Comments on Statements of Case made to Planning Inspectorate

Transport and Works Act - Morlais Demonstration Zone - TWA/3234121

October 2020

Snowdonia Canoe Club Endorsed by Canoe Wales - the National Governing Body for Paddlesport in Wales.

This document has been prepared by Snowdonia Canoe Club (SCC) in support of our objection to the granting of a Transport and Works Act Order (TWAO) to Menter Môn for their Morlais Demonstration Zone (MDZ) project. With the support and endorsement of Canoe Wales (CW), our national governing body, this, alongside our Statement of Case (SoC), should be taken as a representation on behalf of the global sea kayaking community.

We wish it to be understood that neither SCC nor CW are opposed to the development of tidal power in the seas around Anglesey. The aim of our intervention is to ensure that the impact of the Morlais proposal on sea kayaking is properly considered in the planning and consenting process. This is not yet the case.

Contents

Menter Môn Morlais Statement of Case 2 MMC194 ES Chapter 15 - Shipping and Navigation (revised) 3 MMC196 Navigational Risk Assessment (Addendum) 5 MMC193 - Supplementary Kayak and Sailing Activities Assessment 6 SOC001 - Royal Yachting Association 8 SOC002 - Isle of Anglesey County Council 10 SOC003 - Dŵr Cymru 11 SOC004 - Royal Society for the Protection of Birds 12 SOC005 - Maritime and Coastguard Agency 13 SOC006 - Network Rail Infrastructure Ltd 13 SOC007 - M Llewellyn 13 SOC008 - Natural Resources Wales 14 SOC009 - Roberts TS 15 SOC010 - North Wales Wildlife Trust 15 SOC012 - Trinity House 15 SOC013 - ORTHIOS ECO PARKS 17

Annexes

Review of the Morlais Project Shipping & Navigation Chapter 15

Navigation risk assessment Addendum - Morlais Demonstration Zone Document Ref MOR- MCO-DOC-001

Scoping the socio-economic significance of sea kayaking on Anglesey

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Menter Môn Morlais Statement of Case

Neither Snowdonia Canoe Club nor Canoe Wales have the competency to address issues related to the conduct of the Inquiry so we make no general comments on the Menter Môn Statement of Case (SoC). We only make the observation that the plethora of documents, coming out at different times has made it very difficult to grasp exactly what is being proposed and how the various elements fit together.

The exact location of the tidal energy devices (TEC) is of great interest to Snowdonia Canoe Club as we are concerned with the potential for kayaks to be swept onto emergent infrastructure and TECs. Thus far we have been considering the ‘worst case scenario’ presented in Chapter 7 Metocean Conditions and Coastal Processes as the basis for our assessment of navigational risk which in turn determines the impact on socio-economics of sea kayaking. However, we are aware that a phased approach to deployment has been developed and linked to an Environmental Monitoring and Mitigation Plan (EMMP). We have been unable to locate any details or maps of the location and scale of the phases. It has been brought to our attention that maps available on https://www.morlaisenergy.com/navigation/ may represent the phases. The image on the following page has been extracted from this webpage as it appears to represent what maybe proposals for a Phase 1 deployment. If this is correct then it appears that Phase 1 maybe six TEC just south west of South Stack as indicated below. If this is the case we would like to point out that South Stack race is used by kayakers on the ebb and these devices look as if they could be in, or close, to the run out from the race (as indicated in Figure 8 in the SCC SoC). We would need to see some modelling of drift of swimmers and kayaks from the race to be sure that this location is not going to pose a risk to sea kayakers. Using the same logic as the EMMP we would also suggest close monitoring of changes to hydrodynamics around the arrays with particular attention to changes to overfalls and eddies to better understand impacts on metocean conditions and by extension on recreational vessels as suggested in Recommendation 4 in the report ‘Hydrodynamic effects of Morlais Development Zone’ presented as Annex 3 to the SCC SoC.

At the same time as Morlais submitted it’s Statement of Case (SoC) a series of new documents were released. Three of these are of direct relevance to the issues raised by the sea kayaking community and we provide detailed comments with supporting evidence for these here and treat them as part of the SoC. Nevertheless, we note that at least one of these is a Chapter in the ES and should have more properly been made available for public consultation.

Our general observation is that the issues we have previously raised are now acknowledged within the ES but our actual concerns have not in any way diminished. Indeed they have increased as it has become apparent that decision-making by project management is based on the belief that undesirable impacts simply won’t occur, rather than due consideration and respect for the opinion of others and in the case of disagreement, the provision of robust evidence to support claims that impacts will be negligible. We now have serious doubts as to the capacity of Menter Môn to successfully monitor and control a project of this scale and complexity.

