Wylfa Newydd Nuclear Power Station

Representations received regarding Wylfa Newydd Nuclear Power Station

The list below includes all those who registered to put their case on Wylfa Newydd Nuclear Power Station and their relevant representations.

SourceRepresentation - click on an item to see more details
Non-Statutory Organisations
Anglesey Federation of WI
"Members of the WI live in the area where the existing Wylfa was built and where Wylfa B will be - they are concerned about the disruption when the building is happening and the workforce that will be employed for this project. One of the main concerns that the women of the area and on Anglesey will be safe (including young girls) during the time of building and facilitating the project. We understand that to be five years from the start of the project. As a women's organisation we would like reassurance that all measures will be in place to screen the incoming workforce for alcohol, drugs and the relevant employment checks will be done on a regular basis. we do have a representative attending the Horizon update meetings on a regular basis."
Members of the Public/Businesses
Ann Tooze
"I am a carer for elderly parents. (Sentence redacted), at present they still live in their own home which is on the side of the A5025 in Amlwch. I worry on the impact of their health with wagons & heavy plant going past their window for many hours a day, and I would like to know how much the A5025 through Amlwch will be used for the build I am a house owner in Amlwch, and also a landlady of a rental property in Amlwch. I have tenants in the property at present, and I would like them to stay there. If they wish to give notice & vacatem I would like to know the opportunties of renting my house out to contractors who come to Wylfa Newydd, and if there is a register I can put my details on I am the secreatry of a Cimmunity Interest Group in Amlwch, we ahve raised £35K in our first year for the town of Amlwch I would like to know what Horizon have in place to help organisations such as ours- if there will be funding opportunities. If Horizon would fund a community hub for us all to work from My interest is that the people in Amlwch - the nearest town to the build as kept informed of everything that is happening I am a semi retired grandmother of young children living in Amlwch. I would like to know what opportunities there would be for my grandchildren in another 10 years at Wylfa Newydd I have a health condition- and I would like to know how the build will affect this- or any health issues that may arise from the build at Wylfa I work 1 day a week locally and I would like to see the business increase, and I'd like to know what is in place for new workers to the area to use local businesses I worru for my grandchildren about the extra ttaffic on the road and would like information on trasport of materials to the site"
Members of the Public/Businesses
Arthur Wyn Owen
"The proposal now includes on-site worker accommodation for upto 4,000 workers. This will have a detrimental impact on the surrounding area both from an environmental and community point of view. This is contrary to the local Development Plan policies which aim to steer housing to the main settlements. The LPA have already considered and approved a worker campus development at Holyhead and as such this is available and should be used to accommodate a large section of the nuclear workforce. The on-site campus is located close to a SSSI which will be lost. No amount of off-site mitigation can compensate for this unnecessary loss due to the availability of other approved worker accommodation sites."
Members of the Public/Businesses
Dr Jonathan F Dean
"I have concerns about the proposed development for the following reasons: 1 - cumulative impact of power station and pylon line on the environment 2 - grid connection not acceptable to the people of Anglesey 3 - the power station and grid connection should be a single programme not two projects 4 - no “cumulative consultation” for the power station and grid connection 5 - impact of cooling water outflow on the marine environment 6 - construction and operation of the MOF rather than using Holyhead harbour 7 - the CHP feasibility study has not fully explored new agricultural developments and has minimal audit trail 8 - NPS EN-6 assumes private finance and implementation by 2025 9 - NPS EN-6 did not consider the grid connection 10 - it’s in the wrong place!"
Members of the Public/Businesses
Mr Roderick Armstrong
"I am against this development, on the grounds of cost, storage of waste on site, the impact on the surrounding environment and this technology is flawed "
Members of the Public/Businesses
Robin Williams
"I wish to register as an interested part as I am a County Councillor on Ynys Mon and have concerns about the impact that this development will have both on my own ward and the wider community on the island. Firstly I believe that the transport provisions to and from the site haven’t been sufficiently addressed and I am convinced that the developer’s intended reliance on a “lift sharing” mobile app will not be sufficient. Secondly I have great concerns about the impact on the Welsh Language and the Welsh speaking communities of Ynys Mon and am concerned that sufficient provision has not been made to date to address these. The lack of progress in appointing a Welsh Language Coordinator is a real example of this in action."
Members of the Public/Businesses
Roger Dobson
"Together with my wife I live in a property which today is bound on three sides by the Wylfa Newydd Development Area. We occupy an elevated position overlooking most of the WNDA. Since 2010 many neighbouring properties have been demolished or stand empty with a loss of community identity. Horizon's proposal to create artificial drumlins and 2 metre perimeter fencing close to us will have a permanent impact upon our environment. During the construction phase 24-hour operations and our proximity to the 4000-bed campus will make living here intolerable. (Sentence redacted). In the past week we have learnt from Horizon documents lodged with you that our property may be subject to major adverse effects for a period of eight years. We also understand that because of our proximity to the WNDA it is possible that vibration could "cause annoyance, feelings of alarm and could cause structural damage to our property". We are particularly concerned that Horizon is unreasonably refusing to identify which properties will be affected. I do not believe the provisions articulated in Horizon's voluntary Neighbourhood Support Scheme is a credible remedy for our situation. In addition, as a retired HR Director I am very concerned that Horizon intend to rely on a workforce employed on excessive long hours well beyond the 48-hour average week stipulated in the Working Time Regulations 1998. This will put their workforce at risk as well as the public who will share roads with the workforce as they speed to their temporary accommodation or by the A55 and Motorway network to their families. "
Members of the Public/Businesses
Menna Jones
"*I object to the building and its effect visually and environmentally on the land and the coastline. * I dont believe that the local inhabitants ( radius 30miles )have been fully informed about nuclear and alternative method of power.There has been a lack of presentation of facts to discuss the for and against.No money has been allocated to give an unbiased view of the whole project.I feel that the future generation that will inherit this project have not been provided with true facts. *Planning has not shown clear enough how the area would cope with an emergency . *Planning for the future?Anglesey is becoming an increasing popular holiday destination this plan is not in keeping with maintaining this direction.Anglesey's success has been due to agriculture and small businesses. Wylfa B is far too large a project for Anglesey to sustain and I fear it will lose its income from tourism and small businesses will shy away. "
Members of the Public/Businesses
Stephen Smith
"Engineering issues relating to water discharge, reactor scram systems design and worse case accident area evacuation and effects mitigation."
Members of the Public/Businesses
Jack O Toole
"I think another way of making energy is more suitable. Every country who signed the Paris climate agreement must reduce their emissions. I think wind energy is the least polluting to the environment. In my opinion, I think dredging the water to install the windmills could work. The Chinese have done this work in the South China Sea."
Parish Councils
Valley Community Council
"Our representation will include concerns regarding the closure of part of a stretch of road from Valley traffic lights to Llanynghenedl. There are also concerns regarding flooding within the village and the Community cemetery when major changes are made to the highway."
Parish Councils
Llanddona Community Council
"As member of the Community Council of Llanddona we would be interested in voicing opinions/concerns relating to the following areas which are likely to have an impact on our community and the Island as a whole should the Wylfa Newydd project go ahead: Impact on: What plans are in place if there was an accident or catastrophe Welsh Language and culture of the Island and local communities Availability of Employment opportunities for local residents and young people Investment in apprenticeships for school leavers Environmental impact of the development on wildlife/nature Local housing provision/planning and costs - increase demand on local housing Traffic issues and infrastructure to support Possible impact (long term) on the care provision requirements both children and elderly "
Members of the Public/Businesses
Magnox Limited
"Magnox Ltd is the holder of the Wylfa Nuclear Site Licence. Magnox is a tenant of the Nuclear Decommissioning Authority (NDA) contracted to decommission Wylfa Site. Magnox may become an Affected Party due to the proposed land acquisitions made in the application. Magnox is supportive of these land acquisitions through the provision of leases and facilitation of the sale of land by NDA to Horizon. Magnox does not support any acquisition by Compulsory Purchase due to the potential conflict with the Nuclear Site Licence issued under the Nuclear Installations Act."
Non-Statutory Organisations
SP Energy Networks
"SP Energy Networks are in discussion with Horizon Nuclear Power Ltd regarding protective provisions for the existing electrical network affected by the proposed development. SP Energy Networks does not envisage any issues with the agreement of these provisions but requires to be informed of the examination process to ensure these provisions are agreed within the required timescales."
Members of the Public/Businesses
Adran Dysgu Cyngor Sir Ynys Mon
"Rwyf yn awyddus i gofrestru fel y bydd gennyf yr hawl i ddatgan barn broffesiynol ar unrhyw effaith y caiff addasiadau/ newidiadau / adeiladu cael ar drefniadau sy'n effeithio ar ysgolion neu safon addysg gan gynnwys cynnal ac ymestyn darpariaeth ar gyfer y Gymraeg . "
Members of the Public/Businesses
Ysgol Uwchradd Bodedern on behalf of Cyngor Ysgol Uwchradd Bodedern
"Mae Ysgol Uwchradd Bodedern yn ysgol uwchradd ddwyieithog gyda’r pwyslais ar y Gymraeg. Mae wedi ei lleoli ym mhentref Bodedern ac yn gwasanaethu ardal eang yng ngogledd orllewin Ynys Môn. Mae 648 o ddisgyblion 11 i 18 oed yn yr ysgol, gyda chysylltiad hanesyddol rhwng gorsaf b?er niwclear Wylfa a’r ysgol drwy deuluoedd disgyblion, cyn-ddisgyblion yn gweithio yn Wylfa ac fel “Ysgol Busnes” mewn partneriaeth â Horizon. Yn dilyn y cynllun arfaethedig parthed adeiladu gorsaf b?er niwclear Wylfa newydd, mae’r cyngor ysgol, corff democrataidd sydd wedi ei ethol gan eu cyfoedion, gyda 4 pwynt hoffent godi gyda’r Arolygiaeth Gynllunio i ddistewi eu pryderon a chyfleu persbectif ieuenctid sy’n derbyn eu haddysg yng nghyffiniau’r atomfa arfaethedig. Hoffai’r cyngor ysgol ddiolch i’r Arolygiaeth am y cyfle i leisio eu barn ac edrychwn ymlaen am ymatebion i’n pryderon. · Y Gymraeg a’i Diwydiant: Deallai’r cyngor ysgol y gallai ar ei uchafswm 9000 o weithwyr fod yn rhan o’r proses adeiladu, gyda diffiniad Horizon o leol fod tu fewn i awr a hanner o deithio i’r safle. Gallai isadeiledd trafnidiaeth leol alluogi gweithwyr o siroedd a chymunedau Saesneg eu naws gael eu hystyried yn lleol. Mae’r cyngor yn awyddus i wybod sut mae Horizon yn bwriadu gwarchod a datblygu'r Gymraeg yn ardaloedd gogleddol yr ynys yn ystod y cyfnod adeiladu. A fydd gan Horizon polisi dwyieithrwydd ar y safle, er enghraifft arwyddion a staff croesawu dwyieithog? Oes bwriad o godi ymwybyddiaeth gweithwyr y safle o ddiwylliant ac iaith leol, gyda nod o gydweithio gyda sefydliadau lleol i’r perwyl yma? · Trafnidiaeth: Mae’r Ysgol wedi ei leoli ar gyrion Bodedern. Y brif ffordd i’r ysgol yw ar hyd y lon gefn sy’n cysylltu'r A55, A50255 a’r B5109. Yn barod mae pryderon am y traffig yn ystod adegau prysur o flaen yr ysgol, lle mae o ddeutu 90% o ddisgyblion yn cyrraedd yr ysgol ar fws. Gyda datblygiad maes parcio Talar Hir, pryderon y cyngor yw’r effaith ar swm y traffig, defnydd o’r lon gyswllt rhwng y tair ffordd uchod gan nifer i osgoi tagfeydd ac effaith llygredd aer. Yn ychwanegol deallwn fod y swm o drafnidiaeth am gynyddu’n sylweddol ar yr A50255, lle mae nifer o'n disgyblion yn byw. · Cyfleusterau: Pryder y cyngor ysgol yw’r gallu i gyfleusterau sir ac yn arbennig cyfleusterau gogleddol yr Ynys eu rhannu rhwng y poblogaeth lleol a gweithwyr. Mae’r cyngor yn ymwybodol fod cynifer o’r cyfleusterau yn barod yn brin mewn rhai meysydd fel meddygfeydd. Cais y cyngor yw i'r awdurdod lleol a Horizon gyd weithio mewn partneriaeth i ddatblygu cyfleusterau safonol i drigolion a gweithwyr rannu er mwyn creu adnoddau i’r dyfodol. · Datblygu Economaidd: Wrth ymchwilio i’r cynllun, deallai’r cyngor ysgol fod bwriad i letya y rhan fwyaf o’r gweithwyr ar y safle. Cred y cyngor fod cyfle i fedru rhannu cyfoeth yn cael ei fethu h.y. lle buasai gweithwyr yn medru prynu nwyddau gan fusnesi lleol, ac o ganlyniad yn gwella buddsoddiad i ddewis masnachol yr ardal, gyda’r awdurdod yn elwa drwy casgliadau trethi. "
Members of the Public/Businesses
Gareth Wyn Jones
"Mynegi pryder am faint y safle newydd a'r effaith ar bentrfi athrefi cyfagos. Problemau gyda threfniadau parcio."
Members of the Public/Businesses
Bill Howard
"I believe the developement would further despoil the coast and that as there is no route to disposal of the spent fuel then the site will have to hold radioactive waste for at least a century. Our present state of knowledge tells us that to leave future generations with our generations porblems is totally immoral."
Members of the Public/Businesses
Urdd Gobaith Cymru
"Prif bwrpas Urdd Gobaith Cymru ydi hyrwyddo’r defnydd cymdeithasol o’r Gymraeg a sicrhau dyfodol a pharhad i’r Gymraeg fel iaith fyw tu allan i'r ystafell ddosbarth. Fel mudiad rydym yn gweithio gyda chymunedau ym mhob rhan o Gymru gyda Swyddog yn gweithio ym mhob Rhanbarth. Mae gan yr Urdd ym Môn 3100 o Aelodau sydd yn mynd o’r oedran bl derbyn i 25 oed. Yn ogystal â hyn mae gennym ni dros 150 o wirfoddolwyr sydd yn rhoi eu hamser am ddim yn wythnosol ar gyfer dyfodol y Gymraeg. Credwn ei fod yn hanfodol bod unrhyw berson sydd yn gwneud gwaith ar safle'r Wylfa newydd yn derbyn cwrs ymwybyddiaeth iaith fel rhan o'i anwytho, credwn y dylai hyn fod yn wir ar gyfer staff Horizon ac unrhyw gontractwyr / gweithwyr allanol. Credwn yn gryf y dylai cyfleoedd gwaith fod ar gael ar gyfer trigolion lleol ac wrth leol rydym yn ei olygu Môn a Gwynedd yn unol â 'proximity principle' wrth gychwyn ar stepan drws y safle gan roi cyfleoedd i’r bobl fwyaf lleol yn gyntaf gan fanteisio ar y cynllun prentisiaethau / cwrs hyfforddi sydd eisoes wedi bodoli gyda Choleg Menai. Credwn dylai unrhyw fewnfudwyr gael y cyfle i ddilyn cwrs yn Gymraeg fel rhan o'i swyddi. Dylai fod Wylfa Newydd fel cyflogwr cydwybodol fod yn cynnig yr hyfforddiant yma i'w staff ac yn eu hannog i'w wneud hynny. Credwn ddylai wylfa newydd gefnogi'r Ysgolion lleol gan roi arian tuag at gynllun i agor a chefnogi canolfannau Iaith er mwyn roi'r gefnogaeth ar gyfer plant a phobl ifanc hwyrddyfodiad. Credwn y bydd cynllun parcio Dalar Hir yn effeithio ar y drafnidiaeth i Fodedern, Swyddfa'r Rhanbarthol, gan effeithio ar ein Staff yn cyrraedd y safle gwaith. I gloi'r peth pwysicaf i ni fel Mudiad ydi eich bod yn rhoi parch a chware teg i'r Gymraeg ac yn cefnogi Mudiadau fel yr Urdd sydd yn brwydro'n ddyddiol ar gyfer parhad a datblygiad ein hiaith ac ar gyfer cyrraedd nod Llywodraeth Cymru o sicrhau miliwn o siaradwyr Cymraeg a bod ein pobl ifanc yn cael y cyfle i aros ar yn eu cymunedau drwy ennill bywoliaeth yn lleol. Mae croeso i chi ddod i ymweld â ni ar gyfer trafod unrhwy un o'r materion uchod a byddwn yn ymfalchïo yn y cyfle i wneud hynny. "
Members of the Public/Businesses
Ysgol Gymuned Bryngwran
"Rydym yn cynrychioli Ysgol Gymuned Bryngwran ym mhentref Bryngwran, sef pellter o 2.7km o ddatblygiad Parcio a Theithio Dalar Hir ar gyfer Horizon. Mae yna 60 o ddisgyblion yn yr ysgol a Chylch Meithrin gyda tua 20 o blant sy'n mynychu'n ddyddiol. Mae gan y pentref gymuned agos ac mae'r dafarn leol yn dafarn sy'n eiddo i'r gymuned. Yn yr ysgol mae yna glybiau ffitrwydd, Cylch Ti a Fi, Cyfarfodydd Cyngor Cymuned, mae Diwrnod Hwyl blynyddol yn cael ei gynnal ar safle'r ysgol ac mae tîm pêl-droed y pentref yn chwarae ar y cae yn wythnosol. Mae gan yr ysgol faes parcio mawr i'r rhieni a'r athrawon barcio ac rydym yn poeni y bydd pobl sy'n gweithio i Horizon yn parcio yno yn hytrach na'r safle parcio a theithio arfaethedig. A fydd mwy o draffig yn dod drwy'r pentref? Bydd mwy o draffig yn ei gwneud hi'n beryglus i blant reidio eu beiciau a cherdded i'r ysgol? Os oes mwy o draffig bydd mwy o lygredd yn y pentref. Mae'r A5 yn cael ei defnyddio'n rheolaidd gan bobl sy'n mynd am dro i mewn ac allan o Bryngwran, bydd y ffordd yn aniogel gyda mwy o draffig. Mae pobl yn mynd am deithiau cerdded ar y cefnffyrdd; A fydd mwy o draffig ar y ffyrdd hyn? Dyma rai o'r pryderon sydd wedi eu lleisio wrth drafod y mater gyda'r Cyngor Ysgol. "
Members of the Public/Businesses
Cemaes Bay History Group
"The Cemaes History Groups was established in 2015 to bring together local history and educate the community about local history which is very significant in the area. We are very interested in the findings at the Wylfa site and wish to maintain a close relationship with Horizon and the archaeologists. Local residents and members of the Cemaes History Group have noticed many of the archaeological areas are being backfilled on the last few months. In other areas, many of the archaeological excavations appear to have stopped work completely but no machines have been on site. Given the current period of good weather, this seems like and appropriate time to hold a community open day to allow local residents to see the archaeological discoveries in the flesh before they are fully excavated and/or before they are backfilled. Arranging school visits before construction starts is an opportunity that should not be lost. the community, in particular the members of the Cemaes History Group are very interested in the archaeological work and are keen to have as many opportunities as possible to engage with their heritage and educate children in the area. In the long term we hope to see the interpretation, reconstructions and artefacts on display locally that will act as an educational tool for the future and will present an opportunity to enhance the tourism offer int he local area. The history group very much appreciate the regular talks from the archaeologists of the Gwynedd Archaeological Planning Service and look forward to further updates in the future. The Cemaes History Group would like the opportunity to work in partnership with Horizon and develop a living legacy for future generations. "
Parish Councils
Cyngor Cymuned Llanddaniel
"Mae gennym ddiddordeb yn isadeiledd y cynllun, a byddwn am wneud sylwadau ar hyn gan y gall hyn effeithio ar yr Ynys i gyd, gan gynnwys ein hardal ni. Rydym eisiau gwneud sylwadau ar unrhyw agwedd o'r cynllun a all effeithio ar y dirwedd yn ein hardal ni, sef Llanddaniel Fab, neu ardal gyfagos hefyd, a hynny yn y presennol neu yn y dyfodol. Yr ydym felly yn bwriadu gwneud sylwadau ar unrhyw agwedd o'r datblygiadau a fydd yn effeithio yn uniongyrchol neu yn anuniongyrchol ar ein hardal ni, gan gynnwys y datblygiadau presennol a datblygiadau cysylltiedig yn y dyfodol."
Members of the Public/Businesses
Professor David Kay
"My main concern is that we have just completed an EU (WEFO) funded study designed to provide real time prediction of bathing water quality in Cemaes Bay and I wish to ensure that any Wylfa developments do not compromise this work."
Members of the Public/Businesses
Ysgol Syr Thomas Jones
"Local jobs - available for local people More than just construction jobs available - important that young people know about these Will there be light pollution? Who will it affect? Lots of our families have worked at Wylfa Is it safe? What will happen if anything goes wrong? Language - Will Horizon be investing in language and local culture? What will the effect be on local schools - primary and secondary? More pupils = larger class sizes Salaries - more than salaries in the community at the moment? What will happen to Cemlyn? What will happen to the land? Why the need for so much land? How much has been paid for the compulsory purchase of houses?"
Members of the Public/Businesses
Clwb y Cen
"Our over 50's group want to be kept up to date with planning applications etc for this project. Our main interest is: employment opportunities for local labour and tradesmen, local suppliers etc - what the impact of such a project will have on the local community, culture and in particular the welsh language."
Members of the Public/Businesses
response has attachments
Michael Cominetti, BA,FCIWEM, C.WEM, CEnv.
"I was an Environmental Regulator, Senior Environmental Consultant and Member of the Devon and Severn Inshore Fisheries and Conservation Authority (Not writing on their behalf) with a passion for environmental conservation and in particular, the banning of the use of Direct Cooling for Coastal and Estuarine Nuclear and Conventional Power Stations because of the severe problem of fish and other aquatic organisms Impinged and Entraped on filter screens etc. Therefore my objection is soley related to the Cooling System proposed for Wylfa Newydd Nuclear Power Station. The main points are:- * Wylfa nuclear Power station will abstract some 25 BILLION Gallons Per DAY of Seawater, and despite the planned mitigation measures will kill thousaqnds of fish, fish eggs and other aquatic organisms by Impingement and Entrainment on filterscreens and condersors. * Whilst the Direct Cooling of Estuarine and Coastal Power Stations are considered 'Best Available Technique' by the Environment Agency (Natural Resources Wales) (Report -UK RD33 Cooling Water options for thr New Generation of Nuclear Power Stations) This report indicates that- in Para 4.3 Choice of cooling Water Systems - 'Greater awareness of the environmental impact of direct CW system and designation of conservation areas could lead to more use of indirect cw systems for coastal locations' Examples of this include 1) Where the environmental impact of the intake and outfall of direct CW system is not acceptable. (not acceptable in my opinion because of fish Impingement and Entrapment) and 2) Where the sea can support a direct CW system for One reactor, but ther is a proposal to develop Two reactors * The same report also says ''Quanties of fish impinged annually at coastal power stations range from a few tonne to tens or hundred of tonnes per year'' (From personal knowledge Hinkley Point B in Somerset impinges some 750 tonnes per year - 2-05 tonnes every day of dead and dying fish and other aquatic organisms) * The Jacobs report (Fish survey report 60P08007/AQE/REP/003) indicates ''That total annual catches at the Existing Power Station (now closed) were considered tp be low when compared to other coastal stations, this provides further support to the conclusion that fish abundances within the vicinityof the Wylfa Newydd Development area are low compared to fish populations elsewhere in the Irish Sea (eg Eastern Irish Sea). Whilst I cannot argue with this, I have comment that this indicates to me that Impingement and Entrapment at Wylfa MUST BE AVOIDED in order to PRESERVE fish stocks - after all the fish impinged, especially juveniles and eggs, represent Future stocks and these are subject to natural predation as well. * All of this can be avoided by the use of an Indirect Cooling system such as proposed by Nuclear Horizon at their Oldbury on Severn Plant - that is Hybrid Low Profile Cooling Towers. I attach a Photo of similar towers at Chinnon B in France (these are NOT fitted with plume abatement). Seawater can be taken through the Existing Magnox system to fill the Indirect Cooling System and then only 'make up' water will be required. *May I respectfully point out that the UK Government is currently being taken to Court by the European Commission for breaches of Europen Directives including Integrated Pollution Prevention and Control in respect of the Direct Cooling System agreed by the Environment Agency at the Pembroke (South Wales) Combined Cycle Gas Turbine station. Whilst I am aware that this staion discharges to a different water body, i am concerned that the effect of Wylfa could bring about similar action (subject to Bexit). * The American Environment Protection Agency has agreed that Indirect Cooling is now 'Best Technology Available for coastal and estuarine power stations. * Naturally I intend to make these points to Natural Resources Wales in response to their consultation on 'Operational Cooling Water Discharge-PAN-002427' * Finally, I would ask that my submission is given urgent consideration and that Planning Permission is only given for an Indiect Cooling Water System. Naturally I can expand on this brief submissin as required. Thank you."
