Isle of Anglesey County Council · Isle of Anglesey County Council Overview of ... identified as such within the report and are restricted to the ... order that the project promoters

Isle of Anglesey County Council

Overview of Topic Responses

Appendix 1

December 2014

Appendix 1 IACC Overview of Topic Responses

Page 2 of 56

Contents

1.0 Approach to Authority’s Response page 4

2.0 Overview of Topic Responses

page 4

2.1

Countryside and Area of Outstanding Natural Beauty page 4

2.2

Built and Natural Environment page 6

2.3

Welsh Language page 7

2.4 Social Care

page 9

2.5

Trading Standards page 10

2.6

Archaeology and Cultural Heritage page 12

2.7

Housing Services page 13

2.8 Community Cohesion

page 14

2.9 Lifelong Learning

page 16

2.10 Environmental Services

page 17

2.11 Ecology and Nature Conservation

page 19

2.12 Highways

page 20

2.13 Waste and Minerals

page 21

2.14 Waste Management

page 22

2.15 Community Consultation

page 23

2.16 Socio-economic

page 25

2.17 Planning Policy

page 26

2.18 Environmental Impact Assessment (EIA)

page 27

2.19 Nuclear Waste

page 28


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2.20 Soils and Geology

page 28

2.21 Surface and Groundwater

page 29

2.22 Lighting

page 30

2.23 Associated Development

page 31

2.24 Legacy Benefits and Community Facilities

page 32

2.25 Cumulative Impact

page 33

2.26 Infrastructure

page 33

2.27 Sustainability

page 34

Glossary of Terms page 36

Annex ‘A’ – Full URS Socio-economic Response


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1.0 Approach to Authority’s Response

1.1 The main body of the Authority’s response upon Horizon’s PAC 1 public

consultation on the New Nuclear Build has where possible been presented in a

tabular as opposed to a narrative format whereby each paragraph for each of the

topic areas listed has been reviewed by the relevant specialist(s) in an effort to

provide an objective assessment of the impacts of the Nuclear New Build both

positive and negative. The specialist areas which are not supported by a tabular

format, on the basis of insufficient information presented by Horizon, have been

identified as such within the report and are restricted to the areas of ‘Social Care’,

‘Waste and Minerals’ ‘Municipal Waste’ and ‘Community Aspects’. Each of the

paragraphs reviewed within the tabulated format were also then assessed on the

basis of a traffic light or RAG system (Red, Amber and Green) as clarified in the

covering letter. In addition a separate response upon socio-economic issues has

been prepared by URS Consultants on behalf of the Authority which has been

attached as Annexe 1. This document is also supported by a tabular response which

is attached within Appendix 2.

1.2 It should be emphasised that the Authority has expressed concerns across a

range of topic areas. A number of comments, clarifications and requests for further

information have been set out within this document in order that Horizon may

address the points raised where necessary and rectify deficiencies where identified.

The issues raised are presented in a constructive manner and are intended to

provide direction which will ultimately result in a robust submission for the

Development Consent Order (as well as the Town and Country Planning) process.

The Authority would encourage further discussion and consideration of all matters

raised in this report.

2.0 Overview of Authority’s responses upon Horizon’s Pre Application

Consultation

The Authority welcomes the opportunity to respond upon Horizon’s submission, and

having scrutinised the documentation would wish the promoter to take the following

issues into account. These issues can be read in full within Appendix 2 of the

Authority’s response. The issues raised are submitted in a constructive manner in

order that the project promoters may present a robust submission which has taken

full cognisance of the Authority’s comments at PAC 2 through to the DCO

submission (as well as the separate Town and Country Planning Act) process.


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2.1 Countryside and Area of Outstanding Natural Beauty

The following comments draw upon the expertise of the Authority’s Countryside and

Area of Outstanding Natural Beauty Officer and provide an overview of what has

been elaborated and clarified further upon within the tabular format which has been

attached within Appendix 2 of the Authority’s response.

By way of general comment, the documentation is presented well in terms of

its structure and readability however the actual content is somewhat

superficial in that it is very vague and light on detail in a number of key areas.

The approach adopted within the document in terms of its ‘light touch’

approach to detail poses more questions as opposed to informing the reader

and actually providing answers. The submission is also lacking in terms of its

reference/cross reference to the recently adopted Supplementary Planning

Guidance (New Nuclear Build at Wylfa) together with the suite of ten topic

papers which were attached to this document. In terms of specific issues,

these are addressed in turn and provide a brief analysis of the main issues

identified as follows:

It is acknowledged that there will be a significant impact upon the various

environmental designations afforded the area, in particular the areas national

designation as an Area of Outstanding Natural Beauty (AONB) and the

special qualities which define this designation. However, despite its standing

within statute, which is equal in status to the National Parks, the level of detail

whether it be in relation to the direct or indirect impacts of the development on

the AONB’s special qualities either as stand alone or in-combination is wholly

insufficient. In addition, the very close inter-relationship between landscape

and seascape in light of its coastal location also fails to be adequately

addressed within the documentation as does the movement and displacement

of 9 million m3 of material on site. The use of advanced visual techniques

amongst other options to better inform the consultees should have been a

basic requirement given the sensitivity of the landscape which it will potentially

re-shape.

The documents contain very little referencing to site lighting and the impact

which this is likely to cause at the various stages of development through to

the operational stage. This particular issue has potentially serious

ramifications upon the amenities of the area and its residents and as a

consequence should be addressed within its own chapter and closely aligned

to the chapters on air quality, noise and vibration.


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Despite the multi modal transport systems which Anglesey has at its disposal,

the project promoters have dismissed the potential offered by air and rail

without having provided a fully detailed explanation which is sufficiently and

robustly reasoned to qualify their dismissal.

Insufficient information has been provided within the submission to

demonstrate how and where Anglesey can accommodate the construction

workers on a claimed ratio of one third private rented accommodation, one

third using existing tourist accommodation and one third occupying purpose

built accommodation.

It is anticipated that the construction works on site will be ongoing for a period

of approximately 9 years. The lengthy transport delays and disruptions

caused as a result of these works, in particular in crossing the Britannia

Bridge which is already acknowledged as a ‘pinch point’ being the only single

width of carriageway across the UK which serves Euro-route E22, will have a

negative impact on Anglesey as a holiday destination in the short, medium

and long term. As the tourist industry on the island generates approximately

£250 million annually to the islands economy and is estimated to be based on

a figure of 80% as repeat business, such disruptions being sustained over a

decade could effectively be very serious for the islands tourism industry.

The level of detail afforded to the matter of cumulative effects is also

insufficient. The complexities of cumulative impacts in terms of additive and

combined effects on the Wylfa peninsula with the decommissioning of the

ageing Magnox site at Wylfa A and the commencement of construction work

at Wylfa Newydd is in itself (notwithstanding other major projects proposed for

the area) a matter of significant concern which should have been addressed

within Horizon’s PAC 1 documentation.

The photomontages which were attached within Volume 2 of Horizon’s PEIR,

although beneficial to the assessment process, could however have been

presented to make full use of the A3 landscape format on which they were

presented. The photomontages would also have been of significantly greater

benefit had they been developed to a sharper resolution and less pixilated,

illustrating various climatic conditions/seasonal changes. A baseline which

illustrated the actual view without the proposed development for context might

also have been advisable as would a realistic worst case scenario which

illustrated the cumulative impact of the project which included both the

existing pylons and National Grids proposed route corridors.


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There was no reference within Horizon’s PAC 1 documentation to Emergency

Planning measures for any of the various stages of development.

2.2 Built and Natural Environment

The following comments provide an overview of the Authority’s response from a Built

Environment and Landscape perspective. A detailed response has been presented

which has been attached within Appendix 2 of the Authority’s response.

The majority of the Wylfa Newydd development falls within the Anglesey

Special Landscape Area, with elements within the Anglesey Area of

Outstanding Natural Beauty, Heritage Coast and Anglesey Seascape. All of

these designations will be adversely affected by the proposals to varying

degrees. It is also clear that the scale, magnitude and duration of the works

are also likely to impact upon this area for a considerable length of time.

Although it is unclear at this stage, (given the lack of detail presented to date)

to accurately ascertain the degree of these impacts and their full extent, it is

however abundantly clear that timely and appropriate mitigation measures will

be required to reduce and address these adverse impacts.

It will be imperative that further works are carried out prior to the submission

of the second stage of the pre-application consultation process in order that

these impacts can be better understood and quantified through appropriate

assessments using best practice guidelines and approved methodologies to

help drive and steer appropriate and timely mitigation.

It is disappointing that PAC 1 does not appear to consider or propose the

need for an overall and comprehensive Mitigation Strategy to address the

various potential impacts over the duration of the whole works from site

clearance to operation stage. PAC 1 should have made reference to a

programme of mitigation measures over the various stages of the

development. The new landscape setting for the Wylfa Newydd development

could take up to 25 years before it is finalised and established so it is vital that

landscape and seascape mitigation considers the short and medium term as

well as long term proposals.

Wylfa Newydd will be seen in part from many areas and will dominate its

surroundings for many years irrespective of the material finish and landscape

setting that it lies in. It is also clear that not all of the impacts can be suitably

mitigated and that other measures may need to be considered in an effort to


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offset these impacts elsewhere within the Special Landscape Area, Area of

Outstanding Natural Beauty and Heritage Coast.

2.3 Welsh Language

The following comments form a general overview of the Authority’s response with

respect to the Welsh Language in general and are further elaborated upon within

Appendix 2 of the Authority’s response

On a general level, Horizon’s PAC 1 submission does not afford the Welsh

Language and its culture sufficient recognition given the magnitude of

Horizon’s proposals and the propensity for change as a result of this NSIP.

This is disappointing, especially in view of the fact that the language has

deliberately been mainstreamed throughout the New Nuclear Build at Wylfa

SPG. In addition, there is no reference to the requirement to ensure an

alignment between the document and the questions on language impact

assessment on page 18 of the SPG. In order to be in a position to consider

the proposals presented and their impacts, it is necessary to have in place a

reliable baseline of the current position of the language on the island. Given

the current lack of capacity, additional resources will be required to undertake

this exercise. With the baseline in place, it will be easier to assess the

impacts/benefits and in due course, the mitigation steps required to

ameliorate adverse consequences.

The lack of detail within the documentation in respect of workforce (number of

workforce at different times, their locations and how many will bring their

families with them) makes it extremely difficult at this juncture to understand

the implications and possible effects upon the Welsh Language. If additional

information was made available, then it would be possible to look at mitigation

steps earlier in the process such as language immersion centres and

language awareness training. This lack of clarity poses a risk to the fabric of

communities and the Welsh language in relation to matters such as housing

provision for local people, planning of health services and education.

Although there is a reference within the PAC 1 submission to the number of

jobs available when the nuclear power station is operational, there is no

reference to the number of available posts for local people during the

construction stage; for a variety of reasons this is a significant shortcoming.

In addition, the fact that the construction time table is now being compressed

increases the impact on the language as does the increase in construction

workforce numbers from 6,000 to a figure in excess of 8,500. An increase of

approximately 40%.


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Horizon’s lack of detail continues with respect to the content of the Skills and

Jobs Strategy in relation to the Welsh Language. In particular with respect to

the percentage of jobs allocated to local people, the need for language

awareness training and language lessons for staff who are non-Welsh

speakers. There is also a lack of detail again in the document in relation to

the procurement process and the Welsh language. A reference is contained

within their submission to merely employing a ‘percentage’ of the local

population as opposed to specifying the percentage categorically. It is also

imperative that the supply chain provides a fair opportunity for local people to

compete for work.

