to 50 Hz electric and magnetic fields, and these are respectively 5 kV m?1 (kilovolts per metre) and 100 ?T (microtesla). If people are not exposed to field strengths above these levels, direct effects on the CNS should be avoided and indirect effects such as the risk of painful spark discharge will be small. The reference levels are not in themselves limits but provide guidance for assessing compliance with the basic restrictions and reducing the risk of indirect effects. Further clarification on advice on exposure guidelines for 50 Hz electric and magnetic fields is provided in the following note on PHW website: http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1195733805036 The Department of Energy and Climate Change has also published voluntary code of practices which set out key principles for complying with the ICNIRP guidelines for the industry. http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/consents_planning/codes/codes.aspx There is concern about the possible effects of long-term exposure to electromagnetic fields, including possible carcinogenic effects at levels much lower than those given in the ICNIRP guidelines. In the NRPB advice issued in 2004, it was concluded that the studies that suggest health effects, including those concerning childhood leukaemia, could not be used to derive quantitative guidance on restricting exposure. However, the results of these studies represented uncertainty in the underlying evidence base, and taken together with people’s concerns, provided a basis for providing an additional recommendation for Government to consider the need for further precautionary measures, particularly with respect to the exposure of children to power frequency magnetic fields. The Stakeholder Advisory Group on ELF EMFs (SAGE) was then set up to take this recommendation forward, explore the implications for a precautionary approach to extremely low frequency electric and magnetic fields (ELF EMFs), and to make practical recommendations to Government. In the First Interim Assessment of the Group, consideration was given to mitigation options such as the 'corridor option' near power lines, and optimal phasing to reduce electric and magnetic fields. A Second Interim Assessment addresses electricity distribution systems up to 66 kV. The SAGE reports can be found at the following link: http://sagedialogue.org.uk/ (go to “Document Index” and Scroll to SAGE/Formal reports with recommendations) Public Health England has given advice to Health Ministers on the First Interim Assessment of SAGE regarding precautionary approaches to ELF EMFs and specifically regarding power lines and property, wiring and electrical equipment in homes: http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1204276682532?p=1207897920036 The evidence to date suggests that in general there are no adverse effects on the health of the population of the UK caused by exposure to ELF EMFs below the guideline levels. The scientific evidence, as reviewed by HPA, supports the view that precautionary measures should address solely the possible association with childhood leukaemia and not other more speculative health effects. The measures should be proportionate in that overall benefits outweigh the fiscal and social costs, have a convincing evidence base to show that they will be successful in reducing exposure, and be effective in providing reassurance to the public. The Government response to the SAGE report is given in the written Ministerial Statement by Gillian Merron, then Minister of State, Department of Health, published on 16th October 2009: http://www.publications.parliament.uk/pa/cm200809/cmhansrd/cm091016/wmstext/91016m0001.htm http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_107124 HPA and Government responses to the Second Interim Assessment of SAGE are available at the following links: http://www.hpa.org.uk/Publications/Radiation/HPAResponseStatementsOnRadiationTopics/rpdadvice_sage2 http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_130703 "
Members of the Public/Businesses
Tania Scotland
"I live and love living in this valley. My concerns regarding this scheme fall into two broad categories; the potential negative impact on our environment and local economy and the consultation process itself. Specifically my concerns are as follows: RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality, could have a negative effect on this important part of the local economy. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate. MUNITIONS: Previously classified information has been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health and safety and the environment. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground. CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment."
