Wylfa Newydd Nuclear Power Station

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Wylfa Newydd Nuclear Power Station

Received 10 August 2018
From Welsh Government


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.


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.

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.

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.

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.