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 03 August 2018
From Pinsent Masons on behalf of Land and Lakes (Anglesey) Limited

Representation

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.