Members of the Public/Businesses
Tony Grant
"Health & Safety 1/ The Zetica report on munitions storage at Glyn Rhonwy in and of itself should prohibit any development involving underground working at the site. 2/ The proposed construction route via a single track lane through Waunfawr constitutes a serious risk to centuries’ old buildings without foundations, resultant damage/collapse from vibration due to excessive loads poses a serious threat to safety of inhabitants. Environmental 3/ The area adjacent to Glyn Rhonwy and the Snowdonia National Park has just been awarded ‘Dark Sky’ status. The ‘security lighting’ proposed would see this status revoked. 4/ The footprint of the site is far bigger than neighbouring Dinorwic, but would provide less than 5% of its output. The site would be an eyesore, viewable from the summit of Snowdon, and detrimental to the National Park/tourism as a whole. Dinorwic currently runs at less than 25% of its capacity. 5/ There is a significant flood risk to both Llanberis and Waunfawr/Betws Garmon, should accidental spillage occur. Water pollutants could also damage the ecosystem in Llyn Padarn, and pollute private water supplies serving up to 50 households. Moreover, excessive rainfall, which at present drains from Cefn Du into the whole of the surrounding area of Llanberis, Cwm y Glo, Waunfawr, & Betws Garmon, could only drain into Llyn Padarn once SPH is operational, increasing the flood/pollution risk significantly. 6/ No in-depth environmental study of flora and fauna was conducted, the report submitted to Gwynedd Council was incomplete, inaccurate, and missed protected species. Energy Generation 7/ Pumped storage does NOT produce electricity, only partially recycles. With it’s own maintenance and security/lighting proposals, the scheme would at best be 75% efficient, and is not ‘green’ as suggested. 8/ Vanadium batteries are viable large, industrial scale, long lifetime, with multiple charge/discharge cycles in excess of previous battery technology, and which actually store electricity, not water. REDT is a leading British company developing and installing this technology at present (not years in the future). Thus pumped storage is already obsolete. Long Term 9/ Detrimental health aspects are difficult to determine in advance, noxious pollutants from the construction could take several years before becoming apparent. Similarly, once operational, noise/vibration from the overnight pumping could disrupt sleep for many local residents, as sound travels more ‘efficiently’ through solids (such as the geological substrate of this area) and be more obtrusive in an area which is normally so still and quiet. 10/ From point 5 above, the power generation would need to be suspended during heavy rainfall to avoid the scenario stated."
Members of the Public/Businesses
Alessa Jaendling
"The road is unsuitable for the amount of traffic. There will be poor access for emergency vehicles. It will be difficult to get to our home and to away form our home due to large trucks using a narrow lane. Spoil the landscape. Large amount of noise pollution and general disruption for what seems like very little rewards."
Members of the Public/Businesses
Christopher Rowlands
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme. "
Members of the Public/Businesses
Concerned About Glyn Rhonwy (CAGR) (Concerned About Glyn Rhonwy (CAGR))
"MUNITIONS: Previously classified information has just been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about the possible presence of unexploded ordnance including chemical weapons has arisen which the Developers’ documentation fails to address. This needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries during construction and operation, and could carry harmful chemicals mobilised into the water column from reworking of material on site. This could have a profound effect on downstream water catchment areas. Proposals for continuous monitoring and control of this discharge are inadequate. They critically depend on the Developers’ own ability to self-regulate, and on other external regulatory bodies. These mechanisms have recently appeared to fail during the preliminary ground investigations. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Geological reports are overoptimistic about ability to manage this. Residents below Q6 on the A4086 need legally binding assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unannounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme. NOISE: During construction: Blasting rather than tunnelling may be necessary. A continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation: The potential impact of long term exposure to low frequency noise has not been adequately addressed We understand the Developers are seeking a “Power” to be immune from noise nuisance claims relating to the correct construction and operation of the project. We believe the Developers’ noise assessments are inadequate in this regard. Noise is an issue for residents close to the Dinorwig scheme across the valley, resulting in successful claims for compensation. GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground CONSTRUCTION ISSUES: The upper site will be accessed from Waunfawr along a narrow road. Local residents are concerned about disturbance and risk to their properties but believe their views were not adequately addressed by a flawed consultation process. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. "
Members of the Public/Businesses
Concerned About Glyn Rhonwy Community Group - socio-economic branch