Members of the Public/Businesses
Gwen Richards
"The application fails to adequately consider The future economy of the island especially for tourism The potential effects of brexit It covers a much larger area than is required for nuclear power production There is unnecessary destruction of habitats and historic landscape. It is in too close proximity to the nature reserve at Cemlyn which is under threat The long term storage of nuclear waste has not been adequately costed An island with limited evacuation routes should not be selected for a nuclear power station. "
Parish Councils
Llangoed and Penmon Community Council
"As member of the Community Council of Llanddona we would be interested in voicing opinions/concerns relating to the following areas which are likely to have an impact on our community and the Island as a whole should the Wylfa Newydd project go ahead: Impact on: What effect will there be on tourism How many pylons will be erected? Welsh Language and culture of the Island and local communities Availability of Employment opportunities for local residents and young people Investment in apprenticeships for school leavers Environmental impact of the development on wildlife/nature Local housing provision/planning and costs - increase demand on local housing Traffic issues and infrastructure to support Possible impact (long term) on the care provision requirements both children and elderly "
Non-Statutory Organisations
Ministry of Infrastructure and Water
"In 2017 the Netherlands government expressed the wish to participate in the EIA Regulation 24 process for a new nuclear power station at Wylfa, Anglesey, North Wales. The reason for this was that the Dutch government wanted a judgement by the ANVS about the risk of transboundary pollution on the territory of the Netherlands, especially in case of a major accident or incident. We confirm that the Ministry of Infrastructure and Watermanagement still wants to be registered as an interested party. The Ministry wants to be informed about the status and process of the project, and is especially interested in possible transboundary effects and possible measures to prevent transboundary effects. "
Non-Statutory Organisations
Together against Sizewell C (TASC) (Together against Sizewell C (TASC))
"Environmental Impact No resolution to Nuclear Waste Lack of need for new nuclear as renewables coming on stream are less polluting and more sustainable. Impact on Tourist and Visitor numbers, negative socio-economic impact on Anglesea. Impact on RSPB Reserve and on all of Anglesea bird life "
Members of the Public/Businesses
Davis Meade Property Consultants Ltd on behalf of Messrs MW ,EW & M Harper
"We are appointed as Agents on behalf of our Clients-: Messrs MW ,EW & M Harper, Llanllibio Fawr, LLanfachraeth, Holyhead. Anglesey whom in the absence of receiving appropriate clarification & satisfactory consensus is submitting an objection to the Development Control Order (DCO). Whilst not exhaustive with regard to the proposals detailed on Drawing Nos WN0902-HZDCO-OHW-DRG-00014/1.0 & 00018/1.0 & 00022/1.0 (forming part of the DCO application) our client is seeking comprehensive detail, please, as to -: 1. the extent of the area applicable to their property within the order limits which is intended to be acquired permanently /temporarily. 2. the works intended to be undertaken on our client’s land (within the order limits ) and what measures will be undertaken to -: a) mitigate flooding of their adjoining land and neighboring property. Moreover, what measures are to designed to mitigate injurious affection of our clients further land abutting onto both the Rivers Alaw & Llywenna Bach and the benchmarks to be used to demonstrate the status quo directly prior to such proposals being implemented. b) ensure livestock proof boundaries are duly installed and erected on appropriate perimeters (which will not act as a barrier and impede the flow of flood water receding from our client’s adjoining land).In addition the type & location of livestock proof fencing proposed to be installed along the relevant sections of the subject water courses (to replace existing) together with the provision of appropriate Livestock water drinking bays. c) maintain and provide an appropriate piped water supply from a mains source to our client’s farm [including the position of such pipeline together with associated apparatus including the water meter and stop tap; as well as a facility on the roadside (by means of a “ lay-by” to park a vehicle ,so as to be able to safely attend to the same]. 3. Confirmation of whom will be responsible, and also what commitment will be provided , regarding annual future dredging of the subject watercourses . "
Local Authorities
Ad Trac Anglesey County Council
"Ad Trac is a project working with young people 16 - 24 that are not in education or employment, to reduce any barriers they may face getting back into those areas. -Are we able to use the facilities on sight? -Are they going to push the profits back into the community? -What about safety? -Will they build a new bridge for the traffick and workers with registration cameras? -Will they restore the train tracks that go towards Amlwch? -Will they educate people in local college's? -Will people with criminal records work there? -How can you make sure that families coming in to the area respect Anglesey? -Will they be taking houses away from people that live here? -Is there going to be room for their children at the local school? -Why Anglesey? -What if Anglesey needed to be evacuated- How would you control traffick? "
Local Authorities
Cyngor Gwynedd/ Gwynedd Council
"1. Marchnad Dai Mae rhagdybiaeth i safle’r campws liniaru’r effeithiau sylweddol ar y farchnad dai leol. Rhaid cael gwaith adeiladu fesul cam hyblyg, i ateb y galw neu ymateb i amrywiadau yng nghyfansoddiad y gweithlu. Mae angen mesurau monitro’r effeithiau ar Wynedd a gweithredu camau lliniaru. Nid yw prisiau rhent presennol yn fforddiadwy i rai. Bydd cynnydd yn effeithio ar breswylwyr agored i niwed. Gallai poblogaeth wedi’i hadleoli waethygu problemau cymdeithasol. Nid yw’r Cyngor wedi cael trafodaethau penodol ar y Gronfa Dai. 2. Cludiant a Seilwaith Ffyrdd Rhaid rheoli symudiadau cerbydau a gwneud trefniadau ar gyfer adegau pan fydd Pont Menai ar gau. Mae parcio anghyfreithlon yn broblem ar briffyrdd y sir eisoes. Gall y sefyllfa waethygu pan fydd gwaith adeiladu ar ei anterth. Mae HNP yn cynnig un safle parcio a theithio. Ni fyddai’n lleihau symudiadau cerbydau nac yn lliniaru’r broblem parcio anghyfreithlon ar draws Gwynedd. Gallai adeiladu campws y safle fesul cam liniaru rhai o’r effeithiau ar y farchnad dai a lleihau traffig. Mae’r Cynllun Fesul Cam(cyf.8.24) yn nodi y bydd y gwaith wedi’i gwblhau erbyn Blwyddyn 5 pan fydd tua 5,000 o weithwyr. Gall yr effeithiau ar y priffyrdd eisoes fod yn amlwg. Mae’r SLlG (WAS)(cyf.8.4) yn nodi y bydd gofyniad GCD(DCO) ar gyfer cyflenwi’r campws. Ni chyfeirir at hyn yng ngofynion DCO (WN17-25). Mae’r SRhG (WMS)(cyf.8.5) yn ymrwymo i sicrhau cyfradd ddeiliadaeth uchel ar y campws. Sut gellir gorfodi’r ymrwymiad hwn? Mae angen ymrwymiadau i fonitro lle bydd gweithwyr yn byw a sut byddant teithio. 3. Iaith Gymraeg a Diwylliant Mae mesurau sydd wedi’u cynnwys yn y AEIG(WLIA) (cyf.8.21) wedi’u lleihau, yn llai clir a phendant. Ymddengys bod hyn yn diystyru safbwyntiau rhanddeiliaid. Mae angen ymrwymiad i fonitro a gweithredu mesurau yng Ngwynedd. Byddai cynnal adolygiad hanner-ffordd yn rhy hwyr i liniaru’r effeithiau fydd, o bosibl, eisoes yn digwydd. 4. Gwasanaethau Cyhoeddus a Nodweddion Cymdeithasol Ni ddarparir llawer o wybodaeth yngl?n â sut bydd anghenion yn cael eu bodloni. Nodir AEI(HIA) (ref.8.19) bod darpariaeth gofal yn fater sy’n gofyn am gynllunio manwl. Er bod yr Asesiad yn cyfeirio at ddarparu cyfleusterau iechyd ar y safle, nid yw’r GCD(DCO) yn sicrhau eu darpariaeth. 5. Marchnad Lafur Cefnogir defnyddio targedau cyflogaeth leol. Rhaid i bartïon gydweithio i sicrhau bod llafur lleol yn cael ei ddefnyddio i’r eithaf. Dylid ymestyn a mwyhau gweithgareddau’r farchnad lafur leol cyn gynted â phosibl. Dylid cynnal trafodaethau gyda’r ADN (NDA) a BAM Eryri (EZB) i ystyried sut gall y prosiect gyfrannu at weithlu niwclear ardal Meirionnydd. 6. Cadwyn Gyflenwi Croesawir Siarter y Gadwyn Gyflenwi. Dymunir gweld mwy o weithgarwch i ddatblygu’r gadwyn gyflenwi ranbarthol. Mae angen targedau ar gyfer cynnyrch a gwasanaethau lleol a Chymreig. 7. Economi Ehangach Er y bydd effeithiau cadarnhaol, efallai na fydd rhai busnesau a sefydliadau lleol yn elwa. Mae’n bosibl y bydd effaith tymor hir ar y diwydiant twristiaeth. Ymddengys bod HNP yn ymwybodol o’r effeithiau posibl ar dwristiaeth ond mae diffyg ystyriaeth o effeithiau anuniongyrchol ac eilaidd y datblygiad ar elfennau eraill o’r economi ehangach Gogledd-orllewin Cymru. ------------------------------------------------------------------------ 1. The Housing Market The site campus is proposed to mitigate significant effects upon the local housing market. Phasing must be flexible to meet demand or to respond to variations in the make-up of the workforce. Measures are required monitor effects upon Gwynedd and to implement mitigation. Current rental prices are unaffordable to some. Increases will affect vulnerable residents. A displaced population could exacerbate social problems. The Council has had no specific discussion on the Housing Fund. 2. Transportation and Road Infrastructure Vehicle movements must be managed and arrangements will be required when Menai Bridge is closed. County highways currently suffer illegal parking. This situation may be exacerbated particularly at peak construction. HNP proposes one park and ride site. This would not reduce vehicle movements nor address illegal parking across Gwynedd. Appropriate phasing of the site campus could address some effects upon the housing market and reduce traffic. The Phasing Plan (ref 8.24) provides for its completion by Year 5 when there will be approximately 5,000 workers. There may already be highway effects. The WAS (ref. 8.4) states that there will be a DCO requirement for campus delivery. There is no reference within DCO requirements (WN17-25). The WMS (ref. 8.5) provides a commitment to high levels of campus occupancy. How can this commitment be enforced? Commitments are needed to monitor where workers are living and how they are travelling. 3. Welsh Language and Culture Measures contained within the WLIA (Ref. 8.21) have been reduced and are now less clear and definitive. Horizon’s amendments appear to disregard the views of stakeholders. A commitment to monitor and implement measures in Gwynedd is required. A potential mid-way review could too late to address effects already be occurring. 4. Public Services and Social Characteristics The documents provides little information on how needs will be met. For example HIA (ref 8.19) states that care provision is a matter for detailed planning. Whilst the HIA refers to the provision of on-site health facilities there is an absence of a DCO requirement to secure delivery. 5. The Labour Market The use of local employment targets are supported and all parties must work together to ensure that local labour is maximised. Local labour market activities should be extended and escalated as soon as possible. Discussions should be held with the NDA and the Snowdonia EZB to consider how the project could contribute to maintaining the nuclear workforce of the Meirionnydd area. 6. The Supply Chain The Supply Chain Charter is welcome. The Council wishes to see additional activity to develop the regional supply chain. Targets for local and Welsh produce and services are required. 7. The Wider Economy Whilst there will be positive effects, some local businesses and organisations may not benefit and there is the potential long-term effect on the tourism industry. HNP is aware of potential effects upon tourism but there remains a lack of consideration of the indirect and secondary effects of the development on other elements of the wider economy of North West Wales. "
Non-Statutory Organisations
Danish Emergency Management Agency (Beredskabsstyrelsen) (Danish Emergency Management Agency (Beredskabsstyrelsen))
"I want to follow up on safety functions implemented or not at the Wylfa site"
Members of the Public/Businesses
Humphreys Waste Recycling Ltd
"Humphreys Waste Recycling Ltd is a local family run business trading in Caergeiliog and Bryngwran. The business is based less than one mile from the proposed Dalar Hir Park and Ride facility. The documents in 6.6 of the Development Consent order do not mention the businesses based in the locality or the village of Bryngwran which will be affected. It does not make any reference to the facilities available in Bryngwran. We are a local family run business who employ local people The park and ride facility will have an affect on our business due to its locality and the increased level of traffic on the A5, A55 and the Dalar Hir Area. The construction phase and following construction of the park and ride might cause delays for my business and traffic from Bryngwran. How will the increased pollution levels be monitored? How will the traffic both cars and buses be controlled? what will be the hours of work for Horizon workers? When are the shift times? How will this affect my HGV vehicles and commercial vehicles driving on the A5 towards Dalar Hir. How will Horizon ensure that there is not a detrimental effect on local businesses? The people in Bryngwran travel to Holyhead via the A5 passed the Dalar Hir Park and ride facility. We are concerned that there will be increased traffic, delays and that the roads will be dangerous and congested which could impact HGV and commercial vehicle movments to and from site during our operational hours . How will Horizon support local businesses if their current staff move to work for Horizon? "
Non-Statutory Organisations
Jesse Hughes Youth Club
"We are a group of young people who go to Jesse hughes youth club in Holyhead Will local people get jobs? More people moving to the area - Building more homes More people coming to visit the island and see the projects - an increase in tourists More kids in schools More traffic on the roads Slower journeys due to an increase in traffic on the roads Noise / pollution / dust / lighting Questions to Horizon Will we be able to see the archaeological finds? How much pollution will be in the air? Is it a risky process? How much does it cost in total? How will delays in the timeline be managed? How will the sea / water quality be affected? Will there be a visitor centre? Will the visitor centre be interactive? What will happen to the current Wylfa? What kind of job opportunities will be available? How will electricity supply be managed during construction? Will you be providing Welsh lessons / encouraging people who move here to learn Welsh? How will you make sure that young people are trained to be able to worl there? What types of jobs will be available? "
Members of the Public/Businesses
Ysgol Uwchradd Caergybi
"Holyhead School Council What do IACC need to think about? More people moving to the area - Building more homes More people coming to visit the island and see the projects - an increase in tourists More kids in schools More traffic on the roads Slower journeys due to an increase in traffic on the roads Noise / pollution / dust / lighting Questions to Horizon Will we be able to see the archaeological finds? How much pollution will be in the air? Is it a risky process? How much does it cost in total? How will delays in the timeline be managed? How will the sea / water quality be affected? Will there be a visitor centre? What will happen to the current Wylfa? What kind of job opportunities will be available? How will electricity supply be managed during construction? Will you be providing Welsh lessons / encouraging people who move here to learn Welsh? How long until Anglesey will benefit from the development? How will it affect other counties in the area? "
Non-Statutory Organisations
National Trust
"Introduction The National Trust owns 482ha of land and seashore in North Anglesey, including land immediately adjoining the development site. The Trust also owns land at the adjacent Cemlyn lagoon. All land is held inalienably; such land cannot be voluntarily sold or compulsorily purchased against the Trust's wishes without special parliamentary procedure. The Trust has a statutory duty to promote the permanent preservation of these properties for benefit of the nation-for ever for everyone. The Trust does not object to the principle of Wylfa Newydd. However we do not support proposals that would seriously damage the integrity and beauty of our coastline and wider landscape. We believe that the location and design of all energy schemes should take account of the full range of environmental considerations. Cemlyn lagoon is an internationally designated protected area and one of the most important sites in the UK for breeding Sandwich terns. We welcome the opportunity for critical examination and scrutiny of the proposals. National Trust staff, visitors and tenants, like many of our neighbours will suffer a decade of severe construction disturbance. The project also brings with it the potential to significantly degrade the high quality environment of North Anglesey. The Trust’s concerns are summarised below: Coastal Change and the Marine Environment The application will result in the direct loss of 30ha of marine seabed and intertidal habitat and permanent damage at Porth y Pistyll together with the deterioration in the quality of two waterbodies in North Anglesey. Horizon’s proposals for marine enhancement and compensation are inadequate. We wish to see scrutiny of the derogation tests under the Water Framework Directive and to question the conclusions of the hydro-geomorphology, hydrodynamics and wave dynamic information contained in the application. The Impact on Cemlyn Lagoon The viability of the tern breeding colony relies on the retention of the shingle ridge which protects the breeding islands. The Natura 2000 vegetation and saline lagoon are themselves also sustained by the presence of the shingle ridge. The conclusions of the HRA are extremely uncertain and not ‘beyond scientific doubt’. The lagoon and the breeding terns have SAC, SPA and SSSI designation; the highest level of protection, which demands the highest levels of safeguarding. Construction risks significant potential impacts to Cemlyn lagoon through noise, surface water discharge, predator displacement, change in foraging dynamics and the recreational activities of construction workers. The resilience of Cemlyn lagoon and the Sandwich Tern colony has not been adequately considered and insufficient mitigation and compensation is proposed. The marine modelling does not adequately assess the potential long term change to Cemlyn lagoon as a result of the breakwater construction. National Trust considers that a full compensation package should include: compensation sites provided in a state of ecological readiness in advance of all works; consideration of site resilience and compensation measures in the extant tern breeding colonies within the Irish Sea metapopulation of Natura 2000 sites. Impact on the Landscape The application proposes a decade of construction landscape impact, inadequately illustrated or assessed within the application. The application provides insufficient detail to be able to assess the harm to, or evaluate the mitigation for, an area of particular sensitivity containing: • Anglesey AONB; • Three listed buildings and their settings (Felin Gafnan, Corn drying building and Mill house); • A registered park and garden and its essential setting (Cestyll Garden); • What will become the sole visitor access to Cemlyn Bay and lagoon; • The closest residential property to the Power Station site. Landscape harm in and adjoining the Anglesey AONB is underestimated and inadequate mitigation and compensation is proposed. Impact on Heritage Assets The National Trust has responsibility for three listed buildings which adjoin the proposed harbour, including Felin Gafnan a Grade II* mill. The application lacks detail in order to assess fully the impact of the proposal. The application does not give sufficient weight to the heritage assets and an inadequate level of mitigation and compensation is proposed. We wish to see examination of the archaeological mitigation and query the marine archaeological assumptions concerning Porth y Pistyll and Porth y Felin. The Impact of Construction on Amenity The National Trust has two tenanted properties (Felin Gafnan and Tyddyn Sidney) adjoining the construction site which will be impacted by dust, noise, vibration and lighting. There has been insufficient assessment of the effects on residents during construction or operation. An inadequate level of mitigation and enhancement is proposed. The Future for Landscape and Biodiversity The proposed Landscape and Habitat Management Strategy provides an inadequate level of detail, commitment or certainty in the quality of the future landscape. There is lack of clarity regarding “no net loss”/”net gain” of biodiversity. Inadequate consideration is given to the impacts of construction tourism, with the need to consider the impact on Trwyn Pencarreg maritime heath and footpath erosion adjoining Porth y Pistyll. The scheme does not adequately mitigate and compensate for the proposed change to the environment. The application, including the Landscape and Habitat Management Strategy, is too narrowly focused on land within the Development Order boundary and fails to make adequate connections with the adjacent landscape. National Trust land The application documents are unclear as to whether National Trust land will be subject to compulsory acquisition and, to the extent that any land in which the National Trust has an interest will be acquired, the National Trust objects. Conclusion The application brings uncertainty about the level of degradation that will be experienced in relation to the landscape, environment and heritage of North Anglesey as a result of the construction of Wylfa Newydd. The National Trust is concerned about the level of detail, commitment or certainty by Horizon to a high quality environment with the provision only of “illustrative” and “indicative” proposals. The National Trust is concerned about the lack of detail in relation to environmental monitoring. The National Trust remains concerned about the lack of resilience measures for Cemlyn lagoon, degradation of the marine environment and an overarching approach that does not adequately mitigate and compensate for the scale of change to the environment that is proposed. "
Members of the Public/Businesses
Wood Environment & Infrastructure Solutions UK Ltd on behalf of North Anglesey Council's Partnership
"The North Anglesey Council’s Partnership (NACP) is a partnership of local Community Councils who are interested in the effects of the Wylfa Newydd proposals on a range of issues which would affect all of the Community Council areas. In addition, some of the Community Councils may also be pursuing interests in topics that are particular to them, rather than the whole NACP area. The relevant Community Councils will be registering independently to make representations on these issues. The subjects that NACP wish to make representations on are: 1. Impact on Welsh language and culture from the large number of non Welsh speaking workers and their families from outside of the area. 2. Effects on the highway network and its users from: a. The number and types of vehicles using the highway network. b. Minor, local roads being used as shortcuts. c. Uncontrolled car parking in the locality. 3. For local workers and contractors to be prioritised in order to maximise the benefits achieved in the local area. 4. Concern over long construction working hours of workers and the implications on productivity and subsequent delays to construction, impact upon worker health and an increase in accidents both in the workplace and during travel to/from work. 5. The impact from the temporary construction workers accommodation due to a. The plan to accommodate a large number of temporary workers on a single site adjacent to small villages, and the impact on local communities and services. b. The missed opportunity to provide legacy benefits resulting from the single campus site proposals, and from not promoting Rhosgoch as an additional site. c. The reduction in availability of local rented and tourist accommodation. 6. The disturbance to local residents from the construction activities, in particular from vibration, dust/air quality, noise and light pollution issues. 7. The effect on tourism, the Welsh Coast Path and public rights of way in the area from construction and traffic impacts. "
Members of the Public/Businesses
Brian Williams
"I object to the building of accommodation near 'Swimming Gala Bay' and Wylfa Headland to house up to 5,000 people. I object to the fact that the facilities built within the site for accommodation will have a negative affect on local business and deter contractors from using local services which need support. I object to the proposed plans to use up all 'local beds' for contractors. While this will support local hotels, bed and breakfasts and private letting companies, it will have a serious negative effect on tourism in the area. I object to the building of a new breakwater on the basis it may be built during nesting season for birds in Cemlyn. The breakwater should be built outside of nesting season and, so far as reasonably possible, no work causing excessive noise should be undertaken during nesting season. I object to the creation of several 'ponds' in the area around Penrhyn, Tregof Isaf and Ystad Park Lodge area on the basis that they could become a breeding ground for horseflies and mosquitoes. "
Members of the Public/Businesses
M Flooks
"The land will be spoilt beyond recognition The change is going to have a huge impact on the environment in a negative way The incoming sea freight and the extra building associated with it will have an impact on sea life, the birds that nest at Cemlyn disturbed and maybe losing Anglesey's Bird, The Tern forever. Doubtless it will have an impact on other birds including the Puffin, Guillemots and other birds which Currently it is possible to watch dophins, seals and porpoise locally, there is a good chance this will be lost because their food cycle will disappear."
Members of the Public/Businesses
Rosemary Jones
"I do not believe that the Wylfa Newydd Development should be allowed to destroy this area of outstanding natural beauty and the environment that is of utmost importance to local nature. Renewable energy sources are becoming cheaper as well as more advanced technologically, and environmentally less intrusive. Nuclear power is old technology that creates significantly undesirable, and long lasting waste. Adding insult to injury, the proposal to build temporary worker accomodation on the greenfield site close to Wylfa Head and the iconic Anglesey coastal path is abhorrent. There are plenty of brownfield sites on Anglesey where these could reside. Horizon and anyone who thinks these propsals are acceptable need to have a serious rethink. "
Members of the Public/Businesses
response has attachments
Brigitte Artmann
"Dear Madam, Sir. I'm the communicant of ACCC/2013/C/92 , Germany, Hinkley Point C. My reason is public participation in the context of the Aarhus Convention as possible public concerned. I'm the reason why the British Government opened an EIA procedure HPC in Germany after the original British EIA procedure was closed and building permit was given. The new planned nuclear power plant can possibly affect me. See flexRisk project BOKU Vienna. Kind regards, Brigitte Artmann"
Members of the Public/Businesses
Coed Cottages on behalf of Coed Cottages
"Disruption to our existing Holiday Complex (loss of Business) Light, Noise and Dust Mitigation Traffic Issues Influx of Contract Workers to local amenities"
Members of the Public/Businesses
Menter Iaith Mon
"Ymatebwn fel y prif gorff cynllunio a hyrwyddo defnydd y Gymraeg ym Môn. Rydym wedi ymrwymo i gyflawni amcanion y llywodraeth o filiwn o siaradwyr Cymraeg erbyn 2050 ac ystyriaethau Deddf Llesiant Cenedlaethau’r Dyfodol (2015). Hoffwn felly gofrestru fel parti a buddiant yn y cyd-destun hwn. Gwelwn fanteision wedi eu hamlinellu, adnabyddiaeth o heriau pwysig a chamau lliniaru gwerth chweil, fodd bynnag mewn cyd-destun ieithyddol, erys pryder nad yw’r datblygwr yn cydnabod effaith y datblygiad mewn graddfa a chanrannau fyddai’n datgelu pa mor agos i’r newid andwyol (‘tipping point’) yr ydym ym Môn. 1.Yn fras gall 9000 o weithwyr ar ynys o 70,000 boblogaeth ble mae 57% yn siarad Cymraeg olygu 10% yn fwy o siaradwyr di-Gymraeg gan wneud y Gymraeg yn iaith leiafrifol. O ran datblygu ieithyddol mae cymuned gyda llai na 70% o siaradwyr Cymraeg yn galw am rhagweithio i gynnal yr iaith, a dyma, gydag adnoddau prin iawn, yw ein rol ni. 2.O ystyried y pryderon lleol am yr uchod, ni ystyriwn fod yr Asesiad Effaith a’r camau lliniaru yn cyfiawnhau casgliad y datblygwr: “O bwyso a mesur, mae effaith gyffredinol Prosiect DCO Wylfa Newydd ar y Gymraeg a’i diwylliant yn cael ei hystyried yn effaith niwtral.” 3.Yn ychwanegol mae, diffyg manylion, geiriau amwys, diffyg ymroddiad pendant o ran rhaglen, buddsoddiad rhagflaen, a threfn monitro wrthrychol yn ei gwneud yn anodd ymateb yn llawn. 4.Mae angen i’r Asesiad Effaith adlewyrchu polisïau cyfredol ee gwaelodlin: Yng nghyd-destun Cymraeg 2050, Deddf Llesiant, polisïau addysg CSYM, gwaith cynllunio a hyrwyddo iaith asiantaethau megis Menter Iaith Mon/Mudiad Meithrin/yr Urdd ayb, felly rhaid ystyried y potensial twf siaradwyr Cymraeg. 5. Yn eisiau hefyd yw’r data ar effaith y datblygiad ar siaradwyr Cymraeg yng nghyd-destun ymchwil defnydd a throsglwyddo iaith. 6. Yn benodol am y mesurau lliniaru nodwn: • Gweithle ee 1-5, 6, 8. Angen camau i sicrhau gall siaradwyr Cymraeg drafod eu gwaith yn y Gymraeg mewn maes arbenigol gan gynnwys cyfieithiadau o ddogfennau technegol i’r Gymraeg, cadernid i gynnwys Polisi Iaith, data / mesurau i leddfu pryder lleol am golli staff Cymraeg ac allfudo siaradwyr Cymraeg wedi cyfnod o waith byrdymor. • Ymwybyddiaeth ee 12, 18, 20. Angen diffiniad o hyfforddiant ag ymwybyddiaeth, pa mor systematig, hefyd pa gamau penodol i wireddu ‘mewnfudwyr i ddod yn rhan o’r gymuned’ gyda goblygiadau hyn ar fuddsoddi mewn gwersi Cymraeg, cefnogaeth gymunedol a chyfieithu cymunedol ehangach. • Addysg ac oed cyn-ysgol ee 13, 16, 19. Nid yw’r data yn dangos y diffyg capasiti ar hyn o bryd i gyflawni’r nod. Mae’r drefn gynllunio yn wallus a g?yr y datblygwyr hyn o’r adborth yn y Gr?p Llywio a’r Fforwm Iaith. Nid yw’n ddigonol i gynnig adnoddau ar ôl ymddangosiad y disgyblion. Rhaid ymrwymo i amserlen o fuddsoddiad rhagflaen mewn hyfforddi athrawon arbenigol a darparwyr gofal plant all drochi yn y Gymraeg. Rhaid hefyd buddsoddi mewn lleoliadau a chynnal a chadw’r safleoedd trochi heb ddisgwyl i CSYM sybsideiddio hyn ar ran y datblygwyr. Rhaid sefydlu’r egwyddor o fuddsoddi rhagflaen er mwyn cynllunio ieithyddol. • Monitro "
Members of the Public/Businesses
Christopher Wilson
"My concerns about the Wylfa project are:- Environmental- the site is adjacent to a SSSI and SPA which are likely to suffer from the construction and then subsequent operation of the Nuclear Power Plant(NPP). Particular concerns relate to the tern colony and changes to the sea flows due to construction of jetties etc. No mitigation could be expected to rectify the damage caused. Radioactive waste- no new NPP should be constructed until there is a proven and available safe method for storage of the waste. - full provision for the costs of decommissioning and subsequent storage need to be borne by the NPP operator Financing - as a tax payer I do not want to fund any NPP and do not want tax payers to be put at risk by accepting any financial risk due to a nuclear accident. The principle of "polluter pays" must apply. - as an electricity bill payer I want the cleanest and cheapest supply and nuclear is neither Safety - Hitachi have a very poor safety record so should not be allowed to operate a NPP in the UK Health- there are recent studies showing the link between low level radiation and health risks(particularly to unborn and very young children) Jobs - more employment opportunities would arise from an equivalent investment in renewable technologies( without the health and financial risks) which do not leave toxic radioactive waste for future generations to deal with Carbon footprint - a NPP has an extremely high carbon footprint prior to operation due to the manufacture and supply of building materials and the construction and from the mining, milling and processing of uranium. Therefore this could prevent the UK meeting its carbon targets over the next 10/15 years. "
Members of the Public/Businesses
Linda Rogers
"1) The NPS 2011 does not necessarily mean that Wylfa should be the site for a new nuclear build: other sites identified have less impact on protected habitat, AONBs and SSSIs. 2) Site preparation should not be included in the DCO 3) The area cannot be returned to anything near its original state, with for example the demolition of ancient forest 4) The site, covering an area eleven times the original Wylfa site, will damage the historical, cultural and environmental integrity of the island.This includes detrimental impact on use of the Welsh language. 5) Other industries, such as tourism, will be damaged by the new build. 6) Massive building works will interfere with the everyday health and well-being of residents and visitors to the island. This will include noise, air and visual impact, as well as disruption to traffic. 7) The vast majority of jobs will go to incoming workers. The island does not have the infrastructure to cater for up to 10,000 incomers. 8) Waste left on site from Wylfa B will have to be stored for up to 140 years before it can be moved - and beyond if there is no GDF available. 9) There should be no new nuclear build anywhere whilst the question of long-term storage remains undetermined. 10) The impacts of climate change, including flooding, storm surge and the heating of oceans are rendering new nuclear a progressively dangerous option, as opposed to being the answer to climate change as proposed by some people. 11) The cost of new nuclear prevents investment in other more suitable sources of power. Anglesey does not need new nuclear either to meet its carbon targets or to provide its energy."
Members of the Public/Businesses
Thomas Hecht
"1. Basic data of the project 2. EIA procedure New construction of Wylfa Newydd nuclear power plant 3. Reactor type 4. External events 5. Heavy accidents 6. Justification of the demand and alternatives to the planned new nuclear power plant / climate protection 7. Liability for nuclear damage 8. Disposal of accumulating nuclear waste"
Members of the Public/Businesses
Umweltinstitut Munchen e.V.
"Hereby I to submit the registration of Umweltinstitut München e.V. (Munich Environmental Institute) as an interested party. As a preliminary remark, we consider the current procedure of transboundary environmental impact assessment violates the binding rules of the Aahus and Espoo conventions. The registration procedure in particular has been stated to be in non-compliance in the negotiations following the case ACCC/C/2013/92 Germany. Further, for a proper transboundary consultation it is obligatory (and extremely helpful) to receive documents in German language. Despite these formal deficits, we comment on the project under consideration. The Umweltinstitut München e.V. (Munich Environmental Institute) is rejecting the plans to construct the Wylfa Newydd nuclear power plant in Angelsey North Wales, because realising the project would pose a serious threat to the British and the German public. A potential nuclear accident can’t be excluded, and the released radioactive material would not stop at national borders. Further, the planned capacity of up to 3100 megawatts will not even be needed in the future energy mix. A transition to renewable energy, combined with energy efficiency measures is far more effective, as the National Infrastructure Committee has confirmed in July 2018. Recent developments at Hinkley Point C and Wylfa Newydd prove that Nuclear power is not sustainable without substantial public subsidy. Lastly there is no secure method of disposing nuclear waste, particularly since the Swedish concept shows severe deficits of quickly eroding containers. It is thus in public interest to prevent piling up even more nuclear waste. These arguments speak for cancelling the plans for building a new nuclear power plant in Wylfa, and invest into renewables instead. Further arguments may be added in the full document for the environmental impact assessment, as well as in potential hearings."
Members of the Public/Businesses
National Assembly for Wales on behalf of Mandy Jones AM
"This is just to register that we would like to send comments on any future planning proposals. We are currently commenting on environmental permits and marine licence application. In doing so your representatives have indicated we must register here to be able to take part in further responses of a plnning nature. Thank you."
Members of the Public/Businesses
Mudiad Meithrin
"Fe fydd y Mudiad Meithrin yn gwneud sylwadau mewn perthynas a'r iaith Gymraeg, y galw am ofal ac addysg blynyddoedd cynnar cyfrwng Cymraeg, a'r dilyniant i addysg Gymraeg. Cymdeithas wirfoddol genedlaethol o Gylchoedd Meithrin, cylchoedd Ti a Fi, gofal cofleidiol a meithrinfeydd dydd Cymraeg yw Mudiad Meithrin. Y Mudiad yw’r darparwr gofal ac addysg blynyddoedd cynnar cyfrwng Cymraeg mwyaf yn y sector gwirfoddol yng Nghymru. Sefydlwyd y Mudiad ym 1971 gydag oddeutu 50 cylch. Erbyn hyn, wedi tyfu’n aruthrol, mae tua 1000 o Gylchoedd Meithrin, Cylchoedd Ti a Fi, grwpiau ‘Cymraeg i Blant’ a meithrinfeydd dan faner Mudiad Meithrin. Mae’r rhain yn darparu profiadau blynyddoedd cynnar i oddeutu 22,000 o blant yn genedlaethol bob wythnos. Yn ogystal, mae’r Mudiad yn gweithio yn agos iawn gyda rhieni er mwyn darparu cymorth a chyngor i’w galluogi i ddatblygu a chefnogi gwaith y cylchoedd yn y cartref. Er mwyn cyflawni hyn, mae Mudiad Meithrin yn elusen gofrestredig sy’n cyflogi dros 200 o bobl yn genedlaethol, gyda 2000 ychwanegol yn gweithio yn y cylchoedd eu hunain. Cefnogir y cylchoedd gan rwydwaith cenedlaethol o staff proffesiynol sy’n eu cynghori ar amrediad o faterion er enghraifft hybu ymarfer da, hyfforddiant staff a chyswllt ag Awdurdodau Lleol. "
Members of the Public/Businesses
Mark Bennett on behalf of residents of Plas Ellen
"We OBJECT to the scheme on the following points- 1. Noise from increased traffic on A5025 2. Visual impact & noise from proposed bypass 3. Closer proximity to our property, of proposed bypass Our property adjoins the A5025 and includes a Camping & Caravanning Club certificated site field which overlooks the A5025. This proposed scheme will impact our business, which has made a positive contribution to the tourism of the island since 2006, having received good reviews & many returning tourists. Also of course the noise & visual impact will affect us, the residents of Plas Ellen - our main aspect is west, facing the A5025 If this scheme is approved to go ahead, we insist that the planners address these issues, possibly with noise abatement barriers to the east side of the A5025"
Members of the Public/Businesses
Ysgol Uwchradd Bodedern
"Pryder bod maes parcio i ddal dros 1,700 o gerbydau wedi cael ei gynllunio ar gyfer Dalar sydd nepell o bentref Bodedern. Ym mhentref Bodedern mae dwy ysgol - cynradd ac uwchradd. Lon gul sy'n mynd drwy'r pentref - lon sydd eisoes yn ofnadwy o brysur gyda thractorau a bysiau ysgol. Byddai cael 1,700 o geir yn ceisio cyrraedd y maes parcio swyddogol yn rhoi pwysau ychwanegol ar y pentref ac yn creu peryglon i blant, pobl ifanc a thrigolion y pentref heb son am niweidio'r amgylchedd. Os bydd trogylch ychwanegol yn cael ei adeiladu ar yr A55/ A5 mae am greu anghyfleuster mawr i drigolion lleol a'r gweithlu sydd eisiau teithio i'w gwaith yn y pentref. Nodwyd mewn un adroddiad mai dim ond tua 220 o blant y disgwylir iddynt gyrraedd ysgolion yr Ynys yn sgil datblygiad Wylfa. Yn sgil y niferoedd sydd wedi cychwyn symud i'r ardal eisoes gellir herio'r nifer isel hwn. Mae angen ystyried o ddifri y pwysau ar wasanaethau cyhoeddus a'r bygythiad i'r iaith Gymraeg. Mae'r unedau iaith cynradd yn orlawn a nid oes uned iaith uwchradd - rhaid sicrhau un yn awr er mwyn ateb y gofyn. "
Members of the Public/Businesses
Bethan Roberts
"As a local resident within 5 miles of development, I wish to submit my representation to be able to examine and comment on the provision of accommodation for workers within the area, impact on tourism and use of existing accommodation/property within area to accommodate workers / contractors. "
Members of the Public/Businesses
Ernie Brown
"Sir/Madam, Your plan to proceed with Wylfa nuclear station is wrong - It is costly compared with renewable alternatives including base load alternatives (tidal*) It's life span is short compared with tidal alternatives - thirty years compared with over a century. It will require the provision of dangerous fuel which itself will need to be safely stored for the foreseeable future. The site will also require sophisticated and costly de-commissioning at the end of its life. The site is a prime target for terrorist activities. It will be mainly be financed from outside this country. It will use untried technology ( if Hinckley Point is anything to go by ) which has resulted in serious delays and has not been proved to work yet. * Tidal power ( the Swansea Lagoon ) addresses all the problems above and more. Despite misleading reports it will provide near base load ability. If combined with a similar scheme on the Solway continuous substantial amounts of power would be available. "
Members of the Public/Businesses
Grwp Llandrillo Menai
"* The need for greater, and earlier, information regarding skills requirements in differing areas - timelines, expertise required, numbers etc * Increased collaboration on identifying the training/skills/courses required for differing cohorts of potential employees to allow training/education providers to plan and prepare appropriately, particularly during the construction phase * The need to revisit the previous stance of the intention to employ as many suitably qualified/skilled employees as is possible * The need to work with local supply chains to ensure an ongoing benefit for individuals, companies and the regional economy * The impact of the inevitable problems raised by displacement of staff from current employers to companies working on the Wylfa Newydd build - a need for a positive programme of work with local companies to improve their ability/capacity to tender for work in the supply chain, hence strengthening the local companies and economy on a more mid-long term basis"
Members of the Public/Businesses
Gwynedd Archaeological Planning Service
"Gwynedd Archaeological Planning Service (GAPS) represents the historic environment interests of North West Wales. GAPS provides advice to the Local Planning Authority (Isle of Anglesey County Council) on the archaeological implications of developments on the island and we have been monitoring the ongoing programme of archaeological work associated with this project over the last 9 years. The archaeology of Anglesey is rich and the impacts of a proposal of this scale on both upstanding Historic assets as well as below ground archaeological remains will be substantial. In general, it is expected that GAPS' representation will be through the advice to the local planning authority, however, it might also be necessary for GAPS to make independent representation on the DCO which is why we are registering as an interested party."
Members of the Public/Businesses
Anheddau CYF
"Anheddau Cyf is a third sector employer in the Anglesey area and has an interest in any impact the development of Wylfa B nay have on local recruitment and retention of care staff"
Members of the Public/Businesses
Clare Norlander
"Section 2.3.1 of EN-5 states “… the Planning Act aims to create a holistic planning regime so that the cumulative effects of different elements of the same project can be considered together. Therefore the Government envisages that applications for new generating stations and related infrastructure should be contained in a single application. National Grid and Horizon have not done this, and have not considered one project mitigating impacts of the other. Horizon could bury the connection for only 3% more budget _______________________________________________________"
Members of the Public/Businesses
Helen Ralston
"To see how the new plant will affect the local environment as well as the local village and the local economy and jobs. "
Members of the Public/Businesses
Pinsent Masons on behalf of Land and Lakes (Anglesey) Limited
"We act on behalf of Land and Lakes (Anglesey) Limited ("LL"). LL has a longstanding interest in the Wylfa Newydd Project ("Project") as the beneficiary of planning permission (reference 46C427K/TR/EIA/ECON) authorising the delivery of worker accommodation for up to 3,500 nuclear construction workers at the Cae Glas and Kingsland Sites at Holyhead (all owned by LL), approved with a legacy of affordable housing and holiday leisure uses ("TCPA Consent"). The TCPA Consent remains extant and the sites are available for the delivery of the scheme. LL has been fully engaged throughout the consultation for the Project including attending various stakeholder meetings and responding to the 3 stages of pre-application consultation ("PAC1, 2 and 3"). LL raises the following concerns regarding Horizon’s Worker Accommodation Strategy (‘WAS’) :- 1. Inadequacy of PAC3 & lack of empirical evidence in support of the ‘WAS’ in the DCO a. PAC3 represented a significant departure from that which gained widespread support during PAC 1 and 2 and underwent a short 4 week consultation with inadequate evidence to support the proposals. b. LL’s proposals for delivery of worker accommodation pursuant to the TCPA Consent were the subject of nearly 4 years of consultation to ensure that they fulfilled the aims of IoACC planning policy and guidance as well as secure important legacy benefits for the region. By contrast the ‘WAS’ is based on no empirical evidence and will have significant long term damaging impacts on the region. 2. Lack of Policy Support - The Anglesey and Gwynedd Joint Local Development Plan establishes objectives for a variety of accommodation solutions including purpose built permanent accommodation in sustainable locations, which will enable the delivery of future and legacy uses. LL TCPA Consent delivers on these objectives whereas Horizon’s ‘WAS’ does not. 3. Lack of commitment – Horizon’s ‘WAS’ does not commit to building the necessary accommodation early in the Project but instead relies on 2000 workers commuting distances of up to 90 minutes each way, 3000 workers displacing existing tourist & private rented housing and then assessing further demand before committing to build temporary accommodation on site. Their lack of commitment is because ‘on site’ accommodation is unattractive to workers and there would be no room for the scale of accommodation proposed if more reactors are planned 4. Impact on Tourism, Welsh language & culture – Horizon’s ‘WAS’ will have serious adverse impacts as a result of up to 9,000 workers displacing tourist and private rented accommodation. This will shift the risk of Project onto the region’s tourism industry and displacing families from the private rented sector creating long-term damage. 5. Transport and Road Safety - Compared with LL ‘TCPA Consent’, Horizon’s ‘WAS’ is less sustainable in that it will lead to nearly 1000 more vehicle movements per day and will also increase the risk of road traffic accidents. 6. Failing to deliver long term legacy benefits to the region, compared with LL ‘TCPA consent’ which would deliver significant job growth in the tourism industry and 160 affordable homes. A scheme that minimises impact and maximises legacy at no extra cost to the Project. "
Members of the Public/Businesses
Dafydd Griffiths
"Nid oes cyfiawnhad manwl yn y dogfennau a gyflwynwyd gan yr ymgeisydd o ymdrechion a wnaethpwyd ganddynt i geisio sicrhau fod Llwybr Arfordir Cymru yn cael ei ddargyfeirio i ddilyn yr arfordir a rhedeg i'r gogledd o'r Orsaf B?er Magnox. Mae'r dargyfeiriad arfaethedig yn llawer hirach, bydd y golygfeydd yn llai prydferth a bydd yn cael effaith negyddol ar drigolion ac ymwelwyr sy'n defnyddio'r llwybr. Er bod gwyriad y NCR566 i lawr Ffordd Nanner a'r ffordd wledig ger Bwlch tuag at Lanfechell yn ddargyfeiriad dderbyniol mae lleoliad y groesfan y cyfeirir ato yn y ddogfennaeth naratif yn ddiffygiol. Rwyf wedi dod i'r casgliad o ddarllen yr adrannau priodol o'r ddogfennaeth, bod yr ymgeisydd wedi bod yn amharod i ymateb yn bositif i awgrymiadau ar gyfer datblygu'r seilwaith llwybrau ar gyfer Teithio Egnïol a beicio hamddenol a wnaed gan unigolion a CSYM ar hyd rhannau o'r A5025 a llwybrau allweddol eraill yng ngogledd Ynys Môn. Byddai'r costau cymharol fach o ddatblygu'r seilwaith o fudd i weithwyr adeiladu Wylfa Newydd fydd yn lletya yn lleol. Hefyd, yn etifeddiaeth hirdymor i weithwyr gweithredol Wylfa Newydd, yn caniatáu i blant deithio'n ddiogel i ysgolion lleol ac i drigolion lleol sydd angen defnyddio darnau o'r A5025 rhwng Y Fali ac Amlwch fel cyswllt rhwng ffyrdd a lonydd gwledig."