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MMC194 ES Chapter 15 - Shipping and Navigation (revised) Snowdonia Canoe Club (SCC) has previously commented on Chapter 15 - Shipping and Navigation in our Objection and again in our SoC and have had several exchanges with Menter Môn and their consultants regarding sea kayaking activities and navigation risks. SCC has reviewed this latest revision to Chapter 15 and the associated Navigational Risk Assessment (NRA) (see below). The observations we present in our SoC on Navigation are unchanged and we do not repeat them here but confine our comments to the new material in

Page | 3 the revised Chapter 15. A detailed evaluation of Chapter 15 is provided in the reports annexed to this document. The main points we have identified are:

● There is a lack of UK guidance on the navigational and shipping environmental assessment requirements appropriate to inshore projects in areas heavily used by other vessels - expectation is that the developer and stakeholders should work together to come to agreement on routes and acceptable risks and mitigation. It has not proved possible to reach agreement for many reasons including Covid restrictions. This leaves us at an impasse. We suggest a way forward on this would be to go back to the start and for Morlais to invite a number of the local sea kayak guides to participate in an participatory Hazard workshop and to seek to form a navigational stakeholder group to monitor and advise as the project develops.

● Sea kayakers have expressed concerns to the Morlais Project with respect to a risk of loss of life. The Project has responded that the NRA has assessed the risk to unpowered recreational vessels for all identified hazards and device types and found them all to be ALARP. However, we found that Morlais deviated from the International Marine Organisation (IMO) formal safety assessment methodology they said they were using. The method used by Morlais is not able to properly rank hazards and determine where to prioritise risk control options for the navigational aspects of the project site.

● The risk assessment in Chapter 15 of the Morlais Environmental Statement (Ch.15) indicates that Morlais calculate a tolerable risk of a fatality to a member of the public some 10,000 times higher than acceptable in the Health & Safety Executive guidance, Reducing Risks, Protecting People (HSE). This needs further justification before it can be considered acceptable.

● There are no mitigation measures proposed by Morlais which reduce the risks to sea kayakers. We have repeatedly advised that the only mitigation proposed, installation of grab chains and ladders, will increase rather than reduce risk to life as well as entice people into danger. We wish to add that providing access to the public to OREI is also counter to MCA Guidance to Mariners which advises that they should only be accessed in controlled circumstances by trained personnel.

● There are discrepancies between the severe consequences of any interaction between fixed surface breaking elements and an unpowered recreational vessel between the NRA and Chapter 15. The NRA accepts that a worse credible accident with an unpowered vessel could be fatal while Chapter 15 indicates the same accident results in a minor injury. Likewise the risk factor for a single fatality at a frequency of once in every 10 years is halved when passed through the software used to perform the risk assessment. There is no transparent reasoning provided for these reductions in the calculation of risks to life.

● For the Navigational Risk Assessment to be credible, Marico need to provide a simple credible fault tree analysis starting from a sea kayaker surfing in the most affected tide race off Holy Island and ending at a fatal interaction with a surface breaking element of the Morlais Project. Expert professional sea kayaker input

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should be used to help determine credible frequencies for the various steps in the fault tree.

● The inclusion of a worse credible hazard outcome in the Marico Navigational Risk assessment (NRA) significantly changes the risk outcomes as described in Chapter 15. It is concluded that Chapter 15 is misleading and should be extensively rewritten and reissued.

● We have determined that the risk of a fatal accident to an individual calculated in the Marico Navigational Risk Assessment is 1000 times higher than tolerable under HSE guidelines in Reducing Risks, Protecting People (HSE).

We therefore conclude that the current NRA demonstrates that risks to individual members of the public arising from implementing the proposed Morlais Project are intolerable.

MMC196 Navigational Risk Assessment (Addendum)

Snowdonia Canoe Club has conducted a review of the computational element of the Navigational Risk Assessments (NRAs) produced for Morlais by Marico Marine. This review is presented in full as an annex to this document to support our findings. In summary our main points are as follows:

● Marico claim to have based the risk assessments on International Maritime Organisation (IMO) guidance. They also claim to have used Maritime and Coastguard Agency (MCA) guidance. They then describe a methodology unique to Marico, which is what is actually used. The use of a non-standard approach makes the logic difficult to follow and has resulted in several significant errors. ● Risks that are below the limit of tolerability may be acceptable provided they are ‘As Low As Reasonably Practicable’ (ALARP). The limit of tolerability implied by Marico’s risk matrix is between 1000 and 10,000 times higher than expected in HSE, MCA and IMO guidance.

● The initial risk identification process in the NRA Addendum identifies serious risks to members of the public. These are then combined with risks to property, environment and business, which masks their seriousness and, in conjunction with other errors such as the misapplication of ALARP, makes them appear acceptable, which they are not.

● Health and Safety Executive (HSE) and IMO guidance is that for risk to members of the public, the limit of tolerability should be one fatality every 10,000 years. The NRA Addendum calculates that the risk of a fatality involving an unpowered recreational vessel is at least once every 10 to 100 years – a risk to life up to 1000 times higher.