"This submission is on behalf of the Concerned About Glyn Rhonwy Community Group (CAGR), socio-economic branch. CAGR has some 690 members. The main points of objection concern the following issues: REGULATION CONSULTATION RECREATION EMPLOYMENT PROCEDURAL CONSIDERATION OF ALTERNATIVES 1. REGULATION Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. The developer does not already have all the necessary environmental permits in place, and the approach is both piecemeal and does not allow the public to appropriately be informed of and scrutinize in detail the relevant permits. All permits should be secured before the DCO is granted, otherwise there is a risk that both UKPI and NRW etc will assume that the other body is fully scrutinizing and enforcing regulation, when in fact with this level of confusion it is possible that neither will be. Assurance is also sought that regulation and enforcement by Natural Resources Wales (NRW) will be effective. Currently there is evidence that NRW agreed that breaches of the CEMP took place during ground works but did not take any action against the construction company. NRW have also already been subject to judicial review for breaches of water quality monitoring at Llyn Padarn. There is currently very low public confidence that NRW can effectively safeguard Llyn Padarn and surrounds. 2. CONSULTATION The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two-way exchange of views, with their PR material containing a number of inaccuracies (such as an inflated number of jobs created when their own DCO documentation has a much lower figure). SPH states that a single stage consultation is appropriate; we disagree. For a scheme of this scale and potential impact, a detailed and iterative consultation should take place. Dave Holmes of SPH refused on two occasions to meet with the community group CAGR. Elected representatives at local and national level (local councilor, the Llanberis Community council and the local MP) have failed to engage with critics of the scheme. The consultation process has therefore been inadequate. 3. RECREATIONAL Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. There are currently around 10 large sporting events annually which use Llyn Padarn based on its bathing water status, each bringing between 2000-4000 people to Llanberis (competitors and supporters). The amount of income generated by all these activities has not been adequately considered, and the ‘beds survey’ within the documentation is a woefully inadequate way of analyzing the income generated by tourism, which may well be reduced during the construction phase of the project. There is also no consideration of the impact on visitors to the new caravan park in Glyn Rhonwy of continuous noise levels at night during operation. 4. EMPLOYMENT The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns (where 200 plus during construction is quoted). There is no analysis of potential loss of revenue and therefore loss of employment which may result from negative impacts of the scheme (noise, pollution, blasting during construction etc). 5. PROCEDURAL The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body, then this application to UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW. This means the public has had little awareness of what has been going on until it might appear to be too late to contribute. It is apparent from documentation that this scheme has been on the cards for over 10 years; there has been ample time to conduct open public meetings (organized by objective disinterested parties, rather than the marketing meetings held by the developer). These opportunities have not been taken. 6. CONSIDERATION OF ALTERNATIVES The Environmental Statement does not adequately consider the alternative of doing nothing, of looking at a battery storage scheme, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. There has been no consideration of the alternatives to emptying Q2 and Q6 into local water courses (Q6 in particular which will be emptied into Llyn Padarn SSSI, and which contains potentially hazardous waste). Whilst inconvenient and possibly expensive, it would be possible to pump out Q6/Q2 into holding tankers and dispose of the water elsewhere, ensuring proper testing of the quality at all depths and concentrations. This has not been considered. "
Members of the Public/Businesses
Dorrie Jandling
"The road is unsuitable for the amount of traffic and size/weight of vehicles and will damage water supplies to the houses. There will be poor access for emergency vehicles. It will be difficult to get to our home and to away form our home due to large trucks using a narrow lane. Spoil the landscape. Large amount of noise pollution and general disruption for what seems like very little rewards. Moved to the area for a quiet life, and paid for that privilege."
Members of the Public/Businesses
Gruff
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme. "
Members of the Public/Businesses
Haf
"I have read and understood ! Im against this planning as i live locally and use the area a lot for leisure use with my two children . We use the lagoons to swim and are a member of the local canoeing club that uses the lake . It is a shame for any development to use and abuse this wonderfull lake. It would be an eye sore to the land as i have seen the work they do on the way to Beddgelert from Waunfawr on the national park and still they have not sunk the ugly pipe into the ground . It is all about their fat pocket and they don't care about what they ruin as they have no intresting only to make money .It is easy to pinpoint a area on a map for such a sight and not know anything about the local use . My fingers are crossed that this development will be rejected as I think the scale of the project will damage the local wildlife and habitat of the rear birds we have on the lake and beond on Cefn du, Glyn Rhonwy. It would not creat more jobs as it is specialized work and the would already have their manpower for the project. I think the need to build something closer to the south where the electritity surge would be for . Do it on your land not our beauty. Nid oes angen y project yma o gwbl yn Glyn Rhonwy mae'r ardal yma yn berffaith . Diolch yn fawr iawn"
Members of the Public/Businesses
Katie Lloyd
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme."