With respect to the issue of long term benefits, there is no reference to the

Welsh Language. This should be rectified within paragraph 12.3 in Chapter

12 of Horizon’s submission, by adding the Welsh Language to the list of areas

that will require mitigation actions. There will then be an opportunity to

include language immersion centres and adult Welsh Language centres. The

documentation also regrettably fails to address the matter of short term

benefits with respect to the Welsh Language. Horizon are therefore

requested to re-visit the matter and to identify measures which will be

incorporated within their proposals in an effort to re-dress this omission.

2.4 Social Care

The following comments form the basis of the Authority’s response upon matters of

Social Care and are not supplemented by additional information within Appendix 2

of the Authority’s response

The information presented within Horizon’s PAC 1 documentation identifies

areas of significant risks and concern for social care. This relates to areas of

risk to personal safety for vulnerable groups along with the impact on the

sustainability of community based provision and workforce availability in the

future. The available documentation serves to highlight concern and does not

at this stage:

- Provide sufficient detail about how this will impact on the people of

Anglesey

- Address how these risks will be managed and mitigated

Following initial consideration of these issues with key officers and the

documentation available, the Authority’s Social Services Department takes

the view that the following are the key areas requiring further exploration:


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There is currently insufficient information enabling the Authority to consider in

sufficient detail how the development will impact on the islands communities.

There is a need to complete a comprehensive needs assessment. It is

proposed that this is conducted adopting the ‘Communities Voices’

programme. This will need to consider how the building phase will impact on

the lives of people living in the surrounding areas and what arrangements are

required to be put in place to allow for ‘wellbeing’ and ‘social-cohesion’.

It is acknowledged that there will be a requirement to develop ‘service

industries’ during the construction phase, such as accommodation and

catering services. This provides an opportunity to develop ‘social enterprise’

supported employment and apprentice opportunities for those who are known

to Social Services, Youth Justice and Corporate Parenting. Developing such

services would provide an opportunity to mitigate the risks of competing

service industries where support services for the most vulnerable will be

unable to compete given current market considerations and rates of pay.

The development of service industries to cater for the 8,500 posts during the

build project could potentially destroy continuity of services for social care,

day provision and residential/nursing services that are already finding it

difficult to recruit. Reference is also made to the community meals

programme which support people at home in their community. There is a

need to complete a market assessment in an effort to ascertain and mitigate

the risk of ‘displacement’ early on in the process.

From the information presented it is acknowledged that the construction

phase is likely to impact upon safeguarding, thereby potentially exposing

vulnerable adults and children to a high number of transient workers with

disposable income who are likely to be employed on the Wylfa Newydd

project. This again highlights the fact that there is a need to develop the skills

and knowledge of key managers engaged with safeguarding. This will include

appropriate workforce considerations, training and possibly more capacity

within safeguarding teams. It is again recognised that there will be more

detailed knowledge required to inform practice.

Additional capacity will also be required to ‘skill-up’ the workforce across

social care as the experience of working within this changed environment of

transient workers and shift in ‘market management’ will require further

consideration of how the Authority will manage business data and


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safeguarding issues. Funding will need to be identified to appoint staff and

associated expenditure for training and operational activities.

2.5 Trading Standards

The following comments provide an overview of the Authority’s response with

respect to matters which have been assessed by Trading Standards Officers. A

detailed response has also been submitted which has been attached within

Appendix 2 of the Authority’s response.

Insufficient information has been presented as part of Horizon’s PAC 1

submission to demonstrate that the Authority’s road network capacity is

sufficient to cater for the significant level of increase which is anticipated as a

result of its construction activities, particularly in light of their dismissal of

alternative modes of transport at such an early stage of the consultation

process. This concern is compounded by the fact that there are already

capacity issues identified at Britannia Bridge which regularly acts as a

‘bottleneck’.

Notwithstanding the matter of highway resilience, Horizon also appear to have

overlooked the matter of refuelling (in particular HGV’s and AIL’s), parking

requirements in the event that the bridges are closed and the detrimental

impact which would likely arise to the islands roads and infrastructure as a

result of the significant increase in traffic volume which would be further

exacerbated as a result of the high percentage of large vehicles and AIL’s

which would account for this increase in traffic.

Horizon fail to detail what provisions will be put in place to verify the weight of

HGV’s and compliance of Abnormal/Special Loads with certification.

The PAC 1 submission fails to recognise the singular importance of tourism to

the Anglesey economy and the potentially detrimental and long lasting effect

which additional congestion is likely have on tourism unless fully and

appropriately mitigated.

There is currently insufficient information to enable the Authority to properly

consider the likely effect which an increased population (caused by workers,

their families and other ancillary traders) are likely to place on our

communities and the services provided to these communities including

(although not limited to) the Regulatory Services, Waste Management,

Emergency Services, Health Care, Social Services and Education.


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There appears to be little consideration within Horizon’s submission to the

matter of displacement whether it is in terms of employment or with respect to

housing and tourist accommodation. With an influx of 8,500 personnel on site

it is likely that demand for private rental sector accommodation and affordable

homes will increase to the detriment of the existing members of the

community who are also likely to have the least options for alternative

accommodation. Similarly, existing tourist establishments might also be

enticed to adapt to cater for construction workers in an effort to ensure a

regular source of income as opposed to being reliant on the fluctuating and

seasonal tourist industry. The Local Authority and local businesses could also

face difficulties with employee retention, particularly with respect to, although

not exclusively restricted to their domicile staff.

Horizon’s reference to ‘post-construction legacy benefits’ appears to dis-

regard the short and medium term with respect to what the host authority

could reasonably be expected to gain in terms of community benefits given

the fact that it is shouldering the country’s energy burden. Benefits should be

considered both within the planning process and also outside the planning

process. Moreover, the potential also exists for the ‘legacy benefits’ as

described by Horizon to become a greater burden on the Authority as

opposed to any perceived benefit which may be accrued. This would be

particularly relevant in the event that roads weren’t maintained and/or the

weight of vehicles weren’t properly regulated and verified.

A highly material measure of the success or failure of the project could be the

number of local people who would gain employment on site. Although

Horizon’s submission makes reference to employing local traders, no

indication is provided with respect to a target for the proportion of traders who

will be drafted from the local labour market or of any selection process which

may be utilised to assist in this process. Horizon is encouraged to liaise with

the Authority’s Trading Standards Service who could assist in such matters by

providing a register of reliable local traders who are listed on the ‘Anglesey

Buy with Confidence Scheme’.

2.6 Archaeology and Cultural Heritage

The following comments draw upon the expertise of the Authority’s Planning and

Conservation Section which provide an overview of the Archaeology and Cultural

Heritage issues identified. This overview has been supplemented with the detailed

response which has been attached within Appendix 2 of the Authority’s response.


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Given the lack of detail which is contained within Horizon’s PAC 1 submission,

it is difficult for the Authority to accurately establish the degree of impact

which the project will have upon the islands historic environment. However,

from the information presented it can be confirmed that the significant views

from Cestyll Gardens will be adversely affected by the proposed breakwater

and Marine off loading facility both during and upon subsequent completion of

the build.

It can also be confirmed that the Registered Cestyll Gardens have already

been irreversibly harmed as a result of the enabling/investigative works which

have been carried out in advance of the main construction works. Of further

concern in this respect is the statement within Horizon’s PAC 1 submission

which states that there is insufficient space within the defined Power Station

site and the potential threat which this poses on the Registered Gardens.

The three Listed Buildings in Cafnan will have their respective settings

adversely affected as a result of this development. Sections 16(1) and 66(1)

of the Planning (Listed Buildings and Conservation Areas) Act 1990 therefore

apply. The defined Significant Views from Cemaes Conservation Area will

also be adversely affected by the proposed development. However, having

reviewed the photomontages which formed part of Horizon’s PEIR-Volume 2,

it would appear that the impact is greater as a result of the proposed

‘landscaped mounds’ rather than the Power Station itself. These preliminary

comments however are offered without prejudice at this stage as they are

based upon what can only be described as a very basic photomontage of

poor resolution which was not supported by any additional detail which could

reasonably be considered to be of substantive benefit to the Authority in its

assessment of matters.

It can also be confirmed that there are a number of anomalies,

inconsistencies and errors contained within Horizon’s Main Consultation

Document and Preliminary Environmental Information Report-Volume 2, in

respect of heritage receptors and maps which have been highlighted and

elaborated upon further within the main response.

2.7 Housing Services

The following comments draw upon the expertise of the Authority’s Housing Services

Section which provide an overview of the Housing and wider accommodation issues

identified. This overview has been supplemented with the detailed response which

has been attached within Appendix 2 of the Authority’s response.


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By way of general comment it can be confirmed that there is an acute need

for more affordable homes on the island. Increased economic prosperity will

raise house prices and widen the affordability gap. Current median household

incomes are £23,770.00, current average house prices are £168,427.00

based on sales at June, 2013. Despite the recent Government ‘help to buy’

scheme, mortgages are increasingly difficult to obtain, as can be seen at 3.5 x

income, the available mortgage is £83,195.00, demonstrating a significant gap

to afford current house prices. While Horizon is not expected to mitigate an

existing problem, it should assess impacts against the current ‘poor’ baseline.

Horizon’s submission fails to address the fundamental issue of displacement

despite the significant implications which this poses to the Authority. The

island has a larger private rented sector than the rest of Wales with a high

dependence on Local Housing Allowance (Housing Benefit) to pay the rent.

With limited grants available, which are being replaced by loans, there is

currently no incentive to house local people. As a consequence of the

Welfare Benefit Reforms, smaller accommodation is preferred. Contractors

will be looking for this type of accommodation and supply will not be available

to meet the demand. Private Landlords are therefore likely to view

Contractors as an opportunity to achieve higher rents and if so this will

displace tenants who will be unable to source alternative accommodation.

Given the Authority’s statutory homeless responsibilities, particularly with

regard to finding suitable accommodation and the costs incurred, the potential

implications of such actions place the Authority at significant risk. Although

the Authority’s SPG (Topic Paper 3: Housing) identify these risks, Horizon

regrettably offer little by way of substantive information and detail in an effort

to eliminate these risks.

The lack of detail within Horizon’s documentation continues on the matter of

workers accommodation. On the basis of the limited information presented,

initial proposals would suggest that these facilities would be located across

the North of the Island, which again would disregard much of the detailed

guidance contained within the recently approved NNB at Wylfa SPG.

Depending upon worker numbers and size of community, this could create a

dis-proportional imbalance which could adversely affect sustainability,

community cohesion, language and culture. Resources may also be required

to resolve anti-social behaviour issues. One of the aims of current Planning

Policy and the JLDP is growing those communities in the most appropriate

locations that have the necessary infrastructure. Unplanned ‘new’

development will cause difficulties if there is clearly established housing need

in these locations post construction.


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Whilst the ‘new build’ sector has continued to be depressed it is still important

to meet ongoing housing needs. Displacement, by way of attracting a

significant proportion of the existing labour force involved in construction,

could adversely impact on housing needs and result in increased costs on the

basis of demand outstripping supply. Increased supply chain costs regionally,

will impact on the costs of the Authority’s capital programme and responsive

repairs and any proposals to build additional homes in the future. The

Authority is also exposed to the risk of displacement in terms of its own

repairs and maintenance staff.

It is therefore essential that Horizon engages with the Authority and provides

the necessary resources necessary in an effort to address these threats.

These could include, but are in no way limited to:

- Further opportunities to maximise supply by bringing empty homes into

use

- Working with property owners to improve the standard of existing lets

- Assisting people to bring forward spare rooms

- The intention to provide an appropriately resourced ‘Housing Hub’ to

facilitate and co-ordinate this type of provision will encourage the

generation of additional income, target resources to improve the existing

housing stock and assist community integration of the work force.