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In addition to these concerns regarding the process, we disagree with some of Marico’s consequence and frequency estimates and with some of their Suggested Additional Risk Controls. We have not documented these matters here, as we believe that stakeholder input to the risk assessment is fundamental and should be discussed interactively.

Our conclusion is that the risk assessment in the Addendum NRA demonstrates an intolerable risk, under UK law, to the safety of members of the public. We also believe that Marico may have significantly underestimated that risk.

MMC193 - Supplementary Kayak and Sailing Activities Assessment

Representation made by SCC, Canoe Wales and three kayakers to the TWAO public consultation raised concerns that the development of the MDZ could adversely affect sea kayaking businesses on Anglesey. This was later reiterated in 22 objections from kayakers to the Marine License public consultation. In response to this Morlais commissioned a series of reports from Bangor University to include kayaking businesses. The “Supplementary Tourism and Recreation Assessment” [MMC 132] and the “Supplementary socio-economic assessment” [MMC133] were issued in March 2020 as Further Environmental Information (FEI). SCC has commented on these documents in our Statement of Case.

Our comments here are restricted to the third document “Supplementary Kayaking and Sailing Activities Assessment” issued in September 2020.

The report notes “the Developer is committing to include this [recreational boating economy] in the monitoring and mitigation activities for socio-economic effects” It then goes on to outline the process by which this commitment will be honoured.

Two key performance indicators for capturing “Holy Island’s offering as a location for kayaking and sailing activities” are set out as:

● Kayaking and sailing participation in the area, ● Sentiment of marine recreation activities (it is not clear what is intended here)

It is proposed to collect data to identify trends and unexpected changes from interviews. No recommendations are made on the number and sampling strategy for identifying interviewees. Of most concern is the proposal that data will be gathered through interviews over the next two years (i.e. according to Morlais’ timetable after consenting and during construction) then annually for the following five years (i.e. during phase I when the scheme is small scale) then biennially for the duration of the project (i.e. as the project grows larger). Negative impacts are to be identified by significant deviation from trends extrapolated from the baseline which can be attributed to Morlais according to the judgement of Morlais and IoACC. If all these conditions can be met then Morlais is prepared to offer mitigation and has suggested that this might entail actions to promote marine recreation in the area and provide toilet facilities.

We reiterate that several established standards and guidelines for treatment of socio- economic impacts on recreation exist as pointed out in the SCC SoC. We remain willing to

Page | 6 assist in the collection of suitable data from the sea kayaking community. Good practice would suggest at the very least consultation with representatives of the kayak and sailing communities to select suitable key performance indicators and measures which can be easily quantified and monitored. The success of our impromptu online survey suggests that quantitative survey is feasible while records of courses held and awards made could be made available by Canoe Wales (CW) and British Canoeing (BC).

However, the main failing of the proposed approach is that it is post-hoc with the identification of negative impacts after they have happened and livelihoods have been compromised. Morlais and IoACC reserve judgement on the need for mitigation and the language used suggests the threshold for this will be high. The mitigation offered is desultory and does not provide any meaningful compensation for lost or compromised livelihoods and lost revenues associated with any potential reduction in visits by kayakers.

We reiterate that there is ample good practice in socio-economic assessment of marine recreation and established protocols with EIA to deal with assessment, mitigation, compensation or resettlement of livelihoods. We suggest that Morlais look to adopt a more robust and participatory approach to socio-economic assessment. This should include all livelihoods which could be impacted by the development of the MDZ, a baseline survey and cost-benefit analysis to inform consenting with robust monitoring reporting to a stakeholder forum with preemptive mitigation and an agreed compensation plan. We would expect this to be contained within a considerably revised Chapter 25 in the Environmental Statement (ES).

We wish to draw your attention to the report ‘Scoping the socio-economic significance of sea kayaking on Anglesey’ prepared by SCC appended to this document. This is presented as evidence to support our contention that the socio-economic contribution of sea kayaking is of sufficient value to warrant full consideration in the EIA and ES.

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SOC001 - Royal Yachting Association

Snowdonia Canoe Club is in agreement with the Royal Yachting Association (RYA) view that the ‘Environmental Statement and Navigational Risk Assessment fail to consider all possible maritime safety impacts to recreational craft’. We have undertaken an analysis of the NRA and concluded that the analysis is flawed and the risk to all vessels including sea kayakers in the vicinity of the Morlais Demonstration Zone, has not been appropriately assessed.

We agree with the RYA’s analysis of the inadequacy of the use of AIS and radar data to identify recreational traffic. We are aware that subsequent provision of what appears to be Strava data when this is used by only very few kayakers will have missed and misunderstood much of the use by kayaks of the area.

While we have differing uses of the sea in the area we concur with the concerns raised that the proposed navigational passage to the east of the project is ‘too narrow and restrictive’. We have different but related concerns from the RYA about safe distances and overfalls. Sea kayakers, unlike most RYA members, actively use tide-races and overfalls but it remains even more important that the outruns from these are completely clear of obstruction to safeguard life in the event of a capsize and for advanced water training and this has not been taken into account. We are concerned about the potential collision risks arising from forcing RYA members vessels into a narrow passage with overfalls frequented by kayakers. These mean that the specifics of the NRA in particular would need to account for the way the different classes of recreational vessel use these waters.