Members of the Public/Businesses
Mererid Llwyd
"CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. As a resident of Waunfawr with two young children I am concerned about the added traffic especially large lorries that will drive through the village when the children are out playing and would also like assurance the lorries do not pass the school nor any road during school rush hour. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme."
Members of the Public/Businesses
Brad Nicholas
"CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme."
Members of the Public/Businesses
British Horse Society
"I raised matters concerning the Rights of Way and status of the track as an UCR between Llanberis and Waunfawr which had been incorrectly shown on the Consultatation documents . I see that some changes have been made and that the information now appears to be almost correct. The UCR is listed as a route that will have a temporary diversion in place BEFORE the original is closed. I need to be certain that fences, gates and the surface of any works associated with Bridlway or the UCR are carried out so as to be safe and suitable for horses and generally in accordance with Highway and BHS Standards. The documentation of the Apllication is silent in this respect."
Members of the Public/Businesses
British Mountaineering Council
"The British Mountaineering Council (The BMC) is the national representative body for climbers, hill-walkers and mountaineers for England & Wales. The organisation currently has just over 80,000 members, over 200 affiliated climbing clubs with over 5,000 members based in Wales. The BMC's Welsh Area members have requested that I object to elements of this proposal on several matters, namely :_ 1) The land on which this proposal is located is registered common land with consequent right of access for informal recreation under the Countryside & Rights of Way Act 2000. The proposal includes plans to deregister part of this - both the BMC and our members feel strongly that the land being offered in exchange (a felled conifer woodland partially sited on old slate waste heaps) is grossly sub-standard for the purposes of recreation and is a very poor substiute for the high quality open moorland and heath that is being lost on a popular and accessible common. 2) The closure (both temporary and permanent) of open access land and well used public rights of way in such a popular upland location close to the highly popular tourist town of Llanberis and right on the edge of a national park is unacceptable for a development of this kind. 3) There are numerous subjective and untested assumptions in the access element of the develpers submissions - for instance no mention is made of the fact that the old slate quarries are of tremendous historical and active interest to rock -climbers. The old slate quarries at Glynrhonwy are thought to be the first location world wide where its believed climbers first started climbing on slate - a particulary specialised but extremely popular genre of rock climbing that is unlike any other form of climbing. 4) It is the opinion of our members that the landscape impact of this development, on landscapes that are recognised in the developers own submission as being of "outstanding" or having "high" lanndscape value (and in particular the visual impact of the development from nearby Moel Eilio and Snowdo ia National Park), has been underestimated and that the actual impact will be considerable and will negatively detract from a cultural, historic and natural landscape of national significance. 5) Finally - although not part of this application there is considerable concern that should the development proceed that there is no guarantee that the export of electicity generated at the site would not require new intrusive overhead cabling and power lines across the enterance to the iconic Llanberis valley. It is the opinion of our members that to give sufficent and accurate consideration to the impact of this development as a whole that the means by which electricty is exported should be part of this application. Elfyn Jones on behalf of the British Mountaineering Council."