2.8 Community Cohesion

The following comments draw upon the expertise of the Authority’s Social Cohesion

Unit which attempts to provide an overview of the Community Cohesion issues



Horizon’s PAC 1 submission is lacking in content with respect to the Welsh

Governments Community Cohesion priorities. Concentrating firstly on the

subject of hate crime, local and regional structures for tackling hate crime are

in the process of being developed for North Wales. It is highly likely that

foreign workers could well be targeted once construction works commence

with respect to the NNB at Wylfa. Although no information has been

presented by Horizon within their PAC 1 submission in an effort to clarify what

procedures will be put in place by themselves to address such issues, it will

be imperative that suitable arrangements are incorporated within their

induction processes to draw attention to these issues. Local campaigns and

awareness sessions carried out by Horizon in advance of the anticipated in-

migration of workers might also serve to ‘de-risk’ this potential flashpoint


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Several other large construction projects have recently attracted elements of

human trafficking or abuse. Although there is no reference to such within

Horizon’s submission, it is expected that they, together with all other lower tier

contractors, maintain a strict code of ethics within their tendering and

appointment processes. Linked to this are the ‘pop-up’ industries which often

develop around large scale construction projects, which result in prostitution,

an escalation in crime where advantage is taken of ‘rich-pickings’, often

outside the perimeter fence and in neighbouring towns and villages where

workers are accommodated. Again as with hate crime, a multi-agency referral

pathway is being developed in North Wales to deal with this problem and it

will be essential that Horizon be engaged in this process.

The needs of Gypsies and Travellers (GT) are often overlooked in terms of

policy making and Horizon are encouraged to take full account of such

minority groups when identifying locations for off-site works and their future

uses. The North Wales GT Accommodation Needs Assessment is currently

about to be reviewed and any planned sites associated with Wylfa Newydd

would need to be included as part of that assessment. Human trafficking,

although not referenced within Horizon’s PAC 1 documentation should feature

strongly as part of all future consultations. Recent incidents of such crime on

Anglesey coupled with the potential which exists for this issue to escalate

given the scale of the Wylfa NNB requires a proportional response from

Horizon which directly addresses the matter.

It is acknowledged that there is a requirement to better understand the

migration aspects associated with large scale construction projects. Although

there is reference to inward migration associated with Wylfa Newydd, better

baseline data is required to ascertain what impact this is likely to have on local

services and facilities. This should not only include the construction

workforce, but the other ‘associated developments’ which will need to be in

place to support the upsizing of the local infrastructure to better understand

local migration patterns and their implications.

Wylfa Newydd has the capacity to increase community tensions significantly

in some parts. There is also the likelihood that the scale and nature of the

work would impact adversely on the elderly and those living near the site. It

is therefore incumbent upon Horizon to provide details which clearly set out

the mechanisms which would be introduced for monitoring, avoiding and

minimising against such tensions whether it is on cultural or religious grounds

or general anti-social behaviour.


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There is a fundamental requirement to have in place access to the most

recent baseline data in order that changes can be monitored and variations

noted. The last set of local data was collected in Bwyd Mon, 2007 and those

data sets are either no longer collected by the same organisations or have

been merged into two-county partnership structures in line with Government

initiatives to save money. An assessment of data currently available and data

to fill in the gaps identified needs to be undertaken so as to establish clear

baseline data for monitoring the impacts of the NNB at Wylfa.

It is imperative that the issues currently faced by the islands most deprived

communities are not exacerbated as a result of the NNB at Wylfa. Community

wards within Llangefni and Holyhead are now part of a single Communities

First cluster and could well become the focus for worker accommodation. The

Authority would encourage Horizon to liaise with representatives of the

Communities First programme in an effort to minimise any potential adverse

effects and capitalise upon the opportunities which the NNB at Wylfa may

present to those areas.

It is critical that changes in local demographics are thoroughly monitored and

that there are mechanisms in place at an early stage to respond to community

tensions. Horizon is advised to place far greater emphasis on Community

Cohesion within future consultation material.

2.9 Lifelong Learning

The following comments draw upon the expertise of the Authority’s Lifelong Learning

Directorate which provide an overview of the Educational issues identified. This

overview has been supplemented with the detailed response which has been


It is acknowledged that the NNB at Wylfa (and the influx of construction

workers and their families) will have an impact on the social infrastructure on

Anglesey which will include its schools from early year’s education through to

post 16 educational provision. However, insufficient information has been

presented by Horizon to enable the Authority to consider in sufficient detail the

degree to which educational establishments on Anglesey will be affected as a

result of the Wylfa Newydd development. In order that the Authority might be

better placed to deal with such matters it is imperative that Horizon engage in

discussions with the Authority at an early stage and provide details with

respect to projections which would then form the basis of further


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investigations which would be directed towards eliminating/reducing

unnecessary risk in the matter on the part of the Authority.

Such information would also assist the Authority with respect to gauging its

impact upon the Welsh Language in the community and in schools as well as

the potential impact upon its Welsh Language Centres in Llanfawr and

Moelfre.

Insufficient information is contained within Horizon’s PAC 1 documentation to

enable a reasoned judgement to be made as to the potential impact which

construction work is likely to have upon the vehicular movements associated

with school journeys. Greater clarity is required in this respect which will

enable the Authority to make further representations in the matter.

In order to maximise the prospects for local employment, it will be essential

that a scheme is put in place so that pupils make informed subject choices at

school and college to enable them to embark on courses of study at school,

college and university which lead to qualifications and skills that suit them for

employment in the Wylfa Newydd project in the short, medium and long term.

2.10 Environmental Services

The following comments draw upon the expertise of the Authority’s Environmental

Services Section which provide an overview of the Environmental issues identified.

This overview has been supplemented with the detailed response which has been


From a health and wellbeing perspective the loss of the coastal path is almost

irreversible in the lifetime of most residents of Anglesey as the operational life

of the power station is 60 years. Horizon has to consider mitigation for this

and would suggest that they examine other potential stretches of coast where

there are no footpaths and creating equivalent footpath lengths. The Authority

is aware from its work with the Anglesey Race Circuit that there is a suitable

stretch of coast near the circuit which has no path which Horizon might wish

to explore as part of its mitigation in this respect.

As the coastal footpath is being diverted inland and is required to follow the

main road it is suggested that the visitor centre at the Gateway Complex could

form part of the mitigation measures. This in turn might allow for the

possibility of incorporating an interpretation centre for the geology,

archaeology, fauna and flora of the area using valuable resources such as a

video cam display of the barn owls and samples from the rock drilling on site


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to explain the underlying geology of the area. The possibility should also be

explored of providing a viewing area for the construction site on a similar

theme to that which was erected during the construction of the original Power

Station at Wylfa A.

Artificial light is identified by the NPS in table 4.1 of the PEIR Volume 1 as a

significant issue and greater weight should have been given to it in this PAC1

consultation such as that which has been afforded to noise, with which it

forms a cumulative impact in terms of causing sleep disturbance which is

alluded to within section 22.12 of their PEIR.

Horizon acknowledges the fact that artificial light has the potential to become

a significant issue as they point out within their documentation. "Potential

construction and operational impacts include temporary and permanent

changes to landscape and seascape character changes to publicly accessible

views and an increase of light pollution, sky-glow and reduction of dark sky."

However, given the above circumstances, the Authority consider that the

matter has not been addressed to the level of detail which the issue clearly

merits and the Authority would request that Horizon provide greater clarity

upon the matter in order that a meaningful response may be issued.

Accommodating workers employed at the various construction sites will place

significant demands on the private rented sector with the distinct possibility

that it will lead to displaced bed-spaces set aside previously for tourists. It is

critical that Horizon engage with the Local Authority as soon as possible in an

effort to address these matters.

Horizon’s PEIR Volume 1 recognises that noise is a fundamental issue at this

site. However, the document focusses attention on possible noise sources

which are yet to feature in the noise section, such as:

- Acoustic fish deterrent on the CW intake which could potentially emit a

noise which can be as loud as 160dB @ 1µPa primarily at low

frequencies <250Hz:-

- There is also the possibility of a sub-station within the Wylfa Newydd

site boundary. Mains transformer hum is a common phenomenon and

the existing transformer building has been the cause of repeated

complaint in the past. The Local Authority would not wish to see an

additional source of complaint and mitigation will be required.


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- There is no acknowledgement that the process of forming and re-

profiling the earth mounds over the ten year construction period will in

itself cause noise and possible complaints.

- A construction compound within close proximity to Tregele is

considered by Horizon to “represent a good fit with the key

considerations”. It fails however to address the matter of noise

nuisance given its proximity to residential properties and businesses.

- It is the Authority’s considered opinion that avoiding severe noise

nuisance is likely to be a difficult challenge at this site and Horizon are

expected to employ the latest noise monitoring technology and

management systems to ensure that this is achieved.

- As with noise, the Authority believes that avoiding severe dust

nuisance is likely to be a difficult challenge at this site and it is

expected that Horizon will employ the latest dust monitoring technology

and management systems to ensure that this is achieved.

2.11 Ecology and Nature Conservation

The following comments draw upon the expertise of the Authority’s Ecological and

Nature Conservation Unit and provide an overview of the Ecological and Nature

Conservation issues identified. This overview has been supplemented with the

detailed response which has been attached within Appendix 2 of the Authority’s

response.

Horizon identify Tre’r Gof SSSI as a site at risk from sea flooding and state

elsewhere within their PAC 1 documentation that the geomorphology

underlying the whole Wylfa Newydd site is as yet only partly understood. It is

acknowledged at this early stage that the earth and rock removal is highly

likely to severely impact Tre’r Gof SSSI by altering the underlying rock strata

and drainage patterns. On the basis of the above premise, it might also be

reasonable to assume that a sea flood could come through Tre’r Gof and from

there, through the underlying rock and impact upon the main site. The

Authority would request that greater consideration is given to this matter and

that such detail which transpires is made known to the Authority as part of the

continuing consultation process.

Despite the fact that Horizon quote the National Policy Statement for Energy

guidelines which state that non statutory local wildlife sites need to be taken

into consideration as part of their proposals (policy statements which are


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repeated in Planning Policy Wales), they repeatedly fail throughout their

submission to acknowledge the existence of the non-statutory Wildlife Sites

at/around Wylfa or elsewhere, nor do they make reference to the fact that

Wylfa Head was a declared Local Nature Reserve when they obtained

ownership of the site. Horizon is therefore expected to acknowledge such

ecological designations and to have such designations inserted on all

drawings, maps and illustrations where they may have been omitted.

2.12 Highways

The following comments draw upon the expertise of the Authority’s Highways

Section and provide an overview of the Highways and Transportation issues



Further clarification is required of Horizon with respect to its reference to

Holyhead Port. Holyhead Port and the A5 should not be designated as a

freight route until such time as proposals for major improvement schemes for

the access have been authorised and implemented in accordance with the

Authority’s requirements. Pending the completion of such works, the port and

the relevant section of the A5 which serves the port should only be utilised in

the event of extenuating circumstances which temporarily prevented the use

of Horizon’s main transport corridor(s).

Horizon’s documentation with respect to transport corridors is restricted in the

use of its text. Paragraph 9.56 of the Main Consultation Document refers to

improvements which are carried out, the sole intention of which is to

accommodate freight. It fails to discuss the safety and environmental aspects

which are also linked to these proposals. The documentation should

therefore be corrected to reflect the additional factors which are also of

importance in these matters.

The PAC 1 documentation only refers to localised improvements to the

A5025. It does not explicitly detail the fact that it will be subject to full re-

construction and future proofing nor does it detail the arrangements which will

be in place to secure handover. For the avoidance of doubt and to ensure the

future integrity of the Authority’s highways, greater detail is required upon this

matter.

The Britannia Bridge is acknowledged within the Authority’s NNB at Wylfa

SPG as a ‘pinch point’ being the only section of Euro route E22 across the UK

that is a single width carriageway. It is therefore clearly evident that it is a


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matter which needs addressing in greater detail within Horizon’s proposals as

it is the key entry/exit point for all vehicular movements associated with the

NNB site.