Members of the Public/Businesses
Dafydd Roberts
"Hoffwn gael sicrwydd na fydd cynllun y “Marine Offloading Facility” yn cynyddu perygl difrod i’r orsaf petae digwyddiad tebyg i “Meteotsunami” yn digwydd yn y Môr Celtaidd. Oes modelu heidrodeinamig addas wedi cymeryd lle? Ydi newid hinsawdd yn cynnyddu risg Meteotsunami neu ddigwyddiad tebyg yn yr ardal? "
Members of the Public/Businesses
Victor Simms
"Please consider the long term (3,000 years) danger of creating more radioactive waste. The Summary of the project: 2. a. allows for storage buildings for such toxic waste with no plan for it's unlikely, safe disposal. "
Other Statutory Consultees
The Corporation of Trinity House of Depford Strond
"Trinity House is the General Lighthouse Authority for England, Wales, the Channel Islands and Gibraltar with powers principally derived from the Merchant Shipping Act 1995 (as amended). The statutory role of Trinity House as a General Lighthouse Authority includes the superintendence and management of lighthouses, buoys and beacons within our area of jurisdiction. Trinity House wishes to be a registered interested party due to the impact the development would have on navigation within Trinity House’s area of jurisdiction. It is likely that we will have further comments to make on the application and the draft Order throughout the application process. "
Members of the Public/Businesses
Zencity Limited
"This outline consists of seven sections: 1) Health and genetic impact of nuclear power in the light of new scientific knowledge. Details will be provided of adverse health effects of nuclear activities over the last seventy years which hitherto have not been acknowledged publicly. These include increased childhood leukaemia around nuclear power plants, health impact of the Chernobyl nuclear accident on Wales and other parts of the UK, increased Down Syndrome in Wales associated with the Chernobyl nuclear accident, long-term genetic implications of additional exposure to manmade radioactive pollution and finally health implications for women of childbearing age working in the nuclear industry. 2) Monitoring the health and genetic impact of the proposed nuclear power station. In view of the present-day uncertainties associated with the health and genetic impact of nuclear power stations, an epidemiological plan will be presented so that observations of possible health impacts will be based on scientific examination and not anecdotal evidence and subject to public scrutiny. These possible health impacts will be examined under the following headings: births, miscarriages, stillbirths, cancers under 25, therapeutic abortions, and births involving chromosome aberrations. 3) Minimising the health, genetic and social impact of the proposed nuclear power station. Details will be provided of what alert mechanisms can be employed to minimise these effects from the proposed nuclear power plant. 4) Examining the impact of new health standards on the future of the plant. The possibility that plans for the development of the plant may need to be shelved in the light of new health standards is discussed. 5) Maintaining investment opportunities if the nuclear power plant plans are shelved. Details are provided for an alternative option within the proposed design of the nuclear power plant so in the event of the power plant’s plans being shelved for health or economic reasons, this alternative may provide an equal amount of electricity as the proposed nuclear option but at a much lower price. 6) Nuclear power, carbon dioxide and global warming. Comparisons are made of the relative contribution of thermal pollution from coal and nuclear plants to global warming, the impact of manmade thermal pollution overall, the relationship between increase in ocean surface water temperatures and the release of carbon dioxide from coal-burning plants and the part played by increased water vapour levels in global warming due to increased ocean surface temperatures. Attention will be given to the opportunities of employing waste heat from the coal-burning option and the part that could be played and the opportunities for sequestering CO2 output. 7) Optimising global conditions. Here, the concept is introduced that sea level temperatures must be actually reduced now in order to prevent a runaway global warming effect due to a positive feedback loop between increased water vapour levels and increased sea surface temperatures. The potential technology for achieving this by the use of wind-driven sea scoopers which transfer colder water from the depths to surface waters is considered to mitigate thermal pollution from either a nuclear or coal plant."
Non-Statutory Organisations
Ministry For The Ecological Transition
"Spanish Ministry for the Ecological Transition would like to participate as an interested party, in the framework of the Espoo and Aarhus Conventions. In our opinion the transboundary screening assessment gives not enough information to make a judgement. Participation in the EIA process could provide valuable information about the spatial extent within marine mammals, turtles and birds could be affected as well as risk scenarios in the case of major accidents. "
Parish Councils
Oldbury PC
"Oldbury on Severn Parish Council are preparing a Neighbourhood Plan to be effective up until 2036. It is felt that as the proposed potential second Horizon Site is in our Parish we have something to learn from the experience gained as Wylfa moves forward. It is not so much we wish to make points re Wylfa but more a matter of understanding the issues that are identified during the Wylfa consultation and the relevance to Oldbury."
Other Statutory Consultees
Public Health Wales
"Public Health Wales has a responsibility to assess population health risks associated with the Wylfa Newydd development. As necessary, as we have done with the Health Impact Assessment work undertaken to date, we can provide expert public health advice on identified risks and support others to act to mitigate them. While Public Health Wales does not intend to make any formal representation at this stage, the organisation (working in collaboration with Betsi Cadwaladr University Health Board) wishes to remain an ‘interested party’ in this process and be kept informed of key developments. "
Other Statutory Consultees
Betsi Cadwaladr University health Board on behalf of Betsi Cadwaladr University Health Board
"Betsi Cadwaladr University Health Board (BCUHB) is responsible for the planning, provision and commissioning of health services for the permanent and temporary residents of North Wales. The issues as an organisation we want examined by the IPC are; 1. Health Impact Assessment-Horizon has not undertaken a Health Impact Assessment specifically on the impacts of the proposed temporary workforce accommodation for 4,000 workers on site. The submitted HIA is based on previous accommodation proposals. 2. Air quality-The Health Board wishes to understand more about how exactly the developer will ensure that there is no deterioration in local air quality (either short or long-term) and how this will be measured, validated and evaluated. 3. Transport-The Health Board has concerns about a number of impacts the development will have on the transport network, including delays to emergency and non emergency ambulance services responses, potential increase in road traffic accidents and delays for patients accessing routine appointments to primary, community and hospital base services. 4. Safeguarding-The potential impact of the development on safeguarding issues and how Horizon intend to mitigate the risks. 5. The impact of the additional temporary workforce involved in the construction phase on the provision and funding of primary, community, mental health, hospital and tertiary health services. The concerns include; a. The scope of occupational and primary health care services planned for the Wylfa site and the necessary accommodation and infrastructure. b. The staffing, training and skill mix implications for the proposed on site services cannot be assessed until the service model is defined. c. The arrangements proposed by Horizon for health services in the period up to the opening of the proposed on-site health facility d. Horizon’s proposals for the operation of health services, it is not clear if they will be privately or publicly run. e. The arrangements for interface with and impact on local and regional NHS services f. The impact on primary care practices where workers choose to use other practices due to geographical, urgency or convenience issues. g. The knock on effect of the temporary workers on community health services, mental health services, emergency and hospital based services both local and tertiary. h. The impact on substance and alcohol misuse services i. The impact on sexual health services j. The impact and costs of family members relocating to the area have not been adequately addressed. k. The impact on dental services has not been adequately addressed. l. The impact on pharmaceutical services and the prescribing and dispensing of drugs has not been adequately addressed. m. The residual impact on NHS services healthcare for workers appear to be underestimated and may be due to the methodology using figures from the Hinkley and Olympic Park development where the wide availability of alternative NHS suppliers permitting self referral may have led to an underestimate of the true impact. n. The GP workforce capacity calculations contained in the socio economic section are out of date and require updating to enable an accurate assessment of the impact on the local health service. 6. The ongoing impact on health services during the operational and de-commissioning stages. 7. Concern that some of Horizon’s planning is based on the planning and modelling work for Hinkley Point C and an English NHS model and does not adequately take into account the local and NHS Wales context. 8. The cumulative impact of the National Grid development on the above. 9. The arrangements for the ongoing monitoring of the health impacts during the building and operational phases. "
Members of the Public/Businesses
Clybiau Ffermwyr Ifanc Ynys Mon
"Mae Clybiau Ffermwyr Ifanc Cymru yn fudiad ieuenctid gweldig dwyieithog i bobl ifanc 10 -26 oed sydd yn gweithredu ledled y wlad. Ar Ynys Môn mae 6 o glybiau ar draws yr ynys, sydd yn cynnig amrywiaeth o raglenni addysgol, hyfforddiant a chymdeithasol, sy'n annog datblygiad personol, gweithgarwch cymunedol ac amgylcheddol a rhynweithiau cymdeithasol i dros 200 o aelodau. Mae'r mudiad yn cael ei arwain gan y bobl ifanc i'r bobl ifanc yn gwbl wirfoddol. Mi fydd datblygiad Wylfa Newydd ar Ynys Môn yn ddatblygiad cyffrous ond yn codi pryderon yng nghefn gwlad: 1. Iaith - pa effaith fydd 9,000 o weithwyr yn ei gael ar yr iaith Gymraeg a beth fydd Horizon yn ei gynnig i liniaru hyn? 2. Tir amaethyddol - a fydd ffermydd yn mynd yn llai a fydd yn cael effaith ar argaeledd gwaith amaethyddol i bobl ifanc, ac o ganlyniad mi fydd rhaid iddynt symud o'r ardal? 3. Gwaith - sut y bydd Horizon yn cefnogi ffermwyr i gadw gweithwyr ar eu ffermydd os bydd Horizon yn cynnig mwy o arian am waith tebyg er enghraifft gyrru tractor/JCB? 4. Gweithwyr - sut y bydd Horizon yn cadw Cymreictod yr ardal a sicrhau diogelwch ein cymunedau/diwylliant cefn gwlad? 5. Amgylchedd - mi fydd y datblygiad yma yn newid tirlun Ynys Môn am byth, sut y bydd Horizon yn sicrhau fod y tir yn cael ei warchod a bod unrhyw ddatblygiad dros dro yn mynd yn ôl i'w safon wreiddiol. 6. Ysgolion lleol - hefo 9,000 ychwanegol o weithwyr ar yr Ynys, faint o'r rhain fydd yn symud yma yn barhaol a pha effaith y bydd hyn yn ei gael ar ein hysgolion, ysbytai, doctoriaid, deintyddion a gwasanaethau cymdeithasol sydd yn barod yn plygu dan bwysa? 7. Dalar Hir - Sut y bydd y datblygiad parcio a theithio yn Dalar Hir yn effeithio Bodedern, Bryngwran, Caergeiliog, a Llanfihangel yn Nhowyn? Mae bysus ysgol yn teithio ar y ffordd ac mi fydd traffig ychwanegol ar y ffordd yn cael effaith ar hyn drwy achosi tagfeydd ac oedi hir. A fydd gyrwyr y bysus ysgol yn cael mwy o arian i yrru bysur Horizon o'r parcio a theithio? Sut y bydd y bysus yma yn cael eu rheoli ar y ffordd? 8. Sut y bydd traffig amaethyddol sydd yn gweithredu yn barod ac yn teithio yn gynnar y bore a hwyr y nos yn ymdopi hefo tagfeydd traffig ychwanegol ar y ffordd? Mae ffermwyr yn gweithio oriau 'off-peak'. 9. Mae'n bwysig fod Horizon yn ystyried materion amaethyddol/cefn gwlad wrth adeiladu/datblygu'r orsaf niwclear newydd. "
Local Authorities
Isle of Anglesey County Council on behalf of David Hughes School
"We are a group of young people who go attend youth clubs in the Menai Bridge Area Will local people get jobs? is there a specific amount of jobs allocated? More people moving to the area - will they be looking for homes to rent out in our area? How close will they need to live form Wylfa Newydd? More people coming to visit the island and see the projects - an increase in tourists More kids in schools More traffic on the roads - Slower journeys over the Menai Bridge as this is already too long - Will another bridge be built? if there is will this have an effect on the tourism in Menai Bridge? Noise / pollution / dust / lighting Questions to Horizon How will they protect young people in the areas where these staff will be living? (child protection) Will all staff members be DBS checked? Will we be able to see the archaeological finds? How much does it cost in total? How will delays in the timeline be managed? How will the sea quality and traffic be managed? Where will all the boats be docking and will they be staying in the middle of the sea for a large amount of time? Will our local schools be able to visit for Educational purpose? will there be any apprenticeships opportunities? What will happen to the current Wylfa? How will electricity supply be managed during construction? Will you be providing Welsh lessons / encouraging people who move here to learn Welsh? What types of jobs will be available? How old will we have to be work at Wylfa Newydd? "
Members of the Public/Businesses
Pam Lee
" _______________________________________________________ Section 2.3.1 of EN-5 states “… the Planning Act aims to create a holistic planning regime so that the cumulative effects of different elements of?the same project can be considered together. Therefore the Government envisages that applications for new generating stations and related infrastructure should be contained in a single application. National Grid and Horizon have not done this, and have not considered one project mitigating impacts of the other. Horizon could bury the connection for only 3% more budget. _______________________________________________________"
Other Statutory Consultees
SP Energy Networks on behalf of SP Manweb
"SP Manweb has no objections or points of disagreement with Horizon Nuclear Power in relation to the application. SP Manweb has the following interests in the Project: a) confirming that Horizon Nuclear Power's Landscape and Habitat Management Strategy has been amended to include reference to SP Manweb electricity network, and b) Protective provisions are still to be agreed between the parties. "
Members of the Public/Businesses
The Representative Body of The Church in Wales
"We would like to make a representation to be kept informed of progress with regard to the application. The scheme may affect land and buildings vested in The Representative Body of The Church in Wales and we would like the ability to make representations if our property will be adversely affected once the finer details of the scheme is known."
Local Authorities
response has attachments
Cyngor Sir Ynys Mon / Isle of Anglesey County Council
"Mae Sylwadau Perthnasol Cyngor Sir Ynys Môn wedi eu hanfon mewn e-bost i [email protected] at y 9fed o Awst,2018 Isle of Anglesey County Council's Relevant Representation has been sent by e-mail to [email protected] on 9th August, 2018 "
Other Statutory Consultees
Office for Nuclear Regulation
"The Office for Nuclear Regulation (ONR) is the principal regulator of the safety and civil nuclear security of the UK nuclear industry. ONR licenses and regulates a broad range of nuclear facilities and activities, and is also responsible for nuclear safeguards and the regulation of transport of radioactive materials. In March 2017, Horizon Nuclear Power Wylfa Limited (Horizon) applied for a nuclear site licence to allow it to install and operate two UK Advanced Boiling Water Reactor (ABWR) reactors at its Wylfa Newydd site; this application is currently being assessed by ONR. The standard nuclear site licence comes with 36 licence conditions and ONR will not grant a licence to Horizon until it is satisfied that the company has adequate, fit-for-purpose arrangements that address all of these licence conditions. The grant of a nuclear site licence will not give Horizon permission to proceed with nuclear-related construction on the site. The licence conditions allow ONR to exercise a number of controls throughout the construction or installation, commissioning and operation of the station. In particular, commencement of nuclear related construction on the site, which ONR defines as the placement of the first structural concrete for buildings with nuclear safety significance, will require a separate permission by ONR granted under one of the licence conditions. ONR may also elect to permission other stages of construction or installation and commissioning. The proposed twin reactor development at Wylfa Newydd is based on the Hitachi-GE Nuclear Energy, Ltd. UK ABWR nuclear reactor design. ONR has completed a Generic Design Assessment (GDA) of this design which led to the granting of a Design Acceptance Confirmation (DAC) in December 2017. Provision of a DAC means that in ONR’s opinion, on a site bounded by the generic site envelope, the generic reactor design could be built and operated in Great Britain, in a way that is acceptably safe and secure (subject to site specific assessment and licensing). The DAC explains that it does not guarantee that ONR will grant permission for the construction of a power station based on the UK ABWR nuclear reactor design at a particular site in Great Britain. That permission will be informed by a site specific pre-construction safety case after a nuclear site licence is granted. ONR also notes that some safety case work is required before a nuclear site licence is granted. For example, focussing on areas not bounded by the DAC. ONR’s licensing work will also take into account the adjacent Magnox Wylfa site ONR has examined relevant parts of Horizon’s Wylfa Newydd Development Consent Order (DCO) application and its supporting documents. At this stage we have no substantive comments. However, we will provide a more substantive representation at the start of the DCO examination phase which will highlight any issues which arise from our further examination of the DCO application, as well as providing a more detailed progress report on our work on assessing Horizon’s application for a nuclear site licence. In addition, ONR will be pleased to provide advice or evidence to the Examining Authority regarding matters identified as relevant in the Nuclear National Policy Statement as well as on any issues relating to our regulatory role or processes which may arise during the Examining Authority’s consideration of the DCO application. "
Parish Councils
Oldbury-on-Severn Parish Council
"The New Nuclear Build Committee of Oldbury-on-Severn Parish Council meets regularly to review developments concerning the plans by Horizon Nuclear Power to build a new power station adjacent to the old one within our parish. The design and development of this plant shows many similarities with the Wylfa Newydd project. Therefore we wish to understand the detailed development of the Wylfa Newydd Nuclear Power Station. We are especially concerned with precedents that may be set that could then apply to the second similar project planned by Horizon Nuclear Power. In particular we are interested in (a) the land footprint of the completed plant and also the land areas required for laydown, etc. during construction, (b) materials and personnel transport during construction and operation including any new road(s), (c) accommodation requirements and the location(s) of construction staff, (d) environmental impacts such as noise, dust, discharges to air and water, visual impact both short and long-term effects on watercourses (including flood risk), flora and fauna and public pathways. We believe that we can contribute positively to the examination of the Wylfa Newydd Nuclear Power Plant examination by becoming an Interested Party, make relevant representations on the topics noted above and subsequently prepare our community for the expected development in our parish. "
Members of the Public/Businesses
PAWB, Pobl Atal Wylfa B/People Against Wylfa B
"Cyflwynaf y sylwadau canlynol ar ran mudiad PAWB, Pobl Atal Wylfa B/People Against Wylfa B Cynhaliwyd cyfarfod galw i mewn gan Gyfoeth Naturiol Cymru yn Llangefni yn Chwefror 2017 fel rhan o'u hymgynghoriad ar ollyngiadau nwyol a hylifol o adweithyddion newydd posibl yn y Wylfa. Hefyd yn bresennol oedd Hitachi a'r Swyddfa Reoleiddio Niwclear. Yn ystod y sesiwn, cawsom drafferth mawr i gael unrhyw fath o atebion i gwestiynau yngl?n â storio'r gwastraff ymbelydrol o ddau adweithydd Hitachi mewn storfa dros dro ar y safle. Gwyddom y byddai Hitachi yn defnyddio tanwydd wraniwm dwysach yn yr adweithyddion fyddai'n creu gwastraff poethach a mwy ymbelydrol na'r hyn a gynhyrchwyd yn hen adweithyddion niwclear y Wladwriaeth Brydeinig. Gan gymryd oes weithredol o 60 mlynedd i'r adweithyddion hyn, oes gennych chi fel Arolygaeth ffigurau yngl?n â chrynswth y gwastraff o'r tanwydd i seilio eich ystyriaethau cynllunio a dadansoddi arnynt. Nid oedd y sesiwn yn Llangefni yn addo'n dda o gwbl gyda rhyw fath o gynllwyn o dawelwch a diffyg parodrwydd o gyfeiriad y tri chorff i ateb cwestiynau am sut y byddai'r gwastraff yn cael ei storio a beth fyddai lefel ei ymbelydredd? Mae angen atebion manwl ar beth fyddai lefelau'r ymbelydredd dros holl gyfnod gweithredol posibl y ddau adweithydd a thu hwnt i hynny pan fyddent yn cael eu dadgomisiynu. Yn ail,mae angen atebion clir a diamwys eto i ba ardrawiadau all holl adeiladau safle Wylfa Newydd wrthsefyll, yn enwedig y ddau adweithydd a'r storfa wastraff ymbelydrol. Er enghraifft, ardrawiad damweiniol neu fwriadol faleisus gan awyren. Dylid hefyd ystyried effaith ardrawiad arfau uwchsonig sy'n gallu bwrw taflegryn allan ar gyflymder o 5000 milltir yr awr mewn ymosodiad terfysgol neu wrthdaro rhyfel llawn. Oherwydd maint enfawr y gwaith o godi dau adweithydd niwclear newydd yn safle'r Wylfa, dylai'r Arolygaeth edrych yn fanwl iawn ar effeithiau niweidiol prosiect o'r fath ar sefyllfa tai ar rent, digartrefedd oherwydd bod pobl yn cael eu prisio allan o'r farchnad brynu a rhentu leol, effaith negyddol ar fusnesau a thwristiaeth a gwasanaethau cyhoeddus, boed yn Heddlu, y Gwasanaeth Iechyd ac Ambiwlans, y Gwasanaeth Tân, a Chynghorau Sir. Mae ein holl wasanaethau cyhoeddus yn gwegian yn barod yn sgîl blynyddoedd o bolisïau llymder didrugaredd. Sut fyddai'r gwasanaethau hynny yn ymateb i'r pwysau ychwanegol fyddai'n dod yn sgîl mewnlifiad enfawr o weithwyr adeiladu a'u teuluoedd i Fôn a Gwynedd? Cafodd dyfodiad gorsaf gyntaf y Wylfa effaith ar y Gymraeg yng nghymunedau gogledd a dwyrain Môn yn arbennig. Gallai effaith presenoldeb hyd at 8000 o weithwyr adeiladu ar safle adeiladu Wylfa B danseilio'r iaith Gymraeg yn ddifrifol ac achosi iddi fod yn iaith leiafrifol ym Môn. Byddai'r fath fewnlifiad yn fwy na 10% o boblogaeth yr ynys gyfan, ac ar gyfaddefiad Horizon eu hunain, byddai o leiaf 75% o'r gweithlu adeiladu yn dod o'r tu allan i'r ardal leol. Mae'r ardal leol gyda llaw yn estyn hyd at Gaer a Glannau Merswy, felly hyd yn oedd o fewn y pwll hwnnw o weithwyr, gallai llawer ohonynt fod yn ddiGymraeg. Mae'r cais ar gyfer safle'r Wylfa yn unigryw oherwydd sensitifrwydd iethyddol yr ardal, sef y sir gyda'r ail ganran uchaf o siaradwyr Cymraeg yng Nghymru. Gallai'r holl adeiladwyr hefyd gael effaith ar y sir Gymreiciaf o ran canran sef dros y ddwy bont yng Ngwynedd. Mae'n ddyletswydd arnoch fel Arolygaeth i roi ystyriaeth lawn i'r dimensiwn iethyddol unigryw hwn. Mae Horizon ei hunain yn cydnabod y bydd y fath fewnlifiad enfawr yn cael effaith andwyol ar y Gymraeg yn ei chymunedau. Dylai hynny ynddo'i hun atal y datblygiad rhag cael ei wireddu. Mae gan y tir a gafodd ei brynu yn y Wylfa gan Hitachi, a'r tin sy'n ffinio nodweddion arbennig. Mae achos cryf iawn oherwydd agosrwydd Llwybr Cenedlaethol yr Arfordir, tair ardal o Ddiddordeb Gwyddonol Arbennig a lleoliad yr holl safle o fewn Ardal o Harddwch Naturiol Eithriadol Arfordir Môn i wrthod y cais am Orchymyn Cydsynio Datblygu. Mae preseoldeb rhywogaethau bywyd gwyllt yn yr ardal yn ffactor pwysif arall gyda hynodrwydd yr ardal fel un o brif ardaoledd magu môr-wenoliaid yng ngwledydd Prydain. Hyderwn y bydd Ymddiriedolaeth Bywyd Gwyllt Gogledd Cymru yn cyflwyno achos cryf dros ddiogelu'r amrywiaeth gyfoethog honno ac yn gwrthwynebu dinistrio'r amgylchedd hynod hwn am byth. Apeliwn arnoch fel mudiad i wrthwynebu cais Horizon am Orchymyn Cydsynio Datblygu am yr holl resymau uchod, ac am mai technoleg eithriadol o ddrud, peyglus, budr, hen ffasiwn a bygythiol i iechyd amgylchedd a dynol yw ynni niwclear. Dylan Morgan Cydlynydd PAWB (Address Redacted)"
Non-Statutory Organisations
RSPB Cymru
"The Royal Society for the Protection of Birds (‘the RSPB’) has engaged with an extensive period of pre-application dialogue with Horizon (‘the Applicant’) with regard to the Wylfa Newydd Development Consent Order (DCO) application (‘the Application’) with a focus on ornithological-related matters. Unfortunately, despite this helpful process, a number of significant matters remain of concern to the RSPB, as outlined in this representation. The RSPB will continue to work with the Applicant to discuss these concerns further and explore ways to resolve them during the DCO Examination. The Wylfa Newydd Development Area (WNDA) lies adjacent to and partly within the Anglesey Terns/Morwenoliaid Ynys Môn Special Protection Area (‘the SPA’), designated for roseate tern, common tern, Arctic tern and Wales’ only Sandwich tern colony (and one of the largest in the UK). The SPA comprises of three tern colonies, including the colony at Cemlyn Lagoon in close proximity to the WNDA and marine areas extending around the coast of Anglesey including waters within and adjacent to the WNDA. Two further Natura 2000 sites lie in close proximity to the WNDA: Cemlyn Bay Special Area of Conservation (SAC) and North Anglesey Marine/Gogledd Môn Forol candidate SAC. The WNDA is also within an area of importance for chough, a highly localised Schedule 1 (Wildlife and Countryside Act 1981, as amended) and Annex I (Council Directive 2009/147/EC on the conservation of wild birds (the Birds Directive)) species of conservation importance in the UK and across Europe. Wales has particular responsibility for the conservation of chough, holding approximately 79% of the UK population (Hayhow, D.B.H., Johnstone, I., Moore, A.S., Mucklow, C., Stratford, A., Šúr, M & Eaton, M.A. 2018. Breeding status of Choughs Pyrrhocorax pyrrhocorax in UK and Isle of Man in 2014. Manuscript submitted to Bird Study). The RSPB’s principal areas of concern regarding the potential effects of the Application on these important wildlife features are as follows: 1. Potential impacts on the internationally important tern colony at Cemlyn Lagoon, as a result of construction-related effects and potential longer-term effects due to alterations to the marine environment. 2. Potential impacts on the local chough population, as a result of loss of foraging habitat and recreational disturbance. Potential impacts on the internationally important tern colony at Cemlyn Lagoon The Application presents a range of potential impacts to the SPA tern population at Cemlyn Lagoon including acoustic and visual disturbance to breeding, foraging and commuting birds (moving between the Cemlyn Lagoon breeding site and feeding areas) during the 10-year site clearance and construction phase, and potential longer-term impacts on tern foraging dynamics and coastal processes (potentially leading to breaching of the shingle ridge protecting the Cemlyn Lagoon colony) as a result of the proposed marine infrastructure which will remain in place for at least the lifetime of the development. The severity of these potential impacts and the long-term consequences to the SPA tern populations is extremely difficult to predict, but impacts could range from reduced breeding success in one or more seasons to the permanent collapse of the Cemlyn Lagoon colony and potential knock-on effects on seabird colonies within the wider Irish Sea meta-population (which includes a number of other SPAs). In order to help inform the Applicant’s proposals to protect and enhance the SPA and other Natura 2000 sites at risk of impact from the Application, the RSPB together with the National Trust (NT) and the North Wales Wildlife Trust (NWWT) (‘the NGOs’) prepared a joint Ecological Options paper which was shared with the Applicant in May 2017. This paper sets out a series of recommended options for avoidance, mitigation, compensation and enhancement of the Natura 2000 sites in response to the likely impacts of the Application. We are pleased that the Application makes reference to some of the NGO-recommended measures aimed at protecting the tern colony at Cemlyn Lagoon, which the Applicant considers will improve the “resilience” of the colony and benefit the management of Cemlyn Lagoon. However, we are deeply concerned that the Applicant does not consider any of the measures necessary as SPA mitigation under the Conservation of Habitats and Species Regulations 2017 (the Habitats Regulations). Consequently, although broadly referenced in the DCO Application, these critical measures lack any legal certainty, as well as clarity with regards to their scope, duration, funding or indeed their actual delivery. Given the substantial uncertainties regarding the extent of the potential impacts arising from the Application, the long-term response of the terns to them, and the uncertainty of the effectiveness of the mitigation measures proposed (as well as our concerns about the current lack of legal certainty for those measures), we do not consider that an overall conclusion of no adverse effect on the integrity of the SPA can be reached. We note that Natural Resources Wales (NRW) concurs with this view. The RSPB therefore considers that, subject to the Application meeting the tests of ‘no alternative solutions’ and ‘imperative reasons of overriding public interest’ (as required under Regulation 64 of the Habitats Regulations 2017), a robust package of compensation measures (including suitable monitoring thereof) will be necessary to ensure that the overall coherence of the Natura 2000 network is protected (including sites forming part of the Irish Sea tern meta-population). In the absence of such a package of compensatory measures, consent for the Application should be refused. We understand that the Applicant is exploring options for compensation of the Cemlyn Lagoon tern colony, to be put forward in anticipation that the Examining Authority supports the view of NRW and the NGOs that, on the basis of the available evidence, it is not possible to reach a conclusion of no adverse effect on the integrity of the SPA. The RSPB will continue to input on these emerging proposals to help ensure they meet the necessary standards to protect the coherence of the Natura 2000 network. Potential impacts on the local chough population There are up to two breeding pairs of chough in the vicinity of the WNDA (one pair have regularly bred at Wylfa Head, within the WNDA), in addition to which the area within and around the WNDA is regularly used by small numbers of foraging non-breeding chough year-round. The construction of the Temporary Site Campus will result in direct and indirect loss of a key area of chough foraging habitat as a result of the built footprint of the campus and due to the cessation of grazing of any remaining areas of grassland within the campus. The resulting loss of a key food resource could have adverse implications on the breeding performance and productivity of this bird of special conservation interest. Furthermore, there is likely to be additional indirect recreational disturbance to breeding and foraging chough from the inhabitants of the Site Campus, increasing pressure on chough currently relying on this area of the Anglesey Coast. Although we acknowledge the Applicant’s efforts to assess and mitigate the risks of impact to the chough population, we do not consider that adequate mitigation measures have been secured, including an appropriate long-term grassland management regime as recommended to the Applicant by the RSPB. Therefore, it may not be possible to demonstrate that a sufficient diversity and area of habitat has been secured for this Schedule 1 and Annex I species in this location. There are two further Sites of Special Scientific Interest (SSSI) in the vicinity of the WNDA: Tre’r Gof SSSI which is within and Cae Gwyn SSSI which abuts the WNDA. The RSPB defers all matters in relation to these sites to NRW, NWWT and NT, including the provision of Ecological Compensation Sites to off-set potential adverse effects on Tre'r Gof SSSI. The RSPB will wish to comment on the potential direct and indirect ecological effects of the proposed development on the Anglesey Terns/Morwenoliaid Ynys Môn SPA, in particular the Cemlyn Lagoon tern colony. This includes comments on the need for and efficacy of the mitigation and compensation measures we consider necessary. The RSPB wishes to defer to the technical expertise NRW, NWWT and NT in respect of potential changes to coastal processes and geomorphology as a result of the proposed development. The RSPB reserves the right to add to/amend its position in the light of any new information submitted by the Applicant or other Interested Parties. "
Members of the Public/Businesses
Caroline Bateson
"I live within view of the proposed road alterations in Valley and object to the new road and major increase in construction and nuclear traffic close to my property. I object to living within 20 miles of a new nuclear project, the problem of dealing with nuclear waste and the health implications. I have already had cancer and wish to live in a clean, peaceful environment. I have a tourism business [Redacted] which is dependant on peace, healthy wildlife and a beautiful Anglesey. When I tell my clients about a new nuclear power station on Anglesey they are horrified. It will impact on tourism and Anglesey is growing in popularity. People want to escape traffic, construction and industrial blight. Local health services are already under pressure, I am concerned about influx of more workers this. I am concerned about the land Wyfla Newydd will take and the impact on wildlife, particularly around Cemlyn bay and Cemlyn nature reserve."