Members of the Public/Businesses
Dr Dawn Wimpory
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme. "
Members of the Public/Businesses
Elin Williams
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme. "
Members of the Public/Businesses
Emma Edwards-Jones
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by NRW will be effective. CONSULTATION: The developer has misrepresented several aspect of the development which renders the consultation process invalid. The consultation has seemed more like a public relations exercise. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: There is an apparent degree of risk associated with the amount of explosive and chemical munitions potentially remaining on the site. Further information is required to understand the implication of this to public health and the environment (particularly water quality in Llyn Padarn) with respect to the activities proposed by the developer. WATER MONITORING: Proposals for monitoring and controlling discharge from the quarries in both constructional and operational phases are inadequate. Harmful chemicals could have a profound effect on downstream water catchment areas. GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground but this is misleading as the connection to the grid is influenced by other factors. There should be an obligation to make the connection underground to the existing pylons/Pentir sub station. RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Degradation of the environment arising from this scheme could have a negative effect on this important part of the local economy. ACCESS: The “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documented information about the number of "local jobs" is different to the larger numbers being circulated during consultation. NOISE: During construction: The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: There are serious questions regarding the accountability of the development procedures to date. The preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body, then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less additional risk to the local environment. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Assurance that the local water table will not be raised by seepage from the and that rapid river level changes from unnanounced releases of water is required. These risks are not adequately addressed by SPH"
Members of the Public/Businesses
Gethi Jones
"I am deeply concerned by the presence of MOD ordnance in the bottom of oe of the proposed reservoirs. The potential of seepage and subsequent contamination of yhe watershed needs further consideration and adequate removal/remediation prior to any further development of this site."
Members of the Public/Businesses
Huw Llewelyn Jones
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by Natural Resources Wales (NRW) will be effective. Why is a Development Consent Order is being sought before necessary discharge permissions are granted by NRW? CONSULTATION: The Developer’s consultation efforts have seemed more like a public relations exercise not a consultation with two way exchange of views. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: Previously classified information has now been released in the Developer’s documentation about known and unknown ordnance remaining on site. A level of uncertainty about UXO, including chemical weapons has arisen which needs clarification in regard to risk to public health, safety and the environment. WATER MONITORING: Large volumes of water will be discharged from the quarries in both constructional and operational phases and could carry harmful chemicals. This could have a profound effect on downstream water catchment areas. Proposals for monitoring and controlling this discharge are inadequate GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground, but there is no legal obligation. Financial and technical considerations could result in pylons being used. There should be a legal obligation to make the connection underground RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Any degradation of the environment arising from this scheme, particularly water quality for swimming or fishing, could have a negative effect on this important part of the local economy. ACCESS: Some recreational users of the area around the site have indicated that the “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documentation suggests 78 -118 local jobs during construction and possibly as few as 20 operational jobs may result from the scheme. This is at odds with larger numbers being circulated during local PR campaigns. NOISE: During construction: Blasting rather than tunnelling may be necessary, and a continuous conveyor may be used to move excess material uphill. The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: The Developers have gone about the promotion of this scheme in a piecemeal fashion. Fortuitous preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less risk to the local environment. CONSTRUCTION ISSUES: The upper site will be accessed along a narrow country road. Some residents of Waunfawr area are concerned about disturbance they will suffer but feel their views were not adequately represented by the local Community Council at the time of a flawed consultation process. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment for example due to large scale collapse of a quarry wall into upper or lower ponds. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Residents below Q6 on the A4086 need assurance that the local water table will not be raised by seepage from the quarries, thereby affecting their properties. Residents downstream of the Dinorwig scheme are already subject to rapid river level changes from unnanounced releases of water into the system. These risks are not adequately addressed for the Glyn Rhonwy scheme."
Members of the Public/Businesses
Kate Lawrence
"I wholly oppose the Hydro scheme proposed at Glyn Rhonwy on the grounds that I am not satisfied that a) the scheme is necessary and beneficial to the local population, especially given the Dinorwig scheme b) there is far too much uncertainty over the damage the scheme could cause to the water quality in Lake Padarn. The lake is a major tourist attraction, it is enjoyed by locals as a swimming and water sports facility. The employment already provided in this industry could be at risk if the water quality were to be in jeopardy and I do not believe that the stated employment provided by the proposed scheme at Glyn Rhonwy would compensate for this. Lake Padarn is a wonderful local resource in an already very industrial landscape; please don't spoil it for us."