2.13 Minerals and Waste

The following comments form the basis of the Authority’s response upon Minerals

and Waste issues and are not supplemented by additional information within

Appendix 2 of the Authority’s response

It is noted in section 7.15 of Horizon’s Main Consultation Document that

construction waste will be likely to pose some environmental effects.

Paragraph 7.22 goes on to state that an Environmental Management Plan will

be produced as part of the Wylfa construction. It will be imperative that such

plans should assess how the waste produced as part of the 9 year

construction period is to be handled, processed, disposed and utilised in

accordance with the waste hierarchy.

Such assessments should consider the type of waste that will be produced,

the amount and type of wastes that will be utilised on site, consented waste

facilities that are available to handle the waste streams, together with any

other information that is relevant in discussing the waste issues associated

with the NNB at Wylfa. Such assessments should also make reference to the

Associated Developments which are likely to progress as a result of the NNB.

Although these developments are outside of the NNB site, consideration

should be given to the construction waste that will be generated as a

consequence and the potential knock-on / cumulative effects this may have

on the capacity of consented waste facilities to handle these waste streams.

It is noted in section 6 of the Main Consultation Document that spent fuel and

intermediate level radioactive waste are to be dealt with on site, while

paragraph 6.71 states that very low level wastes and low level wastes are

expected to be disposed of in licensed facilities off site. Again, referring to the

site waste management plan that is to be undertaken, it is recommended that

this waste stream together with proposed sites for treatment / processing are

identified.

It is noted within Horizon’s submission that construction work is to take

approximately 9 years for the NNB, with main civil construction activities

including reinforced concrete foundations, building sub structure, super

structure, site roads, mechanical and electrical installations and breakwater.

Given the additional construction projects associated with the NNB and other


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significant building developments proposed on Anglesey, considerable

pressure will be placed on the area’s permitted aggregate reserves.

It is also noted within Horizon’s submission that a MOLF (Marine off-loading

facility) is to be constructed. Will such a facility, be utilised to lessen the

pressure on locally sourced construction aggregates in the development of

the NNB? The Authority would welcome a report on the proposed construction

of the NNB which would address the amount of construction aggregates

required and where such material is to be sourced. In producing such a report

consideration should be given to the following documentation: - Mineral

Planning Policy Wales, MTAN1, and Regional Technical Statement (1st

Review) – North Wales Regional Aggregates Working Party on Aggregates

2014.

In the supply of local aggregates the Authority can engage with Horizon in

identifying sources and providers of aggregate materials on Anglesey,

Gwynedd and across the North Wales region together with the different

modes of transportation that different providers can offer whether by road, sea

or rail.

2.14 Waste Management

The following comments form the basis of the Authority’s response upon Municipal

Waste Management issues and are not supplemented by additional information

within Appendix 2 of the Authority’s response

By way of general comment it can be confirmed that the key points noted in

Topic Paper 9: Waste of the NNB at Wylfa SPG have not been addressed by

Horizon as part of their PAC 1 submission. Key issues such as the Proximity

Principle, alignment with “Towards Zero Waste”, specific detail on Site Waste

Management Plans and proposals on how they will deal with increased levels

of waste arising have not been addressed. There are several references in all

of the submitted documents to “radioactive waste” and the procedures and

proposals to manage this product (this is a specific technical area which will

be responded upon separately within the Authority’s report) but how the

project will impact on municipal waste has been totally overlooked. The

Authority would therefore request that Horizon address this fundamental

omission as part of the ongoing consultation process.

Also of concern to the Authority is the question of how the large amounts of

additional ‘black bag type’ waste produced by the construction workers

themselves will be managed to ensure compliance with current regulations


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and national policies. The location of where construction workers will be

housed will be an important consideration as this will determine the level of

impact of additional ‘black bag type’ waste / kerb-side recycled material

entering the municipal waste stream – this could have major financial

implications on the Council’s waste budgets. Locating all workers in a purpose

built ‘camp’ with a defined boundary will help contain this type of waste and

manage the problem, but if there is an expectation that workers will be housed

at other locations, this will in all likelihood result in added pressure on

municipal waste collection and disposal services on Anglesey. The Authority

would request that greater clarity be provided in this matter.

Furthermore, additional construction workers will inevitably produce more litter

which will need to be collected by the Authority as part of its statutory street

cleansing duties. Again, it is likely that this will increase the financial burden

on the Authority to ensure it meets its statutory responsibilities. This needs to

be considered further by Horizon as there will be an impact on street

cleansing on Anglesey.

Following construction, when the project enters the operational phase, it is

likely that several hundred long term jobs will be created resulting in the

erection of additional houses being built for the workers and their families.

Additional people will result in additional municipal waste being produced;

therefore, once again, this increases the pressure on local authority waste

collection, disposal and street cleansing services. The Authority will therefore

require details to ensure that this potentially long term impact is managed.

In summary, the Authority’s Waste Management Section would expect to

receive far more targeted feedback on the key points raised in Topic Paper 9:

Waste of the NNB at Wylfa SPG and an explanation of the impacts on ‘black

bag type’ waste and litter arisings and how Horizon proposes to manage

these during the construction and operational phases of the project.

2.15 Community Consultation

The following comments form the basis of the Authority’s response upon Community

Consultation issues and are not supplemented by additional information within

Appendix 2 of the Authority’s response.

The community implications of the Wylfa Newydd Project both during the

construction and the operational phases are wideranging.


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Community aspects include the wellbeing of residents of all ages, their health,

welfare and safety; all with a Welsh language and culture dimension.

In order to give full and proper consideration of these aspects the IACC is

pursuing a joined up approach both within the Council, including the Adult and

Children’s Services, Housing & Community Cohesion and Regeneration, and

with other stakeholders. The latter include the North Wales Police, Fire &

Rescue Service, Wales Ambulance Service Trust, Betsi Cadwaladr Health

University Board, North Wales and Local Authority Emergency Planning,

Anglesey & Gwynedd Children & Young People Joint Board, Joint Local

Service Board, Third Sector Community and Voluntary organisations.

There is consensus amongst these stakeholders for the adoption of a multi-

agency co-ordinated approach. There is also recognition of the work initiated

by Horizon through the establishment of a Health Impact Assessment Group.

Whilst all concerned are aware of issues which may arise from the Wylfa

Newydd development, this is by no means comprehensive. The starting point

is seen as collation of up to date data sets on the current state of communities

which will be affected to establish a baseline. The basis for this will be the

‘Bywyd Môn/Anglesey Life Report’ originated in 2007 and subsequently

updated to inform the Single Integrated Plan. This dashboard will need to be

extended to incorporate data not currently included and/ or collected. Such

indicators will be agreed between the parties calling on their particular skills

and expertise.

There is a resource issue with all organisations, especially given ongoing

budget cuts, as regards to resources for gathering and analysing this

information. This will no doubt be highlighted in their responses. This is very

much the case with the IACC.

The establishment of this baseline dataset is seen as imperative. These can

then be overlain by more detailed project information from Horizon. Using

agreed and consistent methodologies the potential impacts will be analysed

and short, medium and long term mitigation measures derived. These

measures would seek to be strategic and joined up with contributions to long

term legacy benefits very much in mind.

The Council understands that individual stakeholder organisations will be

making their own responses to the PAC 1 consultation. These are very much

welcomed and would inform the co-ordinated approach outlined above. A


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close working relationship with the Horizon Group is anticipated with a view to

sharing and agreeing datasets and methodologies etc.

2.16 Socio-economic

The following comments provide an overview of the socio-economic issues identified

(full report attached as Annexe 1). This overview has also been supplemented with

the detailed response which has been attached within Appendix 2 of the Authority’s

response.

A lack of detail on construction and operational worker profile and the labour

market baseline environment. Without this the IACC and partner organisations

will not be able to determine demand for and targeting of programmes for

skills development, training, education etc. to ensure that local people

capitalise on these job opportunities. Further work through the established

Planning Performance Agreement is needed to provide this detail and better

inform IACC and other stakeholders.

Linked to point one an inability for IACC to determine the social and economic impacts of the proposed development and the related demand on a range of services and markets including leisure, education, health, labour and housing at different stages of the project.

A lack of clarity as to the workers accommodation proposals for the project during the construction phase and the impact on the wider housing market including rental and tourism accommodation impacts. Further detail from Horizon is needed on the baseline housing market, the accommodation proposals, their likely impact and potential mitigation and long term benefits. This should form a specific element of the reporting from this point in the application process given the importance and potential impacts.

A very limited focus on the tourism sector as a whole and the potential impacts of the project. The tourism/visitor economy and related activities are key to the economy and a major source of employment and economic growth for Anglesey and Tourism as a sector is not given due consideration. Future reporting should include more detailed analysis of the tourism baseline and the potential impacts.

The issue of displacement in terms of jobs and contracts, tourism, public services and facilities, take up of housing for sale and rent in the short, medium and long term is another area that will need to be considered. The scale of additional demand is a positive opportunity for businesses and the workforce but there is also a need to manage the effects of this demand on existing contracts, businesses and projects which have the potential to be


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displaced by opportunities created by Wylfa Newydd. This will require further co-operation between IACC, Horizon and a range of other partners including business support providers to ensure that existing businesses can effectively manage these demand side issues over the course of the project. Also, there is a need for consideration of redeployment of skilled workforce post the construction phase.

Lack of commitment and detailed information from Horizon on the measures to be taken to ensure local employment and supply chain opportunities are realised. Further work is need on the identified Jobs and skills strategy as a matter of urgency given the lead in times for training outcomes to be realised, the existing knowledge held by Horizon and stakeholders in this context and to ensure partner commitment.

Llangefni should be considered as a suitable location for associated developments. Excluding Llangefni is in direct contradiction to the Locational Guidance outlined in Section 5 of the SPG – explicitly Section 5.3 Guiding Principle (GP) 28 – Llangefni & Environs. Llangefni also has Enterprise zone status under the EZ5 designation of the 'Bryn Cefni Industrial Estate' and EZ6 ‘Creamery Land Zone’ – Close to the A55 and offering design and build opportunities for the low carbon energy supply chain, as well as being identified as one of the main areas of growth in the existing Development Plan, Stopped UDP and emerging JLDP.

Paragraphs 2.17 – 2.28 provide an overview of topic areas assessed by AMEC

Consultants on behalf of the Authority. These comments are supported with a

detailed tabulated response attached as Appendix 2 of the Authority’s response.

2.17 Planning Policy

The Consultation Document appears to take a highly selective approach to

the referencing of policy which will guide the development. Whilst reference is

made to National Policy Statements on Energy (EN-1) and Nuclear Power

(EN-6) which accords with the SPG position (para 2.12) that they are the

principal decision-making framework for the decision-maker, national level

documents are not identified. For example, Planning Policy Wales, the Wales

Spatial Plan and Technical Advice Notes (such as 6 Rural Communities and

14 Coastal Planning) are not referenced. These documents provide relevant

policy context for the development in the form of other matters which the

decision-maker may consider both important and relevant to its decision.

The specific expectations set out by the NNB SPG are not acknowledged

beyond simply quoting the vision. As a minimum, the objectives should be set

out, given their role as the framework for the remainder of the SPG document.


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Reference to the emerging JLDP would also be expected given the specific

references to large infrastructure projects and nuclear-related development,

principally PS7.

Overall, far more detailed reference to the various tiers and aspects of

aspects of policy guidance should have been made which collectively will

guide the preparation and evaluation of the project. This is particularly the

case for the NNB SPG where clear reference to the defined policy areas

(rather than occasional footnotes) would have helped subsequent signposting

of where, how and the extent to which policy expectations will be met.