Local Authorities
Conwy County Borough Council
"Summary Response Only (subject to fuller written representations when the examination begins). Conwy County Borough falls within the Daily Construction Commuting Zone (DCCZ) of 90 minutes. However, the application only explores in detail the Key Socio-Economic Study Area (KSA) of 60 minutes (Holyhead to Bangor), excluding the wider catchment. The application further states that there will be some impacts beyond the KSA, within the DCCZ. This raises concerns as to the potential impact and mitigation on a number of sectors within Conwy without mitigation and appropriate monitoring: Housing Accommodation (including secondary impacts on Homelessness): The application further states that there will be some impacts beyond the KSA, within the DCCZ. However, the application does not consider the potential impact on Conwy’s rental markets caused by the residing workforce, displacement and Welfare Reform. The capacity of the rental market in Conwy is strained and as such further impacts on demand may exacerbate stock levels and impact on homelessness. Access to the Accommodation Portal would go some way to mitigate these from workforce demand, but issues related to displacement, coupled with Welfare Reform, would require further mitigation and monitoring. The application further states that there will be some impacts beyond the KSA, within the DCCZ. Tourism Accommodation: The application further states that there will be some impacts beyond the KSA, within the DCCZ. As with housing, the workforce demand and displacement impacts, coupled with Welfare Reform impacts, could place pressure on tourism accommodation and tourism economy without mitigation and appropriate impact monitoring. END "
Members of the Public/Businesses
J Chanay
"1. Representation resource capacity: gross asymmetry 1.1 As lay Interested Party, lacking necessary resource capacity to commission expert appraisal of DCO Application, any representation is likely to fall short of adequacy. 2. Devolved land use planning jurisdiction in Wales: deletions arguably warranted from proposed Grant of DCO 2.1 At least two proposed elements (2.3 and 2.4 below) seemingly engage devolution settlement. These arguably warrant removal from the Wylfa Newydd DCO. 2.2 PINS is respectfully requested to requisition expert reports on devolution questions arising, in the public interest. 2.3 Proposed Spent Fuel Storage Facility (SFSF: Building 201) and Intermediate Level Waste Storage Facility (ILWSF: Building 202), respectively (PINS APP-014). a. Neither structure is classified under statute as an NSIP (Section 14 of the Planning Act 2008, as applying to Wales) b. In planning terms, are Buildings 201 and 202 in Wales properly classifiable as standalone non-NSIP developments, in their own right, subject by default to devolved land use planning consents determination (TCPA 1990)? c. By, • design; • location: fenced-off, isolated, highest AOD Platform Level; • function: safe and secure surface storage of radwaste evacuated from Buildings 1-101, 2-101 and 104, respectively; • purpose: bridge a long duration time gap for radwaste, pending permanent removal to offsite disposal elsewhere; and, • lifespan: interim period up to 140 years beyond end of electricity generation (PINS APP-233) by proposed NSIP Nuclear Generating Station (section 15 of the Planning Act 2008, as amended), the very long duration Buildings 201 and 202 stand manifestly distinguishable from the four other short duration radwaste storage installations on the neighbouring Power Station Site. Namely, Buildings 104 and 246, and one installation each inside Buildings 1-101 and 2-101, respectively. These four installations are destined for permanent dismantlement and removal at the same time as the end-of-life decommissioned NSIP reactors, within 20 years of cessation of electricity generation (PINS APP-233, in particular, paragraph 6.1.3). d. Misleading and inadequate Public Consultation 15.01.2018: concealment and inexplicable failure to distinguish these two structures from the other four radwaste installations. “Project Summary” in Section 48 Public Notice (PINS APP-008), tantamount to masquerading false equivalence. Concealment was maintained in subsequent Section 56 Notice published 6 July 2018 (PINS OD-002). Serial masquerade of false equivalence traces back to a Public Notice published 19 May 2017, at the least, if not from the outset. 2.4 Site Preparation and Clearance (SPC): Planning Application 38C310F/EIA/ECON a. TCPA 1990 Planning Permission sought from host Planning Authority on 10.11.2017 (revised 31.05.2018). b. Welsh Ministers were requested in January 2018 to call-in the Application for independent examination at TCPA 1990 Public Local Planning Inquiry. c. SPC works included in DCO Application to PINS, 01.06.2018. d. Evidently, long and fully activated devolved TCPA determinations had not expired by the time of DCO Application. 2.5 Marine Works PINS requested to require disaggregation of all elements and matters: a. exclusive devolved jurisdiction; b. electively included in the DCO; and, c. exclusive PINS jurisdiction net of (b). 3. Disclosure warranted from Statutory Consultees 3.1 PINS is respectfully requested to require following disclosure, in the interest of appropriate representation: a. all advice, including legal advice, regarding Buildings 201 and 202 considered at any time by the host Planning Authority and the Welsh Government, respectively; b. IROPI advice to relevant Secretary of State 2008-2011, from Countryside Council for Wales; c. proposed DCO IROPI test: evidence on alternatives considered regarding NSIP Nuclear Generating Station, and Buildings 201 and 202, respectively; d. Anglesey AONB and Heritage Coast diminution: evidence on public consultation by Anglesey Council and NRW, respectively; e. major nuclear accident impact in North Wales, Wales and within UK: evidence on public consultation, complementing transboundary consultation evidence; and, f. PINS AoC-001 deficiency: host Planning Authority’s responses to all public responses to each Horizon PAC. "
Other Statutory Consultees
Natural Resources Wales
"PROPOSED WYLFA NEWYDD NUCLEAR POWER STATION PLANNING INSPECTORATE REFERENCE: EN10007 RELEVANT REPRESENTATION FROM NATURAL RESOURCES WALES (NRW) 1. INTRODUCTION 1.1. NRW have identified key concerns relating to the following areas. We provide further details and clarification below: - PROJECT WIDE • Code of Construction Practice • Waste - MAIN SITE • Flood Risk • Water Framework Directive O The Skerries Coastal Water Body O Ynys Môn Secondary Groundwater Body O Cemlyn Lagoon Water Body O Article 4(7) Information O Cemaes Bathing Water • Habitats Regulations Assessment O Morwenoliaid Ynys Môn / Anglesey Terns Special Protection Area (SPA) O Dee Estuary SPA O Bae Cemlyn / Cemlyn Bay Special Area of Conservation (SAC) • Site of Special Scientific Interest (SSSI) o Tre’r Gôf SSSI o Tre’r Gôf SSSI Compensation o Cae Gwyn SSSI • European and Nationally Protected Species • Marine Environment • Protected Landscapes - PARK AND RIDE • Flood Risk • Foul Drainage - A5025 OFFLINE HIGHWAY IMPROVEMENTS • Flood Risk • European and Nationally Protected Species 1.2. 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 Horizon Nuclear Power (‘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 2015 and as an ‘interested party’ under s102(1) of the Planning Act 2008. 1.3. We shall continue to provide advice to the applicant through correspondence and meetings with the aim of reaching as many positions of agreement and common ground as possible prior to the examination of the proposals. Our relevant representation is based solely on the information provided within the application documents. Any changes in our position will be reflected in our full written representation and SoCG. 1.4. In addition to being an interested party under the Planning Act 2008, NRW exercises functions under distinct legislation including (but not limited to) the Environmental Permitting (England and Wales) Regulations (EPR) 2016 (as amended), Water Resources Act 1991 and Marine and Coastal Access Act (MACAA) 2009. NRW has received applications for a Construction Environmental Permit, Operational Environmental Permit and Combustion Installations Permit under the EPR Regulations 2016 (as amended), and a Marine Licence application under the MACAA 2009. For the purpose of clarity, comments from NRW Marine Licensing are titled as such and are produced in Annex A; all other comments pertain to NRW’s advisory role. 1.5. NRW provide the comments below (structured according to the reference used in the Environmental Statement) on Volumes 6 C – H which cover Project Wide Effects (Vol 6C), Main Site (Vol 6D) and Associated Developments (Vol E – H). We provide a comment on the Code of Construction Practices for the Wylfa Newydd Project in section 2 below, and on NRW’s general purpose in section 8. In Annex A, we also provide a comment with respect to the draft DCO Requirements in relation to activities which are also licensable under the MACAA 2009. 2. CODE OF CONSTRUCTION PRACTICE (CoCP) 2.1. The Wylfa Newydd CoCP, together with location-specific sub-CoCPs, are intended to set out how construction activities will be managed and controlled in order to deliver the mitigation commitments arising from the project. There is insufficient detail in the submitted Sub-CoCPs to demonstrate that construction activities will be managed appropriately. NRW advise that if the DCO is made, that detailed Sub-CoCPs will need to be agreed with the consenting authority(ies) as well as NRW as a statutory consultee. We would expect this to be secured as a DCO Requirement. 3. PROJECT WIDE EFFECTS (VOLUME 6C) 3.1. Waste 3.1.1. There is insufficient detail in ES chapter C6 to demonstrate how construction generated waste will be managed. The assessment of available waste management capacity will need to be updated prior to and throughout the construction phase, to ensure that appropriate decisions on waste management routes are taken for the duration of the scheme. The principles of the Waste Hierarchy will need to be applied at all times. NRW advises that if the DCO is made, that a detailed Site Waste Management Plans will need to be agreed with the consenting authority(ies) as well as NRW as a statutory consultee. We would expect this to be secured as a DCO Requirement. 4. MAIN SITE (VOLUME 6D) 4.1. Flood Risk 4.1.1. NRW has significant concerns that, through modifying and increasing catchment areas at the Wylfa Newydd main site, the project may cause unacceptable flood risk to third party property and/or land. 4.1.2. The Flood Consequence Assessment (FCA) identifies that through modifying the catchment area of Nant Cemaes, there is predicted to be an increased flood risk to residential and commercial properties upstream of Cemaes village. The increased flood depth for the 1 in 100 event (1% Annual Exceedance Probability (AEP)) is predicted to be 40mm. The proposals will also increase the catchment area for the Nant Cemlyn and Afon Cafnan watercourses. The FCA predicts the proposals will result in an increase in flood depth for the 1 in 100 event (1% AEP) for the Afon Cafnan of between 60mm and 140mm. The FCA predicts an increase of 20mm in flood depth for the 1 in 100 event (1% AEP) for the Nant Cemlyn stream. Technical Advice Note (TAN) 15, which provides technical guidance that supplements the policy set out in Planning Policy Wales in relation to development and flooding, states that there should be no increased flood risk elsewhere. 4.1.3. In view of the increased flood risks highlighted in 4.1.2, the FCA states that “the outline landform and drainage scheme would be revised at detailed design stage so as not to exacerbate any existing flood risk”. NRW is concerned that no mitigation is presented as part of the DCO application to demonstrate that measures can be delivered to mitigate the increased flood risk. NRW advises that details of mitigation measures should be presented to the Examining Authority to demonstrate that increased flood risk can be managed and that the proposals are compliant with TAN15. 4.2. Water Framework Directive (WFD) - The Skerries Coastal Water Body 4.2.1. NRW agrees with the conclusion of the WFD Compliance Assessment (WFD CA) that the hydromorphological conditions quality element may deteriorate from high to good status. NRW agrees that, for this quality element, there will be a need for a derogation under Article 4(7) of the WFD. 4.2.2. NRW advises that further information is required to demonstrate that benthic invertebrates would not be at risk of deterioration as a result of the Wylfa Newydd project. - Ynys Môn Secondary Groundwater body 4.2.3. NRW agrees with the conclusion of the WFD CA that there is potential for the Wylfa Newydd Project (including dewatering effects) to cause a deterioration in the Ynys Môn Secondary groundwater body due to saline intrusion. This effect is relevant to both quantitative and chemical tests for saline intrusion. 4.2.4. In relation to the Groundwater Dependent Terrestrial Ecosystem (GWDTE) quality element, NRW agrees that the Wylfa Newydd Project could cause deterioration in the status of the Ynys Môn Secondary groundwater body with respect to the effects on Tre’r G?f Site of Special Scientific Interest (SSSI) GWDTE. 4.2.5. NRW agrees with the conclusion of the WFD CA that, for the quality elements highlighted in 4.2.3 and 4.2.4 in the Ynys M?n Secondary groundwater body, there will be a need for derogation under Article 4(7) of the WFD. - Cemlyn Lagoon Coastal Water Body 4.2.6. NRW advises that further information is required to demonstrate that Cemlyn Lagoon will not be affected by impacts on water quality due to surface water run-off from Mound E. Further information is also required to demonstrate that changes in coastal processes due to the presence of the marine structures will not affect the shingle ridge, which supports the functioning of Cemlyn Lagoon. NRW is therefore, unable to agree with the conclusion that "the Wylfa Newydd Project would neither cause deterioration in the status of the Cemlyn Lagoon water body, nor compromise the ongoing achievement of its objectives". Please see section 4.3.8 – 4.3.11 for NRW’s advice in relation to Cemlyn Bay SAC. - Article 4(7) Supporting Information 4.2.7. NRW advises that further evidence is needed to support the information provided and to justify the conclusions reached in the document regarding mitigation measures, environmental impacts and alternatives considered. 4.2.8. The Article 4(7) report (Ref no. 8.27) identifies water bodies and elements that the applicant considers will require derogation. It is important that the scope of the report is reviewed following the completion of the consenting authority(ies) WFD compliance assessment and any potential updates (such as further water bodies and/or elements to be included in the scope of Article 4(7)) are provided. - Cemaes Bathing Water 4.2.9. NRW does not agree with the conclusion that “there are no effects predicted on the bathing water at Cemaes, and that the Wylfa Newydd Project is considered to be compliant with the Bathing Water Directive”. 4.2.10. NRW has previously advised the applicant that discharges of elevated suspended solids and sewage discharges into the marine environment has the potential to affect Cemaes Bathing Water. NRW does not consider that the sewage modelling has been conducted appropriately and that further modelling, including meteorological conditions, will need to be conducted. NRW advises that a Bathing Water Compliance Assessment be provided to examine how both the construction sewage discharge and site campus discharges (via the D?r Cymru Welsh Water (DCWW) sewage works) impact the Bathing Water. NRW would expect the applicant to work closely with DCWW to model both discharges, to ensure all discharges are included appropriately. NRW also advises that clarification is required regarding the suspended sediment modelling undertaken. 4.3. Habitats Regulations Assessment (HRA) - Morwenoliaid Ynys Môn / Anglesey Terns SPA 4.3.1. NRW considers that the evidence and mitigation presented in the Shadow HRA does not demonstrate that noise and vibration associated with the construction phase will not have adverse effects on the sandwich, arctic and common tern populations at the Cemlyn colony. NRW considers that adverse effects on the SPA (relating to sensitivity of sandwich, arctic and common terns to construction noise) cannot be ruled out. 4.3.2. NRW advises that the increase in noise and visual stimuli on land and sea, from the cumulative building activity, may potentially lead to abandonment and/or a decrease in productivity of the Sandwich tern feature of the SPA and thus an adverse effect on the Sandwich tern conservation objectives for productivity and population. NRW also advises that the impacts from increased noise and visual stimuli may potentially lead to the abandonment of the colony by the Arctic and common tern features of Anglesey SPA which would be an adverse effect on the conservation objective for range. 4.3.3. With regards to fish (as prey items of terns), there is no consideration of the effect of the creation of a sheltered bay as a result of the breakwater and thus the possible increased use of the area by some fish species – this could potentially result in increased impingement rates for some species. There is also the risk of large amounts of shoaling fish, such as sandeels, sprats, and herring, being herded into the area behind the breakwater by predators. In certain weather conditions and at certain times of the year, this could increase the impingement of these species which are a food source for terns. 4.3.4. Further information is also required to demonstrate that changes in coastal processes due to the presence of the marine structures will not affect the shingle ridge, which supports the functioning of Cemlyn Lagoon (including the tern breeding islands within the lagoon). 4.3.5. In view of the above comments, NRW is unable to rule out an adverse effect on the site integrity of the Morwenoliaid Ynys Môn / Anglesey Terns SPA. 4.3.6. NRW, as the Appropriate Nature Conservation Body, advise that it cannot be ascertained that the Wylfa Newydd project will not adversely affect the integrity of the Anglesey Terns SPA and that the project would need to be modified accordingly so that any adverse effects can be ruled out. If not, for consent to be granted the provisions of Regulation 64 of the Conservation of Habitats and Species Regulations 2017 must be satisfied - that there are no alternative solutions and that the project must be carried out for imperative reasons of overriding public interest. If the competent authority is satisfied that there are no alternative solutions and that the project must be carried out for imperative reasons of overriding public interest, then compensatory measures would need to be secured. - Dee Estuary SPA 4.3.7. We are aware that some sandwich terns that breed at Cemlyn also form part of the Passage Sandwich Tern feature of the Dee Estuary SPA. Abandonment of the Cemlyn population as a result of Wylfa Newydd project could therefore impact the conservation objective for the Dee Estuary SPA which is to maintain the population of passage Sandwich terns at the 5-year peak mean population of 957 individuals from 1995 – 1999. NRW therefore advises that an adverse effect on site integrity cannot be ruled out. - Bae Cemlyn / Cemlyn Bay SAC 4.3.8. Cemlyn Bay SAC consists of two features, the coastal lagoon and the perennial vegetation of stony banks (i.e. the Esgair Gemlyn shingle ridge). 4.3.9. NRW advises that Esgair Gemlyn, which is critical to the functioning of the lagoon and in supporting the shingle ridge vegetation, may be affected by the marine structures. Further information is required with respect to coastal processes modelling to understand whether the Wylfa Newydd project may cause an adverse effect on Esgair Gemlyn. There are still outstanding issues as follows: a) No coupled wave-bed shear stress modelling of a North West 99%ile storm event to show morphological impacts on Esgair Gemlyn; b) Lack of sediment data in Cemlyn Bay which then limits assessment of impact; c) There are protective structures (rock foundation overlain by concrete mats) surrounding the waste water outfall pipe (adjacent the western breakwater) which will be in place for the length of the construction phase. The impact of this structure has not been modelled and assessed. It is therefore not possible to assess whether focussed energy from the marine structures may cause deposit of fines, reworking of the gravel or a breach at Esgair Gemlyn. The above information is required in order to inform the competent authority’s HRA. 4.3.10. As highlighted in comment 4.2.6 above, further information is required to demonstrate that Cemlyn Lagoon will not be affected by impacts on water quality due to surface water run-off from Mound E. We note that the project design has been amended and that no construction water discharge is now proposed to be discharged into Nant Cemlyn via discharge location E1 until vegetation has been re-established on the western slope of Mound E. Further clarity is required in relation to the mitigation measures detailed in 7.4.5 of the Shadow HRA and in relation to the drainage proposed on and around Mound E. It appears to NRW that pumping capacity is limited and that in extreme events some runoff will enter Nant Cemlyn; clarification from the applicant is required on the level and frequency of such occurrence. 4.3.11. In view of the comments in 4.3.9 and 4.3.10 above, NRW considers at this point that it is not possible to rule out adverse effect on site integrity of the Cemlyn Bay SAC. 4.4. Sites of Special Scientific Interest (SSSIs) - Tre’r Gôf SSSI 4.4.1. Based on the ES and supporting ES Appendices, NRW advises that the proposed works are likely to significantly affect the functioning of the SSSI and likely to damage the SSSI features. The proposed mounding and drainage proposals, dewatering of the deep excavations as well as locating the Site Campus immediately adjacent to the SSSI pose a number of risks to the SSSI. NRW note that fen creation is proposed as SSSI compensation due to the likely loss of the SSSI (see our advice below on SSSI compensation). However, NRW advised the applicant in our Section 42 responses that all reasonable alternatives and mitigation should be considered to reduce and avoid effects on the SSSI. NRW consider that there is inadequate consideration of direct mitigation measures in the ES. 4.4.2. NRW does not agree with the conceptual hydrogeological modelling undertaken and used to assess impacts on Tre’r Gôf SSSI. It is based on an unsupported assumption that shallow and deep groundwater behave independently. The evidence does not support this. NRW consider that the dewatering has the potential to cause significant damage to the SSSI. 4.4.3. The embedded mitigation refers to the use of an underlying “blanket” (a gravel layer under the mounds) for which its success is uncertain. There is also risk associated with the complex system of ditches, swales and overflow points in the mound drainage which is designed to replicate the natural hydrological regime. NRW has limited confidence in the ability of this system to meet design objectives. NRW considers that further direct mitigation measures should be secured. 4.4.4. We note (Table D9-11) that long-term botanical monitoring and operational monitoring of water quality and quantity will be undertaken. The monitoring should also inform an updated conceptual site model which should be agreed with NRW and used to inform detailed mitigation measures. 4.4.5. The air quality impact assessment predicts there will be exceedances of the air quality thresholds for NOx and nitrogen deposition at Tre’r Gôf SSSI. NRW advise that the specified mitigation measures, including cutting and removal of vegetation litter with consideration of the sensitivity of the designated features, should be undertaken to offset air quality impacts. - Tre’r Gôf SSSI Compensation 4.4.6. NRW notes the SSSI compensation proposals outlined in ES Appendices D9-24. NRW has previously advised HNP (letter to HNP dated 8/12/2018) that a number of factors will be considered when assessing the sufficiency of proposed compensation to offset damage to the SSSI interest. These factors include the quantity of proposed compensation (extent), the quality of proposed compensation (wetland type), distance from the affected SSSI, the potential connectivity with existing wetland areas, the likelihood / feasibility of successful habitat creation and the arrangement for long-term monitoring, management and security of the compensation. 4.4.7. Based on the information presented in the ES and supporting information, NRW is not able to conclude that the proposed compensation package for Tre’r Gof SSSI will deliver adequate quantity or quality of replacement habitat. No hydrological baseline information for the Cors Gwawr and Cae Canol-dydd compensation sites is provided in the ES; however, this information is critical in informing the likely success of the compensation. - Cae Gwyn SSSI 4.4.8. Water quality impacts from parking and mounding in the vicinity of Cae Gwyn SSSI will need to be carefully managed to ensure the SSSI is not damaged. We refer to our comment above in section 2 in relation to the CoCP which will need to be agreed with NRW. 4.4.9. ES chapter D5 identifies air quality threshold exceedances at Cae Gwyn SSSI, however ES chapter D9 does not fully address how mitigation measures will offset the exceedances. 4.5. European and Nationally Protected Species 4.5.1. NRW has considered the draft mitigation licences submitted as part of the DCO application. NRW advises that the duration of the post-construction monitoring is not satisfactory for evidencing the successful mitigation in terms of maintaining or restoring the current conservation status of the species to favourable levels. 4.5.2. ES Appendix D9-21 (Draft Great Crested Newt (GCN) Mitigation Licence) identifies a GCN translocation area. The applicant will need to ensure that the site can be secured and can be managed as a GCN receptor site. 4.5.3. NRW advises that the detailed phasing and the final layout of the Landscape and Habitat Management Strategy will need be agreed with the consenting authority(ies), and NRW as a statutory consultee, to ensure that the project is not detrimental to the maintenance of the Favourable Conservation Status of the affected protected species. 4.6. Marine Environment - Benthic habitats 4.6.1. NRW advises that there is insufficient evidence presented to demonstrate that the cumulative effects of the project on benthic habitats are insignificant. Further consideration of mitigation and/or enhancement measures will be required. 4.6.2. The ES does not fully assess the potential risks posed by the introduction of Invasive Non-Native Species. The presence of the sea squirt Didemnum vexillum in Holyhead is a particular concern. The applicant will need to ensure there is a joined-up approach with the Port of Holyhead with respect to ensuring risks posed by this species (and others) are minimised as far as possible. 4.7. Protected Landscapes 4.7.1. NRW agrees with the conclusions in the ES and its assessment of Landscape and Visual effects relating to the Ynys M?n / Isle of Anglesey Area of Outstanding Natural Beauty (AONB). NRW advises detailed proposals will need to be submitted to ensure mitigation of impacts upon the AONB are fully developed. NRW considers detailed proposals are required to confirm that the power station’s landscape and visual integration with the AONB has been developed to best effect. If the project is approved, the scope, requirements and acceptability of this information should be agreed with the consenting authority(ies), and NRW as a statutory consultee. 4. OFFSITE POWER STATION FACILITIES (VOLUME 6E) 4.1. We refer you to our comment in section 2 in relation to the Code of Construction Practice and Sub-CoCPs. 5. PARK AND RIDE FACILITY (VOLUME 6F) 5.1. Flood Risk 5.1.1. NRW has significant concerns that the proposal will result in unacceptable increased flood risk. 5.1.2. This site will suffer from significant flood depths and will fail the criteria of TAN15 of being flood free during the 1% event (1 in 100 year) (para A1.14 of TAN15). The site will also flood on more frequent events (1:20) and it is unclear if any mitigation is proposed or feasible. The FCA/hydraulic modelling has also identified flood depths greater than 2m at the 0.1% Annual Exceedance Probability (1 in 1,000 year) event in the south-central area of the Park and Ride. 5.1.3. The proposal is not compliant with TAN15 in terms of flood risk (tables A1.14 nor A1.15). Mitigation measures have either not been provided, are unclear, or no evidence has been provided to demonstrate that the proposal would comply with TAN15. We advise that the FCA is unacceptable to NRW in terms of addressing the flood risks of the proposal. The Lead Local Flood Authority should also comment on the pluvial flood risks which shows the application site flooding to considerable depth and poses a risk to users and their property. 5.2. Foul Drainage 5.2.1. Toilet facilities and sewage treatment are briefly discussed, but no details are provided as to the proposed sewage treatment and volumes generated. Limited assessment of the sewage treatment options has been carried out. As the site is upstream of Llyn Traffwll SSSI, we have concerns regarding additional nutrients discharging into the watercourse. The discharge would require an Environmental Permit from NRW. 5.3. In relation to the comments made above on flood risk (5.1) and foul drainage (5.2), NRW advises that the applicant must ensure that it will be possible to incorporate all mitigation measures within the application boundary and demonstrate how such measures can be secured. 6. VOLUME 6 G – A5025 OFF-LINE HIGHWAY IMPROVEMENTS 6.1. Flood Risk - Valley (Section 1) 6.1.1. NRW has significant concerns that the proposal will result in unacceptable increased flood risk. 6.1.2. The tidal defence only provides protection up to and including the 1/1000-year tidal flood level (0.1% AEP). However, the tidal defence embankment would be overtopped when climate change is also considered, for the lifetime of the development. Overtopping is more likely to lead to breaching from levels exceeding crest heights. The impact the works would have on flood risk elsewhere should a failure (breach) of the tidal defence occur has not been assessed. Mitigation has been provided for other modelled scenarios but the tidal breach scenario has not been assessed, as we have requested. NRW advise that should a failure (breach) occur to the defences affording tidal protection to the area, then existing properties (and land) may be inundated to deeper flooding following the development in Section 1. - Llanfachraeth (Section 3) 6.1.3. Following the development, the water level immediately upstream of the bypass increases in the Afon Alaw and Afon Llywenan in all flood events. The increase for the ‘design event’ (table A1.14 in TAN15) for the 1% AEP plus climate change is 0.09m and 0.02m respectively. Table G8-8 refers to mitigation which would involve “…minor ground re-profiling …… without increasing flood risk elsewhere…..”. It has not been demonstrated that this can be achieved. It is also unclear if this can be carried out within the current DCO application limits, and NRW therefore advise it is unclear whether the proposal is compliant with TAN15. 6.2. European and Nationally Protected Species 6.2.1. NRW advises that land identified for mitigation and/or compensation measures with respect to protected species will need to be secured. We also advise that long-term monitoring as well as management/wardening will be required, and appropriately secured through the DCO, to ensure that the project will not be detrimental to the maintenance of the Favourable Conservation Status of the affected species. 7. VOLUME 6 H – LOGISTICS CENTRE 7.1. Code of Construction Practice 7.2. We refer you to our comment in section 2 in relation to the Code of Construction Practice and Sub-CoCPs. 8. NRW’S GENERAL PUPROSE 8.1. NRW is satisfied that this advice is consistent with its general purpose of pursuing the sustainable management of natural resources in relation to Wales, and applying the principles of sustainable management of natural resources. In particular, NRW acknowledges that the principles of sustainable management include taking account of all relevant evidence and gathering evidence in respect of uncertainties, and taking account of the short, medium and long term consequences of actions. NRW further acknowledges that it is an objective of sustainable management to maintain and enhance the resilience of ecosystems and the benefits they provide and, in so doing meet the needs of present generations of people without compromising the ability of future generations to meet their needs, and contribute to the achievement of the well-being goals in section 4 of the Well-being of Future Generations (Wales) Act 2015. ANNEX A Marine Licensing Comments DCO Requirements 1. NRW has concerns that works which are licensable under the Marine and Coastal Access Act 2009 are also contained within the requirements of the draft Development Consent Order, with the identification of NRW as a discharging authority for such works. NRW will make further representations and would expect detailed scrutiny of these issues during the examination. "
Other Statutory Consultees
Addleshaw Goddard LLP on behalf of Network Rail Infrastructure Limited
"Network Rail Infrastructure Limited (Network Rail) owns, operates and maintains the railway infrastructure of Great Britain. Network Rail operates the railway infrastructure pursuant to a network licence granted under section 8 of the Railways Act 1993. Network Rail does not object in principle to the Wylfa Newydd Project to which the Development Consent Order (DCO) application relates. Network Rail notes that the DCO seeks compulsory acquisition powers in respect of three Plots to enable highway improvements to be carried out; namely plots 407, 408 and 409 (Plots). The Plots include land which is leased to Direct Rail Services for use as a nuclear loading facility and land which is public highway. Network Rail objects to the compulsory acquisition of its land, rights it has over third party land and the compulsory creation of rights over land owned by Network Rail or in which Network Rail has an interest. In order for Network Rail to be in a position to withdraw its objection, Network Rail requires agreement from the Applicant that the acquisition of any part of its land, rights over its land, rights that Network Rails has over third party land and the creation of new rights over Network Rail's land, will only be on terms agreed with Network Rail so as to protect its statutory undertaking and to ensure that compulsory powers will not be exercised in relation to Network Rail's interests in such land. It also requires agreement that if any public highway, the subsoil of which is owned by Network Rail, is stopped up, appropriate rights over that land, should it no-longer be in Network Rail's ownership at the date of the stopping up, will be provided to Network Rail so that access is maintained to its retained land at all times. Network Rail considers that there is no compelling case in the public interest for the compulsory acquisition of rights over the Plots. Network Rail considers that the Secretary of State, in applying section 127 of the Planning Act 2008, cannot conclude that new rights and restrictions over the railway land can be created without serious detriment to Network Rail's undertaking and no other land is available to Network Rail which means that the detriment can be made good by them. Network Rail notes that there are no protective provisions in the DCO for the benefit of railway interests and also objects to the DCO on this basis and asks that such provisions are included in the DCO. Network Rail reserves the right to raise further issues in evidence and intends to take a full part in the examination process including, if required, attending and making oral representations at, relevant hearings. "
Other Statutory Consultees
Welsh Ambulance Services NHS Trust
"1 Introduction 1.1 The Welsh Ambulance Service NHS Trust (WAST) provides: • 999 blue light response for medical emergencies in Wales; • NHS Direct Wales/111 service - telephone health advice and information service available 24 hours a day, every day; • Non-Emergency Patient Transport Services (NEPTS) • Special response, for example to terrorist/chemical/biological/radiological/ nuclear/otherwise hazardous incidents, by the Hazardous Ambulance Response Team (HART, based in South Wales with a limited UK mutual aid arrangement) or Special Operations Response Team (SORT) for casualty decontamination which is operated on a recall-to-duty regional basis 1.2 WAST notes that Horizon Nuclear Power (HNP) recognises that demand on ambulance services is already acute, with high levels of demand (circa. 45,000 999 calls nationally per month) and incident demand increasing at between 4% and 5% per annum. • Red calls (life-threatening calls within 8 minutes) account for approx. 5% of WAST’s 999 incident demand. • The majority of incidents are Amber - serious, but not immediately life threatening • The remaining number are Green - lower acuity. 1.3 WAST has no capacity to meet additional demand arising from the construction, operation or decommissioning of the proposed nuclear power station and this statement seeks to register WAST as in interested party in the totality of the development. Whilst WAST supports any development which improves the health, general resilience infrastructure and socio-economic prosperity of Anglesey, it is critical that HNP provides for appropriate mitigation through the provision of all necessary healthcare facilities and section 106 financial contributions to WAST; this is necessary to mitigate the impact of the proposals so that the operational needs and obligations of WAST are fully satisfied enabling it to carry out its functions without extra cost to WAST. 1.4 In addition, it is essential that WAST, alongside the wider emergency services community, is able to access resources to procure services which support the critical operational infrastructure where site developments warrant it. If these issues are not adequately addressed then WAST would be concerned that, not only would it be unable to provide an appropriate service to the proposed facility, but it would also be possible that the quality of service that it currently offers to the existing population of Anglesey would be impacted. 2 Further information required 2.1 WAST has undertaken initial reviews of the DCO documentation and requires further time during the DCO process to review the documents in detail; WAST will need to seek resource from HNP to complete this work. From an initial review of the documentation, WAST has identified three significant risks (in line with the response to PAC2 and PAC3) under which all concerns and questions are categorised, encompassing the construction, operation and decommissioning phases. 2.2 Increase in life threatening or life changing medical emergency/ies created by activities associated with the construction of the main power station site and associated developments. 2.2.1 WAST would expect to receive further confirmation of: • How injuries on site will be managed, further specifically how casualties requiring hospital treatment will be removed from site. • The arrangements on site to deal with hazardous environments or difficult to reach locations 2.2.2 WAST welcomes confirmation that the site campus will have a paramedic, an ambulance and on-site healthcare facilities. WAST requires assurance on the capability and availability of these arrangements and detailed discussions on arrangements for responding to hazardous areas, or responses that require multiple paramedics, and handover/site access protocols. Further, the management of hazardous environments does not appear to be covered in the documentation and is a particular area of concern on which WAST would want assurance from HNP to ensure appropriate mitigations are in place. • The medical arrangements present on site, including operational hours and clinical capability. 2.2.3 WAST notes the proposed provision of on-site campus medical facilities, but further detailed information is required to ensure that this mitigation is sufficient and does not lead to increased demand for WAST. • Details of HNP major incident plans, including management of multiple casualties • Details of HNP plans for – fire, pandemic, disorder or protest at site and temporary worker accommodation, and Marine Offloading Facility. • Details of HNP plans to manage life threatening or life changing emergencies across all associated development sites. 2.2.4 These do not appear to be addressed in our initial review of the documentation. 2.3 An increase in the population base brought about by the provision of temporary workers introducing a higher demand for ambulance services, resulting in needing to meet the physical and mental health needs of workers. 2.3.1 WAST would expect to receive further confirmation of: • How temporary residents will receive primary and community care, through to complex secondary care (including referrals into secondary care pathways from Healthcare Professionals) • HNP arrangements for entertaining staff during time off • HNP policies for managing drug/alcohol misuse issues • How HNP intends to meet physical and mental health needs of workers, including chronic conditions management • How HNP intends to manage antisocial behaviour and safeguarding issues HNP intends to manage the health needs of the workforce living in the wider community • Mitigation in support of the wider supply chain throughout the region to manage both the effects of direct and indirect workforce on ambulance services • Impacts of temporary worker families moving to the area 2.3.2 Generally, WAST is supportive of single integrated accommodation sites as they make the provision of medical services and responding easier. 2.3.3 WAST notes that the Health Impact Assessment identifies large magnitude and significant major adverse impacts on medical and healthcare services’ demand and NHS capacity. The HIA identifies mitigation through “appropriate healthcare provision or contribution”. WAST must be involved in the discussions as the NHS Direct Wales service is a key part of the primary care sector, and unmet demand in the primary care sector can impact on the ambulance care pathway. 2.4 Impacts on domestic or routine ambulance services brought about by associated construction activity and developments such as improvements on the highways hindering response times to non-HNP activity; increased frequency and severity of incidents such as road traffic accidents brought about by the increased volume of vehicles their type and size. 2.4.1 WAST would expect to receive further confirmation of: • Information to support an assessment of how ambulance travel and job cycle will be affected across the immediate and regional areas • Information to support an assessment of impacts on WAST provision of core 999 services on Anglesey • Arrangements for translation for non-English speaking staff • Mitigation to avoid delays to both emergency and non-emergency patient transport across the region, given increased traffic volumes 2.4.2 WAST notes the various proposed highway improvements which, it is stated, should improve access, once completed. WAST will want to see the results of detailed modelling of the impact of proposed highway changes and average road speeds on its ability to respond. As part of this modelling work, WAST will supply up to date demand and performance data. 2.4.3 Other considerations include potential staffing impacts on WAST, wider socio-economic effects on both staff and patients, and partnership working across the breadth of organisations across North Wales. The cumulative effect of this development, alongside all other developments within the area (notably National Grid, Bluestone and other energy projects on both Isle of Anglesey and the mainland) will have a significant impact on WAST. The impact of noise, air pollution and other environmental impacts on the wider island population need to be better understood, and may impact on demand for ambulance services in the future. 2.5 Further information on the effects of these issues will, therefore, also be required in order to assess the full impact on the totality of services provided by WAST. 3 Conclusion 3.1 WAST is a statutory body required by law to manage ambulance and associated transport services. Any factors which are likely to increase its operational obligations need to be fully addressed and financially resourced. All direct and non-direct impacts of the HNP proposals need to be assessed. Further information is required about the effect on WAST's operations and financial and other commitments need to be put in place to ensure that WAST can satisfactorily meet its legal obligations and expectations otherwise imposed. 3.2 As a result, WAST has a duty to ensure it makes all necessary representations in the planning process. WAST reserves the right to expand on or add to any points made in this representation by way of written evidence to the inquiry. "
Non-Statutory Organisations
Welsh Anti Nuclear Alliance
