Wylfa Newydd Nuclear Power Station

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Wylfa Newydd Nuclear Power Station

Received 10 August 2018
From 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.