We agree with the RYA’s assessment that there is insufficient information ‘to determine the effects of tidal streams on recreational small craft handling and manoeuvrability within areas proposed for floating/surface piercing arrays or by concentrating vessels in the Eastern Inshore Route.’

We also agree that ‘the validity of the model used by HR Wallingford may not be accurate with respect to the extent of the increase of tidal currents along the Eastern Channel. and the consequential recommendation that ‘The RYA recommends that the project cannot be implemented until such time as an accurate prediction of current velocities demonstrates that increases in tidal currents (in combination with naturally occurring overfalls) does not lead to a significant negative impact on recreational boating.’ We agree with the RYA proposal for the need for appropriate analysis of the changes to ‘set and rate of tidal stream(s), wind masking, turbulence, or shear’

We have indicated in our SoC and other documentation our concern about the impact of the project on the socio-economic and tourism sector and therefore agree with the recommendation by the RYA that it will be necessary to agree ‘a suitable method to identify the value of the maritime tourism and recreation economic sectors impacted by the MDZ and associated activities. This should also include expanding the monitoring by interview to the recreational boat clubs and include recreational organisations in agreeing a baseline with Morlais and Anglesey County Council.’ We include our report ‘Scoping the socio-economic significance of sea kayaking on Anglesey’ which we provide as evidence in support of the argument that kayaking is a substantial additional tourism resource bringing economic gain

Page | 8 to the island which may be at risk. We would be happy to work with RYA, Morlais and IOACC in the development of a full socio-economic assessment of recreational boating.

We agree with the RYA recommendation about imposing strict conditions on the series of developments proposed where they recommend ‘that the consenting process use these key points to establish conditions for developers if the applicant can establish a framework to ensure recreational boating issues are addressed post-consent or in a array-specific consenting process’ However, we would recommend that greater control is retained by the licencing authority over the phased development of the site whereby analysis of any mitigation previously applied and detailed consultation and engagement with stakeholders which is subject to scrutiny is required at each stage.

We note the RYA concerns about the need for the NRA and ES to take account of the potential impacts on the maritime safety of recreational boaters as they take action to avoid wildlife disturbance. It is worth noting that the sea kayak community has an informal arrangement to remain sufficiently off-shore from the cliffs during the auk breeding seasons to avoid disturbance of nesting birds which will in effect further narrow the eastern navigation route.

We note that the RYA, along with MCA and Trinity House, were consulted in 2015 regarding the decision to relocate the project from the WADZ to the MDZ. So far as we are aware, no representatives of sea kayaking were consulted. The relocation has significantly increased the risk to kayakers.

We do not agree with the overall conclusions of the RYA SoC that objections could be removed ‘subject to review of a revised NRA and ES, if the area were used to site submerged devices and arrays with UKC of 8m or greater depth.’ In the first instance we would in any case require a proviso that the specific implications for sea kayaking would need to be accounted for in the development of the revised ES and NRA. In addition we cannot support this conclusion because we do not consider that we had a satisfactory answer to our question concerning the individual and cumulative effects on water surface features over submerged turbines in the tidal and wind conditions in the area. No evidence has been provided to support Morlais’ contention that these effects would be minimal. In the case of devices with diameters of > 20 m in 30-40 m of water it seems reasonable to suppose these will generate surface features and setting these into an array will create cumulative effects which cannot be adequately modelled using the HR Wallingford approach. Given the specific use of these waters by sea kayakers and our dependence on the surface conditions at a micro level we would need detailed and complex modelling of the effect on the tidal stream of submerged devices including speed, flow, eddy and wake modelling. We would also need to be reassured about the surface mounting of other installations such as marker buoys and lights as these would need to be subject to a detailed NRA and ES analysis.

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SOC002 - Isle of Anglesey County Council

Snowdonia Canoe Club have reviewed the Isle of Anglesey County Council (IoACC) Statement of Case and believe that the following additional specific issues require consideration. We note that they list the legislation that is directly relevant to the Statement of Case (SoC) however we are not convinced that the wider requirements of the seven goals and five ways of working within the Well-being of Future Generations (Wales) Act have been appropriately considered.

The Welsh National Marine Plan states that “Proposals for tidal stream energy generation will be supported where they contribute to the objectives of this plan”. However, it does go on to clarify that “Proposals should comply with the relevant general policies and sector safeguarding policies of this plan” (ELC_03a). We point out that the Marine Plan implies that these developments will be off-shore and states that “Much of the tourism and recreation activity occurring in the Plan area takes place on or near-shore, typically within three nautical miles of the coast" (para 495). However, we consider that the Morlais proposed development is for an near-shore tidal power scheme less than one nautical mile from the coast and overlaps an area of high recreational activity.