"1. New nuclear power stations are not now required as green renewable energy sources (including tidal lagoons) are able to provide for future energy needs, It is also becoming increasingly apparent that renewables will offer the lowest cost of electricity over their lifetime of all generating options. 2. Proposed new developments at Wylfa are at variance with the Welsh Government’s “Wellbeing of Future Generations Act (Wales) 2015” . This flagship legislation offers a huge opportunity to make long-lasting, positive changes for future generations around clean energy. Nuclear energy is not renewable, green or clean in fact it creates a legacy of radioactive waste at every stage of its cycle (from uranium mining, milling, transport and reprocessing) 3. The Welsh Government Energy Statement (Lesley Griffiths 6/12/2016) outlined 3 priorities. “ First, we will reduce the amount of energy we use in Wales. Second, we will reduce our reliance on energy generated from fossil fuels. Third, we will actively manage the transition to a low-carbon economy. We contend that nuclear energy is no solution to climate change. • Considerable amounts of carbon are released in the mining, milling and separation of Uranium from the ore and then it has to be transported. Current estimates for Uranium say reserves will last 50 - 70 years and the higher the demand the more and more poor ores will have to be processed. This will lead to a CO2 balance for atomic power, which gets worse and worse over time (J. W. Storm van Leeuwen and P. Smith, 'Nuclear Power: The Energy Balance', www.stormsmith.nl. ) • “ Nuclear energy is not renewable and Earth’s uranium would eventually deplete meaning that we are effectively depriving our future generations from using that in new and maybe less harmful ways in the future.” (Sophie Howe - Future Generations Commissioner for Wales 2018 when supporting the Swansea Tidal Lagoon) • “Claims that nuclear power is a 'low carbon' energy source fall apart under scrutiny. Far from coming in at six grams of CO2 per unit of electricity for Hinkley C, as the Climate change Committee believes, the true figure is probably well above 50 grams - breaching the CCC's recommended limit for new sources of power generation beyond 2030.” (Professor Keith Barnham https://theecologist.org/2015/feb/05/false-solution-nuclear-power-not-low-carbon) 4. Building a large new nuclear reactor and waste stores on a beautiful island like Anglesey seems madness in light of serious concerns about the ecology, evacuation plans, and potential rises in sea-level due to climate change "
Other Statutory Consultees
Welsh Government
"Introduction 1.1.1 The Welsh Government has stated that in principle it is supportive of a new nuclear facility at Wylfa in the context of energy security, contribution towards meeting our decarbonisation agenda, and the potential social and economic opportunities that could be provided over its lifetime for future generations. However, this support is conditional on all the potential impacts in relation to key areas of interest to the Welsh Government being sufficiently mitigated, and that in the event that there are any unmitigated costs these do not fall on the Welsh public purse, not least because Wales would be hosting infrastructure that will be of benefit to the whole of the United Kingdom. As noted later within this letter there remain a number of outstanding issues which require resolution. For the record, it is very disappointing that we are in this position when we have actively engaged and been seeking agreement with Horizon Nuclear Power (HNP) on these outstanding issues over the last three years. 1.1.2 The Welsh Government is listed in legislation as a Statutory Party in respect of any Nationally Significant Infrastructure Project in Wales. The relevant planning legislation for Nationally Significant Infrastructure Projects does not prescribe restrictions on the role of the Welsh Government in the Development Consent Order (DCO) process. 1.1.3 Welsh Government has a general power under s60 Government of Wales Act 2006 (“the 2006 Act”) to do anything which it considers is appropriate to achieve the promotion of economic, social or environmental well-being of Wales. Areas of responsibility which are devolved to Welsh Government pursuant to the 2006 Act (as amended by the Wales Act 2017) include; ? Economic development; ? Education and training; ? Environment; ? Health and health services; ? Highways and transport; ? Housing; ? Tourism; ? Planning;and ? Welsh Language. 1.1.4 Welsh Government, as a devolved public body (alongside Isle of Anglesey County Council (IACC)) is also under a duty pursuant to section 3 of the Well-Being of Future Generations Act 2015 (“the 2015 Act”) to carry out “sustainable development”. Consequently, Welsh Government is under a duty pursuant to s3 of the 2015 Act to take all reasonable steps in the exercise of its functions to meet the well-being objectives. Engaging in the DCO process and ensuring appropriate mitigation is secured, is consistent with that duty. 1.1.5 Welsh Government, in conjunction with IACC, has established a ‘Team Wales’ group of organisations that are also bound by the 2015 Act, and who have been engaging with HNP in relation to Wylfa Newydd. The Team Wales group is made up of the following organisations: ? Welsh Government; ? Isle of Anglesey County Council; ? Gwynedd Council; ? Conwy County Borough Council; ? Welsh Ambulance Service Trust; ? North Wales Police; ? North Wales Fire and Rescue Service; ? Public Health Wales; and ? Betsi Cadwaladr Health Board. 1.1.6 The work of the group is ongoing but the principle objective is to develop a collaborative approach to identifying areas of common ground when identifying the baseline environment, the potential impacts from Wylfa Newydd, and appropriate mitigation. 2 Pre-application Engagement 2.1.1 Welsh Government has been consistent throughout the pre-application stage and in our response to HNP’s consultations. All the points set out under the summary of main thematic issues below have previously been identified to HNP. Having reviewed the application documents it appears that in many areas HNP is yet to provide an adequate response to the issues Welsh Government have raised together with appropriate information. Welsh Government looks forward to the provision of this information and the applicant seeking to resolve outstanding issues prior to the examination of the DCO application. 3 Statement of Common Ground 3.1.1 Welsh Government is hosting ten Statement of Common Ground (SoCG) workshops (scheduled 08 August – 31 August 2018) with HNP regarding each of the principal issues that Welsh Government has responsibility for. The purpose of each workshop is to address matters which can be agreed, matters where there is disagreement, and matters where there are ongoing discussions to inform the Examination. The ability to reach agreement is dependent on the extent to which HNP shares further information, particularly in relation to the mitigation package contained in DCO obligations and the s106 agreement which Welsh Government has, to date, not been consulted on. 4 Summary of Main Issues 4.1 Economic development 4.1.1 Wylfa Newydd is one of the largest investments in Wales in a generation and provides the potential to make a significant contribution to the North Wales economy. If the activity of all stakeholders can be aligned the legacy benefit of the project’s investment could be substantial. Conversely, the potential impact of economic displacement in the region arising from the inadequate mitigation of the impacts of such a large development should not be underestimated. Planning Policy Context 4.1.2 NPS EN-1 requires developers to consider environmental, social, and economic benefits and adverse impacts, at national, regional, and local levels during all phases of the development (paragraph 4.1.4 & 4.2.3). It also highlights the need to consider all relevant socio-economic impacts, which may include the creation of jobs and cumulative effects (paragraph 5.12.3). Development should also consider the impact of a changing influx of workers, leading to changes in the local population dynamics and the demand for services and facilities in the settlements nearest to the construction work (including community facilities and physical infrastructure) (paragraph 5.12.3). 4.1.3 It is understood that, as it currently stands, the application will be considered under section 105 of the Planning Act 2008 because the deployment date of the first reactor has been identified as being beyond the 2025 date specified in the current National Policy Statement (NPS) EN-1 and EN-6. It is understood that on this basis the Examining Authority will give significant and appropriate weight to Welsh Planning Policy at National and Local level, and as legislation identifies this will be both important and relevant to the Secretary of State's decision. 4.1.4 The 2015 Act is seeking to create a ‘Prosperous Wales’ and a ‘more equal Wales’. The draft Planning Policy Wales (PPW) 10 (2018) builds on this through highlighting the need for “increased economic activity across all sectors and at all scales” (paragraph 4.6) and “opportunities for people to achieve their potential and by recognising and building on the existing economic strengths of places supporting prosperity for all” (paragraph 4.9). PPW 9 (November 2016) encourages development to “take account of the likely economic benefits including whether and how far the development will help address economic disadvantage” (paragraph 7.6.1). Main Issues and Impacts Supply Chain Development 4.1.5 Supporting the growth of the supply chain in Wales is a key issue for Welsh Government to ensure the provision of a valuable economic legacy well beyond the relatively narrow time parameters associated with the direct investment in site construction. The positive impact of supplier investment will be experienced primarily in Anglesey, in North West Wales, and North Wales – especially in terms of local services. However, the positive impact on suppliers for more specialist products, advanced manufacturing capability, construction and services could result in positive impacts across the whole of Wales, if opportunities are actively and appropriately promoted. 4.1.6 Welsh Government views the local and regional exploitation of supply chain opportunities as being a key objective in our optimisation of Wylfa Newydd benefits in Wales, and a key component in mitigating the potential impacts of displacement. Throughout the DCO documents, HNP have made reference to collaborative engagement with Welsh Government around the development of the Supply Chain Action Plan. Welsh Government wish to make clear that this engagement has not happened, and, consistent with consultation responses provided to HNP since October 2016, Welsh Government maintains its request that HNP: - Provide significantly more detail on how HNP aim to effectively and proactively engage with the Welsh supply chain over the short, medium and long term; - Provide the Supply Chain Action plan, including details of the approach to engagement/governance structure beyond the adoption of the Supply Chain Charter; - Provide information on HNPs strategic view on supply chain development; - Provide detail on how and where HNP aims to highlight supply chain opportunities and how it aims to communicate these opportunities to the supply chain; and ?- Provides a commitment to work with Welsh Government and local stakeholders to; ?- Produce realistic and deliverable targets for local service supply chain contracts; and ?- Develop a monitoring system with input from local stakeholders to scrutinise delivery against commitment. 4.1.7 Despite the assertion in the DCO documents, it is evident that very little practical progress has been made to the development and detail of a Supply Chain Charter and Action Plan. Welsh Government believes there is insufficient detail to be able to comment on the intended supply chain approach in any meaningful way. Digital Infrastructure – Broadband and Mobile Capacity 4.1.8 There is insufficient information on how the risk of disruption of digital networks will be addressed. Businesses and communities who live and work near to Wylfa Newydd and the associated logistics hubs are likely to suffer the effects of network congestion. These effects could have a detrimental impact on local trade, public services, as well as the social well-being of the local population. 4.1.9 Welsh Government has been trying to engage with HNP to agree an approach to understanding the potential impact of Wylfa Newydd on existing digital services. There is no evidence that this issue has been considered in support of the DCO application and it should be explored further as part of the Examination. 4.1.10 In the short term, Welsh Government requests that HNP conduct an urgent audit of existing digital networks infrastructure to fully understand the potential implications of introducing congestion and performance degradation to the existing network. 4.2 Education and training 4.2.1 Wylfa Newydd will provide great opportunities to the economy and communities in North Wales, but it will also bring significant risk to the skills landscape and the local employer base. The risk of displacement of skilled and experienced individuals is significant and could destabilise what is already a fragile economy. Of concern are the potential impacts on Anglesey, Gwynedd and Conwy, and the wider North Wales region and further into Wales. Planning Policy Context 4.2.2 Energy projects should aim to contribute to meeting the need for job creation (paragraph 4.1.3, NPS EN-1) and training opportunities (paragraph 5.12.3). Within the proposals, there should be an assessment on the impact of a changing influx of workers on local population dynamics, social cohesion, and demand for services and facilities (paragraph 5.12.3). 4.2.3 Paragraph 4.4.3 of PPW (Edition 9, November 2016) highlights how planning decisions and proposals should promote access to employment, and should also promote quality, lasting, environmentally sound and flexible employment opportunities to contribute to goals within the 2015 Act. Key factors in the assessment of a project include: ? -The numbers and types of jobs expected to be created or retained on the site; ?- Whether and how far the development will help to redress economic disadvantage or support regeneration priorities, for example by enhancing employment opportunities; and ? -A consideration of the contribution to wider spatial strategies, for example for the growth or regeneration of certain areas. (Paragraph 7.6.1, PPW 9). 4.2.4 The Welsh Ministers are responsible for the provision of proper facilities for education and training for persons aged 16 to 19 and reasonable facilities for persons over 19 (s31, Learning and Skills Act 2000). Main Issues and Impacts 4.2.5 Welsh Government welcomes the following inclusions of the Wylfa Newydd Employment and Skills Service (WNESS) and Flexible Skills Fund which have been proposed as mitigation within the Jobs and Skills Strategy (Application Document 8.3) (J&SS). Welsh Government also welcomes: - An increase in the percentage of the operational workforce being home-based, thereby maximising opportunities for the local population whilst reducing the impact to tourism, housing and Welsh Language; - HNPs commitment to and investment in apprenticeships, recognising apprenticeships as being a fundamental career path at Wylfa Newydd; - Investment in the WNESS; - Investment of £1m to the Engineering Centre at the Llangefni Campus of Gr?p Llandrillo Menai (GLLM); and - Engagement with the education sector. 4.2.6 However, the J&SS does not provide any assurances that there is a clear plan in place (including clear timings and trigger points) to deliver the commitments outlined above or that the mitigation proposed properly addresses the main concerns pertinent to Welsh Government. The main topics of interest that still require further clarification and evidential support have been set out below; - Insufficient information provided on the types of roles/skills required/number of people in the construction of Wylfa Newydd to allow an effective education and skills response to be put in place, in particular in the further education sector; - Lack of a Supply Chain Plan; without this, Welsh Government fails to see how the risk of displacement can be properly assessed. Its absence also ignores the needs of the local employer base in the region; - Lack of detail about the monitoring arrangements of the construction phase through the Supply Chain Service (for the number of local employers who successfully gain contracts at Wylfa Newydd). Key questions around contingency plans and implementation of mitigation strategies have not been answered; - The J&SS focuses on the construction and engineering sectors; however, skilled employees will be lost from other sectors, being particularly attracted to the roles that can be included in ‘site services’. Sectors likely to be impacted include (but are not limited to): social care, tourism, agriculture, and hospitality. - The assumptions around the employment demand from within the Daily Construction Commute Zone (DCCZ) and payment terms (and terms and conditions of employment) for construction employees will need to be investigated further with HNP. HNP have changed their position in terms of only paying salaries and rates in accordance with those outlined in the National Agreement for the Engineering Construction Industry (NAECI). Further information is required to understand the scale of the risk of displacement that may result from this change in approach; - Skills Fund: There is insufficient information about the nature of the fund, how much it will cost, how it will be managed, when it will be available and for how long, and who makes decisions on accessing the fund; - WNESS: Welsh Government has asked for clarification about the long-term funding of this initiative and specific parameters, this is still not clear with the J&SS. Welsh Government would also like assurance that the problems the WNESS encountered during the pilot phase are now resolved and that it is currently operating successfully, and has resulted in placing people into jobs with contractors already on site. Without this assurance, Welsh Government remains to be convinced that this is a suitable mitigation measure; - There is a lack of commitment from HNP to encourage local people into the higher skilled roles at Wylfa Newydd. Welsh Government expects commitment to up- or re-skilling local people to gain higher level jobs during the construction phase and clearly the timing of these measures will be vital; - From discussions with HNP, an assumption had been made that a percentage of non-home-based workers will be required from outside the United Kingdom. The J&SS does not provide any contingency planning for the potential impacts of BREXIT on the workforce demographic; and - The cumulative impacts on the displacement of the local workforce because of other large infrastructure projects across the United Kingdom has not been considered as part of the socio-economic impact assessment (Application Reference 6.3.1). 4.2.7 Welsh Government want to work with HNP and other stakeholders to ensure that opportunities for local people and the employer base are maximised and displacement impacts are mitigated wherever possible. At this stage, Welsh Government does not feel assured that the Jobs and Skills Strategy (and associated Skills Fund) adequately protects the North Wales region from these risks. 4.3 Environment 4.3.1 Welsh Government recognise that the special and unique characteristics of the natural and built environment need to be protected for scenic, aesthetic, historic and nature conservation reasons. Wylfa Newydd will have an impact on the historic environment (registered park and garden and archaeology), air quality, flooding, and waste, and Welsh Government has a commitment to monitor, manage and reduce the impact of development on natural and built environment. 4.3.2 These representations made by Welsh Government interests are separate to any that are made by Natural Resources Wales. Planning Policy Context Historic Environment 4.3.3 Consideration of the Historic Environment as well as the Landscape and Visual Impact of an energy project is set out in section 5.8 and 5.9, respectively, of NPS EN-1; “there should be a presumption in favour of the conservation of designated heritage assets” (para 5.8.14) and “any harmful impact on the significance of a designated heritage asset should be weighed against the public benefit of the development” (para 5.8.15). 4.3.4 The Welsh Government has an objective to “protect, conserve and promote the historic environment as a resource for the general well-being of present and future generations” (paragraph 5.79, draft PPW 10). Cadw’s published Conservation Principles highlight the need to base decision on an understanding of the impact a proposal may have on the significance of an historic asset. 4.3.5 Paragraph 6.5.26 of PPW (Edition 9, November 2016) refers to the effect of a proposed development on a registered park or garden or its setting should be a material consideration in the determination of a planning application. Paragraph 7.1 – 7.4 of Technical Advice Note (TAN) 24: Historic Environment refers to the Register of Historic Parks and Gardens in Wales, and highlights that there should be understanding the impact a proposal is likely to have on such a historic asset. Air Quality and Noise 4.3.6 Welsh Government policy is clear that the requirements of 2015 Act, as interpreted by the latest air quality, planning and noise guidance mean that the approach should extend beyond simply compliance with legal limits. In addition, the 2017 statutory policy guidance on local air quality management in Wales and the Welsh Government’s draft Noise and soundscape action plan 2018-2023 (currently in consultation) state a clear expectation that public bodies in Wales will follow the five ways of working when undertaking air quality, noise and soundscape management. Flooding 4.3.7 PPW (Edition 9, November 2016) provides the framework for the assessment and management of flood risk for new developments. Technical Advice Note (TAN) 15: Development and Flood Risk states that new development should not increase flooding elsewhere; and that consideration must be given to the impacts climate change may have on the risk of flooding over the lifetime of a development. Waste 4.3.8 PPW (Edition 9, November 2016) sets out the policy context for Welsh Government to help in delivering their objectives for waste management. PPW and Technical Advice Note (TAN) 21 (2014) seek to provide targets and policies for implementing the Welsh Government’s overarching waste strategy ‘Towards Zero Waste – One Wales: One Planet’, which sets out a long-term framework for resource efficient and waste management in Wales up until 2050. 4.3.9 The Construction and Demolition Sector Plan (2012) supports ‘Towards Zero Waste’, by detailing outcomes, policies and delivery actions for the construction and demolition sector in Wales. Water supply and sewerage 4.3.10 PPW 9 (November 2016) states that development should promote increased efficiency and demand management of water resources, considering the effects that a changing climate may have over the lifetime of development. The draft PPW10 highlights that “new development should be located and implemented with sustainable provision of water services in mind, using design approaches and techniques which improve water efficiency and minimise adverse impacts of water resources” (paragraph 5.159). Main Issues and Impacts Historic Environment 4.3.11 There is a major adverse impact identified on Cestyll registered historic park and garden and its setting (Application Reference 6.4.11). HNP have provided insufficient evidence to identify the extent of these impacts of the development on Cestyll. 4.3.12 Greater detail should be provided on how the design of the proposed landscaping (mounding, tree planting, restoration of field boundaries) within the current essential setting has been informed by the impact on the registered park and garden. Visualisations are requested to show how the power station will appear in views adjacent to the southern extent of the Cestyll and would inform a landscaping scheme for this area. Further clarification is required on how the valley garden will be accessed if the historic access is removed through the proposed landscaping mound/bank. 4.3.13 There are nationally important archaeological remains and features that are likely to meet the criteria for scheduling designation. The research value in excavating these remains is considered high, and as such, Cadw is satisfied that a programme of archaeological excavation is appropriate in this instance. Designation of these sites and features remains a possibility if for any reason they are not appropriately dealt with as part of the proposed development programme. An agreed archaeological excavation and recording programme is required which will need to be adhered to and completed prior to the Examination. It is essential that HNP commit to the post-excavation work programme and the subsequent archiving and dissemination/publication that will be required. Air Quality 4.3.14 Mitigation measures for air quality are proposed within the DCO application. The proposed measures will be implemented during the construction phases where it is anticipated the greatest effects will occur. Flooding 4.3.15 The FCA has identified a higher risk of flooding to residential properties upstream of Cemaes village during the construction and operation of Wylfa Newydd. Further mitigation will need to be identified to address these risks. 4.3.16 There is also a risk of flooding on the proposed Dalar Hir Park and Ride site. Details of further mitigation has not yet been provided. Waste 4.3.17 Further clarification is still required to explain why the volume of waste from construction and demolition has increased by 50,000 tonnes, when the number of buildings on site is reducing and more opportunities are being pursued for modular off-site construction. The Waste Hierarchy needs to provide greater detail on how the waste arisings, both from construction and demolition, and domestic, food and recycling waste from the temporary worker accommodation are to be dealt with. 4.3.18 All waste is proposed to be transported on the road network. It is not clear whether the trip generation associated with the waste tonnage have been included within the Transport Assessment modelling work. It is understood that this is based on one-way trips travelling up to the site via Parc Cybi. Water supply and sewerage 4.3.19 Welsh Government require further information in relation to water supply and water stress before being satisfied on these issues. 4.4 Health and health services 4.4.1 In line with the 2015 Act, it is essential that Wylfa Newydd does not have an adverse effect on health and well-being. This includes physical, mental and social well-being of both the Wylfa Newydd workers and local population. There is a need to ensure that an increase in population during the construction phase does not lead to a reduction and/or deterioration in the access and quality of services for the local communities and population of North Wales. Planning Policy Context 4.4.2 Proposals for energy projects may “affect the composition, size and proximity of the local population, and in doing so have indirect health impacts, for example if it in some way affects access to key public services” (NPS EN-1, paragraph 4.13.4). Paragraph 4.13.2 of the NPS EN-1 highlights that energy projects will have direct impacts on health through increased traffic, air or water pollution, dust, odour, hazardous waste and substances, noise, exposure to radiation, and increases in pests. 4.4.3 Paragraph 4.4.3 of PPW (Edition 9, November 2016) demonstrates that the Welsh Government considers the protections, and where possible, the improvement of people’s health and well-being as a core component of achieving the well-being goals. Main Issues and Impacts 4.4.4 Whilst reference has been made in the DCO to comments raised by Welsh Government in PAC2 and PAC3, there are still many areas that will require detailed discussions and agreement with partners to address concerns and confirm appropriate mitigation. Welsh Government’s main areas of outstanding concern relate to: - Additional work needed to define the final list of services that would make up the Site Campus Medical Centre occupational health and primary care and provision of emergency services; - Further details on when the medical centre will be provided and the interim arrangements until the facility is operational; - Confirmation that costs of NHS prescriptions that are free of charge in Wales will be covered for the construction workforce; - Further evidence of a process to agree indicators for monitoring the construction workforce access to community healthcare services and evidence of how HNP will work with BCUHB, WAST, and PHW on forecasts and detailed planning; - Section c.6.15 of the Health Impact Assessment incorrectly states that General Practice funding follows the population. Funding for dependents should be provided in full and not as proposed by HNP as a lag in funding; and - The Health Impact Assessment does not consider impact on the movement/displacement of the region’s existing workers, particularly for health and social care community services. The assessment notes a mitigation measure to support IACC and BCUHB in the development of their workforce strategies. However, this will require further evidence gathering and additional mitigation measures, for example related to skills and training. 4.4.5 Welsh Government’s firm position is that mitigation of any health impacts arising from the development should not fall on the public purse. Without the information requested of Horizon outlined in a letter to them in March 2018, as well as the PAC2 and PAC3 response, Welsh Government is not able to properly assess and reach agreement on: - The effect of the construction workforce on demand for primary and secondary healthcare services and emergency services; - The effect of the construction workforce on demand for subsidised healthcare services, including prescribed medication, dental, and optical health services; - The effect on local community health and well-being because of hosting large numbers of workers during the construction period, especially in relation to vulnerable groups; - The effect of the well-being and health of the construction workforce housing in temporary worker accommodation in a remote exposed location; - The effect of the local resident population because of cumulative amenity impacts arising from lighting, noise, traffics, dust, and workforce population changes during construction; and - Proposed mitigation measures for safeguarding in relation to vulnerable groups; - Proposals for monitoring arrangements including independence, development of the baseline information and timeline for setting in place. 4.5 Highways and transport 4.5.1 The impact of the increased volume of construction and operational traffic due to Wylfa Newydd will exacerbate existing congestion on the trunk road network, potentially creating new areas of congestion and generally have a negative impact on road users, including response times of the emergency services. This could have a knock-on impact on the local economy and health services and will increase maintenance costs especially on Welsh Government owned infrastructure such as the Britannia Bridge. Planning Policy Context 4.5.2 Energy projects should recognise that the transport of materials, goods and personnel to and from a development during all project phases can have a variety of impacts on the surrounding transport infrastructure and potentially on connecting transport networks (NPS EN-1, paragraph 5.13.1). Where cost-effective, water-borne or rail transport is preferred over road transport at all stages of the project (NPS, EN-1, paragraph 5.13.10). Section 3.15 of the NPS EN-6 highlights the significant impact which a nuclear project will have on infrastructure and resources, particularly for the local consideration. 4.5.3 PPW (Edition 9, November 2016), paragraph 8.3.3 encourages the use of Park and Ride to improve the relative attractiveness of public transport and reduce the overall dependence on cars; this can be considered as a key element of a comprehensive planning and transport strategy. Main Issues and Impacts 4.5.4 Welsh Government has continued to raise concerns about the following issues: - Transporting construction workers: There is a need to further investigate ways to reduce the impact on the road network; - Capacity of network to cope with worker and construction traffic and all the associated development traffic required to construct offline A5025, Marine Offloading Facility (MOLF), and Dalar Hir Park and Ride site; - Capacity and travel patterns of worker accommodation to cater for the envisaged 4000 workers prior to the construction of the Site Campus and Dalar Hir Park and Ride site to include sensitivity to changes of shift patterns; - The assumptions around car sharing, the management of the scheme, and the appropriateness of the management tool; - Transporting materials: Impact of road freight traffic on the network; - Clarification on management of operational workforce during outage periods; - A55 Trunk Road junction capacity assessment, J1-11; - Broadening the catchment of home base workers; - Impact on Britannia Bridge; - Provisions to support bus shuttle services; and - Resilience of logistic centre during incidents on the network. 4.5.5 Welsh Government has requested further evidence in the following areas: - Traffic modelling: Clarification of where non-work trips (those made by non-home-based workers outside working hours) are included how such trips would be made in a rural location if cars must be left at the park and ride site; car sharing factors generally; mode share and car occupancy for weekend trips home; shift assumptions; use of ‘quarter 3’ flows; junction modelling outside the peak highway hours; - Early years assessment and lack of commitment to the MOLF: An Early Years scenario, which does not include the MOLF, should be assessed, and a worst-case scenario of peak construction traffic in the absence of a MOLF should be included in the Transport Assessment; - Cumulative assessment of the impacts of both Wylfa Newydd and North Wales Connection: Further information of how trip generations associated with the National Grid application have been included in the modelling; - Britannia Bridge: How has construction traffic associated with the Third Menai Crossing been included in the Early Years Assessment and how/whether it has been included in the peak construction year assessment; - Gravity Model: How the number of workers in the five residential locations have been derived from the Gravity Model; how the proportion using bus has been assessed; and location of operational staff; - Travel Plan and Traffic Management: Further evidence will be needed to demonstrate how car sharing will be managed in practice; - Commitment to use Holyhead Port to reduce freight traffic on the strategic highway network; - How will empty HGVs be marshalled on site to ensure that there is no negative impact on the strategic highway network; - Disposal of waste impact, scenarios for different options and how it will impact on the strategic highway network; - Updated methodologies for Traffic Incident Management Strategy, Construction Traffic Management Strategy, Operational Travel Strategy, and Operational Delivery Service Strategy; and - Commitment to contributing to and utilising additional Park and Ride / Park and Share facilities and shuttle bus service. 4.6 Housing 4.6.1 Welsh Government is concerned about the impact of Wylfa Newydd on the housing market and those seeking accommodation (construction workers and the local community) and that this will extend across the Key Socio-economic Study Area (KSA) and potentially into other parts of North Wales. Planning Policy Context 4.6.2 NPS EN-1 states that the Examining Authority should consider social and economic benefits and adverse impacts, at national, regional, and local levels (paragraph 4.1.4). The Environmental Statement submitted as part of the proposals should cover the environmental, social and economic effects arising from pre-construction, construction, operation and decommissioning of the project (paragraph 4.2.3). 4.6.3 The provision of housing and accommodation as part of an energy proposal should “consider all relevant socio-economic impacts which may include the impact of a changing influx of workers, during the different construction, operation and decommissioning phases of energy infrastructure” (paragraph 5.12.3). 4.6.4 Paragraph 3.20 of draft PPW 10 highlights the role the planning system plays in enabling “provision of a range of well-designed, energy efficient, good quality market and affordable housing that will contribute to the creation of sustainable places”. Paragraph 9.2.1 of PPW 9 sets out several considerations which must be taken account of in the provision of new housing, notably local housing and community strategies, the needs of the local and national economy, and the capacity of an area in terms of social, environmental and cultural factors (including consideration of Welsh language) to accommodate more housing. Main Issues and Impacts 4.6.5 Welsh Government has consistently raised concerns with HNP about the development of the Workforce Accommodation Strategy for Wylfa Newydd. The inadequate consideration for the accommodation of the construction workforce could give rise to several adverse impacts, including: - Pressure on the local housing stock (particularly the private rented sector, and tourist accommodation), this would adversely affect the local community and local tourist economy; - Reduced provision and choice of accommodation for local households at an affordable price (both first time buyers and those wishing to rent privately); and - Risk of displacement and homelessness within the local community (including Welsh speakers). 4.6.6 Whilst the concept of the Workforce Accommodation Strategy (Application Reference 8.4) is supported, Welsh Government and its partners have made consistent representations to HNP in relation to the following concerns: - A lack of contextual understanding of the current housing situation in the KSA and North Wales, including capacity of the housing sectors to accommodate works; - Fully sourcing and evidencing the data relied upon to inform the strategy and the methods/approaches used for the figures that have been derived; - A lack of contingency planning should any assumptions about the distribution of workers amongst accommodation types not reflect the modelled assumptions; - The proposed reliance on the CWAMS is at a very high level and does not set out a clear framework to how supply will be switched on/off within a sector. The control mechanisms and monitoring arrangements also need to be identified; and - The need for triggers and requirements to deliver phases of on-site temporary worker accommodation, and how the uptake of accommodation will be monitored over time. - A lack of robust planning regarding the role to be played by the Temporary Workers Accommodation including the absence of detailed plans designed to encourage as many workers as possible to select this accommodation option to minimise the impact the workers will have on housing pressures across the region. 4.6.7 A Housing Fund has been proposed to “enable the local authorities to boost the supply of housing, including affordable housing, provide support for residents needing access to housing services; and boost enforcement”. The Workforce Accommodation Strategy does not include any details about the scale of the Housing Fund, the capacity to extend the fund through a contingency fund if more is needed, and the way the fund is to be accessed or managed. 4.7 Tourism 4.7.1 The tourism sector is key to the economic and social well-being on Anglesey and North Wales. The IACC economic impact model (STEAM) estimates that Anglesey’s economy alone currently benefits by some £304m annually from Tourism. This figure is from 2017. Planning Policy Context 4.7.2 Section 11 of PPW (Edition 9, November 2016) sets out the importance of tourism as an economic driver in Wales. Welsh Government’s aim is “for tourism to grow in a sustainable way and to make an increasing contribution to the economic social and environmental well-being of Wales” (paragraph 11.1.2). 4.7.3 PPW also states that “in rural wales, tourism-related development is an essential element in providing for a healthy, diverse, local and national economy” (para 11.1.7). Tourism is also recognised as an economic driver in rural areas in Technical Advice Note 23 on Economic Development (2014). Main Issues and Impacts 4.7.4 Welsh Government recognise that the construction and operation of Wylfa Newydd is likely to have significant effects on the tourism sector in Anglesey with wider impacts felt within Gwynedd and Conwy. It is the objective of Welsh Government to ensure mitigation for the tourism sector from both the short and long term adverse impacts associated with Wylfa Newydd, and continue to grow a world-class tourism sector. 4.7.5 Welsh Government and its partners have made consistent representations to HNP about the evidence base, assumptions, and potential impacts of Wylfa Newydd on the tourism sector in Anglesey and the wider area. The following concerns are still outstanding: - The impact of the demand of temporary construction workers on the supply and viability of tourism accommodation stock. Welsh Government believe there is a clear disparity between available bed-stock and estimated demand as evidenced by IACC Accommodation Bedstock Survey June 2018. This will result in a shortage in tourism accommodation and a direct adverse impact on the housing stock on Anglesey and more widely; - Further consideration must be given to the wider impacts on tourism. For example, the impact on accommodation, attractions, events and activities on the island itself and wider North Wales region; - The impact on employment and skills within the tourism sector has not been assessed. The risk of displacing hospitality skills has not been considered in any detail; - Impacts on the short- and long-term perception of Anglesey and North Wales as a high-quality tourism destination; -The implications on tourist visitors (both overnight and day visitors), both during the construction period and longer term. Welsh Government is concerned about potential traffic congestion and its adverse impact on tourism in the long-term through potential visitors staying away; - The extent, role, and governance structure of the Tourism Fund and introduction of a Tourism Action Plan, and whether they are sufficient to be able to deliver the activities needed to ensure the long-term sustainability and growth of the tourism sector. Without a draft Tourism Action Plan and further detail on the Tourism Fund, the Welsh Government is unable to properly consider the adequacy of any proposed mitigation. 4.8 Welsh Language 4.8.1 The Welsh language is part of the social and cultural fabric of Wales. Welsh Government, through Cymraeg 2050: Welsh language strategy, is committed to increasing the number of Welsh speakers, increasing the use of Welsh, and creating favourable conditions for Welsh language and culture through strategic frameworks, programmes, and planning policy. Planning Policy Context 4.8.2 New energy infrastructure may affect the composition, size and proximity of the local population (paragraph 4.13.4, NPS EN-1) and proposals should consider all relevant socio-economic impacts at a local and regional level, which may include changes to the local population dynamic and effects on social cohesion depending on how populations and service provision change (section 5.12, NPS EN-1). 4.8.3 Welsh Government’s position is further highlighted within their Welsh planning policy and guidance. Paragraph 2.47 of draft PPW 10 (2018) states that the land use planning system should take account of the conditions which are essential to the Welsh language and in so doing contribute to its well-being and use. Development should contribute positively to the well-being of the Welsh language and ensure any negative impacts on the use of the language are mitigated (paragraph 4.4.3, PPW 9). Main Issues and Impacts 4.8.4 Welsh Government has acted as an observer to the Welsh Language Impact Assessment (WLIA) Steering Group throughout the development of the DCO application. Welsh Government have worked in collaboration with HNP to develop the Welsh Language Risk Assessment Framework. 4.8.5 Welsh Government welcome the 24 mitigation measures proposed in the Welsh Language Impact Assessment (Application reference 8.21) which have been developed with the Steering Group but further detail and discussions are required with HNP before Welsh Government can come to an agreement. 5 Crown Land 5.1.1 Welsh Government notes from studying the Book of Reference that Horizon have included parcels of land belonging to Welsh Ministers or the National Assembly for Wales upon which they wish to acquire rights. There has been an oversight as these have not been identified as being Crown Land and are not categorised under the Crown land section of the Book of Reference. 5.1.2 Section 85 (2) and (3) of Government of Wales Act 2006 states: “(2) References in any enactment to property vested in or held for the purposes of a government department is to be construed as including references to property vested in or held for the purposes of the Welsh Ministers, the First Minister or the Counsel General (and in relation to property so vested or held the Welsh Ministers, the First Minister or the Counsel General are each deemed to be a government department for the purposes of any enactment).” (3) In this section “enactment” includes a future enactment.” 5.1.3 Consequently, we would wish to draw the Examining Authority’s attention to the fact that under s135 of the Planning Act 2008 the developer has not made a formal approach seeking Welsh Ministers consent for these rights. 6 Conclusion/ Expectations 6.1.1 In conclusion, we would welcome early sight of the information identified above and the opportunity to resolve the outstanding issues we have identified. This will involve Welsh Government being offered an active and ongoing role in the negotiation of section 106 obligations and DCO requirements as part of the Team Wales approach to secure necessary mitigation with immediate effect on issues raised in this representation. As will be noted, for many topic areas impacts will be felt across North Wales as a whole and beyond a single local authority boundary and we should be addressing these impacts now, in particular those relating to supply chain, education and training."