Members of the Public/Businesses
Michael Vitkovitch
"I wish to make representation regarding the deficiency in the submission on the effects of noise created by the generators of the proposed development. The comments to my Consultation question have stated that it is not possible to assess this noise until after completion. However Dinorwic Power Station across the valley has a known history of turbine noise afeecting properties, and apparently pay compensation as a result. I am concerned that the Powers requested under the Development Order allow the Company protection against nuisance caused by the operation of the station, thus avoiding the issue completely. The construction will be by drill and blast as TBMs cannot operate economically in the rock conditions and short tunnel length. No assessment has been carried out of noise and vibration, something that is easily done as even the quantity of explosives is easily calculated. I am a retired Chartered Civil Engineer with 6 years experience of tunnelling at Dinorwic and 6 ears tunneling experience elsewhere in the major A55 rock tunnels. The application documentation is sadly incomplete and inaccurate."
Other Statutory Consultees
Natural Resources Wales
"Dear Sirs, Glyn Rhonwy Pumped Storage Scheme Relevant Representation from Natural Resources Wales (NRW) Introduction The purpose of the Natural Resources Body for Wales (NRW) is to ensure that the environment and natural resources of Wales are sustainably maintained, sustainably enhanced and sustainably used. Our functions are set out in the Natural Resources Body for Wales (Functions) Order 2012. Our advice and comments to the Planning Inspectorate (PINS) are therefore provided in the context of this remit. Our comments are made without prejudice to any further comments we may wish to make in relation to this application and examination whether in relation to the Environmental Statement (ES), provisions of the draft Development Consent Order (‘DCO’) and its Requirements, Statements of Common Ground (SoCG) or other evidence and documents provided by Snowdonia Pumped Hydro (‘the Applicant’), the Examining Body 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 2010 (as amended) and as an ‘interested party’ under s102(1) of the Planning Act 2008. We have provided pre-application advice to the Applicant and their consultants periodically since 2011 as part of the previous planning application/permission process, and subsequently before submission of the DCO application. More recently the Planning Inspectorate sought our scoping advice before adopting its scoping opinion. Our scoping advice was sent to the Planning Inspectorate in our letter of the 4th of February 2015. Subsequently we have responded to a draft Environmental Statement consultation under Section 42 of the 2008 Act, our letter dated 12th March 2015. We shall continue to provide advice to the Applicant with the aim of reaching positions of agreement and common ground, wherever possible, prior to and during the examination. Our relevant representation is based solely on the information provided within the application documents. Any changes in our position will be reflected in our written representation and Statement of Common Ground (SoCG). These relevant representations contain a summary of what NRW consider to be issues for which our continued involvement is required in relation to the DCO application, and indicate the principal submissions that we currently wish to make. NRW will develop these points further as is appropriate during the examination process; however, we may have further or additional points to make, particularly if further information about the project is submitted or becomes available. Environmental Permits The requirement for an Environmental Permit is governed by distinct and separate legislation, namely the Environmental Permitting Regulations 2010. Such applications are determined by NRW’s permitting function, which is distinct and separate to NRW’s advisory role by virtue of its interest in the Development Consent Order application. Notwithstanding this internal separation of function within NRW, we will endeavour to provide the Examination with an update as to progress of any permit applications, however it should be noted that we will not be in a position to comment in detail on the substance or merits of any particular application. We understand that as of yet, NRW has not received any Environmental Permit applications for the required 6 discharges from the scheme. We strongly encourage the applicant to submit their Environmental Permit applications as soon as possible so that the permitting process can run concurrently with the DCO examination process. National Policy Statement (EN1) advises “Wherever possible, applicants are encouraged to submit applications for Environmental Permits and other necessary consents at the same time as applying to the IPC for development consent.” This will allow Natural Resources Wales to proceed with its assessments, and it will then be much more likely to be in a position to indicate whether it is likely to grant a permit before the DCO examination closes.” Annexe C of the No Significant Effects Report includes an Operational Discharges Technical Note point 5, dated September 2015 argues that only 4 Environmental Permits would be required for the proposed development. We were consulted by the applicant on this note, and