We note that IoACC state that, with caveats about specific amendments they have “no outstanding concerns relating to … socio-economics, tourism and recreation”. We wish to point out that we continue to have concerns that the substantial use of the area for sea kayaking is not accounted for adequately in either Chapter 15 or Chapter 25 of the ES. We request that IoACC seek to reflect the interests of the sea kayaking community in their requirements under the list of mitigations at points 15 and 17 in their SoC.

We welcome the approach IoACC are taking to requiring further specific decisions on deployment rather than a blanket approval without detailed data and analysis. We are not yet convinced that the cumulative impact of the whole range of deployment on the tidal streams and wave heights even for the sub-surface arrays has been adequately characterised. In addition, we do not consider that the safety aspects of the deployment of surface mounted arrays are adequate, particularly in terms of safety for unpowered personal watercraft such as sea kayaks. If this development goes ahead it is therefore imperative that the permissions are specific and precise, based on further investigation and data derived from progressive installation starting with the least potentially damaging areas that are furthest offshore.

We note IoACC concerns relating to socio-economics, tourism and recreation and would add the implications for sea kayaking into their requirements for further study including both the impact on recreational tourism and on the businesses impacted. In particular we note that sea kayaking contributes to the recreational tourism economy. The report ‘Scoping the socio-economic significance of sea kayaking on Anglesey’ attached as an Annex to this documen is provided as evidence in support of the argument that this is a substantial additional tourism resource bringing economic gain to the island which may be at risk. Our assessment is that sea kayaking contributes to all of the objectives of the Destination Anglesey Management Plan 2016-20 [File No: MMC223 Document reference: MOR-EXT- DOC-026] but has been overlooked by IoACC in its list of relevant tourism activities in paragraph 5.18. Furthermore, we would request that under Strategic objective 6 of the

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Destination Plan that Morlais be treated in the same way as Wylfa Newydd and that IoACC should endeavour to ensure that this “development should go ahead with minimal disruption to local communities and the tourism economy”. We contend that this will only be possible with a more considered and sympathetic involvement of local interests in the tourism economy.

We note that IoACC are proposing that in relation to the siting of specific arrays “The Council continues to submit that these key mitigation restrictions cannot be relied on in the ES but not secured in the Order.” We would support this approach but ask IoACC to note that we do not consider the mitigations proposed will be sufficient to address the safety concerns we have raised for sea kayakers in particular.

We note the IoACC requirement for amendments to the Order “to require that all deployments of devices are subject to the approval of a Device Deployment Protocol to allow the impacts to be assessed for each deployment and cumulatively. The Council further requests that it is a named consultee on every application for approval of a Device Deployment Protocol in order to ensure it has an opportunity to formally comment on the seascape, landscape and visual impacts, and any potential impacts on small craft and recreational users.” We would propose that they ensure that the sea kayaking community including recreational and business interests are represented as part of these consultations.

In connection with the “Supplementary Kayaking and Sailing Activities Assessment” released by Morlais in September and the proposal for the identification and compensation for negative impacts on sea kayaking businesses. We would point out that we do not agree this proposal is acceptable and direct you to our comments on this document in our response to the Morlais SoC. Our preference would be that Morlais establish a recreational stakeholder liaison group which includes IoACC and representatives of all recreation and tourism stakeholders. This group should then co-produce a suite of suitable indicators, a pre- consenting baseline survey and undertake a full cost-benefit analysis. We contend that this would provide a more robust and equitable approach to determining impacts and suitable forms of mitigation or compensation.

SOC003 - Dŵr Cymru

No comment.

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SOC004 - Royal Society for the Protection of Birds

Much of the RSPB SoC deals with issues beyond the competence of the Snowdonia Canoe Club but it should be noted that the unique ornithology of this coastal area is integral to the interest that kayakers enjoy and is part of the attraction of the area for visiting kayakers. It is worth noting that the sea kayak community has an informal arrangement to remain sufficiently off-shore from the cliffs during the auk breeding seasons to avoid disturbance of nesting birds. We support the RSPB’s concerns about the impacts on the ecology of the bird-life in the area.

We note that experience of seeking to respond to a series of new documents (in this case the Ecological Monitoring and Mitigation Plan) some of which have not superseded the previous version or addressed key issues is in line with our experience.

We support the RSPBs call for a phased development and that monitoring of all impacts should be a continuous process throughout the life of the project. We support the following proposal from RSPB on the basis that it includes the monitoring of all impacts including impacts on navigational risk, recreational use of the area and economic impact for the sea kayaking (and other) sectors:

Phasing of Deployment 87. We welcome the Applicant's reference within the EMMP for a phased deployment of the tidal arrays linked to the mitigation, monitoring and measurable outcomes of the DEMMP to be overseen by the Regulators and Advisory Group. However, for this to be enforceable both by way of the TWAO and Marine Licence this phased approach needs to be present within the Order and the Licence (if approved) as both grant permission. 88. The indicative phases (as set out in the EMMP for the Marine Licence (version dated July 2020) are welcomed in principle by the RSPB however we contend that at this consenting stage greater clarity needs to be given to the number and capacity of arrays envisaged as being deployed at each phase.