2.18 Environmental Impact Assessment (EIA)

The approach to EIA is set out primarily within the PEIR. The relevant section

of the report contains mainly factual information concerning the regulatory

requirements surrounding EIA. Horizon recognises that EIA will be required

for the main site, for associate developments (TCPA applications) and for

those elements of the development subject to Marine Licensing. The key

area of concern over the information provided within chapter 4 of the PEI, and

indeed other methodological chapters, is a lack of reference to the Council’s

'Approach and Methodology for Environmental and Cumulative Assessment'

May 2014. This document was produced with the intention of providing

guidance to developers, including Horizon on the Council’s favoured approach

to EIA. The Council would expect that the methodology established by

Horizon follows this approach to EIA or at least recognises the guidance and

explains and justifies why it has not been adopted.

The Consultation Document at paragraph 4.22 references the phases of

development to be scoped in, and makes no reference to decommissioning.

Whilst the difficulty of assessing the effects of decommissioning is accepted

by the Council (SPG paragraph 1.2.7) NPS EN-1 paragraph 4.2.3 is clear that

the EIA should include for consideration of construction, operation and

decommissioning effects. In addition EN-6 references at 3.5.2 the need to

ensure that the site is sufficient to accommodate both construction and later

decommissioning. Other references are found at 3.8.5 and at 3.11.3 (socio

economic). At a local policy level JLDP PS6 requires consideration of

decommissioning effects. Reasons for not including for the decommissioning

phase should be presented.

In the list of topics to be considered within the EIA no reference is made to

climate change. Horizon should provide details of where these impacts will be


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considered within the ES and whether it is proposed to prepare a stand-alone

chapter.

The Consultation Document at 4.25 states that the ES will set out how

consultation responses have influenced the design of mitigation measures.

The Council should expect that opportunities will be available to influence the

design of the project as well as mitigation (Section 49 of the Planning Act

2008 requires the applicant to have regard to relevant responses).

2.19 Nuclear Waste

PAC 1 discussion on nuclear waste is contained within the PEIR only. Key

considerations arising from the PEIR is the lack of a consideration of

alternatives for the storage of Intermediate Low Level Waste and Spent fuel

on site and clarity is also sought on the definition of short-term (PEIR

paragraphs 6.75 and 6.76 respectively).

A key concern arising from the review is the length of time that Intermediate

Low Level Waste and Spent Fuel may require storage on site. The document

states that a period of between 60 and 140 years may be required before the

waste is sufficiently cooled to be transported to a geological disposal site.

With an anticipated station operational life of 60 years this could result in fuel

stored on site for up to 200 years. It is of critical importance to the Council

that consideration is given by Horizon to the effects arising from the retention

of the storage building once the operational site has been decommissioned.

The environmental effects of it remaining in situ should be identified and

assessed. Key policy guidance implications include SPG GP17 which

requires that socio-economic and environmental impacts associated with the

operation of the storage facility be mitigated and furthermore given the

anticipated lifetime of the facility, GP26 which requires that the development

be resilient to flood risk impacts of climate change.

2.20 Soils and Geology

Consideration of effects upon soils and geology are contained primarily within

the PAC 1 PEIR, however relevant information is also contained within

Chapters 7 and 8 of the Consultation Document. Chapter 8, paragraph 8.13

of this latter document notes that there is potential to reuse some excavated

materials within new marine structures. The Council should expect that other

beneficial uses of excavated material in construction of the plant should be


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considered, e.g. granular fills, facing stone and walling etc. SPG GP26

identifies reuse of materials as a key development principle.

Whilst images are provided of anticipated topsoil mounds, paragraph 8.14

suggests that further studies may result in a greater volume of material

requiring excavation. This could give rise to additional impacts upon Tre’r Gof

SSSI and Cestyll Garden in potential conflict with GP20. Potential effects

upon the Porth Wnal Dolerite regionally important geological site (RIG) are

also identified.

Chapter 13 of the PEIR considers soils and geology. Table 13.2 lists a

number of activities with the first potentially requiring interim stockpiling. The

Council should seek to clarify whether this is the case and if so request details

including the intended stockpile location. The second activity relates to

dredging and tunnelling. The Council will require information concerning the

amounts to be recovered and location for disposal. It is recommended that

this and other information be provided within a draft Materials Management

Plan for submission at the next stage of consultation. Further information

should also be sought of areas of potential contamination (Areas of Potential

Concern) particularly those which have not been tested. Contamination

should be addressed in line with SPG policy guidance contained within GP20.

2.21 Surface and Groundwater

Consideration of surface and groundwater is focused within PEIR Chapter 14.

A review of this chapter has raised a number of questions and requirements

for further information rather than any in-principle objections. Key information

which the Council will wish to receive include the potential for impacts upon

the SSSI’s particularly Tre’r Gof and whether the SSSI’s are water dependant,

or capable of being impacted upon via surface or groundwater. Essentially

the Council should seek to understand from Horizon further detail on the

extent to which there is connectivity between existing surface and

groundwater sources and the SSSI’s and the extent to which their features

are dependent upon existing hydrological and hydrogeological conditions.

A significant amount of further information is sought from Horizon in order to

understand the potential for significant environmental effects. In addition, the

potential to affect existing services and facilities requires further information

before any negative effects can be ruled out. In particular Horizon should

confirm that surface water management would include sustainable drainage


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techniques to ensure that surface water runoff does not exceed baseline

levels or increase pressure on existing foul sewers.

Horizon should also be asked to confirm that the mitigation measure to

minimise water use would extend to the domestic water demand of

construction workers and their families. At the moment there is no evidence

in the report that Horizon has distinguished between the demand for water for

construction purposes and domestic demand. Similarly there is no

consideration of impacts on municipal wastewater treatment capacity,

sewerage, or receiving waters quality. A significant increase in demand for

water supply from construction workers would have a corresponding increase

in demand for wastewater services. Identification of the treatment works and

it/their treatment headroom would be useful for the baseline.

Desalination has its drawbacks including its energy intensity (associated

carbon emissions - depending on fuel mix) and disposal of hyper-saline

residues. The environmental impact assessment needs to adequately take

these issues into account if desalination is to be seriously considered as a

mitigation measure.

2.22 Lighting

In both the Consultation Document and PEIR, consideration of the potential

impacts of night-time lighting required for the construction and operation of the

power station and associated developments is sparse and lacking in detail.

One of the main reasons for this is likely to be that the topic is not accorded a

dedicated chapter within the PEI, but is instead spread across the Terrestrial

& Freshwater Ecology and Landscape & Visual chapters. Whilst the potential

impacts of lighting are referred to in both these chapters, these references are

relatively perfunctory and there is a danger that this topic is treated as a

peripheral issue and that assessments may fail to identify significant impacts.

whilst accepting that a scoping opinion has been issued it is recommended

that lighting be treated as a separate topic in future consultation documents

and as a separate topic or sub-topic within the ES.

Key issues identified within the Consultation document include the following:

- No consideration is given to potential breakwater lighting;

- Lighting impacts should be included within the list of key environmental effects;


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- A study area for the assessment of lighting impacts should be proposed;

- Lighting effects should be considered during construction, operation and decommissioning periods in relation to Terrestrial & Freshwater Ecology and Landscape & Visual impacts;

- The minimisation of impacts from lighting should be included in the core principles for landscape design;

- Consideration of lighting impacts should be integral to the Landscape and Biodiversity Management Plan;

- The impacts of lighting should be considered as part of the process of identifying potential sites for associated development.

Key Issues identified within the PEIR include the following:

- As the strategic level HRA (NPS EN-6) could not rule out adverse effects of lighting on the integrity of six European sites, light pollution must be included on the list of topics to be addressed by the proposed working groups;

- Potential effects on the dark skies of the AONB should be identified as a key potential environmental impact, assessment should be complaint with Professional Lighting Guide PLG 04: Guidance on Undertaking Environmental Lighting Impact Studies published in 2013;

- Detail is required on the policy that will inform the restriction of night-time construction and operational activities;

- Mitigation of the impacts of lighting should be identified in relation to potential indirect effects on cultural heritage assets and their settings;

- Lighting should be included as a separate topic for EIA relating to associated developments.

2.23 Associated Development

The approach adopted in the Consultation Document to the impacts of the

proposed workforce on various aspects of the functioning of the Island is a

mixed one. The commitment to the preparation of a Worker Accommodation

Strategy, along with draft principles, is a starting point which accords with the

requirements of SPG GP10, although much of the detail which is likely to

inform the Strategy through additional data gathering is deferred.

Beyond the principle of preparing an Accommodation Strategy, the principles

to guide its preparation wholly ignore the criteria set out in GP10, being


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centred on a strategy of utilising existing bedspaces and thereafter seeking to

"facilitate a range of options to offer the workforce appropriate choices and

flexibility in accommodation types and sizes and development measures to

match supply to demand." Potential impacts on the local housing market are

ignored, as is legacy, in favour of consideration of temporary worker

accommodation. Here some of the accessibility, socio-economic and cultural

criteria of the SPG are identified, but this does not include opportunities for

the re-use of buildings for example, or consideration of the likely effects on

existing communities. As such the principles are considered to be weak and

inadequate in providing re-assurance that the Worker Accommodation

Strategy will properly anticipate the full implications of this issue and provide a

balanced response.

The Consultation Document fails to offer any re-assurance, or proposals for

evaluation, as to how the additional demands on accommodation are likely to

be dealt with in the context of existing communities, either at construction or

operation stage. There appears to be reliance on the capacity of the existing

rental and tourism sectors within the TTWA, and no detail on likely effects.

Even in respect of the proposals for purpose-built accommodation, there is an

absence of detail (beyond a broad area of search which is in itself

contestable) on its local impact and re-assurance that any such development

will be appropriately integrated with existing patterns of service provision and

that following use for construction workers will find an appropriate after-use.

With regard to other associated development such as a proposed logistics

centre this is, in principle, supported by SGP Policy Guidance. However the

document fails to recognise the potential for legacy benefits associated with

such provision, the opportunities that may present themselves to create a

multi-modal facility that may support the expansion of Holyhead Port, or even

possible links to Enterprise Zone sites and initiatives. SPG references to the

benefits of a ‘corporate hub’ are not referenced. In setting out an approach to

locating associated developments no reference is made to their placement

within locations physically accessible to local communities in such a way as

that any related job opportunities would be available to existing residents in

the surrounding area. The rational for the identification of the ‘broad areas of

search’ which is provided fails to acknowledge the area specific policy

guidance contained within the NNB SPG and the opportunities for legacy

benefit. This should be included within the area and the site suitability criteria.

The consideration of associated development sites also includes for the

proposed MOLF. The provision of such a feature is accepted, in principle, by


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the SPG. The extent to which it can cater for all transhipments of bulk

construction materials including all AILs is however doubted and opportunities

to improve facilities at Holyhead Port or example should have also been

considered and taken forward for detailed consideration.

2.24 Legacy Benefits and Community Facilities

Horizon’s approach to legacy benefits associated with the NNB Project raises

a number of concerns, both in terms of the range of issues addressed and the

proposed commitments (as far as they are made at this stage). This contrasts

with the expectations of the NNB SPG which goes to considerable lengths to

identify how and where a demonstrable legacy might reasonably be secured.

Paragraph 11.2 of the Consultation Document establishes the tone for the

remainder of the analysis, setting out a narrow conception of what constitutes

a legacy and what it has the potential to be. This is carried through the

remainder of the chapter and the resulting proposed community facilities. This

contrasts with the NNB SPG which clearly identifies at GP6 the range of

community facilities which should be considered, and, crucially, the need for

the co-ordination of provision with construction and operation phases. The

importance of on-going dialogue with key stakeholders is singled out, but this

is not responded to in the Consultation Document.

