Glyn Rhonwy Pumped Storage

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Glyn Rhonwy Pumped Storage

Received 14 January 2016
From Concerned About Glyn Rhonwy Community Group - socio-economic branch

Representation

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.