We note that RSPB welcomes the proposal to set up an Advisory Group but we would propose that this should be mirrored in all aspects where potentially damaging impacts have been identified including recreational and socio-economic use of the area.

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SOC005 - Maritime and Coastguard Agency

Snowdonia Canoe Club (SCC) agrees with the Maritime and Coastguard Agency (MCA) that use of the commitment to “possible mitigation measures” would seem to undermine the Navigation Risk Assessment, where residual risk scores are predicated on certain mitigation measures.

Morlais Chapter 15 of the Environmental Statement (MMC194) explains (see page 80 para 232) that a formal Navigational Risk Assessment is presented in Appendix 15.1 Volume III . We take this to mean the NRA (MMC196). We also agree with MCA that the discrepancies between Chapter 15 and the NRA need to be resolved.

We also support the MCA expectation that the applicant apply for separate marine licences for each test array which will involve submitting an array-specific NRA for each application.

It was noted by Morlais in November 2018 that there were many kayakers in the area that follows the coastline around Holyhead and utilise the inshore passage (see Chapter 15 page 13). However it was not until February 2020 that a meeting took place at which it was possible to make clear to Morlais that the surface breaking elements of the project presented a threat to life for sea kayakers. MCA expectations have not been met because kayakers have had no involvement in hazard workshops, nor have their concerns been adequately addressed in Chapter 15 or the NRA.

Please also see our response to Trinity House and the proposal to paint the majority of the Morlais infrastructure grey to blend in with the seascape - regardless of the increased risk to navigation.

In connection with the MCA’s penultimate point regarding Stakeholder Concerns - we wish to make it known that we do not consider that Morlais have adequately addressed our concerns and we have not come to any agreement with Menter Môn regarding the NRA or ES.

SOC006 - Network Rail Infrastructure Ltd

No comment.

SOC007 - M Llewellyn

Snowdonia Canoe Club note in particular that the Statement of Case supports our proposition relating to the inadequacy of the assessment of the impact of the proposal on tourism and recreation and refer to our response to the IoACC SoC that a robust baseline survey and full cost-benefit analysis are required.

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SOC008 - Natural Resources Wales

Snowdonia Canoe Club note that Natural Resources Wales (NRW) SoC states that ‘the off- shore elements of the proposal is subject to an application for a marine licence (ref. ORML1938) to be determined by NRW’s permitting service’ however it is important that the advisory section of the NRW are made aware of the issues relating to this application and navigational risk. We have presented an analysis of the NRA from the perspective of sea- kayaking as part of our evidence.

While much of this SoC deals with issues relating to ecology and biodiversity beyond the competence of the Snowdonia Canoe Club, it should be noted that the unique ornithology and ecology of this coastal area is integral to the interest that kayakers enjoy and is part of the attraction of the area for visiting kayakers.

We note that NRW expresses concerns about the approach and lack of detailed and appropriate information taken to date to justify adaptive management approaches which we share. The NRW concerns relate to ecological impacts and we would argue that these concerns are mirrored by those raised about all aspects where potentially damaging impacts have been identified including recreational and socio-economic use of the area.

The NRW raises issues related to visual amenity and we consider that consideration should be taken of the amenity value of the seascape as viewed from the sea itself including from sea kayaks and other recreational vessels, in addition to:

25. This section of coastline includes areas assessed by LANDMAP to be of ‘Outstanding’ and ‘High’ value for their visual and sensory aspects. South Stack/Ynys Lawd lighthouse, Tŵr Elin/Elin’s Tower and the RSPB visitor centre are popular destinations for visitors by car. The Isle of Anglesey Coastal Path, the public rights of way, the open access land, the landmarks and the coastal experience generally in this location make it a popular area for visitors, walkers and birdwatchers within the AONB.

When assessing any mitigation of the visual impact of the project as identified in the point in paragraph 27 it will also be essential to consider these from a navigational safety in addition to the visual impact perspective:

A commitment to monitor the visual effects of offshore development to allow the LPA, planning consultees and future developers to have current information about the visual baseline; allow the worst-case visual effects presented within the ES photomontages to be compared with the as-built development and allow any phased development of the MDZ to be undertaken in a way that does not exceed the worst-case development effects presented by the ES Photomontages.

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SOC009 - Roberts TS

Snowdonia Canoe Club note the comments and images relating to visual impact, we note that Morlais have proposed using paint colours with lower visual impact. However we consider that giving a higher priority to visual prospective over risk to life is not acceptable and this will need to be reconsidered from a navigational safety point of view.