The seven areas of legacy benefit identified in para 11.7 of the Consultation

Document are dealt with in a shorthanded fashion which relies on unspecified

consultation: "Horizon intends to work with communities to understand local

issues and consider appropriate enhancements"; "Horizon is considering a

range of initiatives"; “Horizon intends to consider" etc. Again this contrasts

with GP6, GP7, GP8 and GP9 of the NNB SPG which are clear in their

expectations. The contrast in approach is brought to a head in paragraphs

11.3-11.9 where various commitments on ‘community facilities’ are made but

which are fundamentally at odds with the principles of integration, cohesion

and equality of opportunity set out in the NNB SPG.

2.25 Cumulative Impact

The approach and methodology to the consideration of cumulative impacts is

set out within the PAC 1 PEIR. The document fails to mention the Council’s

document Approach and Methodology for Environmental and Cumulative

Impact Assessment, which is referenced within the NNB SPG and which

provides advice and guidance on the Council’s recommended approach to

assessment. Horizon sets out the types of projects that may be considered


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within the cumulative assessment and includes the names of some known

projects, however the Council’s assessment guidance recommends a more

formalised screening process of projects which can be agreed with the

Council. This has not been recognised in the document. The Council will

need to agree the projects to be included within the cumulative assessment.

In addition to projects, forthcoming site allocations contained within the JLDP

may require consideration and further discussion with Horizon will need to

take place.

2.26 Infrastructure

This topic includes consideration of air, sea, rail and road. The Consultation

document provides limited consideration of air as a transport mode but

recognises its inherent weaknesses for mass transportation of people or

goods. Reference is made to small scale movements and links from

Anglesey Airport by shuttle-bus to the main site. Reference to linkages to a

proposed ‘corporate hub’ should also be included.

Consideration is given to the movement of bulk construction materials and

AILs by sea with the favoured destination being the proposed MOLF. The

construction and use of a MOLF is recognised and supported in principle

within the NNB SPG at Policy GP14. However the SPG is also keen to

establish legacy benefits and sees support for Holyhead Port as a potential

opportunity arising from the Wylfa Newydd Project. Horizon considers, at a

high level, opportunities to use Holyhead but limits these to the temporary

mooring of craft and limited delivery by ships not capable of using the MOLF.

The Council should seek further consideration of opportunities to support the

Port through improvements to facilities and in particular opportunities to link

the Port, more successfully to the rail network, (see below).

The Consultation Document identifies existing and previous (Amlwch Branch

Line) rail infrastructure and provides a high level, strategic response to the

suitability of each. It dismisses all types of rail from consideration, mainly due

to the requirement for double handling, or the implied costs and environmental

effects of re-opening the branch line. The NNB SPG GP14 is very clear that

sea and rail are the two modes of transport which should be used over road.

Opportunities to import goods by rail and then transfer them by sea via

Holyhead Port, and via an intermodal facility should be considered as this

could provide a significant legacy for the Island’s economic future and support

initiatives to enhance and expand the Port. Little consideration is given to the

use of rail by construction workers. Studies undertaken on behalf of the


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Council have suggested that as a commuter service, the existing rail system

is inappropriate. However Horizon contributions to expand and develop the

number and frequency of passenger trains would remove vehicles from the

A55 and provide benefits to existing communities. Horizon should give further

consideration to the feasibility of increased frequency services.

The PAC1 consultation, across the various documents, identifies road

transport as the appropriate mode of travel for freight and for workers during

the construction phase. This is at odds with the NNB SPG (see above) which

favours rail and sea and also the Wales Freight Strategy and NPS EN1 (Part

5.13, paragraph 5.13.10).

Reference is made to the management of traffic and to mitigation in the form

of Park and Ride facilities and to consideration being given to a bus system

linking existing settlements and transport nodes to the site. Such facilities

should be made available to all members of the local community. A level of

detail is provided with regard to the highway works proposed for the A5025.

In order for the Council and local communities to understand the need for

such works further information should be provided with regard to projected

vehicle numbers.

2.27 Sustainability

Horizon NP has chosen to adopt a hybrid approach to the consideration of the sustainability performance of the proposed development which seeks to use the structure of the statutory SA/SEA process, but in a fashion tailored to their particular purposes. As a result, the document neither fulfils the requirements of the formal SEA regime, nor responds to expectations in respect of a robust and systematic approach to identifying sustainability issues associated with the proposals and their consequent performance. Key problems with the resulting document are:

- The absence of clear project objectives against which sustainability

objectives can be tested for compatibility.

- The absence of the identification of key sustainability issues which form

the basis of assessing the significance of effects.

- The absence of the identification of key issues relating to areas of

particular environmental importance.


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In addition, the quality of aspects of what is presented can be called into

question, notably:

- The limited review of plans, policies and programmes which excludes

consideration of key European legislation such as the Birds and

Habitats Directive.

- No connection made between the plans, programmes and policies

reviewed and the scheme proposals.

- Limited depth to the baseline data, with no systematic referencing of

sources.

- The absence of signposting as to how the data presented relates to the

proposed Sustainability Objectives, and in the case of the Welsh

language absence of data to substantiate the proposed objective.

Glossary of Terms NSIP’s Nationally Significant Infrastructure Projects DCO Development Consent Order WG Welsh Government IACC Isle of Anglesey County Council PAC Pre-application Consultation WNP Wylfa Newydd Project ABWR’s Advanced Boiling Water Reactors CWS Cooling Water System MOLF Marine Off-loading Facility SoCC Statement of Community Consultation AONB’s Area of Outstanding Natural Beauty JLDP Joint Local Development Plan


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NNB Nuclear New Build SPG Supplementary Planning Guidance GT Gypsies and Travellers PEIR Preliminary Environmental Information Report NPS National Policy Statements SSSI Site of Special Scientific Interest HGV’s Heavy Goods Vehicles AIL’s Abnormal Indivisible Loads MTAN Minerals Technical Advice Note HRA Habitats Regulations Assessment TTWA Travel to Work Area GVA Gross Value Added HIA Health Impact Assessment LIA Local Impact Assessment TCPA Town and Country Planning Act LA Local Authority RSCP Regional Supply Chain Programme


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Annex A

Response to Socio-economic

aspects of PAC1


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EXECUTIVE SUMMARY

This document sets out the Economic & Community Regeneration’s response to the PAC1 documentation issued by Horizon Nuclear Power in October 2014 focusing on the socio-economic aspects of the documentation. This includes areas such as employment, skills development and training, supply chain, sector impacts, housing and labour market demand amongst others. The review focuses on the main consultation and Preliminary Environmental Information (PEI) documents The overall socio-economic content in the technical documents needs to be extended and updated where and whenever possible to give a much more informed picture of baseline conditions to the intended audiences. A range of issues are set out within the report that requires further attention and action from Horizon in discussion with IACC. In summary the key points to note from the review are 1. A lack of detail on construction and operational worker profile and the labour

market baseline environment. Without this the IACC and partner organisations will not be able to determine demand for and targeting of programmes for skills development, training, education etc. to ensure that local people capitalise on these job opportunities. Further work through the established Planning Performance Agreement is needed to provide this detail and better inform IACC and other stakeholders.

2. Linked to point one an inability for IACC to determine the social and economic impacts of the proposed development and the related demand on a range of services and markets including leisure, education, health, labour and housing at different stages of the project.

3. A lack of clarity as to the workers accommodation proposals for the project during the construction phase and the impact on the wider housing market including rental and tourism accommodation impacts. Further detail from Horizon is needed on the baseline housing market, the accommodation proposals, their likely impact and potential mitigation and long term benefits. This should form a specific element of the reporting from this point in the application process given the importance and potential impacts.

4. A very limited focus on the tourism sector as a whole and the potential impacts of the project. The tourism/visitor economy and related activities are key to the economy and a major source of employment and economic growth for Anglesey and Tourism as a sector is not given due consideration. Future reporting should include more detailed analysis of the tourism baseline and the potential impacts.

5. The issue of displacement in terms of jobs and contracts, tourism, public services and facilities, take up of housing for sale and rent in the short, medium and long term is another area that will need to be considered. The scale of


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additional demand is a positive opportunity for businesses and the workforce but there is also a need to manage the effects of this demand on existing contracts, businesses and projects which have the potential to be displaced by opportunities created by Wylfa Newydd. This will require further co-operation between IACC, Horizon and a range of other partners including business support providers to ensure that existing businesses can effectively manage these demand side issues over the course of the project. Also, there is a need for consideration of redeployment of skilled workforce post the construction phase.

6. Lack of commitment and detailed information from Horizon on the measures to be taken to ensure local employment and supply chain opportunities are realised. Further work is need on the identified Jobs and skills strategy as a matter of urgency given the lead in times for training outcomes to be realised, the existing knowledge held by Horizon and stakeholders in this context and to ensure partner commitment.

7. Llangefni should be considered as a suitable location for associated developments. Excluding Llangefni is in direct contradiction to the Locational Guidance outlined in Section 5 of the SPG – explicitly Section 5.3 Guiding Principle (GP) 28 – Llangefni & Environs. Llangefni also has Enterprise zone status under the EZ5 designation of the 'Bryn Cefni Industrial Estate' and EZ6 ‘Creamery Land Zone’ – Close to the A55 and offering design and build opportunities for the low carbon energy supply chain, as well as being identified as one of the main areas of growth in the existing Development Plan, Stopped UDP and emerging JLDP.


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1.0 Context

1.1 Isle of Anglesey County Council and Wylfa Nuclear New Build

1.1.1 IACC has been a strong supporter of the Nuclear New Build at Wylfa over an

extended period and recognises the opportunities that could be realised by the investment for the local economy, workforce and residents of Anglesey and wider North Wales area. This support is predicated on the understanding that measures will be developed in partnership with Horizon Nuclear Power to mitigate any adverse impacts and maximise the positive benefits of investment.

1.1.2 To this end IACC have been instrumental in helping support the nomination and inclusion of the site for nuclear new build in the National Policy Statement and have worked extensively with partners including Horizon, Welsh Government, NDA and others to deliver initiatives and support to maximise the potential benefits for Anglesey and North Wales. This includes a major commitment in the Energy Island Programme – a comprehensive strategy and resources to create a world-renowned centre of excellence for the production, demonstration and servicing of low carbon energy:

Production – Investing in new low carbon energy production to help secure a stable energy future for Wales;

Demonstration – Establishing world-class facilities to place Anglesey as a leading location for low carbon energy innovation and demonstration;

Servicing and supply chain – Ensuring that local companies and people benefit and take advantage of opportunities from new energy investments.

1.1.3 IACC’s support for the project has remained despite a series of potential setbacks including RWE and E-On pulling out of the original project. IACC remained supportive and provided considerable political and officer support to Horizon during the subsequent sales process. Similarly with the Fukushima disaster in 2011 there was additional scrutiny of the role of nuclear power in the UK energy mix the IACC again remained fully committed and supportive of the NNB project.

1.2 The Wylfa Newydd Opportunity

1.2.1 The IACC recognise the scale of the opportunity which Wylfa Newydd

presents and this is set out at a high level in the current PAC documents. However there is currently only limited detail as to the specifics of the requirements in terms of workforce, supply chain opportunities and legacy that Wylfa Newydd will create and importantly no real emphasis on the measures and mechanisms by which these impacts will be realised at the Anglesey and North Wales levels.


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1.2.2 One area that Horizon has the ability to shape is the procurement process

and supply chain through the letting of contracts and including a commitment to local sourcing and social responsibility. It is disappointing that this commitment is not yet evident in the PAC documents. Horizon should quantify an acceptable level of local supply chain opportunities and project content and make a commitment to this in the project proposals.

1.2.3 At this stage in the process it is clear that further work is needed to understand the nature and scale of opportunities and the means by which Horizon will work with IACC and other partners to realise benefits and mitigate any adverse impacts.