we dismissed the applicants’ justification for only 4 Environmental Permits, and confirmed to the applicants that 6 Environmental Permits would be required. NRW had some concerns over the sampling regime and data contained within the Water Framework Directive Compliance Assessment report, Appendix 9.1 of the Environmental Statement. However, following further discussions with the applicant, these concerns have been alleviated. An Environmental Permit for the initial filling of the development by abstraction from Llyn Padarn has already been granted, although the applicant have indicated to us that they may wish to vary that Permit (abstraction licence) to increase the rate of abstraction. Contaminated Land Within the application, and specifically the Environmental Statement, previous contaminative land uses have been considered, and a Land Discovery Strategy will be submitted as part of a DCO Requirement, which is consistent with our standard approach to deal with land contamination. Requirement 13 (c) requires the applicants to deal with and remediate any contamination that is identified. Ecology We are satisfied that the Environmental Statement has adequately assessed the ecological matters of the development. We have considered the No Significant Effects report, document 5.03, within the application under the Conservation of Habitats and Species Regulations 2010 (as amended) and we agree with the conclusion that the proposal is not likely to have a significant effect on the Natura 2000 sites within pages 1 and 2 of the report. As long as the mitigation measures, specified within the Schedule of Mitigation the Environmental Statement Volume 2B, Chapter 18, and within the Code of Construction Practice (CoCP), and its associated Plans, are adhered to, we believe that the proposed development will not have a significant impact upon these sites. This is also the case for Sites of Special Scientific Interest, Llyn Padarn SSSI, being the most relevant site as this is where the main discharge from the scheme will flow in to. The relevant European Protected Species licence for bats which covers the whole scheme has already been granted, dated 27th March 2015. Flood Risk Flood risk from the development has been demonstrated that it can be managed from the Flood Consequences Assessment submitted with the DCO application. The Flood Risk from the operation of the proposed development will be managed by the Excess Water Management Strategy, which will be developed as a DCO Requirement. The discharge rate for pumping during the initial dewatering exercise will need to be specified within the final Code of Construction Practice that is consistent with the maximum discharge rate within any Environmental Permit. Landscape We agree with the updated assessment within Chapter 6.0 Landscape Effects 6.1.11 “due to more accurate mapping and modelling, the slate mounds are slightly bigger than those assessed in the 2012 assessment and as a result Figures 6.4a, 6.4b and 6.4l have been updated. The change, however, is not discernible and it is considered that the findings of the previous assessment remain unchanged”. Development Consent Order DCO Requirements will play an important role in securing appropriate environmental risk management measures and ensuring that the impacts of the development are minimised. Relevant provisions will need to be developed further and approved by NRW during the course of the examination. Article 17 of the draft Development Consent Order entitled “Discharge of Water”, also needs to refer to requirement 20 “Excess Water Management Strategy”. Due to a number of plans that are requirements within the DCO, these should be developed concurrently so that they are consistent in their timescales and approach. Resolution of Matters Raised Please contact Gareth Thomas ([email protected]) should you require further advice or information regarding this representation. Yours’ sincerely, Richard Ninnes Head of Ecosystems, Planning and Partnerships, North and Mid Wales "
Members of the Public/Businesses
Owain Rhys
"Concernes on blasting Water contamination Hgv access Dangers of possible munitions"
Members of the Public/Businesses
Ray Wood
"I am concerned about the issue of noise once the scheme is running, particularly as I understand it, low frequency noise (difficult to assess). The problem can be proved to exist as it is an issue with Dinorwig Power Station. Residents - myself included as I've previously lived there - can attest to this. It's known locally as the 'Dinorwig hum'. Operators should not be allowed the powers of avoiding nuisance claims if they themselves cannot show they have made assessments and advised of the effects beforehand. I have further concerns with its landscape impact adjoining Snowdonia National Park and being so clearly visible from the nearby hills such as the adjacent Moel Eilio. The Park has just been awarded dark sky status which would be affected by any security lighting etc. As a precautionary principle nothing should be given planning that could potentially affect the good water quality of Llyn Padarn - recently given bathing water status - the only inland water to do so in Wales. Discharging from SPH into the lake has many unknowns. No in-depth environmental study of flora and fauna was conducted, the report submitted to Gwynedd Council was incomplete, inaccurate, and missed protected species. "
Members of the Public/Businesses