Members of the Public/Businesses
Bryngwran Cymunedol Ltd
"Our representation is based on concerns about the possible effects of the Wylfa development on 3 main areas 1. Possible effects of increased Traffic flow through the village of Bryngwran related to the Dalar park and ride proposal 2. Possible effects on house prices/availability of rented housing due to influx of Wylfa construction workforce 3. Possible negative effects on the Welsh Language both in the short and longer term on the village of Bryngwran and Anglesey generally due to influx of large numbers of non-Welsh speaking workers during and after construction phase (e.g possible effects on local School etc). "
Members of the Public/Businesses
Jennifer Wilson
"I wish to object to the proposed Wylfa nuclear project because:- The site is adjacent to a SSSI and SPA which is renowned for its breeding Tern colony this will undoubtedly suffer from the construction and then subsequent operation of the Nuclear Power Plant. It is well known that Horizon's safety record is very poor. The UK government should not allow a company with a negligent safety record to operate a nuclear power station in the UK. The carbon footprint of a nuclear power station during construction plus the mining, milling and processing of uranium is extremely high, taking years of operation for its C02 levels to average out. I believe this could mean the UK will not make its carbon targets over the next ten to fifteen years. There is still no safe proven way to store radioactive waste anywhere in the world. It is immoral of UK government to embark on a plan to create more radioactive waste for future generations to deal with. The government should not proceed with these proposals as there are recent studies which show the links between low level radiation and health risk especially to unborn and young children. It is well known that private investors are not interested in Nuclear Power because the financial risks are enormous. As a taxpayer I object to the government using taxpayers funds to prop up ailing foreign companies nuclear ambitions. This also puts the taxpayer funds at risk if a nuclear accident was to occur. If Horizon became insolvent the consequences for the taxpayer could be huge. As an electricity bill payer I have chosen a provider that does not sell electricity produced by nuclear power. I want to support the methods of electricity production that have the least damaging environmental impact nuclear is not one of them. If my taxpayers funds are used to support this project you have taken this choice away from me. It well known that electricity produced by nuclear power is far more expensive than that produced by renewables. The government deal for HPC has been widely criticised. Using taxpayers money to reduce the cost to bill payers does not actually result in the UK population receiving the cheapest electricity. It has been shown more employment opportunities would arise from an equivalent investment in renewable technologies. Choosing to do this would also mean there would be less health, environmental and financial risks and we would not be adding to our lethal stockpile of radioactive waste. "
Other Statutory Consultees
North Wales Fire and Rescue Service
"The volume of documentation submitted, by Horizon, to support the DCO application is extensive in nature but lacks any detail or clarity on the issues that have been raised by North Wales Fire & Rescue Service (NWFRS) throughout the pre-consultation stages. NWFRS is submitting a considered representation of the key issues which it believes will impact upon the services it delivers to the communities of North Wales. North Wales Fire and Rescue Authority (“the Authority”)(NWFRA) is required to make provision to meet “normal” requirements in the area it serves (Part 2 Section 7(1)(2), 8(1)(2) of the Fire and Rescue Services Act 2004). In addition to this the Authority must also comply with the requirements of The Well-being of Future Generation (Wales) Act 2015. In discharging its duties the Authority must do so in a context of severe medium to long-term pressures on public finances. The functions of the Authority are discharged by North Wales Fire and Rescue Service (“the Service”)(NWFRS). The Service understands that it is Welsh Government’s view that Nationally Significant Infrastructure Projects, such as Wylfa Newydd, should not have any adverse impact on the public purse. On the basis of current available information, NWFRS believes that the main works involved in the Wylfa Newydd development go beyond the “normal” requirements of its statutory obligations and raises risks that will place additional demands on the Service. The Service is of the opinion that the scale is such that, unless the developer provides additional funding and/or mitigation, that there will be a cost implication passed on to the Council Tax payer. The identified risks include: Operational Response • An increase in traffic including large vehicles that will have an adverse impact on response times and mobilisation of resources to incidents across North Wales. • An increase in the number of incidents attended as a direct result of the development. • Additional risks that NWFRS personnel may require training for, such as maritime incidents and rescue from height. Staffing • The loss of NWFRS staff to roles in the new development which could impact both frontline and support functions. Recruitment and retention of retained duty system personnel is already a challenging issue. • A significant impact on time and resources in order to provide liaison with Horizon and respond appropriately to the consultation process and beyond. Organisation • An increase in fire safety audit/enforcement activity as a result of the construction and operation of the site. • An increase in prevention work with the existing community, some of whom may be displaced in favour of construction workers, and the migrant workforce. • Communication systems currently include Airwave and mobile telephony. This is due to be replaced by a new system and assurance will be required that this will include coverage for the site both during construction and operation. Operational response, protection and prevention activities are the key focus for the Service. The development will inevitably have an impact on the Service which, without the provision of additional resources, will impact on the current service to all sectors of the community and/or have a financial impact. "
Members of the Public/Businesses
Aled Naylor
"Can you provide clear evidence that this will have no affect on local flooding? To local farm users and property in the near by area? Will the water course be affected in anyway? Ditches that come from the village to help with flooding will not be affected in anyway ? due to a new wetland area being exacavated. "
Members of the Public/Businesses
Amlwch and Cemaes Youth Club
"We are a group of young people who go to Amlwch and Cemaes youth clubs. Will local people get jobs? Slower journeys due to an increase in traffic on the roads Noise / pollution / dust / lighting how will this be dealt with? More people moving to the area - Building more homes? More people coming to visit the island and see the projects - an increase in tourists More kids in schools will they be able to cope More traffic on the roads What will happen to nature/ environment? Questions to Horizon Will we be able to see the archaeological finds? How much pollution will be in the air? Is it a risky process? How will delays in the timeline be managed? How will the sea/water quality be affected? Will there be a visitor centre? Will the visitor centre be interactive? What kind of job opportunities will be available? How will electricity supply be managed during construction? Will you be providing Welsh lessons / encouraging people who move here to learn Welsh? How will you make sure that young people are trained to be able to work there? What types of jobs will be available? "
Members of the Public/Businesses
Andrew Robert Patience
"*How and why has this work begun in advance of a planning decision to proceed with Wylfa Newydd at all? Neither the preliminary work nor the proposed subsequent main work is not even listed in the 'Wylfa Newydd Project 6.1.2 ES Volume A - Introduction to the project and approach to the EIA A2 - Project overview and introduction to the developments' document published in June 2018. * Some villagers are concerned at the apparent lack of notice that the preliminary works were to occur with access via a small narrow lane. Only one small sign at an out-of-village intersection. Why were public consultation events not held in our village to show what works were to be undertaken? * Preliminary work has begun, seemingly without notice to villagers, including neighbours, immediate or otherwise, with no signage on site indicating timescale, purposes, etc. I was told on the telephone by a Horizon representative that these were to last 10-12 weeks. * Public footpaths run through the fields outlined in the proposal. Wylfa Newydd Project Consultation on Additional Land Main Consultation Document’ PEI states on p30: ‘During construction the footpaths would likely either be temporarily stopped up or diverted to allow the topsoil layer to be removed’. Who will make the decision about closure / diversion, and for how long? *There are huge concerns amongst residents (aka ‘Human Receptors’) that 20,000 cubic metres of earth will be 'taken off site' through the village, either now, or in 3 years after completion of the work. To quote from the same document mentioned above: ‘To inform this consultation exercise, two options for spoil management have been presented: Wylfa Newydd Project Main Consultation Document Consultation on Additional Land Option 1 – All topsoil is stockpiled on site for up to three years before being transported off-site for use elsewhere; and Option 2 – All topsoil is transported off site for use elsewhere after it is stripped from the site.’ So, all removed topsoil will be transported off-site. It’s just a question of when…calculating a full load of 15 cubic metres per tipper lorry load, that will mean 1300+ full lorry loads of earth being transported through the village, with 1300+ empty lorries travelling to the site before loading. A total of 2600 lorry journeys! *The traffic impact assessment on the village appears to be a model of optimism about managing the traffic. ‘Traffic volume increases associated with construction plant and worker movements are unlikely to be high enough to result in significant adverse effects. Managing the number and timing of lorry movements taking spoil from the site would ensure significant adverse effects are avoided’. *The main focus on moving 20,000sqm of soil seems to be financial: ‘Option 1: Topsoil would be stripped and stored on the site, potentially being lost as a resource’, and ‘Option 1: There is likely to be a potential significant adverse effect associated with loss of the topsoil resource’(p42) * Where is the evidence that the likely environmental benefits of the fen improvement scheme will outweigh the carbon costs associated with 2600 diesel lorry movements, plus all the personnel traffic, earth-moving and other equipment etc needed to remove / extract the soil? * Is there an impact assessment on the possible likely negative effects or consequences upon adjoining land, and neighbours, once the work is completed, such as drainage, flooding, etc.? "
Members of the Public/Businesses
Cheryl Weaver
"Section 2.3.1 of EN-5 states “… the Planning Act aims to create a holistic planning regime so that the cumulative effects of different elements of the same project can be considered together. Therefore the Government envisages that applications for new generating stations and related infrastructure should be contained in a single application. National Grid and Horizon have not done this, and have not considered one project mitigating impacts of the other. Horizon could bury the connection for only 3% more budget "
Members of the Public/Businesses
CYNGOR CYMUNED PENMYNYDD on behalf of CYNGOR CYMUNED PENMYNYDD
"Mae Cyngor Bro Penmynydd yn cynrychioli ardal a effeithir yn uniongyrchol gan y llwybr trosglwyddo a byddwn yn cyflwyno tystiolaeth uniongyrchol o effaith hynny ar y gymuned. Byddwn hefyd yn cyflwyno barn am yr iaith Gymraeg ac effaith y datblygiad ar y gymuned hon. Mae gennym sylwadau pellach i’w cyflwyno am drafnidiaeth, sydd eisoes yn achosi problemau sylweddol ac a fydd yn cynyddu ar sail y datblygiad hwn. "
Members of the Public/Businesses
John Idris Jones
"- Lle trydan o ynni niwclear : yn rhan o'r gymysgfa o ffynhonellau ynni carbon isel sydd ei angen ar gyfer y dyfodol ac i leihau y posibilrwydd o effeithiau newid hinsawdd - Pwysigrwydd datblygiad Wylfa i ddyfodol economaidd-gymdeithasol a ieithyddol Ynys Mon - Yr angen am waith i bobl leol i sicrhau cymdeithas leol gref yng ngogledd orllewin Cymru - yr angen am brentisiaid lleol - yr angen i sicrhau nad yw y datblygiad yn dod ag effeithiau negyddol hir dymor i'r gymraeg a diwilliant leol. Yr angen am weithredu pwyntiau gweithrediu i liniaru effeithiau ac i sicrhau bydd yr iaith a'r dn diwilliant yn cael ei gryfhau gan y datblygiad - Pwysigrwydd datblygiad Wylfa Newydd i hybu economi gogledd Cymru - yr angen am gadwyn gyflenwi gref yng ngogledd Cymru ac Ynys Mon a'r angen i Horizon, Llywodraeth Cymru a cynghorau gyd-weithio i sicrhau ffyniant hir dymor y gadwyn gyflenwi - y potential i greu canolfan o ardderchogrwydd yng ngogledd orllewin Cymru ar gyfer cynhyrchu trydan o ynni carbon isel"
Members of the Public/Businesses
Talwrn Village Hall
"*How and why has this work begun in advance of a planning decision to proceed with Wylfa Newydd at all? Neither the preliminary work nor the proposed subsequent main work is not even listed in the 'Wylfa Newydd Project 6.1.2 ES Volume A - Introduction to the project and approach to the EIA A2 - Project overview and introduction to the developments' document published in June 2018. * Some villagers are concerned at the apparent lack of notice that the preliminary works were to occur with access via a small narrow lane. Only one small sign at an out-of-village intersection. Why were public consultation events not held in our village to show what works were to be undertaken? * Preliminary work has begun, seemingly without notice to villagers, including neighbours, immediate or otherwise, with no signage on site indicating timescale, purposes, etc. I was told on the telephone by a Horizon representative that these were to last 10-12 weeks. * Public footpaths run through the fields outlined in the proposal. Wylfa Newydd Project Consultation on Additional Land Main Consultation Document’ PEI states on p30: ‘During construction the footpaths would likely either be temporarily stopped up or diverted to allow the topsoil layer to be removed’. Who will make the decision about closure / diversion, and for how long? *There are huge concerns amongst residents (aka ‘Human Receptors’) that 20,000 cubic metres of earth will be 'taken off site' through the village, either now, or in 3 years after completion of the work. To quote from the same document mentioned above: ‘To inform this consultation exercise, two options for spoil management have been presented: Wylfa Newydd Project Main Consultation Document Consultation on Additional Land Option 1 – All topsoil is stockpiled on site for up to three years before being transported off-site for use elsewhere; and Option 2 – All topsoil is transported off site for use elsewhere after it is stripped from the site.’ So, all removed topsoil will be transported off-site. It’s just a question of when…calculating a full load of 15 cubic metres per tipper lorry load, that will mean 1300+ full lorry loads of earth being transported through the village, with 1300+ empty lorries travelling to the site before loading. A total of 2600 lorry journeys! *The traffic impact assessment on the village appears to be a model of optimism about managing the traffic. ‘Traffic volume increases associated with construction plant and worker movements are unlikely to be high enough to result in significant adverse effects. Managing the number and timing of lorry movements taking spoil from the site would ensure significant adverse effects are avoided’. *The main focus on moving 20,000sqm of soil seems to be financial: ‘Option 1: Topsoil would be stripped and stored on the site, potentially being lost as a resource’, and ‘Option 1: There is likely to be a potential significant adverse effect associated with loss of the topsoil resource’(p42) * Where is the evidence that the likely environmental benefits of the fen improvement scheme will outweigh the carbon costs associated with 2600 diesel lorry movements, plus all the personnel traffic, earth-moving and other equipment etc needed to remove / extract the soil? * Is there an impact assessment on the possible likely negative effects or consequences upon adjoining land, and neighbours, once the work is completed, such as drainage, flooding, etc.? "
Members of the Public/Businesses
Tregele Action Group (TAG) (Tregele Action Group (TAG))
"The Wylfa Newydd Development Area falls within the parish of Llanbadrig, as does the village of Tregele. The development proposes constructing two reactors with capacity of 2.9 Gigawatts, a support services complex and a proposed 4,000 bed temporary workers campus. Construction will involve major earthworks with the creation of artificial drumlins which will significantly change the landscape. As Tregele is the village situated closest to the proposed project’s site, we have a particular interest in knowing the extent of any potential vibration, noise, light, air and odour pollution that the site's construction and subsequent operation will create, and how effective the artificial drumlins will be in protecting the quality of life of Tregele residents. Horizon have indicated in Document 6.10.2 ES Volume J2 that at least 67 residual receptors in Tregele and between Tregele and Cemaes will experience major or moderate effects from the development; and that for residential properties and other buildings in close proximity to the Wylfa Newydd Development Area vibration during construction could cause annoyance, feelings of alarm and, in the most severe cases, could cause damage to structures; high noise levels during construction could cause annoyance and reduce speech intelligibility at five offices and one commercial premise; and that these effects could persist for eight years. Tregele Action Group needs to be informed of the identity of affected properties and to be assured that owners of affected properties are advised of their situation. We are concerned that Horizon takes adequate steps to mitigate against these adverse effects and provides appropriate support to individuals and families who wish to relocate. We consider their published voluntary Neighbourhood Support Scheme to be wholly inadequate in this regard. Furthermore, we are concerned about the impact on our community by potentially 4,000 people residing on site and as many as 9,000 working on site. We have an interest in knowing how Horizon intends to ensure that workers integrate with the local community, avoiding this very large number of individuals disrupting our small village, whether through crime, anti-social behaviour and/or via the increased demand for local resources. We share common concerns with Llanbadrig Community Council and the North Anglesey Partnership about Horizon’s Transport and Accommodation strategies. We have specific concerns about Wylfa traffic using the A5025 East of Tregele and using the Rhosgoch/Llanfechell/Tregele minor road. Finally, we have an interest in the plan to store high level radioactive material on site for many decades."
Members of the Public/Businesses
UNLLAIS MON on behalf of UNLLAIS MON
"Mae’n gwbl angenrheidiol fod UNLLAIS yn cael ei alw i gyflwyno tystiolaeth. Mae’n cynrychioli pob cyngor bro a thref ar Ynys Môn, namyn un. Bydd y datblygiad hwn yn cael effaith sylweddol ar bob un o’r cymunedau hyn, rhai yn fwy na’i gilydd, ac y mae ganddynt oll faterion cyffredinol i’w cyflwyno trwy UNLLAIS. Yn ogystal, bydd UNLLAIS yn dymuno cyflwyno tystiolaeth a gwybodaeth am effaith y peilonau fydd yn trosglwyddo’r trydan fel canlyniad i godi Wylfa Newydd. Byddwn hefyd yn cyflwyno gwybodaeth a barn am wasanaethau cyhoeddus ar yr Ynys gan gynnwys ysgolion ac iechyd. Rydym hefyd yn awyddus i gyflwyno sylwadau ar effaith ar y diwydiant twristiaeth. Rydym o’r farn fod gwir angen ehangu’r ardal sydd yn cael ei heffeithio gan y datblygiad a chydnabod hynny; nid yw’r cynllun yn gwneud hyn eto. "
Members of the Public/Businesses
Albert Owen MP
"I am completing this DCO as the Member of Parliament for Ynys Mon, but also as a local resident and individual. I support the principle of successive UK Government’s policies in recent years to ensure energy supply is secure, affordable and environmentally considerate-dubbed the ' Energy Trilemma' and the role new nuclear can play. Therefore I support the development by Horizon Nuclear Power of Wylfa Newydd and its important role in establishing a low carbon economy locally and nationally. Wylfa Newydd, like its predecessor Wylfa A, brings mass employment and learning opportunities to the local community and beyond. Major infrastructure projects such as this have the ability to transform the livelihoods of communities they are situated in; they provide skilled opportunities for generations of locals and allows Anglesey to retain its talented workforce. Current projections envisage over 4,000 workers will be required during the construction period 9,000 during its peak. Aside from these initial workers there will be the local, regional and U.K. companies involved in the important supply chain. In addition Wylfa Newydd will demand up to 850 permanent jobs over the operational lifetime, which will likely last 60 years. These are 'jobs for life' and few other industrial sectors can say this and there is real evidence of this with Wylfa A, when those who started as apprentices completed their working life and the plant and or in the nuclear industry. This has a positive impact on the local culture and Welsh language as local people have the opportunity to live, work and remain in their local community on good wages. I have spoken to local apprentices already employed by Horizon who are excited by the long term opportunities the project offers them and future young people from the local communities. The forecasted economic benefits to the Welsh economy of Wylfa Newydd are sizeable, with an expected contribution to Gross Value Added of £2.4 billion over planning, (already underway), building, operations and maintenance of the project up to 2033. Links with the local colleges, schools and university is vital to provide the necessary skills required. The local authority, Welsh and UK Governments along Horizon must continue to work with these local skill providers and take action for businesses to engage with the sector and project. Preparation is pivotal for Anglesey, North Wales to make the most out the prospects that Wylfa Newydd offers. Finally, the UK Government launched its Nuclear Sector Deal in North West Wales because of the potential the area offers the sector. Wylfa Newydd is key to the development of not just the nuclear sector but in the creation of a low carbon centre of excellence and he benefits this will provide future generations. I have concentrated on the economic benefits only due to the restrictions of words. "
Members of the Public/Businesses
Anti Atom Komitee
"- Nuclear energy is no form of producing sustainable energy - Nuclear energy is no way to solve the problem of climate change (Don`t nuke the climate) - Nuclear energy is no way to solve the upcoming worldwide lack of energy, due to the end of fossil energy - only 3-4% of the worldwide produced energy is nuclear electricity!!! - There is worldwide no solution for the longterm storage of nuclear waste - The plans, to finance the NPP of Hinkley Point C show, that nuclear energy is one of the most expensive ways of producing electricity. Nuclear energy has had its chance, after 60 years of massive public financial support, nuclear energy is still not economic. NPPs can be misused to produce fissile material for nuclear weapons an stand therefore against the necessary worldwide bann of nuclear weapons. "
Non-Statutory Organisations
Austrian Institute of Ecology
"Request: The missing assessment of alternatives for the EIA Wylfa should be conducted from an environmental perspective, and the future need of electricity production should be declared. Request: The potential rise of the sea level caused by climate change can result in a higher risk of flood and coastal erosion than assumed in the National Nuclear Policy. This risk has to be assessed using new facts and knowledge on climate change, and also updated regularly over the whole lifetime of NPP and radioactive waste facilities at the site. It is not clear why this reactor type (UK ABRW) was chosen. Request: An assessment of different reactor types from an environmental point of view should be presented in the EIA, including a description of the method of decision. The source term for the analysed severe accident scenario is 1.86E+08 Bq Cs-137. Such a release of Cs-137 seems to be very low for the biggest severe accident one can think of. In comparison: In the still ongoing EIA for the new NPP in Dukovany/CZ a release of Cs-137 for a severe accident with core-melt is assumed to be maximal 30 TBq. Moreover, a containment failure cannot be completely excluded without a “residual risk”, especially when regarding the performances of ABWRs in operation or in construction. In case of containment failure of an ABWR a study of BOKU Wien assessed that up to 294 PBq Cs-137 could be released in the environment. The project flexRISK presents dispersion calculations for such a release and results in a possible contamination of Austrian territory with several 100 kBq Cs-137/m2 depending on the weather situation. This is more than the contamination in Austria after Chernobyl. Moreover, in Austria, agricultural countermeasures have to start at an expected contamination with Cs-137 of 0.65 kBq/m2. Austria therefore can be severely impacted by the project. In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. Request: Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible. Request: If an accident happens, it has to be guaranteed that the full damage will be covered. Request: In the documentation it should be explained what consequences the Brexit will have on the whole project. Request: For every new NPP the safe disposal of all spent fuel and radioactive waste has to be proven in an EIA. It is not enough to present only plans for future disposals, especially if no functioning solutions for final disposals exist anywhere in this world. "
Members of the Public/Businesses
Ayumi Fukakusa
"Dear whom may concern, Written representation, re Wylfa Newydd projects Emergency planning Wylfa A’s current emergency plans only covers a 1.6km area around the nuclear site, and emergency plans for most of other nuclear power plants cover a few km area around the sites. Fukushima nuclear disaster sees at least 160,000 people evacuated in 30 km area, and at least 70,000 people are still evacuating. 30 km radius around Wylfa means almost the entire Island of Anglesey. The island and the main land is connected with only two narrow bridges. Given situation, if there were a severe accident like Fukushima at Wylfa Newydd, it is nearly impossible for people, especially people with disabilities or in needs to evacuate from the island quickly enough. Environmental impact There are six nationally and internationally designated sites near the Wylfa Newydd, such as SSSI, SAC or SPA. Colony of protected birds’ was found at the site. ( https://www.theguardian.com/environment/2018/apr/09/plans-for-welsh-nuclear-power-plant-delayed-concerns-seabirds-anglesey-tern-colonies-wylfa ) Wylfa Newydd requires large area of land, which is 10 times larger than existing Wylfa power station. The impact on environment and biodiversity will be enormous. Impacts on local economy and society for hosting thousands workers The Environmental Statement – Non Technical Summary (para 1.1.5) says; “The Wylfa Newydd Project would create 850 permanent jobs, with a construction workforce of approximately 4,000 rising to approximately 8,500 workers at the peak of construction. It would also bring benefits to north Wales and local communities, not only through employment and training opportunities but also from the demand for local goods and services.” However, Horizon expects the real job opportunity provided locally would be just up to 2,000, not 8,500. Moreover, it is reported that hosting thousands workers in a tiny island with population of 70,000 will be affecting private rent. (https://www.bbc.co.uk/news/uk-wales-north-west-wales-43563174) The impact on social infrastructure will be enormous if hosting thousands of workers from outside, and the real economic benefits of project for the community is limited. There is also a concern over welsh language. Thousands of workers are likely to be from outside thus likely to be non-Welsh speakers. Local communities will have an adverse effect on the Welsh language and culture by reducing the proportion of Welsh speakers in a community. Assumptions are out of date The current nuclear NPS (EN-6) sets out the need for nuclear power, which predicted that “electricity generation may need to more than double”. However, the demand for both energy and electricity is decreaseing. The Overriding NPS on Energy (EN-1) said the Government believes that nuclear power is economically competitive with other technologies. However, according to National Audit Office (NAO)’s report in June 2017, “deal for Hinkley Point C has locked consumers into a risky and expensive project with uncertain strategic and economic benefits.” Strike price for HPC is nearly twice higher than the price for offshore wind. (https://www.carbonbrief.org/analysis-uk-auction-offshore-wind-cheaper-than-new-gas). These assumptions outlined in the policy statement is outdated, thus necessity of building new nuclear power plants including Wylfa should be reviewed. Given reasons, Wylfa Newydd should not be built. "
Members of the Public/Businesses
Brian Horsey
"Neither the preliminary work nor the proposed subsequent main work is listed in the 'Wylfa Newydd Project 6.1.2 ES Volume A - Introduction to the project and approach to the EIA A2 - Project overview and introduction to the developments' document published in June 2018. There was no notice that the work was due to begin. One small sign near the work site outside the village gave me no indication of the scope or timing of any work. There were no public consultation events in our village to show what works were to be undertaken. Preliminary work has already begun and temporary roads installed, without notice to the village or any signage on site indicating timescale, purposes, etc. I understand a Horizon representative informed one local resident that this work was to last 10-12 weeks. Public footpaths run through the fields outlined in the proposal. The work already started seems to impact one footpath. The documents show that 20,000 cubic metres of earth will be removed from the site through the village, either during, or in 3 years after completion of the work. At a full load of 15 cubic metres per tipper lorry, that will mean 1300+ full lorry loads of earth being transported through the village, with 1300+ empty lorries returning to the site for loading, a total of over 2600 lorry journeys. With a 5 day working week that means around 10 journeys a day for 1 year or 20 journeys a day for 6 months through the village down what is predominately a single track road with soft verges, and already in poor condition.Removing 20,000 cubic m of top soil from the site seems to be for financial rather than environmental reasons as while in some places it is referred to as ‘spoil’ it is also referred to as a ‘resource’. It seems unlikely that the soil would be transported to the Wylfa Newydd site for use as the mitigation plan timing is ahead of the construction completion - which suggests it would be sold. There is no evidence shown that any environmental benefits, locally or wider, of the fen improvement scheme will outweigh the carbon costs and local detriment associated with 2600 diesel lorry movements, personnel traffic, earth-moving and other equipment required for the project, nor any assessment on the possible likely negative effects locally once the work is completed, such as drainage, flooding, and no mention of any affect on adjoining land and consequences for the owners or farmers."