1.3 Partner Commitment

1.3.1 The Wylfa Newydd project is a long term commitment from all partners

involved given the lifecycle of the Nuclear New Build. The IACC as the host authority for this multi-billion pound investment, and Hitachi/Horizon as the parent and project development organisation, have a statutory and moral obligation to Anglesey to ensure that its residents and economy fully capitalise on the opportunities available and ensure that a strong legacy ensues.

1.3.2 At this stage in the process, the IACC is disappointed in the level of ambition

and commitment shown by Horizon in the PAC documents. The IACC feel that the time and investment made by partners over the past six years to develop a sound and informed understanding of the issues and impacts, particularly around socio-economic matters, is not currently reflected in the PAC documentation.

1.3.3 Whilst the IACC recognise the changes in the project have changed some of the parameters, this has not resulted in a further request or need for a new scoping opinion. At the same time the PAC consultation document indicates limited scope for changes in the programme giving another indication that a significant amount of project planning and background work has already been undertaken. Given the positive relationship between Horizon and the IACC, we would have expected to see a greater commitment by Horizon to developing an informed view on these matters.

1.3.4 Given this position this report sets out the key issues we have identified from a review of the PAC documentation focusing on socio-economic issues. This includes a series of recommendations as to where there is a need for further work to clarify and improve the information and to outline the IACC’s expectations for the future development of the project.


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2.0 Key issues & recommendations

2.1 Introduction

2.1.1 The following section sets out the key issues in relation to the socio-economic

information and activities presented within the PAC documentation following a review which has focused on the main PEI and consultation documents. This reflects more detailed comments, which should be considered alongside this report, made by a range of officers from across the authority relating to different socio-economic aspects. These are primarily:

Population;

Employment and Labour market issues including labour supply and demand, wage levels, economic displacement;

Supply chain opportunities and impacts including displacement;

Tourism, leisure and recreation including public access;

Community services and facilities provision and demand;

Also of relevance in the socio-economic context are the following

Housing market effects including displacement and impacts on affordable housing provision;

Associated development;

Aspects of traffic and transport; and

Combined and cumulative impacts

Further to this there are a series of comments which relate to:

Overall content of the socio-economic sections

Socio-economic study areas

Presentation of socio-economic information

2.2 Overall Content

2.2.1 The consultation document sets out the evolution of the project1 and the work

that has been undertaken to date. This sets out a period from of over four 1 Paragraph 1.10 and Figure 1.1, Wylfa Newydd Project Pre-Application Consultation - Stage One, Consultation document,

Horizon Nuclear Power, October 2014.


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years from April 2010 to September 2014 where baseline environmental survey work has been undertaken by Horizon.

2.2.2 The consultation document confirms that the information presented in the PEI “has been gathered through a combination of desk-based reviews of publicly available information and survey work commissioned by Horizon”. This includes work on socio-economics2. Given this the overall level of detail on the socio-economic baseline conditions, issues and potential impacts within the PAC documentation is limited despite what has been a significant period of time in which work has been undertaken.

2.2.3 The overall socio-economic content in the technical documents needs to be extended and updated where possible to give a much more informed picture of baseline conditions to the intended audience. The limited content provided at this time is disappointing given the long lead in time and co-operation with/research studies commissioned by IACC. These have been identified by IACC officers in discussion with Horizon and are also identified in the NNB Wylfa SPG.

2.2.4 The IACC are in the process of commissioning a detailed socio-economic study which needs to be developed in collaboration with Horizon. The study will undertake a 'baseline analysis of the Anglesey economy and develop scenarios for its re-structuring through the Wylfa Newydd nuclear new build’. This study will be key in identifying the baseline economic conditions of Anglesey and what measures & mitigation will need to be undertaken to ensure that local people capitalise on these opportunities. To prevent duplication and to ensure consistency, the IACC are eager to share the outcomes of this study with Horizon so that a common baseline is used for all future socio-economic analysis.

2.3 Study Area Selection

2.3.1 The introduction to the socio-economic section in the PEI is misleading3.

There is reference to Chapter 4 to confirm the terminology associated with the Wylfa Newydd Development Area but this information is not contained within Chapter 4.

2.3.2 The introduction to the socio-economic topic also notes that the chapter

“describes the baseline environment for socio-economic features, and the potential socio-economic impacts associated with the Wylfa Newydd development area “. This area only covers “the indicative area of land

2 Paragraph 4.21, Wylfa Newydd Project Pre-Application Consultation - Stage One, Consultation document, Horizon Nuclear

Power, October 2014.

3 Paragraph 7.1, Wylfa Newydd Project Pre-Application Consultation - Stage One, Preliminary Environmental Information

Report – Volume I, Horizon Nuclear Power, October 2014.


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including the Power Station Site and the surrounding areas that would be used for the construction and operation of the Power Station4”

2.3.3 As such this is misleading as the impacts for the socio-economic topic will result from this area and associated development in other locations. This needs to be amended and clarified.

2.3.4 The local socio-economic study area is defined as within a 5km boundary of the power station site. The IACC is unclear as to the justification for this local study area. Residents, communities and businesses directly affected by the construction of the power station will experience a range of impacts at different geographical scales which will be determined by the different topics. These individuals and groups will also access a range of services and travel for work over a much larger area on a day to day basis and as such the socio-economic study area needs to be widened out particularly at the baseline stage to understand and provide an informed view. This is partially addressed by utilising the wider socio-economic study area identified. Further discussion and clarification on the approach here is needed.

2.4 Presentation

2.4.1 Formats

Overall the baseline information would benefit from more graphical representation using tables, charts and graphs. At present a lot of the information is presented as text and as such is less accessible. Given the wide target audience this will limit the extent to which an informed picture of the baseline environment and impacts is provided. Further emphasis should be placed on using different formats for presenting information to improve interpretation.

2.4.2 Using proportion and scale

In the context of economic statistics, for example employment, it is not just the proportion/percentage figures that is important to understand but the absolute numbers. This should be included in the information presented. For example 7% of those in employment on Anglesey may work in construction but this may equate to a comparatively small number of people (approximately 1200 on Anglesey) compared to the likely demand created. This will be particularly pertinent in relation to the proposed wider study area and help give the intended audience/stakeholders an informed view on the scale of the existing workforce relative to the likely demand created.

2.4.3 Travel to work data

Horizon should check the current and future availability of travel to work geographies and supporting data to understand the position is in relation to




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use of 2011 census and any potential improvements that could be made to the baseline and analysis.

2.5 Population

2.5.1 Clarification of social challenges

The PEI document references social challenges caused by demographic change but fail to identify what these challenges are5 clarification is needed here. There is also a need for work on projecting the likely demographic impacts of the project, providing analysis by age group, gender and other factors, throughout the project timescale. This will help to understand the different aspects of market, service and facility demand created by the project.

2.5.2 Inclusion of an equality impact assessment

Within the existing PAC documentation there is no mention of an equality impact assessment. Further consideration of this work to complement the wider studies around language and health impacts is needed.

2.6 Employment and Labour Market

2.6.1 The introduction of a major new source of long term employment will only

have a positive effect on the social and economic situation of the local and wider area if local people secure these jobs .The IACC has been actively supportive of the Wylfa Newydd proposal for a number of years and has demonstrated tremendous good will and positivity towards the project. This good will is based on the premise that local people will benefit from the opportunities presented by the new nuclear build.

2.6.2 Further detail on the labour market baseline environment, workforce

requirements, potential impacts and a detailed strategy to address these issues is a priority. Whilst IACC recognises Horizon's reference to the development of such a strategy within the PAC documentation we feel that work could have been much more progressed at this stage, based on Horizon's and partners existing knowledge of project requirements, to put this in place and ensure a focus on practical delivery of skills, workforce development and supply chain engagement activity that would enable local benefits to be realised.

2.6.3 Workforce profile

There is currently limited information on the scale and scope of the workforce during the different stages of the project. This is important in determining the




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scale of impacts in a variety of contexts including labour market, housing, facilities and services. Without this detail it is not possible for the PAC documentation to meet its stated aims to provide stakeholders with an informed picture of the likely project impacts.

Further information is needed as a matter of urgency to inform service planning and allow IACC, local people and businesses the opportunity to prepare and maximise the possibility of positive benefits and mitigate any negative impacts. Further detail is of particular value in understanding the impacts on labour supply and knock on effects on existing businesses and wages in specific sectors for example construction and catering which are likely to be impacted. This makes it more difficult to plan for business support and training and skills provision.

The IACC are in the process of commissioning a detailed socio-economic study which will help inform Horizon's economic baseline and future employment projections. The study will undertake a 'baseline analysis of the Anglesey economy and develop scenarios for its re-structuring. This study will provide labour market intelligence of the existing employment 'pool' on Anglesey (and the wider sub-region) and will identify the likelihood of local people securing these jobs (given existing skill levels, educational attainment, qualifications etc.). Once this study has been undertaken, more accurate and targeted mitigation can be identified to ensure that local people can capitalise on these opportunities.

2.6.4 Scale and phasing of employment

The peak construction employment figure has increased significantly from a position of 6000 to 8500 with little explanation of the reason for the change. If there is sufficient evidence to suggest this increase in overall construction workforce at peak it would be concluded that further detailed information should be available that has helped to calculate the higher figure. Further information should be provided on the phasing and scale of the project workforce over time to understand the temporal pattern of demand in a range of markets including labour, housing, leisure and other services.

2.6.5 Existing economy and employment baseline

The level of detail across the baseline is limited and would benefit from more contextual (e.g. key employers) and quantitative information (e.g. employment in existing major employers, job losses etc. to give a clearer view of the sectoral and company profile.

As noted elsewhere in this response the tourism sector and its economic role needs to be given a higher profile with a more detailed baseline and this should also be repeated for the construction sector given the potential benefits to the sector from the project.

2.6.6 Ageing workforce and replacement demand


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The issue of an ageing workforce needs to be referenced and evidenced. This will mean a subsequent issue of replacement demand for those retiring and this will likely have an additional impact and create further demand for labour during different phases of the project. This is a particular issue in the energy and existing Wylfa workforce.

2.6.7 Assessment of employment impacts

At the current time there is only limited detail on the approach to assessing employment impacts and further detail is needed as to the approach to be taken to ensure that the assessment is objective and takes into account appropriate considerations around additionality looking at factors including deadweight, displacement, substitution, leakage and multiplier effects. This approach needs to be set out by Horizon.

2.6.8 Consideration of displacement effects

Displacement is a key issue for the IACC and we believe it should be given further consideration as to how it will be assessed in relation to employment and wider demand for services and products. For example this could include potential displacement of employees from existing businesses to the Wylfa Newydd supply chain and diverting tourism trade away from exiting accommodation providers on the island. Horizon should outline how issues of displacement will be assessed.

2.7 Skills and Training

2.7.1 Strategy

IACC welcome Horizon’s proposals to produce a jobs and skills strategy document but there is little detail at this stage on the specifics of this. The IACC expect to see further detail in the immediate short term in order to ensure a supply of locally based labour that can capitalise on the different employment opportunities. Timing and quick action is critical particularly in terms of the direct construction and operational activities where training has a relatively long lead in time and where there is also a need to replace skills lost through an ageing workforce.

2.7.2 Commitment from suppliers to training

Similarly with training relating to “indirect opportunities” during the construction phase there is no clarity as to how or the extent to which suppliers will be required to use local labour and provide training opportunities. Further clarty is needed as to the proposed approach to ensuring indirect opportunities include elements for workforce training and skills development.


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2.7.3 Clarity on supporting research

The Local Labour Availability Study will need to be consistent with the study currently being commissioned by the IACC on economic future. Consistency in baseline conditions and scenarios is essential to make sure that training and skills development is effectively targeted to ensure that local people capitalise on the opportunities. Further clarity on the timescale and likely involvement with partners including Local Authorities, Welsh Government and supporting initiatives is needed.