Snowdonia-Active
"REGULATION: Mitigation of environmental and other risks associated with the scheme will depend on effective monitoring and regulation. Assurance is sought that regulation and enforcement, particularly by NRW will be effective. CONSULTATION: The developer has misrepresented several aspect of the development which renders the consultation process invalid. The consultation has seemed more like a public relations exercise. Elected representatives at local and national level have failed to engage with critics of the scheme. The consultation process has been inadequate. MUNITIONS: There is an apparent degree of risk associated with the amount of explosive and chemical munitions potentially remaining on the site. Further information is required to understand the implication of this to public health and the environment, particularly with respect to the activities proposed by the developer. WATER MONITORING: Proposals for monitoring and controlling discharge from the quarries in both constructional and operational phases are inadequate. Harmful chemicals could have a profound effect on downstream water catchment areas. GRID CONNECTION: The Developer gives assurances that the connection to the national grid will be underground but this is misleading as the connection to the grid is influenced by other factors. There should be an obligation to make the connection underground to the existing pylons/Pentir sub station. RECREATIONAL: Llanberis area is very popular for outdoor recreation, including fishing and watersports for local people and visitors. Degradation of the environment arising from this scheme could have a negative effect on this important part of the local economy. ACCESS: The “land swap” being offered as part of this scheme is not a satisfactory arrangement. EMPLOYMENT: The Developer’s documented information about the number of "local jobs" is different to the larger numbers being circulated during consultation. NOISE: During construction: The impact of this noise has not been adequately addressed. During operation:. The potential negative impact on human health of long term exposure to low frequency noise/vibration has not been adequately addressed. PROCEDURAL: There are serious questions regarding the accountability of the development procedures to date. The preparation of the lower site by Gwynedd Council, then application for Planning Permission to this same body, then this application to the UKPI for a larger scheme, and applying for this DCO without a water discharge consent from NRW seems disingenuous. CONSIDERATION OF ALTERNATIVES: The Environmental Statement does not adequately consider the alternative of doing nothing, or of simply enlarging the similar but much larger scheme just across the valley at Dinorwig with far less additional risk to the local environment. FLOOD RISK: Risks due to flooding are not considered adequately with regard to residents directly in the flowpath. They do not adequately address the possibility of catastrophic and sudden loss of containment. There is high possibility of unexpected flowpaths connecting the whole quarry system deriving from earlier documented and undocumented quarry workings. Assurance that the local water table will not be raised by seepage from the and that rapid river level changes from unnanounced releases of water is required. These risks are not adequately addressed by SPH"
Other Statutory Consultees
SP Manweb
"Representation These comments are made by SP Manweb which is the licenced Distribution Network Operator (the DNO) for the Manweb (Merseyside, Cheshire, North Shropshire and North Wales area, within which the proposed development is located. SP Manweb is a statutory consultee in DCO applications. Reference has been made to the Applicant's Grid Connection Statement, in particular paragraphs 4.3 to 4.5 and 5.2. In relation to paragraphs 4.3 and 4.4, to clarify where reference is made to the POC offer, SP Manweb would only be responsible for providing new network from the POC. Likewise, in paragraph 4.4, under the POC offer, it is not the case of an either/or in terms of who would be appointed to complete the Grid Connection and SP Manweb consider it should read: 4.4 SPH have accepted the Point of Connection offer and are currently evaluating options to undertake the work. Following this process, an ICP will be appointed to complete the Grid Connection. They will have responsibility for: • Finalising the route • Undertaking the detailed engineering for the connection • Undertaking any surveys or ground investigation work • Installation and commissioning the equipment at the Development’s Substation • Installing the underground cable • Jointing the cable at the Connection Point Reference in paragraph 5.2 to it being possible to complete the works under SP Manweb's permitted development rights, should also be clarified by noting that this might not be the case where SP Manweb is not involved in providing the connection to the POC. SP Manweb suggest this paragraph is further reviewed following discussions between the promoter and SP Manweb. The above comments are made on the basis that the current connection agreement is a POC offer. The promoter does have the option of varying or applying for a new connection offer in which case the above comments could change. SP Manweb would welcome further discussions with the promoter in any aspect of the above. "