Members of the Public/Businesses
David Irfon Rowlands on behalf of Bryngwran Comunity Council
"1. Increased traffic through village 2. Pollution "
Non-Statutory Organisations
CBI Wales
"The CBI is the UK's premier business organisation, providing a voice for firms at a regional, national and international level to policymakers. Our purpose is to help business create a more prosperous society. In Wales we are the leading business organisation engaging with the Welsh, UK and local governments to drive growth and prosperity to all parts of Wales. Secure, affordable and sustainable energy supplies are critical to households and businesses across the country, underpinning the UK’s economic health and prosperity and providing the foundations of a modern industrial strategy. In 2016, the energy sector created £24 billion in GVA, and delivered £88 billion in economic activity through its supply chains – purchasing goods such as aluminium for transmission lines, and services ranging from construction to cost-saving technologies. The value of investments made by the UK energy sector in 2016 was £11.9 billion, meaning that almost £1 in every £16 invested in the UK was in the energy sector. The energy sector has an important presence across all regions of the UK. The sector directly employs around 148,000 workers and supports a further 582,000 through supply chain, consulting and other energy related activities. This means that the energy sector supports around 1 in 48 jobs across the UK – and these jobs are not just in London. Nuclear power has a key role to play, along with renewables, in tackling the large scale energy challenge the UK faces. Experience from several countries has shown nuclear power is a proven pathway to delivering decarbonisation at a national level. This is borne out in the UK, where nuclear currently provides 45% of the UK’s low carbon power and, together with renewables, ensures that around 50% of the country’s electricity is clean and sustainable. With continued support from the UK and Welsh governments nuclear has a strong role to play in delivering clean, stable power for generations to come. Wylfa Newydd specific benefits: 1. Jobs – construction & operations: 2. Apprenticeships & skills: 3. Supply chain opportunities – construction & operations 4. Local investment – infrastructure, community, education etc. 5. Welsh language & culture, retention of local youngsters on the island, attracting back Anglesey natives to the island 6. Potential for North Wales to be a nuclear hub/centre of excellence With a total cost of £16bn and a capacity of 3GW in addition to significantly helping to meet our energy needs, this project is expected to create 4,000 jobs during the construction phase, rising as high as 9,000 at the peak of the project, on top of the 850 permanent staff members who will be required to run the plant once operational. "
Members of the Public/Businesses
Cymdeithas yr Iaith Gymraeg
"Rydym yn gwrthwynebu'r datblygiad oherwydd yr effaith y fydd yn ei gael ar y Gymraeg, ar lefel lleol a chenedlaethol"
Members of the Public/Businesses
Cyngor Bro Llanfairpwll
"Mae Cyngor Bro Llanfairpwll yn cynrychioli ardal sydd yn cael ei effeithio yn ddifrifol gan ddatblygiad Wylfa Newydd er nad yw hyn efallai wedi ei amlygu gan Horizon yn yr ymgynghoriad sydd eisioes wedi cymeryd lle. Yn fras mae’r pryder yn cwmpasu: • Methiant i dderbyn cyfrifoldeb am yr holl effeithiau cronnus a’i amlygu yn y ddogfen. Ymgais i osgoi ymateb ar y pwnc yn y ffurflen adborth • Yr angen i ehangu’r ardal sydd wirioneddol am gael ei effeithio gan y cynllun • Anghyfiawnder cymdeithasol o anwybyddu adborth a buddiannau poblogaeth Môn drwy barhau i gynllunio a chefnogi cynllun peilonau sy’n gorfodi trigolion difreintiedig Môn i sybsideiddio arbedion/elw i Horizon, y Grid a defnyddwyr trydan gweddill y DG Fel cynrychiolwyr democrataidd o’r gymuned lleol mae gennym hefyd bryderon ar sut mae’r datblygiad fawr yma yn effeithio, a pha mesurau lliniaru sydd yn eu lle, ar: • Wasanaethau cyhoeddus ar yr Ynys gan gynnwys ysgolion, iechyd ayyb • Yr iaith Gymraeg a’r diwylliant Gymreig sydd yn holl bwysig i drigolion ar hyd a lled yr Ynys • Trafnidiaeth ar yr Ynys a dros y pontydd yn ystod y cyfnod adeiladu. • Diwydiant twristiaeth sydd yn holl bwysig i economi yr Ynys Hefyd rydym yn awyddys i sicrhau bod swyddi o safon yn cael eu cynnig i bobl lleol dros gyfnod adeiladu yn ogystal a’r tymor hir. Rydym angen sicrhau bod polisi hyfforddiant i brentisiaid a phobl ifanc yr Ynys yn rhan o’r strategaeth tymor hir y datblygwyr. "
Parish Councils
Cyngor Cymuned Mechell Community Council
"Mae Ardal Ddatblygu Wylfa Newydd yn dod o fewn plwyfi Mechell a Llanbadrig. Mae adeiladau'r adweithydd a'r cymhorthion gwasanaethau cymorth yn bennaf yn Mechell ac mae'r campws arfaethedig dros dro 4,000 gwely ar gyfer gweithwyr yn gyfan gwbl o fewn Llanbadrig. Rydym yn rhagweld cydweithio gyda Horizon Nuclear yn y Datganiad o Gytundeb Cyffredin os byddant yn rhoi gwybodaeth sylfaenol i ni sy'n ein galluogi i gyfrannu. Rydym yn pryderu am yr effaith ar ein cymunedau o 4,000 o bobl yn byw ar y safle a chymaint â 9,000 yn gweithio ar y safle. Disgwyliwn ymgysylltu â Horizon wrth gytuno ar fesurau priodol i osgoi nifer fawr iawn o unigolion yn amharu ar yr holl agweddau cymdeithasol, diwylliannol a chorfforol ar ein cymunedau. Rhaid i'r egwyddor agosrwydd fod yn berthnasol i bennu cymesuredd y mesurau lliniaru sydd eu hangen i atal canlyniadau niweidiol posibl. Rydym hefyd am gael sicrwydd bod gwasanaethau brys ac iechyd yn cael digon o adnoddau ar gyfer galw cynyddol. Mae Horizon wedi nodi yn Nogfen 6.10.2 ES Cyfrol J2 y bydd o leiaf 67 eiddo yn Nhregele a rhwng Tregele a Cemaes yn cael effeithiau mawr neu gymedrol o'r datblygiad; ac ar gyfer eiddo preswyl ac adeiladau eraill yn agos at dirgryniad Ardal Ddatblygu Wylfa Newydd yn ystod y gwaith adeiladu, gallai achosi aflonyddwch, teimladau o fraw ac, yn yr achosion mwyaf difrifol, achosi difrod i strwythurau; gallai lefelau s?n uchel yn ystod y gwaith adeiladu achosi aflonyddwch lle gallai'r effeithiau barhau am wyth mlynedd. Mae gwybodaeth leol am weithrediad Wylfa yn awgrymu y bydd rhai eiddo ym mhlwyf Mechell nad nodwyd gan Horizon hefyd yn cael eu heffeithio Mae angen hysbysu'r Cyngor Cymuned yngl?n â hunaniaeth yr eiddo yr effeithir arnynt a sicrhau bod perchnogion eiddo yr effeithir arnynt yn cael gwybod am eu sefyllfa. Rydym yn pryderu bod Horizon yn cymryd camau digonol i liniaru'r effeithiau andwyol hyn neu'n darparu cefnogaeth briodol i unigolion a theuluoedd. Rydym o'r farn bod y Cynllun Cefnogi Cymdogaeth gwirfoddol a gyhoeddwyd yn gwbl annigonol. Rydym yn rhannu pryderon cyffredin gydag aelodau eraill Partneriaeth Gogledd Ynys Môn ynghylch strategaethau Trafnidiaeth a Llety Horizon. Mae gennym bryderon penodol yngl?n â thraffig Wylfa gan ddefnyddio'r A5025 i'r Dwyrain o Dregele a defnyddio ffordd gul o Rhosgoch / Llanfechell / Tregele a Llanddeusant, Mynydd Mechell i Dregele. Rydym hefyd yn bryderus i ddiogelu cyn belled ag y bo modd llwybrau troed cyhoeddus y gallai'r datblygiad effeithio arnynt ac aradaloedd o harddwch nodedig naturiol Yn olaf, mae gennym ddiddordeb a phryder am y cynllun i storio deunydd ymbelydredd lefel uchel ar y safle am sawl degawd a'r effeithiau ar genedlaethau'r dyfodol."
Members of the Public/Businesses
Dafydd Owen
"I have great concerns over the proposed works that is to be carried out at Gors Gwawr Talwrn, and wish that Horizon and Isle of Anglesey County Council in better detail to the entire village of Talwrn of the propose works. My main concern is the major impact and disturbance on the village that the logistics of the site traffic in relation the the proposed removal of 20,000m3 of material from site. I kindly request that Horizon and IOACC visit the village hall to provide an explanation of this. "
Non-Statutory Organisations
Department of Environment, Food & Agriculture
"We wish to be kept informed of the progression of the Development Consent Order through the planning process and any environmental risks identified through the consultation including the planning and development process."
Members of the Public/Businesses
response has attachments
Doris Shaw
"See attached document."
Members of the Public/Businesses
Dr Carl Iwan Clowes OBE FFPH DTM MSc.(Soc. Med.) FRCGP
"Horizon Nuclear Power’s application for a Development Control Order for the Wylfa Newydd NPP is reliant on Government National Policy Statements from 2008. Time has moved on and these Statements are now largely out-dated as NPPs are no longer competitive with renewable energy and fall far short of the timescale that renewable energy offers in addressing the urgent challenges of climate change. Energy efficiency measures further add to the clear view that there is no longer a need for NPPs and the gap between what `nuclear`can provide and the cost, timescale and efficiency of renewables and storage battery technology is growing by the day. Building a large infrastructure project in a remote rural area such as Ynys Môn is known to have a negative impact on the local economy in the long term. The island today, after 40+ years of Wylfa `A` has the lowest GVA in the whole of the UK. Wylfa Newydd will undermine the far greater job-creating potential of other industries, such as was evidenced in Manifesto Môn - e.g. an energy efficiency programme, and an offshore renewable industry, and may actually damage existing industries such as tourism and agriculture which rely on the area having an unpolluted environment, free from toxic waste proposed to be stored on the Wylfa site for well over a century. As was the case with the previous Wylfa station, Wylfa Newydd would have a detrimental effect on the Welsh Language. Prior to Wylfa `A`, the percentage of Welsh-speakers in the Cemaes area was >80%. The most recent Estyn School Inspector`s report showed that just 4% of the children attending the local school were from homes where Welsh was spoken. Q.E.D. I have visited Fukushima Prefecture on two occasions and have seen at first hand the evacuation of an area similar in size to Ynys Môn and the adjacent part of Gwynedd. This involved some 168,000 people, many of whom are still unable to return to their homes - a story largely untold in our media. Given an unforeseen accident here the limited capacity of crossings to the mainland would make for chaos in our community. The devastating impact the proposals would have on designated conservation sites of international importance is wholly unacceptable. The development of Wylfa Newydd would make a mockery of their status as Special Areas of Conservation, Specially Protected Areas and Special Sites of Scientific Interest "
Members of the Public/Businesses
Dr David Lowry
"My primary concerns with the proposed Wylfa Newydd nuclear plant arise from the additional security problems any such reactor will create in the UK, both in terms of vulnerability of the reactor complex to malevolent intrusion and/or external attack; and the potential for deliberate misuse of the fissile ( ie explosive plutonium) material created necessarily in the spent irradiated nuclear fuel by operating the reactor. I intend to demonstrate that plutonium created in the current Wylfa nuclear plant has been historically managed under nuclear “safeguards” arrangements that permit it to be diverted to military misuse by ministerial fiat; and that the new domestic “safeguards” system being developed by the Office for Nuclear Regulation for the post-Brexit environment plans to allow such diversion to be permitted. I will also set out several plausible and realistic scenarios under which the security of Wylfa Newydd could be successfully breached or disruptively sabotaged – by, inter alia, an aerial armada of advanced drones, by high tech penetrator weapons from off or on shore, by malevolent sleeper infiltrators etc- and outline to consequences for Anglesey and the wide north West of such a failure of security provisions. None of these issues is addressed in the Horizon application document “Wylfa Newydd Project 5.1 Main Consultation Report.” I note that this document states: “Horizon has also taken care to consult on the whole project… This has allowed consultees to have a rounded picture of the impacts of the Wylfa Newydd Project from the outset.” It also states elsewhere in the same document: “The NPS EN6 (para 2.7) advises decision makers to avoid unnecessary duplication and to ensure that planning and regulatory expertise are focussed on the most appropriate areas. While most consents that will allow the development of Wylfa Newydd to proceed are included in the application for a DCO, consents and permits related to nuclear safety, security, protection of people and the transport of nuclear material are regulated separately.” I regard it as inappropriate to hive-off such concerns to bodies outside the infrastructure planning process, which permits public input into decision-making. It is unclear to me how any consultation by outside bodies might progress. The PI must address this. I retain additional concerns over the project proposal, including it is premised upon a National Nuclear policy Statement which is both questionable in its current form ( the Government admits as much in holding consultation on proposals to update it), and manifestly out of date; with the proposed creation of radioactive waste when there is as yet no demonstrated long term method for its management; and the fact the UK Government is planning to find new ways to subsidise Wylfa Newydd, which would have the inevitable consequence of less investment of public taxpayers’ money into sustainable, clean renewable energy technologies and energy efficiency. But I shall leave the detailed argument over these matters to others. Dr David Lowry senior international research fellow Institute for Resource "
Members of the Public/Businesses
Dr Isabel Hargreaves
"I am writing concerning the proposed developments at Gors Gwawr at Talwrn. Work appears to have started in advance of planning for Wylfa B being granted. The notices placed near the site do not give any meaningful information about the work being proposed and the village appears not to have been consulted about the developments. Concerns are being raised about the transport implications of removing very large quantities of top soil from the site. The destination of the top soil remains unclear and whether there is any financial gain to be had from the possible sale of the soil, and for whom."
Other Statutory Consultees
Dwr Cymru Welsh Water
"1. D?r Cymru Cyfyngedig (DCC) is a statutory undertaker responsible for providing over three million people with a continuous, high-quality supply of drinking water and for taking away, treating and disposing of wastewater. DCC owns, operates, maintains, improves and extends the system of public sewers, water mains and associated apparatus together with treatment works and pumping stations and has corresponding statutory duties to ensure effectual drainage and for making available supplies of water. DCC’s primary concern within the context of this application for Development Consent therefore is to ensure that statutory obligations are met and the environment is protected. 2. DCC has actively engaged with Horizon Nuclear Power (HNP) at pre-application stages in regard to its application for the Wylfa Newydd power station. This pre-application engagement has primarily related to the provision of water and wastewater infrastructure to service the construction and operational phases of the development. In addition, discussions have been held in regard to the protection of existing assets that may be affected by the development proposals. 3. In this context, specific concerns for DCC include, but are not limited to, the potential impact on: a. The provision of water supply to service the construction and operational phases of development b. The provision of adequate wastewater infrastructure to ensure the effectual drainage of wastewater discharges that are generated at construction and operational phases of development c. Water quality and resources d. The structural integrity of DCC assets and apparatus e. DCC’s statutory rights of access to its watermains and associated apparatus f. DCC’s ability to fulfil its statutory obligations g. DCC’s land and associated rights 4. As part of ongoing dialogue with HNP work continues to agree a Statement of Common Ground that, once finalised, can be submitted to the Inspectorate as part of the examination. In regard to Protective Provisions, which will form part of the Development Consent Order, discussions remain ongoing in regard to the provisions and this is duly noted in the Applicant’s submission (Explanatory Memorandum, paragraph 7.46). We therefore encourage the Applicant to continue this engagement at its earliest opportunity. 5. DCC intends to make detailed representation on the draft DCO during the examination stage of this PA2008 process."
Members of the Public/Businesses
Ellen Menai Jones
"My husband and myself are the farmers living in the farm immediately adjacent and surrounded by this proposed development. We graze 60+ sheep and Shetland Ponies on our farm. My husband and I are very concerned at this proposed development: The out of village sign that was erected on a very small and quiet junction, could have been placed in the centre of the village in order to alert villagers to the work proposed; We have had no prior knowledge or communication from , or anyone else, about this work. The consultation shown as being in Llangefni on 27 May was not publicised in our village by poster or leaflet, and we were thus unaware of the development; We only knew of the work when lorries arrived in an adjacent field and started unloading last week. This surprise was a great distress to my husband and myself; We are worried that the planned work will have a negative effect on drainage and vegetation in our fields next to the site; We are concerned about the way that problem of noise pollution, dust, and traffic movements seem to have been dismissed as being easy to manage and overcome. A reference to ‘daylight hours’ not inconveniencing residents, even in summer, does not fully explain why they were working on site until about 8pm in the first week of activity (w/b Monday 6 August); We believe this development will have a detrimental effect upon our farm and livelihood, yet there is no mention of possible compensation in any documents we have seen; The movement of thousands of lorry journeys to create the site and then move the spoil right past our front door, will have a huge impact on a small country lane and village, that is not in good condition at present; At the very least, there should be a public meeting in Talwrn Village Hall to explain the size and scope of the work and the planned timescale of this preliminary and actual future work. This would enable local people to have their say on the proposal; As a final point, the naming of the site is incorrect, and could cause offence to some local people. The correct names of the whole site are Cors Tyddyn Waen, Cors Ty Coch, and Cors Bron Haul. So, in future literature, please can you change the name? "
Members of the Public/Businesses
Femke Hustert
"If the premise should be that only those registering now via this procedure will be allowed to comment at later stages, especially the transboundary EIA, I would like to point out that I do not accept this premise and would consider it in violation with the Aarhus Convention. In addition, I would also consider it in violation with the Aarhus Convention that you demand an outline of the main points at this early stage of the process without proper information and that failure to provide the points leads to an immediate exclusion from the procedure. "
Members of the Public/Businesses
Fforwm Iaith Strategol Ynys Mon
"Mae’r sylwadau isod yn cael eu cyflwyno ar ran Fforwm Strategol Iaith Ynys Môn. Mae’r Fforwm yn bartneriaeth sy’n bodoli ar lefel sirol er mwyn rhoi ffocws strategol i’r Gymraeg ar yr Ynys. Y Fforwm sy’n gyfrifol am adnabod blaenoriaethau a llunio Strategaeth Iaith Gymraeg 2016 – 2021, (http://www.ynysmon.gov.uk/Journals/q/b/n/Strategaeth-Iaith-Gymraeg-2016-2021.pdf) a thrwy hynny, adwaenwn fod i’r Gymraeg bwysigrwydd sylfaenol i fywyd Ynys Môn. Mae aelodaeth y Fforwm yn cynnwys Cadeirydd Annibynnol, Bwrdd Iechyd Betsi Cadwaladr, Consortiwm Addysg ôl-16 Gwynedd ac Ynys Môn, Cymdeithas yr Iaith, Cyngor Sir Ynys Môn, Ffermwyr Ifanc, Gr?p Llandrillo Menai, Gwe, Heddlu Gogledd Cymru, Medrwn Môn, Menter Iaith Môn, Menter Môn, Môn CF, Mudiad Meithrin, Prifysgol Bangor, Uned Polisi Cynllunio ar y Cyd (Gwynedd a Môn), Unllais Cymru, Llys Eisteddfod Môn, Llywodraeth Cymru, Y Ganolfan Cymraeg i Oedolion, Yr Urdd. Blaenoriaeth y Fforwm yw bod ystyriaeth lawn yn cael ei rhoi tuag at y Gymraeg ym mhob agwedd o’r gwaith, erys pryder nad yw’r datblygwr yn cydnabod effaith y datblygiad mewn graddfa a chanrannau fyddai’n datgelu pa mor agos i’r newid andwyol (‘tipping point’) yr ydym ym Môn. • ¬Yn fras gall 9000 o weithwyr ar ynys o 70,000 boblogaeth ble mae 57% yn siarad Cymraeg olygu 10% yn fwy o siaradwyr di-Gymraeg gan wneud y Gymraeg yn iaith leiafrifol. Mae cymuned gyda llai na 70% o siaradwyr Cymraeg yn galw am weithdrefnau i gynnal yr iaith, a dyma, gydag adnoddau prin iawn, yw rôl partneriaid y Fforwm. • Mae diffyg manylion, geiriau amwys, diffyg ymroddiad pendant o ran rhaglen, buddsoddiad rhagflaen, a threfn monitro wrthrychol yn ei gwneud yn anodd ymateb yn llawn ar y pwynt yma. • Mae angen i’r Asesiad Effaith adlewyrchu polisïau cyfredol lleol a chenedlaethol e.e Cymraeg 2050, Deddf Llesiant, polisïau addysg CSYM, gwaith cynllunio a hyrwyddo iaith partneriaethau’r Fforwm. • Yn eisiau hefyd yw’r data ar effaith y datblygiad ar siaradwyr Cymraeg yng nghyd-destun ymchwil defnydd a throsglwyddo iaith. • Angen camau i sicrhau gall siaradwyr Cymraeg drafod eu gwaith yn y Gymraeg mewn meysydd arbenigol a chadernid i gynnwys Polisi Iaith. • Angen ymroddiad a chamau penodol i wireddu cymhathu mewnfudwyr i’n cymunedau. • Rhaid ymrwymo i amserlen o fuddsoddiad rhagflaen mewn hyfforddi athrawon arbenigol a darparwyr gofal plant all drochi yn y Gymraeg. Rhaid hefyd buddsoddi mewn lleoliadau a chynnal a chadw’r safleoedd trochi. Rhaid sefydlu’r egwyddor o fuddsoddi rhagflaen. Mae’r Fforwm Strategol Iaith yn cysidro bod angen gwrandawiad ffurfiol i ystyried y materion pwysig hyn a buasai’r Fforwm yn awyddus iawn i gael cynrychiolaeth yn, a chwarae rhan yn y gwrandawiad. Efallai bydd gan y Fforwm bwyntiau penodol eraill o fanylder pellach y bydd eisiau ei godi trwy Sylwadau Ysgrifenedig dilynol maes o law. "
Members of the Public/Businesses
Fred McCormack
"I believe future work should not be above ground which impacts on visual amenity and leads to loss of energy. Any unnecessary waste increases the risk of damage to our environment and to the health of future generations. "
Members of the Public/Businesses
GLOBAL 2000 - Friends of the Earth Austria
"Request: The missing assessment of alternatives for the EIA Wylfa should be conducted from an environmental perspective, and the future need of electricity production should be declared. Request: An assessment of different reactor types from an environmental point of view should be presented in the EIA, including a description of the method of decision. It seems that Horizon Nuclear Power severely downplays the consequences of a possible severe accident – the given figure of 186 MBq Cs-137 release even in case of a severe accident scenarios is not plausible. In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. Request: Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible Request: In the EIA documentation it should be explained what consequences the Brexit will have on the whole project."
Non-Statutory Organisations
Greenpeace
" EN-6 does not apply to this development. Whilst some of EN-1 is not outdated, its nuclear policy read with EN-6 cannot apply to new nuclear operational after 2025. In context EN-1 does not apply to this application. The policy objectives for new nuclear have not been met and the changes which have occurred since 2008 show that there is no justification for this development. The 2008 policy was: (a) new nuclear may be part of the future energy mix should the private sector build it without public subsidy. No new nuclear has been built on that basis. Hinkley has been given state aid, including top-up subsidy payments that may reach £50bn. This demonstrates Government policy is outdated and the harm caused by new nuclear vastly outweighs any benefit. (b) new nuclear was needed urgently, and before 2025. This objective has not been met. No new nuclear power will be operational by 2025. Only Hinkley has obtained development consent but it is unbuilt and there remains uncertainty about whether it can be built. Nuclear power cannot be relied upon to provide the low carbon energy needed to tackle climate change. This evidence, which has emerged since 2008, must be considered. Renewable energy, particularly offshore wind which is a comparable large-scale, low-carbon technology, can produce electricity at a lower price and sooner meaning lower cost for the consumer and public purse. Between 2012-2017, the cost of offshore wind fell by 50% to a price significantly less than nuclear. In a modern energy system, with a flexible grid, renewable generation plus more interconnectors and storage will deliver all the electricity the nation requires. The harm caused would far outweigh any benefit because (a) It cannot provide low carbon electricity in time or for value for money and (b) Its operation relies on transporting and using hazardous materials and creating exceptionally hazardous and indestructible waste for which there is no solution. Due to technical difficulties experienced by many new nuclear stations across the developed world, and the high price of nuclear electricity, the Committee on Climate Change’s June 2018 Progress Report stated that nuclear power carried a delivery risk, and that ‘if new nuclear projects were not to come forward, it is likely that renewables would be able to be deployed on shorter timescales and at lower cost.’ In July 2018, the NIC’s first report stated: ‘a quiet revolution in renewable costs means government should prioritise wind and solar.’ The proposal would never be privately financed and/or built/operated and the benefits will never be realised. The granting of development consent would cause harm by diverting resources away from renewable energy projects that are less risky, more quickly delivered and more cost-effective. More harm: no solution to waste. The Royal Commission on Environmental Pollution in 1976 said that new reactors shouldn’t be built until the waste problem has been solved. The government still haven’t solved it, and the proposal would add to the problem. For decades the government has failed to find a community willing to host this growing stockpile of high-level radioactive waste. Making the problem bigger makes it both more urgent, and more difficult to solve. More harm: the transport of hazardous materials poses additional obstacles. There is no clarity on the security of movement of highly hazardous materials in Europe, or the basic logistics of how the industry will work following Brexit. This raises not only the inherent problem and dangers of transporting radioactive materials but also makes investment improbable. "
Members of the Public/Businesses
Gwawr Jones
"Rwy'n gwrthwynebu codi gorsaf niwclear Wylfa Newydd am y rhesymau canlynol: 1. Rwy'n wyddonydd gyda gradd Ph.D. mewn Cemeg ac wedi gweld sgil-effeithiau dinistriol gwaith fel hyn ar nifer o bobl. Gallai'r orsaf effeithio'n ddrwg ar iechyd a diogelwch y cyhoedd ym Mhrydain ac Iwerddon, a barnu oddi wrth effeithiau'r orsaf Wylfa bresennol. 2. Mae cynhyrchu trydan trwy'r broses niwclear yn llawer rhy gostus, gan fod rhaid ystyried gofalu am y gwastraff am ganrifoedd i ddod. Hefyd mae cynhyrchu trydan mewn dulliau adnewyddol yn mynd yn rhatach bob dydd. Gydag ychydig o dychymyg gallem ddefnyddio llai o drydan gan osgoi'r angen am orsaf niwclear yn llwyr. 3. Gallai Gorsaf Wylfa Newydd yn hawdd fod yn darged terfysgwyr. 4. Nid yw pobol Siapan yn fodlon peryglu nhw eu hunain gan y dechneg yma gan Horizon/Hitachi, felly pam ein trin ni gyda llai o barch? "
Members of the Public/Businesses
Ieuan Jones
"I am concerned that the topsoil is to be removed from the site on two basis: 1) The topsoil could be used on site to landscape the bordering land and plant trees which the island in general is short of 2) The transporting of such a large quantity of soil would involve damage to already poorly maintained minor roads. It would also involve unwanted disturbance in the village of Talwrn. The information you give implies that selling the topsoil is to offset costs . That is not sufficient reason to disregard the implication for villagers. I would also like to know if an assessment has been made of the potential risks for flooding on the road from Talwrn to Ceint . Are there any plans to repair and improve the local roads which are in a poor state at present."