2.8 Supply Chain

2.8.1 As noted throughout the PAC documents and in work undertaken by IACC the

scale and complexity of the supply chain for the project means there are likely to be significant opportunities and benefits for local firms and the workforce. However there is no real detail as to the requirements/profile of the potential supply chain throughout the project planning, construction, operational and decommissioning phases yet provided or the extent to which this is likely to involve procurement with local firms. A clearer commitment from Horizon and higher Tier suppliers to a target for the proportion of local procurement and content is needed.

2.8.2 This will be a critical factor in determining the scale of the positive impacts of

the project that are experienced and remain at the "local" level (as opposed to being captured by workers and firms from outside of Wales) and the wider implications for services, housing, transport and a wide range of other factors. There are a number of WG/LG initiatives taking place to support and enable local companies to achieve accreditation and a realistic standpoint from Horizon is considered essential in maximising government support for the local and regional economy.

2.8.3 The IACC welcome Horizon’s intention to promote the development and use of local supply chains6 for the Wylfa Newydd Project but wish to see more detail to understand how these proposals will work in practice.

2.8.4 The issue of displacement both in terms of jobs and contracts is another area that will need to be considered. The scale of additional demand is a positive opportunity for businesses and the workforce but there is also a need to manage the effects of this demand on existing contracts, businesses and projects which have the potential to be displaced by opportunities created by Wylfa Newydd. This will require further co-operation between IACC, Horizon and a range of other partners including business support providers to ensure that existing businesses can effectively manage these demand side issues over the course of the project.

6Paragraph 2.14, Wylfa Newydd Project Pre-Application Consultation - Stage One, Consultation document, Horizon Nuclear



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2.9 Tourism

2.9.1 Economic contribution and importance of the tourism sector

On Anglesey tourism, the public sector, retail and manufacturing are the largest sectors in employment terms7. Further evidence from STEAM visitor data and the Office for National Statistics (ONS) demonstrates the growing economic impact of the sector and as such there is a strong basis for a more detailed analysis of the sector and the potential impacts. IACC believe this needs to be recognised and the role of tourism prioritised by inclusion of a separate chapter within the PEI documentation and later stages of the EIA process and reporting.

As the PAC currently stands the IACC feel that baseline information on tourism and the wider economy is very limited and doesn't provide an informed view of the baseline environment or potential impact upon it from a tourism perspective. Further work is required to understand the tourism baseline and potential impacts covering:

Tourism, leisure and visitor facilities;

Tourism accommodation (linked to the required work on the housing market baseline and impacts);

Perceptions and visitor survey to understand the impacts of a nuclear new build on visitor behaviour. Repeat visitors are a key component of the visitor profile and impacts on this cohort need to be understood to gauge wider potential economic effects;

2.9.2 Engagement and consultation with tourism businesses and visitors

The proposed consultation process identifies that Horizon will undertake targeted consultation and engagement work with specific groups where appropriate. The IACC feel that groups relating to tourism including tourism and accommodation operators and visitors would be appropriate consultees in this context given the importance of the sector to the economy.

The IACC would suggest that further dialogue is required with the Destination Anglesey Partnership (DAP) Board which was established to co-ordinate all the activities and services which impact on visitors and their enjoyment of a destination. 8 This will ensure that Horizon understand the importance of tourism on the Island and will facilitate dialogue with the service providers.

2.9.3 Impact of project elements on leisure and tourism

7

8 Destination Anglesey Partnership: Terms of Reference http://www.anglesey.gov.uk/Journals/2012/08/24/DAP-structure-and-

ToR.pdf

http://www.anglesey.gov.uk/Journals/2012/08/24/DAP-structure-and-ToR.pdf

http://www.anglesey.gov.uk/Journals/2012/08/24/DAP-structure-and-ToR.pdf


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The lack of any detail on tourism and recreational activities also makes it difficult to have an informed view of the impact of project elements, including the MOLF and cooling water system. Further baseline information as to the extent of recreational and leisure activity is required to inform the impact assessment.

2.9.4 Evidence – age and content

More recent data is available that is not currently referenced within the tourism section (see detailed comments in spreadsheet). In addition there is very little information on existing facilities, accommodation and wider tourism/visitor assets to provide a sound baseline. The Destination Management Plan is not included within the referenced material and this is the key document from an Anglesey perspective. Further work is needed to incorporate a better range and more up to date information to allow an objective and informed assessment of the project on the tourism sector to be undertaken

2.10 Public Access and Recreation

2.10.1 Baseline

The PEI refers to “A full assessment of the potential impacts of the Proposed Activities on the established public access and recreation baseline9; - Further clarification on the established access and recreation baseline is needed. At the present time the information in the PAC documents on the recreation baseline is high level. Is further detail available and can it be provided by Horizon?

Whilst the approach to assessing access to Public rights of way is well set out within the PEI there is no detail on the approach to assessing access to facilities outside of Public Rights of Way i.e. Open space. This information should be provided.

2.10.2 Terminology

Further clarity is needed on the recreational facilities in the wider “regional” study area10 – which are the leisure centres and other facilities being referred to and what capacity/facilities do they have? Is there further baseline information available to date and can this be made available to inform other ongoing studies?


Report – Volume I, Horizon Nuclear Power, October 2014


Report – Volume I, Horizon Nuclear Power, October 2014


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2.10.3 Mitigation

Further detail is needed on the proposed mitigation for re-directing a range of cycling and walking routes alongside road closures11 identified within the Consultation and PEI documents12 and potential off site mitigation to compensate for the disruption and inconvenience during the construction phase

2.11 Community Facilities and Legacy Benefits

2.11.1 IACC welcomes Horizon’s commitment to ensure that appropriate facilities are

provided to cater for the construction workforce and mitigate against adverse impacts in this context. However there is little detail on the demand for services and facilities that will be created by the workforce through the different phases of the project. This is a significant gap in the current baseline which lacks any comprehensive information on the scale and nature of community services and facilities that may be impacted by the project.

2.11.2 Provision of community facilities needs to be considered in the round and

across an appropriate area to get a clear and informed view of provision and existing demand. IACC is undertaking work in this respect. However it is currently unclear as to the nature of any work undertaken by Horizon to date in terms of mapping community, leisure and visitor facilities. Further dialogue is required with Horizon on this matter to inform the on-going work commissioned by IACC in this context.

2.12 Housing

2.12.1 The IACC considers housing and impact on the housing market as a key topic

area which requires a much better understanding and detailed baseline than is currently provided. Project impacts could have an adverse effect on rental and purchase prices, as well as the overall supply of market and affordable housing. One impact of this would potentially exacerbate an already challenging market for those looking for accommodation in lower income groups and have knock on effects on community structure and cohesion.

2.12.2 The impact on the housing market from the construction phase also has a

potential and linked impact on the tourism accommodation sector which has both potential beneficial and adverse impacts. IACC feel that this warrants the inclusion of housing as a distinct topic within the EIA process and wishes to see this reflected in future baseline and assessment reporting.

11

Paragraph 7.7, Wylfa Newydd Project Pre-Application Consultation - Stage One, Consultation document, Horizon Nuclear


12 Paragraph 3.16, Wylfa Newydd Project Pre-Application Consultation - Stage One, Consultation document, Horizon Nuclear



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2.12.3 The information provided is of limited value and is questionable from an analysis perspective. An example here is the highlighted "discrepancy" between asking prices which are identified for the current year and then compared to actual sales value over a five year period.

2.12.4 Further discussion on developing the content of the baseline information and impact analysis is needed. At present the baseline is not fit for purpose and the technical documents give very little idea as to the nature of the impacts. In the consultation document there is no reference to the potential impacts on the local housing market resulting from enabling and main construction phase activities and associated workforce demand.13.

2.12.5 The IACC are intending to update the 'Wylfa Construction Worker Accommodation Position Statement' published in 2011. The project has changed since this study was published (i.e. Horizon ownership, reactor technology, number of construction workers etc.) as well as the IACC's knowledge and understanding of the proposed development. The IACC will be looking to work with Horizon to ensure that these studies are consistent and to minimise duplication of work wherever possible.

2.13 Associated Developments

2.13.1 Assessing associated development within the ES: The scoping opinion states that:

“Associated development in Wales does not fall within the legal definition of ‘associated development’ as set out in Section 115 of the Planning Act and will not fall to be determined by the Commission. Nonetheless, the applicant should note that associated development should be assessed as part of the ES.”

2.13.2 This is important in that it links with the approach to looking at impacts on community facilities in that the demand from associated developments, principally the workers accommodation, will create additional demand for community and recreational facilities and services.

2.13.3 Site selection

2.13.4 The approach to selecting sites for associated developments needs to comply with the existing policy set out within the Wylfa Newydd SPG within section 5. At present the policy is not being followed by Horizon as demonstrated in the following examples:

13

Paragraph 7.15 and 7.44, Wylfa Newydd Project Pre-Application Consultation - Stage One, Consultation document, Horizon

Nuclear Power, October 2014.


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The figure showing ‘Indicative distribution of Project components – Off-Site14’ does not include Llangefni as an area identified for consideration of facilities away from the Wylfa Newydd Development Area i.e. Associated Developments. This is in direct contradiction to the Locational Guidance outlined in Section 5 of the SPG – explicitly Section 5.3 Guiding Principle (GP) 28 – Llangefni & Environs.

Llangefni also has Enterprise zone status under the EZ5 designation of the 'Bryn Cefni Industrial Estate' and EZ6 ‘Creamery Land Zone’ – Close to the A55 and offering design and build opportunities for the low carbon energy supply chain, as well as being identified as one of the main areas of growth in the existing Development Plan, Stopped UDP and emerging JLDP.

As highlighted by the IACC to Horizon on a number of occasions, the methodology utilised for identifying sites for associated development is flawed. The approach being undertaken by where Horizon are looking at the Candidate Sites Register (CSR) for sites which meets your functional specification does not take into account existing allocated sites, brownfiled sites etc. Horizon should look at the Locational Guidance in the Wylfa Newydd Supplementary Planning Guidance (SPG) and then look for suitable sites utilising this Locational Guidance with the Guiding Principles in mind.

2.13.5 These sections and the broader approach to identifying suitable sites need to be revised to comply with the existing policy.

2.14 Traffic and Transport

2.14.1 Experience suggests that the transport assessment (TA) elements of large

scale infrastructure projects have one of the longer lead in times. Given the reliance of other disciplines on the information produced by the TA to inform their assessments it is essential that work to identify associated development sites and start on the modelling and assessment is undertaken as soon as possible. The IACC would expect to see the issues identified above and in other comments relating to associated development to be resolved quickly to allow the baseline data for the assessment to be produced as soon as is possible.

2.14 Combined and Cumulative Impacts

2.14.1 The commentary in relation to cumulative impacts is covered elsewhere in

IACCs response but it is worth highlighting that in the socio-economic context the potential for overlapping and increased impacts resulting from Wylfa Newydd alongside other projects is significant. Efforts should be made to

14

Figure 2.3, Wylfa Newydd Project Pre-Application Consultation, Stage One Consultation document, Horizon Nuclear Power,

October 2014.


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identify the specific projects that could have cumulative impacts with Wylfa Newydd and associated developments and this has been tackled although there is no attempt made to highlight the likely impacts of combined and cumulative inter and intra-project impacts or the timing of these. The IACC have produced a detailed approach to the assessment of cumulative impacts and would expect Horizon to enter into further dialogue on these aspects of the project.

Documents

Isle of Anglesey County Council · Isle of Anglesey County Council Overview of ... identified as such within the report and are restricted to the ... order that the project promoters