Wylfa Newydd Nuclear Power Station

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

Wylfa Newydd Nuclear Power Station

Received 27 July 2018
From National Trust

Representation

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.