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 13 August 2018
From North Wales Wildlife Trust

Representation

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.