SOC010 - North Wales Wildlife Trust

Much of the North Wales Wildlife Trust (NWWT) SoC deals with issues beyond the competence of the Snowdonia Canoe Club but it should be noted that the presence of cetaceans in this coastal area is integral to the interest that kayakers enjoy, including the observation of feeding behaviour of both dolphins and porpoises along the tidelines of the races and overfalls and is part of the attraction of the area for visiting kayakers.

We share NWWT’s concern about the ecological issues they raise and the inadequate monitoring and mitigation proposals.

We note the concerns raised about the issues related to the modelling report related to sediment transport and the conclusion that:

We raised concerns about the quality of the sediment transport modelling, absence of nearshore sediment transport modelling and lack of consideration of the impacts of a tidal surge caused by an extreme low-pressure weather system coinciding with a spring tide.

Although our analysis was focussed on a different perspective this reflects our concerns about hydrodynamic changes and the modelling of these by HR Wallingford which are documented in the SCC Statement of Case and accompanying report “Hydrodynamic effects of Morlais Development Zone”.

We note concerns from the NWWT about Seascape Landscape and Visual Impact and we note that Morlais have proposed using paint colours with lower visual impact. However we consider that giving a higher priority to visual prospective over risk to life is not acceptable and this will need to be reconsidered from a navigational safety point of view.

SOC012 - Trinity House

Snowdonia Canoe Club (SCC) agrees with the Trinity House statement in para 4.2 that “Without appropriate safeguards in place, the Project presents a significant risk to the safety of navigation”.

As we pointed out in our response to Morlais Ch15 and the Navigational Risk Assessment (NRA), we consider the risk to life posed by the project as currently planned, to be

Page | 15 intolerable. We have suggested further work to improve the NRA and failing this recommend that no tidal devices or project infrastructure that affects the sea surface should be placed within 1.5 nautical miles of the coast.

We also agree with Trinity House (para 4.9), that further site and device specific navigational risk assessments should be built more unequivocally into article 21 of the draft Order.

We also share a concern with Trinity House regarding the 500m safety zones proposed in Article 43 of the Draft Order. Due to the limited width of the internal passage between the Morlais Demonstration Zone and the coast, we are very concerned that Morlais Project operations could very easily close any prospect of transit between Porth Dafarch and Soldiers Point. We have raised this concern with Morlais and been given assurance that they do not intend to close off the inshore passage and that safety zones will be up to 500m (see Morlais Environmental Statement Chapter 15 page 24) - however we do not see this reflected in the Draft Order. Furthermore, we have suggested to Morlais that a navigation stakeholder liaison group will be required to allow for accommodation of any works which will impact on the inshore passage.

Please note that we have concerns with respect to the apparent agreement between Menter Mon, Trinity House and the Marine and Coastguard Agency (MCA) documented in MOR/SLR/DOC/0002: Outline Landscape Management Plan Version F3.0 dated February 2020 which was submitted to Natural Resources Wales in support of the Marine Licence. Pages 4 to 5 paras 23 - 25 state:

23. Consideration is currently being given to the colour of the offshore structures and the navigation lighting that is required as part of the Project. Post application consultation has been undertaken with the relevant navigation consultees (Trinity House and MCA), recognising that marine safety is a paramount consideration. The outcome of the consultation is that the colouring on the structures can be altered and the lighting requirement can be reduced compared with those assumed in the SLVIA.

24. Colouring can be altered so that only a proportion of the structures is coloured yellow. A number of potential colour schemes were discussed with Trinity House with reference to other offshore installations where visual impact is an important factor. One scheme proposed was to have only the devices at the edge of each array yellow, and the devices within a grey or other less conspicuous colour to be agreed. However it has been concluded that given the length of the devices at up to circa 70m in length, Trinity House would require yellow marking at both ends of all devices as mitigation in case any of the units broke away and was left floating by itself. Also this colour scheme would maintain the marking should any of the devices on the array edge need to be removed for maintenance.

25. For this reason Menter Môn can commit to marking the ends of each of the devices yellow, or a band 5m high on hubs or similar vertically shaped infrastructure. The extent of the yellow marking would depend on the design of the devices and would comprise a 5m band at the ends of each device. The remainder of the devices would be coloured grey, although the exact colour grey would be agreed with NRW and IoACC.

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Noting that the NRA page 13 section 4.1.1 Visibility states:”The study area is often cloudy in all seasons with the coast often obscured by low cloud and driving rain. Fog at sea is most common in June and less frequent from November to May. Radiation fog over the land is most common in autumn and winter around dawn”

Our concern is that by painting the proposed installation predominantly grey and restricting warning colours to the structures on the edge of the array the safety of the public in vessels off the West Coast of Holy Island is being unacceptably compromised. A kayaker swept into the array would depend on being able to see surface piercing devices as far in advance as possible, in order to have any chance of avoiding a collision. A kayaker’s eye level is only 70cm above sea level.

SOC013 - ORTHIOS ECO PARKS

No comment.

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Review of the Morlais Project Shipping & Navigation Chapter 15. Snowdonia Canoe Club, October 2020.

