“Mona NSIP Representations by Bodorgan Marine Limited PART 1: Co-Location Co-location strategy matters 1. The Applicant recognises the need for an effective co-location strategy and indeed claims that an overview of the co-location strategy will be set out in the Outline Fisheries Liaison and Co-Existence Plan (‘FLCP’); see 1.1.5 and 1.3.2 of the FLCP. 2. However, the FLCP does not present a co-location strategy. What the FCLP does is present a strategy for a form of co-existence – and not co-location - in allowing business as usual scallop fishing to continue in part of the development area. 3. Business as usual fishing is not in our opinion co-location. Indeed, the applicant’s own material recognizes this reality: see ES Volume 6, Annex 6.1 Commercial Fisheries Technical Report where business as usual fishing is described as co-existence 4. What the applicant should have done was to have turned its mind to the meaning of co-location, in particular as that term is understood in Welsh waters. If it had done so, it would have considered CEFAS’s April 2020 document entitled: “Welsh National Marine Plan: A review of the potential for co-existence of different sectors in the Welsh Marine Plan Area” (‘the 2020 CEFAS Report). 5. It is not clear that the applicant has considered the 2020 CEFAS Report as it is not listed in the Environmental Statement Chapter on Policy and Legislative background, Volume 1, Chapter 2. 6. If the applicant had considered the 2020 CEFAS Report: • its consultation activities, • its mitigation strategy, and • its socio-economic and other assessments would have focused on defining and delivering a strategy for realising the potential of the most promising form of co-location with offshore wind energy. This is widely and authoritatively recognised to be the co-location of mussel acquaculture and offshore wind energy. The 2020 CEFAS document: the meaning of co-location in Welsh waters 7. The 2020 CEFAS Report confirms that co-location is not the same thing as co-existence. Co-location is narrower and more specific. This is in contrast with the applicant’s definition of co-location in the FLCP at 1.3.1.1. 8. The 2020 CEFAS Report does not treat the interaction of offshore wind energy and fishing as co-location. Rather, its focus is on acquaculture as a co-location activity and it includes a specific chapter heading examining the co-location of acquaculture and offshore wind energy. 9. Extracts from the 2020 CEFAS Report confirm the potential of acquaculture to be the most promising form of co-location. PART 2: compliance with national policy requirements National Policy Statement EN-3 and co-located acquaculture 10. NPS-EN3, at paragraph 2.8.250 and .251, sets out 2 requirements, that: a. there should be effective consultation with the relevant part of the fishing industry; and b. mitigation should be designed to enhance positive benefits to the fishing industry. 11. As to the first requirement, for effective consultation, we are not aware there has been any consultation between the applicant and the acquaculture industry. This is surprising given that there is and has been a significant mussel acquaculture industry in the waters off Anglesey. Furthermore, we note that the FLOWW best practice guidance is now 10 years old. 12. As to the second requirement, for mitigation to be designed to enhance positive benefits to the fishing industry: a. we are not aware that the applicant has given any consideration to the enhancement of acquaculture; and b. in our view the mitigation proposals set out in the applicant’s proposal (i.e. those set out in the FLCP which look to preserve current fishing practices) cannot be characterised as an enhancement of benefits to the fishing industry. Welsh Government policy and co-located acquaculture 13. The 2019 Welsh Government Marine Plan policy requires optimization of the value of co-existence opportunities. 14. For the reasons set out above relating to NSIP EN-3, the applicant’s proposals have not considered the opportunities to co-locate with the mussel acquaculture industry to optimize the value and use of the marine area and marine natural resources. (our emphasis) PART 3: Other matters Method of securing mitigation 15. We question whether the current proposal for securing mitigation will be effective to secure mitigation in the form of co-located acquaculture. 16. We would like to reserve our ability to make further representations on this issue in due course. Evidence base 17. We ask PINS to add the 2020 CEFAS Report“Welsh National Marine Plan: A review of the potential for co-existence of different sectors in the Welsh Marine Plan Area”, , to the document library.”