Members of the Public/Businesses
Karin White
"As full time residents owning a property in Tregele, the village situated closest to the Wylfa Newydd development area we have a particular interest in knowing the following: - The extent of any potential vibration, noise, light, air and odour pollution that the Marine Off Load Facility (MOLF) / site construction and subsequent operation will create, and how effective the artificial drumlins and mitigation measures put in place will be in protecting the quality of life of Tregele residents.   - Horizon ES Volume J2 section 6.10.2 says that at least 67 residual receptors in Tregele and between Tregele and Cemaes will experience major or moderate effects from the development; and that for residential properties and other buildings in close proximity to the Wylfa Newydd development area vibration during construction could cause damage to structures. Property owners and householders should be informed of the identity of affected properties. - The development proposes constructing a 4,000 bed temporary workers campus. Concerned about the impact on our community by potentially 4,000 people residing on site and as many as 9,000 working on site. How does Horizon intend to ensure that workers integrate with the local community, and that this very large number of individuals don't disrupt our small village, whether through crime, anti-social behaviour and/or the increased demand for local resources.   - Concerned about Wylfa newydd traffic using the A5025 East of Tregele and using the Rhosgoch/Llanfechell/Tregele minor road as a rat run from Llangefni/A55.   - Finally, have an interest in the plan to store high level radioactive material on site and how the construction and use of the MOLF will affect wildlife and the Cemlyn Bay Tern colony. "
Members of the Public/Businesses
Keep it Green
"Representation from the Community Group named Keep it Green Theme of Group: Environmental Protection Group Area: Carlingford Lough (as part of Northern Ireland and the Republic of Ireland) and South Down (Northern Ireland) I, on behalf of the above Group, am putting forward objections to the current proposal for a Nuclear Plant in Anglesey for the following reasons: 1. There still exists substantial ambiguity over the exact site(s) to be dedicated to this (and related, local) development. 2. The Government says the current nuclear NPS (EN-6) sets out the need for nuclear power, whilst also providing planning guidance for developers and for the Planning Inspectorate and Secretary of State in their consideration of applications. I now question the need in as far as: a. the Government has been misguided in their prediction of electricity consumption in the UK ie in lieu of the fact that the Government forecasted UK consumption of 15% more than that time of application for Hinkley Point C, (HPC), the UK now in fact is consuming 15% less. The forecasting mechanism that is used by the Government is therefore unrealistic, unreliable and should not be used as material evidence for this application in Anglesey. b. NPS (EN-6) had been based on an analysis outlining different ‘pathways’ to 2050 published by the Department for Energy and Climate Change (DECC) in 2010 which predicted that “electricity generation may need to more than double”. Yet the potential for energy saving was not fully assessed by Government until after EN-6 had been approved. The Government data used in this argument is one that is incomplete, misleading and therefore immaterial to the justification of this application. c. The Overriding NPS on Energy (EN-1) said the Government believes that nuclear power is economically competitive with other forms of generating technology. However, to the contrary, The National Audit Office (NAO) reported in June 2017 that the “deal for Hinkley Point C has locked consumers into a risky and expensive project with uncertain strategic and economic benefits.” And further, Mike Thompson, Head of Carbon Budgets at the Committee on Climate Change stated “It is increasingly apparent that renewables do or will offer the lowest cost of electricity over their lifetime of all generating options.” Also, Michael Grubb, Professor of International Energy and Climate Change Policy at University College London, told the House of Lords Selected Committee on Economic in 2016, although he had supported new nuclear during his time on the Committee on Climate Change, he felt “times and conditions had substantially changed … renewables are now clearly cheaper. Committing to a 35-year contract at that level was economically inappropriate” It is reasonable to assume that this application is justified on the same grounds of need as Hinckley C and therefore all statements here are relevant to this case and provide evidence that the Government is misguided and that experts in nuclear power have indicated the contrary in that it is indeed uncompetitive. d. The actual output of the Plant will not be in operation until c2040 and where the indicators above in a) are that renewables are increasing and power consumption is decreasing, the Government would need to revise their forecast to reflect actual and current data to better accurately forecast based on trend analysis for the years following 2040. e. It is well known that the Welsh Government had invested considerable time at the public’s expense to put forward a proposal for a tidal lagoon proposal in Swansea Bay only for the Government to refuse this renewable energy proposal based on the cost. However, the Government failed to note that renewable energy projects attract funding and had they approved this going forward, public funding would have been available before Brexit (and perhaps afterwards if the Government had argued for that case for the benefit of Ireland’s future demand). Nuclear power does not attract funding and therefore to attempt to justify the cost/needs analysis of the latter and not the former would seem irrational and inconsistent. 3. It is also questionable as to the Government’s determination of costs associated with this proposal when the full life-cycle of the project has yet to be decided upon. The spent fuel and management of waste on site for a potential 200 years and any costs related to storage and/or harm done to people or the environment have not been factored in. Costs would correlate with the high level of risk that is carried in any nuclear development and are therefore non-comparable to those within the renewable energy developments. The Government is misguided in its interpretation of costs related to nuclear energy compared to that of renewable energy and lacks strategic long-term thinking and planning. 4. Former CoRWM member Professor Blowers stated: “It is perverse to compound the problem by a new-build programme that will result in vastly increased radioactivity from spent fuel and other highly radioactive wastes which will have to be stored indefinitely at vulnerable sites scattered around our coasts.” As our Group have already evidence of radioactive waste from Sellafield in Carlingford Lough (Southampton University three year report on Radioactive Waste in Northern Ireland 2011-2014), the costs related to the following have not been factored in : a. With the wind direction of storms in Northern Ireland being South-easterly (while prevailing winds are usually south-westerly), there would be a high risk factor of air and sea pollution being carried directly to our Lough, coastline and beyond. It is the Government’s responsibility to ensure our Human Rights are protected now in their determination of this application and therefore these risk factors should be taken into serious consideration. b. Fishing Industry in the Irish Sea and Carlingford Lough where information is nore readily available on pollution and therefore consumer demand will decline in line with consumer confidence. c. Farming and related industries will be affected if any seepage or waste is poured into the Irish Sea or indeed carried through the air. There are already precedents of this crisis occurring from Chernobyl. The Government is misguided in not taking this risk factor into consideration in affecting the farming industry locally and any potential for exports (including in and out from the Republic of Ireland) d. Higher levels of sickness and deaths arising from digestion of radioactive water and food sources will further put strain on our NHS. Regardless of what the Government intend to plan for the NHS in the future, it is the Government’s responsibility now to factor in these costs taking into consideration our current health system. e. Northern Ireland is distinct from the rest of the UK (and Ireland) in that it does not enjoy the protection of an Environment Protection Agency (EPA). In fact, Ireland has two, one being specifically set up as a “Radiation EPA” to, inter alia, provide for crises management, monitoring and reporting on radiation levels in the air, water and land. To provide for the Human Rights Act 2000, the Government must protect our lives and homes. The cost of setting up an EPA (and comprehensive and appropriate legislation) to provide Northern Ireland with the same protection as the rest of the UK has not been factored into this application or indeed any other nuclear applications. This is a material matter and one that the Government must address before any further approvals and/or consents are made. The Human Rights Convention is still applicable at this time and the Government have misguided themselves where they have perceived that the potential risk to NI would be unlikely when we still have evidence of Sellafield’s pollution in our Lough. f. The cost of climate change has not been taken into consideration for +30m and therefore demonstrates that the application is lacking in integrity and robustness. With the rise in sea level the risk is higher for any nuclear coastal development that would promote seepage into the sea and affect those factors highlighted above. g. As the world does not hold a permanent GDF to date, it is premature of the Government to proceed with any nuclear development without the proper facilities in place, having been tested and approved by experts for its suitability and safety. I believe that the arguments outlined above are all material to this application and any ongoing and subsequent applications for development of nuclear plants along the western coast of England and Wales. The proposal is contrary to the Human Rights Convention for the people living around and reliant upon, Carlingford Lough which will have protection of the HRC after Brexit as it is jointly owned by both Governments. "
Members of the Public/Businesses
Kevin Barnett
" Registration of Interest – The Wylfa Newydd Development Area falls within the parish of Llanbadrig, as does the village of Tregele. The development proposes constructing two reactors with capacity of 2.9 Gigawatts, a support services complex and a proposed 4,000 bed temporary workers campus. Construction will involve major earthworks with the creation of artificial drumlins which will significantly change the landscape. As Tregele is the village situated closest to the proposed project’s site, I have a particular interest in knowing the extent of any potential vibration, noise, light, air and odour pollution that the site's construction and subsequent operation will create, and how effective the artificial drumlins will be in protecting the quality of life of Tregele residents. Horizon have indicated in Document 6.10.2 ES Volume J2 that at least 67 residual receptors in Tregele and between Tregele and Cemaes will experience major or moderate effects from the development; and that for residential properties and other buildings in close proximity to the Wylfa Newydd Development Area vibration during construction could cause annoyance, feelings of alarm and, in the most severe cases, could cause damage to structures; high noise levels during construction could cause annoyance and reduce speech intelligibility at five offices and one commercial premise; and that these effects could persist for eight years. As a home owner in Tregele I need to be informed of the identity of affected properties and to be assured that all owners of affected properties are advised of their situation. I am concerned that Horizon takes adequate steps to mitigate against these adverse effects and provides appropriate support to individuals and families who wish to relocate. I consider their published voluntary Neighbourhood Support Scheme to be wholly inadequate in this regard. Furthermore, I am concerned about the impact on our community by potentially 4,000 people residing on site and as many as 9,000 working on site. The residents of Tregele have an interest in knowing how Horizon intends to ensure that workers integrate with the local community, avoiding this very large number of individuals disrupting our small village, whether through crime, anti-social behaviour and/or via the increased demand for local resources. I share common concerns with Llanbadrig Community Council and the North Anglesey Partnership about Horizon’s Transport and Accommodation strategies. I have specific concerns about Wylfa traffic using the A5025 East of Tregele and using the Rhosgoch/Llanfechell/Tregele minor road. Finally, I have an interest in the plan to store high level radioactive material on site for many decades. "
Parish Councils
Llanbadrig Community Council
"The Wylfa Newydd Development Area falls predominantly within the parishes of Llanbadrig and Mechell. The development proposes constructing two reactors of 2.9-Gigawatt capacity, a support services complex and a proposed 4,000 bed temporary workers campus. Construction will involve major earthworks with the creation of artificial drumlins which will significantly change the landscape. We anticipate co-operating with Horizon Nuclear in the Statement of Common Agreement process if they will provide us with basic information that enables us to contribute. We are concerned about the impact on our communities of potentially 4,000 people residing on site and as many as 9,000 working on site. We expect to engage with Horizon in agreeing appropriate measures to avoid this very large number of individuals disrupting our communities. We also wish to be reassured that emergency and health services are adequately resourced for increased demand. Horizon have indicated in Document 6.10.2 ES Volume J2 that at least 67 residual receptors (properties?) in Tregele and between Tregele and Cemaes will experience major or moderate effects from the development; and that for residential properties and other buildings in close proximity to the Wylfa Newydd Development Area vibration during construction could cause annoyance, feelings of alarm and, in the most severe cases, could cause damage to structures; high noise levels during construction could cause annoyance and reduce speech intelligibility at five offices and one commercial premise; and that these effects could persist for eight years. Local knowledge of the operation of Wylfa suggests that other properties not identified by Horizon may also be affected The Community Council needs to be informed of the identity of affected properties and to be assured that owners of affected properties are advised of their situation. We are concerned that Horizon takes adequate steps to mitigate against these adverse effects or provides appropriate support to individuals and families who wish to relocate. We consider their published voluntary Neighbourhood Support Scheme to be wholly inadequate. We share common concerns with other members of the North Anglesey Partnership about Horizon’s Transport, Accommodation and Welsh language strategies. We have specific concerns about Wylfa traffic using the A5025 between Tregele and the proposed new roundabout South of Tregele and using the Rhosgoch/Llanfechell/Tregele minor road. We are also concerned to protect as far as is practicable public footpaths that may be affected by the development. Tourism is an important driver of employment and prosperity in North Anglesey - Cemaes Bay is a major focal centre. The Wylfa Newydd development will have a negative effect upon tourism through its impact on accommodation, environment, traffic and services over many years of construction. We are concerned about the effect of the development will have upon the marine environment including quality of sea water off our coast because of works to create a Marine Offloading Facility and the use of sea water for cooling. Finally, we have an interest in the plan to store high level radioactive material on site for many decades. "
Other Statutory Consultees
Marine Management Organisation
"Dear Sir/Madam THE PROPOSED WYLFA NEWYDD NUCLEAR POWER STATION - RESPONSE TO SECTION 56 OF THE PLANNING ACT 2008 (AS AMENDED) The Marine Management Organisation (MMO) notes that Natural Resources Wales has submitted its "Relevant Representation" for this project. The development area is located over 50km from English inshore/offshore waters. At this stage, the MMO does not have any comments to make on the proposals. If you have any queries on the above response please do not hesitate to contact me. Kind regards Jamie McPherson "
Members of the Public/Businesses
Medrwn Mon
"Medrwn Môn welcome the opportunity to provide representation to the Planning Inspectorate. Overall, we understand that communities across Anglesey are generally supportive of Wylfa Newydd but, as outlined in all our PAC responses, many concerns and worries regarding the impacts on people and communities remain unresolved within the detail of the documentation. As with all PAC responses, Medrwn Môn’s response to the Planning Inspectorate will be a general overview, as providing a detailed response is difficult due to limited resources that are available within the organisation to respond in a detailed way to a vitally important consultation as well as not having the capacity as an organisation to engage fully with the voluntary sector regarding Wylfa Newydd. Medrwn Môn acknowledge the financial support given to undertake the Community Involvement Officers project, in partnership with Horizon and Isle of Anglesey County Council, but it is both disappointing and disheartening to note that this important piece of work, designed and delivered in partnership with Horizon, to engage with Anglesey’s residents has not been cited as evidence or (as far as Medrwn Môn is aware) used as evidence to make decisions about developments and changes. Within the consultation, Horizon identified ranges of between 4-7 potential effects on local communities. Potential effects or impacts on local communities cannot, and must not, be considered in isolation and should be looked at using a holistic approach in order to be able to, firstly, understand the issues and secondly, determine the most appropriate solution. Many observations from communities regarded as solutions to potential effects are made within the CIO Report. Although additional information and solutions have been provided during the PACs, concerns and worries remain unresolved – including community cohesion during the construction phase, as well as safeguarding issues such as illegal markets and public health issues. Concern also remains regarding the lack of engagement opportunities with voluntary sector organisations and the voluntary/third sector, as a whole. With the prospect of a new Power Station and its Associated Developments being built on Anglesey, it is imperative that the voice of the voluntary/third sector is heard and their opinions considered regarding the far reaching and profound effects of this major development on the island and the possible implications to voluntary/third sector services and support. As the work that the CIOs have undertaken to engage with people in our communities, Medrwn Môn would welcome opportunities and resources to engage with the wider voluntary/third sector to respond collectively and cohesively to Wylfa Newydd Applications. The benefit of the voluntary/third sector playing a full role in the Application process is to identify issues that could impact voluntary organisations, community groups and the wider voluntary/third sector that arise from the proposed plans; identify potential mitigations and solutions for contributions from the developers that will contribute towards mitigating impacts on the wellbeing of our current population as well as future generations. "
Members of the Public/Businesses
Davis Meade Property Consultants on behalf of Messrs G & I Hughes
"We are appointed as Agents on behalf of our Client: Messrs G & I Hughes . Our client is concerned as to the extent of the impact the proposed scheme will have on productive land ,owned by a third party, which they farm at Clefiiog Isa, Ynys Wen and Morfa Ynys Wen ,Valley ,Anglesey . Whilst not exhaustive with regard to the proposals detailed on Drawing Nos WN0902-HZDCO-OHW-DRG-00004/1.0 & 0007 /1.0 & others (forming part of the DCO application) our client is submitting representations in order to seeking clarification please, as to -: 1. the extent of the area within the order limits which is intended to be acquired permanently /temporarily. 2. the flood mitigation works intended to be undertaken (within the order limits) and what measures will be actioned to -: a) mitigate injurious affection to neighbouring land used as part of our client’s agricultural enterprise. b) arrange accommodation works including, for instance, ensuring livestock proof boundaries are duly installed to an appropriate specification (together with clarification on maintenance obligations thereafter) and the provision of livestock water facilities, as appropriate; as well as drainage remediation ( including also in view of the proposals for surface water run off) "
Non-Statutory Organisations
Abteilung 8, Ref. 1086 on behalf of Ministerium fur Umwelt, Energie, Ernahrung und Forsten des Landes Rheinland-Pfalz
"Relevant representation of the Federal State of Rhineland-Palatinate within the frame of the process of the cross-border environmental impact assessment relating to the construction of a new nuclear power station at the Anglesey site - Wylfa Newydd Nuclear Power Station The government of the Federal State of Rhineland-Palatinate is grateful for the opportunity to state its position – by means of relevant representation - within the frame of the process of the cross-border environmental impact assessment relating to the construction of a new nuclear power station at the Anglesey site - Wylfa Newydd Nuclear Power Station. The government of the Federal State of Rhineland-Palatinate is acting in the knowledge that each member state of the European Union is entitled per se to determine the structure and composition of its power supply. The decision for or against a particular form and use of energy is incumbent on the individual states. The position taken by the Federal State of Rhineland-Palatinate on the above process of the cross-border environmental impact assessment is also based on this concept. However, we are deeply concerned on the evidence of the plans developed by the United Kingdom to expand and continue the use of nuclear power, and declare ourselves emphatically against the project for a new construction at the Anglesey site (Wylfa Newydd Nuclear Power Station) and the plans proposed in this connection. The government of the Federal State of Rhineland Palatinate does not perceive the use of nuclear power as a way to solve the challenges facing power supply in the future. It believes in energy conservation and the expansion of renewable energy sources. The use of nuclear power was, is and remains an uncontrollable high-risk technology. In the case of disruptive incidents, it is associated with unforeseeable wide-ranging environmental hazards and serious consequences for human health. The fact that the severe impact on humankind and the environment reaches far beyond the national and regional boundaries of the respective country of origin has been clearly demonstrated by the serious reactor accidents in Chernobyl and Fukushima. The reactor accident in 1986 in Chernobyl especially showed how radioactive material could be disseminated via the air pathway over great distances and expanses. Due to the really short distance to the Anglesey power plant site (Wylfa Newydd Nuclear Power Station), in the case of a comparable disruptive incident in certain weather conditions, radioactive air masses could reach the boundaries of the Federal State of Rhineland Palatinate in just a few hours and lead to contamination. Following the catastrophe in Fukushima in 2011, the assessment of nuclear power risks resulted in the German legislature deciding by consensus with a large social majority to abandon the peaceful use of nuclear power. The government of the Federal State of Rhineland-Palatinate played a role in organising this rapid withdrawal by the Federal Republic of Germany from the peaceful use of nuclear power and, in consequence, underlines once more its opposition to the construction of a new nuclear power station at the Anglesey site (Wylfa Newydd Nuclear Power Station). A further application or even expansion of nuclear power technology is unjustifiable not least because there is no repository in existence as yet in the world for highly radioactive waste and, in addition to the risk to their health, many future generations will be burdened with immense financial disposal risks. Against the backdrop of these objections in principle, we request a revision of the decision on the plan to construct a new nuclear power station at the Anglesey site (Wylfa Newydd Nuclear Power Station). "
Other Statutory Consultees
National Grid
"Dear Sir/Madam REPRESENTATION BY NATIONAL GRID ELECTRICITY TRANSMISSION PLC (“NGET”) TO THE Wylfa Newydd Nuclear Power Station DCO (“THE PROJECT”) NGET wishes to make a relevant representation to the Project DCO in order to protect its position in relation to infrastructure and land which is within or in close proximity to the proposed Order limits. NGET’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits should be maintained at all times and access to inspect and maintain such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme are being reviewed in relation to impacts on NGET’s existing apparatus and land interests located within this area, and NGET may require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET will liaise with the Promoter in this regard. NGET assets which have been identified as being within or within close proximity to the proposed Order limits are: SUBSTATION Wylfa (400kV) Substation OVER HEAD LINE 4ZA (400kV) overhead line route – Pentir to Wylfa (circuits 1&2) UNDERGROUND CABLE Wylfa 1 (132kV) underground cable Wylfa 2 (132kV) underground cable DCO LAND BOUNDARY Horizon’s DCO boundary and interaction/overlap with the proposed NGET North Wales Connection DCO boundary especially at: o Wylfa substation/the powers Horizon are seeking over the NGET substation at Wylfa and the land needed by NGET for its own project and; o at Horizon’s environmental mitigation area where similarly there is an overlap in terms of DCO boundary. As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. NGET reserves the right to make further representations as part of the examination process but in the meantime will negotiate with the promoter with a view to reaching a satisfactory agreement. I hope the above information is useful. If you require any further information please do not hesitate to contact me. Yours sincerely Spencer Jefferies Development Liaison Officer, Land and Acquisitions "
Non-Statutory Organisations
North Wales Police
"I write to formally register North Wales Police (NWP) as an interested party in the Wylfa Newydd Nuclear Power Station Development Consent Order (DCO) and provide below our Relevant Representation. NWP covers the whole of North Wales, including the counties of Isle of Anglesey, Gwynedd, Conwy, Denbighshire, Flintshire and Wrexham and as such has responsibility for the provision of policing for the development, including its associated works and its impacts. Based on all the information seen to date, NWP submit that the development will have a significant impact on the organisation and the public it serves, which at present in the application is not adequately mitigated. These impacts relate to services provided across the force including Roads Policing, Local Policing, Protecting Vulnerable People, and Forensic Services etc. Overall the proposals need to ensure that NWP will be properly resourced to ensure that policing is fully effective in the area and can cover all eventualities without detriment to the current level of policing afforded to existing communities. We have also identified a number of factual inaccuracies in the submitted application documents in relation to the force and current levels of provision. The key issues that we foresee and are a direct result of the development are: Workforce and Transport – A significant increase in population (six times the population of the nearest town Cemaes) and road traffic, particularly during construction, will require an appropriate increase in our resources and infrastructure in order to maintain a safer North Wales for all. Additionally, ongoing management of both these elements are critical and NWP needs to be involved in the drafting and agreement of these requirements in the DCO, accompanying plans and obligations in order to minimise the effects on service provision. The application does not contain sufficient information to validate the traffic assessment and we have questions in regard to the baseline data used. MOLF – The application contains very little detail about the classification and working practices including security in relation to the MOLF. This infrastructure is critical to the delivery of the construction programme but NWP has been unable to determine the potential impact due to the lack of information. There is also a lack of detail around contingencies should the construction of MOLF be delayed or closed during its operation (potentially as a result of water-based protest) - both of which could have a significant impact on demand for police services. Protest – The experience from other nationally significant developments has shown that should protest/s occur and become protracted the resulting impact on the local police force can be extremely detrimental both in terms of resourcing and finance. This risk is from both land and sea. This is a potential impact of the development that needs to be assessed and adequately mitigated. Monitoring and Reporting – Agreement on the definition of the figures and terms included in the monitoring and reporting is critical to understanding the impact from the development and applying appropriate mitigation*. Intangible Impacts - NWP is undertaking an assessment of the potential impacts of the development but expect there will be intangible impacts that will become clearer as the construction gets under way. These will need to be factored in with an appropriate mechanism and funding put in place to cater for them. We reserve the right to add to the matters raised herein as the Examination proceeds. Further, detailed comments will be provided through the submission of Written Representations to the Examination. *For example the definition of the term ‘worker’."
Members of the Public/Businesses
North Wales Wildlife Trust
"North Wales Wildlife Trust (NWWT) manages Cemlyn Nature Reserve (SPA, SAC & SSSI), which is located less than 150m from the WNDA boundary. NWWT has advocated over a number of years for consideration of environmental matters and changes to the proposals as guided by PINs (Advice Note 8). We have found the consultation process obfuscating and frustrating with key substantive environmental matters being dismissed, not addressed or remaining unresolved. At a time of increased funding pressure on three third sector bodies (NWWT, National Trust and RSPB), we have been obliged to direct significant resources towards challenging the inappropriate approach adopted by the applicant. Our key concerns are: - • Important natural resources have not been properly recognised, leading to late surveys, inadequate protection and damage already initiated. • Necessary additional mitigation and compensation are only at embryonic stages of development. • Alternative approaches to design or layout do not embrace Best Available Technology (BAT) or other Best Practice guidance. • The application of due process via the Habitat Regulations Assessment (HRA) and Water Framework Directive (WFD), taking into account recent judicial decisions and case law. NWWT request that the Planning Inspectorate consider the following matters in full and via evidence and hearings to ensure that the proposals can be implemented to the highest standards and in accordance with the UK’s legal obligations. NWWT are committed to continuing to work professionally and pragmatically during the DCO examination to achieve outcomes that are the least environmentally damaging. We reserve the right to amend or add to our representations in light of new information. CEMLYN NATURE RESERVE – Anglesey Terns SPA, tern breeding colony and SSSI The HRA process requires that no Adverse Effect on Site Integrity (AESI) is evidenced ‘beyond reasonable scientific doubt’. The cumulative effects and the severity of 10-years construction and operation are extremely uncertain, difficult to predict and appropriate consideration has not been given to the precautionary principle. Concerns include: - • Noise impacts • Predator displacement • Foraging/feeding dynamics and consequences for maintenance of the colony’s breeding population. • Worker recreational and construction tourism. • The lack of clarity or mechanism for delivery resulting from Horizon’s informal recognition of the jointly prepared ‘Ecological Options’ paper (NWWT, National Trust & RSPB, May 2017). NWWT are aware that Horizon have begun preparation of a compensation package in anticipation that the Examining Authority will concur with NRW’s conclusions; that it is not possible to conclude no AESI. The Examining Authority should consider this package and its ‘fitness for purpose’ encompassing; compensation sites in a state of ecological readiness; Cemlyn long-term resilience; and measures within the Irish Sea metapopulation of Natura 2000 sites. CEMLYN NATURE RESERVE – Cemlyn Bay SAC, saline lagoon and shingle ridge and SSSI The viability of the tern breeding colony (SPA) is functionally reliant on the retention of the shingle ridge. The SAC Nautra 2000 site; its vegetation (Annex 1 perenial vegetation of stony banks) and the saline lagoon, is sustained by the shingle ridge. NWWT, in association with National Trust, question the conclusions of the hydrogeomorphology, hydrodynamics and wave dynamics presented in the DCO. The conclusions of no AESI on the SAC & SPA features are extremely uncertain and not ‘beyond scientific doubt’ during operation. Best practise guidance (OSPAR) and consideration of existing policy (SMP) have not been effectively applied, contrary to overarching policy NPS EN-1 (para 5.5.15). The changes to chemical conditions within the lagoon’s freshwater ‘water budget’ have not been adequately considered. WATER FRAMEWORK DIRECTIVE - The Skerries Coastal and Tre’r Gof SSSI waterbodies The late acknowledgement of deterioration in the quality of two waterbodies has left insufficient time for consideration of the Article 4(7) derogation tests (PINS Advice Note 18) in respect to least damaging design options and use of best available technology. Concerns include: - The Skerries Coastal Waterbody (marine) • Hydromorphology, geomorphology & wave dynamics • Extent and loss of subtidal and intertidal habitats • Hydrological consequences of the cooling water system Ynys Mon Secondary Groundwater Body (freshwater) • Impacts to the hydrologically dependent fen habitat - Tre’r Gof SSSI • Inappropriate siting of the Temporary Site Campus • The effectiveness and achievability of the proposed off-site SSSI compensation THE TEMPORARY SITE CAMPUS - Tre’r Gof SSSI, grassland fungi (CHEG), chough [Annex 1 Birds Directive] and Local Wildlife Site In addition to impacts on the hydrologically reliant SSSI, the siting of this associated development which could be located elsewhere, has unacceptable impacts on a suite of other substantive receptors, contrary to NPS EN-1 (para 5.3.7 & 5.3.11). Concerns relate to: - • Impact from the Temporary Site Campus' scale, site infrastructure and foul sewer diversion. • Belated site assessment has already resulted in and will continue to damage nationally significant grassland fungi and chough foraging. • Impacts from uncontrolled worker recreational usage. • The ability to “return to current condition” pays no regard to the fact that once damaged these habitats are extremely difficult if not impossible to restore; ‘old’ soil structures; interrupted shallow groundwater flows; soil-invertebrate assemblages. BIODIVERSITY NET GAIN (Landscape Habitat Management Strategy, species receptor sites Mynydd Ithel & Notable Wildlife Habitat Enhancement Site) The overarching policy framework of NPS EN-1, TAN5 and Environment (Wales) Act (2016) provides a strong imperative that developments should not result in net loss to the environment and that net gain and ecosystem resilience should be achieved. NWWT consider that the application as laid out in the DCO, including the Landscape Habitat Management Strategy, is evidentially and demonstrably a long way from meeting this UK and Wales policy requirement in important areas: - • European Protected Species, Section 7 and RDB species. • Habitat connectivity in the restored landscape for recolonisation by protected species. • Loss of 30ha marine habitats. • Long term maintenance and sustainability of recreated biodiversity habitats. NWWT trust that the Planning Inspectorate will see the substantive nature of our relevant representation and will call evidence and hearings on all the above matters. "
Members of the Public/Businesses
Nuclear Free Local Authorities
"• It is highly regrettable that consideration of Horizon Nuclear Power’s application for a Development Control Order for the Wylfa Newydd Nuclear Power Station is reliant on Government National Policy Statements which are totally out of date. Nuclear Power stations are not economically competitive, cannot be built urgently by 2025 and energy efficiency measures mean there is no longer a need for them. • Regardless of this, the particular proposal put forward by Horizon Nuclear Power for this particular site on the Island of Anglesey is totally inappropriate and therefore should not be approved. • Building such a large infrastructure project in a remote rural area like Anglesey is likely to increase local unemployment in the longer term, and have a disruptive impact on the local economy. Going ahead with Wylfa Newydd is likely to detract attention from the far greater job-creating potential of other industries, such as a domestic energy efficiency programme, and the offshore renewable industry, and may actually dissuade companies from setting up in Anglesey, as well as damaging existing industry, such as tourism and agriculture, which rely on an areas reputation for a clean environment to attract business. • It is also likely to be particularly disruptive to the future of the Welsh Language. • Wylfa Newydd would produce nuclear waste which would contain almost 70% of the radioactivity in existing waste, and which will most likely need to be stored on the Anglesey site for at least the next 120 years. • If there were an accident at Wylfa Newydd which required the evacuation of an area similar to the area evacuated around Fukushima, experience suggests this would cause complete chaos because of the limited capacity of routes to the mainland. • Given that alternatives to Wylfa Newydd do exist which are cheaper and can be implemented more quickly it is particular perverse to accept the rather devastating impact the proposals will have on designated conservation sites. • The impact of sea level rise on the proposed site needs to be thoroughly examined in the light of the latest scientific projections on the impact of climate change. "
Members of the Public/Businesses
Nuclear Industry Association
"The Nuclear Industry Association (NIA) is the trade association and representative voice of Britain’s civil nuclear industry. It represents more than 250 companies including nuclear power station operators, new build developers and vendors, those engaged in decommissioning, waste management and all aspects of the nuclear fuel cycle, the supply chain and consultancy companies. The NIA believes nuclear energy is essential to meet the UK’s clean energy needs. As part of a diversified energy mix, nuclear-generated energy provides safe and reliable electricity for UK homes, hospitals, schools and industries, whilst helping to reduce carbon emissions. The civil nuclear sector in an important contributor to the UK’s GDP, the public purse, as well as being the biggest source of low-carbon energy. As the representative trade association for the nuclear industry, the NIA would like to register our interest in the planning process of this new power station. Our representations would specifically focus on the following areas: the economic contribution of nuclear to the UK; the value of the Wylfa Newydd project to both the North Wales and the overall UK economy; its role in local and national jobs growth for the industry; the need for new nuclear in a balanced energy mix; and how the Wylfa Newydd project fits into the government’s Industrial Strategy, as part of the recently agreed Nuclear Sector Deal. It is important to note, as the majority of the UK’s current nuclear fleet comes offline over the next decade, provisions need to be made to replace it with new nuclear plants if we are to meet our legally-binding climate change targets. Wylfa Newydd is the next step towards realising the government’s programme to build 18GW of new nuclear and is a strategic part of the government’s attempt to ensure a secure, low-carbon future for all."
Members of the Public/Businesses
Paula Stegmuller
"1) The future need of electricity production is not declared. 2) The potential rise of the sea level caused by climate change can result in a higher risk of flood and coastal erosion than assumed in the National Nuclear Policy. This risk has to be assessed 3) In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. 4) Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible! If an accident happens, it has to be guaranteed that the full damage will be covered. 5) For every new NPP the safe disposal of all spent fuel and radioactive waste has to be proven in an EIA. It is not enough to present only plans for future disposals, especially if no functioning solutions for final disposals exist anywhere in this world. "
Members of the Public/Businesses
Stowarzyszenie Ekologiczno-Kulturalne Wspolna Ziemia (Association Common Earth) (Stowarzyszenie Ekologiczno-Kulturalne Wspolna Ziemia (Association Common Earth))
"Request: The missing assessment of alternatives for the EIA Wylfa should be conducted from an environmental perspective, and the future need of electricity production should be declared. Request: The potential rise of the sea level caused by climate change can result in a higher risk of flood and coastal erosion than assumed in the National Nuclear Policy. This risk has to be assessed using new facts and knowledge on climate change, and also updated regularly over the whole lifetime of NPP and radioactive waste facilities at the site. It is not clear why this reactor type was chosen. Request: An assessment of different reactor types from an environmental point of view should be presented in the EIA, including a description of the method of decision. The source term for the analysed severe accident scenario is 1.86E+08 Bq Cs-137. Such a release of Cs-137 seems to be very low for the biggest severe accident one can think of. In comparison: In the still ongoing EIA for the new NPP in Dukovany/CZ a release of Cs-137 for a severe accident with core-melt is assumed to be maximal 30 TBq. Moreover, a containment failure cannot be completely excluded without a “residual risk”, especially when regarding the performances of ABWRs in operation or in construction. In case of containment failure of an ABWR a study of BOKU Wien assessed that up to 294 PBq Cs-137 could be released in the environment. The project flexRISK presents dispersion calculations for such a release and results in a possible contamination of Polish territory with about 100 kBq Cs-137/m2, for small parts even higher, depending on the weather situation. In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. Request: Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible! Request: If an accident happens, it has to be guaranteed that the full damage will be covered. Request: In the documentation it should be explained what consequences the Brexit will have on the whole project. Request: For every new NPP the safe disposal of all spent fuel and radioactive waste has to be proven in an EIA. It is not enough to present only plans for future disposals, especially if no functioning solutions for final disposals exist anywhere in this world. "
Members of the Public/Businesses
Verein Lebensraum Waldviertel
"Request: The missing assessment of alternatives for the EIA Wylfa should be conducted from an environmental perspective, and the future need of electricity production should be declared. Request: The potential rise of the sea level caused by climate change can result in a higher risk of flood and coastal erosion than assumed in the National Nuclear Policy. This risk has to be assessed using new facts and knowledge on climate change, and also updated regularly over the whole lifetime of NPP and radioactive waste facilities at the site. It is not clear why this reactor type was chosen. Request: An assessment of different reactor types from an environmental point of view should be presented in the EIA, including a description of the method of decision. The source term for the analysed severe accident scenario is 1.86E+08 Bq Cs-137. Such a release of Cs-137 seems to be very low for the biggest severe accident one can think of. In comparison: In the still ongoing EIA for the new NPP in Dukovany/CZ a release of Cs-137 for a severe accident with core-melt is assumed to be maximal 30 TBq. Moreover, a containment failure cannot be completely excluded without a “residual risk”, especially when regarding the performances of ABWRs in operation or in construction. In case of containment failure of an ABWR a study of BOKU Wien assessed that up to 294 PBq Cs-137 could be released in the environment. The project flexRISK presents dispersion calculations for such a release and results in a possible contamination of Austrian territory with several 100 kBq Cs-137/m2 depending on the weather situation. This is more than the contamination in Austria after Chernobyl. Moreover, in Austria, agricultural countermeasures have to start at an expected contamination with Cs-137 of 0.65 kBq/m2 In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. Request: Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible! Request: If an accident happens, it has to be guaranteed that the full damage will be covered. Request: In the documentation it should be explained what consequences the Brexit will have on the whole project. Request: For every new NPP the safe disposal of all spent fuel and radioactive waste has to be proven in an EIA. It is not enough to present only plans for future disposals, especially if no functioning solutions for final disposals exist anywhere in this world. "
Members of the Public/Businesses
Waldviertler Energie-Stammtisch - Woodquarter Energy-Roundtable
"Request: For every new NPP the safe disposal of all spent fuel and radioactive waste has to be proven in an EIA. It is not enough to present only plans for future disposals, especially if no functioning solutions for final disposals exist anywhere in this world. Request: The missing assessment of alternatives for the EIA Wylfa should be conducted from an environmental perspective, and the future need of electricity production should be declared. Request: The potential rise of the sea level caused by climate change can result in a higher risk of flood and coastal erosion than assumed in the National Nuclear Policy. This risk has to be assessed using new facts and knowledge on climate change, and also updated regularly over the whole lifetime of NPP and radioactive waste facilities at the site. It is not clear why this reactor type was chosen. Request: An assessment of different reactor types from an environmental point of view should be presented in the EIA, including a description of the method of decision. The source term for the analysed severe accident scenario is 1.86E+08 Bq Cs-137. Such a release of Cs-137 seems to be very low for the biggest severe accident one can think of. In comparison: In the still ongoing EIA for the new NPP in Dukovany/CZ a release of Cs-137 for a severe accident with core-melt is assumed to be maximal 30 TBq. Moreover, a containment failure cannot be completely excluded without a “residual risk”, especially when regarding the performances of ABWRs in operation or in construction. In case of containment failure of an ABWR a study of BOKU Wien assessed that up to 294 PBq Cs-137 could be released in the environment. The project flexRISK presents dispersion calculations for such a release and results in a possible contamination of Austrian territory with several 100 kBq Cs-137/m2 depending on the weather situation. This is more than the contamination in Austria after Chernobyl. Moreover, in Austria, agricultural countermeasures have to start at an expected contamination with Cs-137 of 0.65 kBq/m2 In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. Request: Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible! Request: If an accident happens, it has to be guaranteed that the full damage will be covered. Request: In the documentation it should be explained what consequences the Brexit will have on the whole project. "
Members of the Public/Businesses
Za Zemiata/Friands of the Earth Bulgaria
"If such a severe accident happens, what are the consequences? The inventory and source term of an ABWR can show us the maximum amount of radioactive material that can be expected to be released into the environment. In a study from 2014 the inventory of an ABWR was described as follows: Data on possible ABWR inventories are not publically available. However, neutronic characteristics of ABWR and the reactor type ESBWR allow calculating an ABWR core inventory based on an ESBWR inventory by multiplying with a factor of 0.86. The Cs-137 inventory of an ABWR can therefore be assessed as 507 PetaBq (PBq). Under the assumption of the study that 58% of the Cs-137 could be released in case of a severe accident, a release of 294 PBq can be expected in worst case. The project flexRISK made a dispersion calculation based on real European meteorological conditions to show how the released radioactive material will be spread all over Europe. For this assessment a Cs-137 release of 61.5 PBq was assumed which is less than the inventory of an ABWR and less than the assumed severe accident in the above mentioned study. The following figures show weather situations leading to a maximum contamination of Bulgarian territory from the Wylfa site. Parts of the Bulgarian territory could be contaminated with up to 50 kBq Cs-137/m2 (the olive scale). This could be similar to the contamination after Chernobyl when the average contamination in the south of Bulgaria was about 12 kBq/m2. In case of a severe accident in Wylfa with a containment failure, whole of Europe could be contaminated severely. Request: Any new NPP in UK needs to prove that a severe accident with a containment failure is not possible! Request: If an accident happens, it has to be guaranteed that the full damage will be covered. "