This note uses the structure of quoting or referencing statements associated with Chapter 15 of the Environmental Statement (CH.15) and Navigational Risk Assessment (NRA) submitted as part of the Statement of Case to the Transport and Works Act 1992 inquiry into the Morlais Demonstration Zone and then reviewing those statements. The review has a particular emphasis on the risk to life of sea kayakers arising from the Project. To assist the reader, acronyms rather than numbers are used for each reference. Key statements relevant to kayaking are in bold.

Ch.15 page 3 para 15 states: Guidance on the assessment requirement was primarily sought from the Maritime and Coastguard Agency (MCA) Marine Guidance Note (MGN) 543 (M+F) which replaces MGN 371. MGN 543 advises the correct methodology to evaluate navigation safety around Offshore Renewable Energy Installations (OREIs).

Ch.15 page 13 Table 15-2 states that in November 2018 Morlais Project Noted: There are many kayakers active in the area that follow the coastline around Holyhead and utilise the inshore passage.

Ch.15 page 61 para 145 states: Recreational craft are highly influenced by season, daylight, fair weather and tidal conditions. This insight is consistent with the observations of the marine traffic survey, where during the summer, gate analysis (Appendix 15.1, Volume III) identified 52 % of all transits were by recreational craft making them the most prolific receptor, both in proximity to the development site and intersecting the development site.

However the Project proposes an inshore, rather than offshore facility, in an area heavily used by recreational vessels including unpowered sea kayaks.

1) There is a lack of UK Guidance on the navigational and shipping environmental assessment requirements appropriate to inshore projects in areas heavily used by other vessels.

Ch.15 page 4 Table 15-2 details NRW requirements expressed in 2018: The Environmental Statement must provide details of the possible impact on navigational issues for both commercial and recreational craft, specifically:  Collision Risk,  Navigational Safety,  The risk to drifting recreational craft in adverse weather or tidal conditions,  The likely squeeze of small craft into the routes of larger commercial vessels

Ch.15 page 23 Table 15-2 details some sea kayaker concerns expressed in February 2020: Kayaks are very different to any other small vessel as they are solely human powered. This means that there are huge safety issues – and these have not been addressed in the current NRA. Collision of human powered vessels is not considered as part of the assessment. There could be potential dangers of collision with floating devices and marker buoys. A capsize in the array could be very hazardous and a rescue could be very difficult. Significant risk and safety hazards. And this is not only to sea kayakers, but this area is also used by paddle boarders and sit on top fishing etc.

And the Project response: The NRA (Appendix 15.1 Volume III) has separated hazards to unpowered and powered recreational vessels.

Review of Morlais Shipping & Navigation Ch15 – Issue 1 Page 1

Ch.15 page 35 Table 15-2 documents subsequent sea kayaker concerns expressed in August 2020: We are concerned that floating and emergent structures within the MDZ are a significant hazard and pose a risk to life. The navigation risk for kayaks between the coast and MDZ are likely to be intolerable.

With the Project response: The potential risk of loss of life has been considered as a consequence within the NRA and assessed across all vessel and device types. The NRA assessed the navigation risk to un-powered recreational vessels assessed for all identified hazard and device types.

2) Sea Kayakers have expressed concerns to the Morlais Project with respect to a risk of loss of life. The Project has responded that the Navigational Risk Assessment has assessed the risk to unpowered recreational vessels for all identified hazards and device types.

Ch.15 page 39 para 30 states: This risk assessment was conducted in accordance with the International Maritime Organisation (IMO) Formal Safety Assessment (FSA) methodology for risk assessments.

Ch.15 page 3 para 15 states: …..guidance used ….International Maritime Organisation (IMO) Formal Safety Assessment. Revised Guidelines for Formal Safety Assessment (FSA) MSC-MEPC.2/Circ.12/Rev.2;

It is noted that the reference for IMO quoted on page 108 of Ch.15 is incorrect.

Ch.15 page 39 para 31 states Hazard identification is the first fundamental step in the risk assessment process and was informed by analysis and feedback from stakeholders. Key navigation hazards were identified and grouped with the identified vessel types operational in the vicinity of the MDZ to form the list of potential impacts for assessment. The hazards were then assessed as a factor of likelihood (frequency) and consequence. This approach considered two scenarios; “most likely” and the “worst credible”. The quantified values of frequency and consequence were then combined using the Marico HAZMAN ll software to produce a risk score for each hazard and collated into a “Ranked Hazard List”. Risk control measures were then suggested that may reduce the hazard to ALARP.

As mentioned above, the Shipping & Navigation Chapter 15 of the Morlais Project explains that hazards are identified and assessed in accordance with the International Maritime Organisation (IMO) Formal Safety Assessment (FSA) methodology.

Ch.15 Page 39 para 36 states: The FSA methodology used determines where to prioritise risk control options for the navigational aspects of a project site. The outcome of this risk assessment process should then act as the basis for a Navigation Safety Management System, which can be used to manage navigational risk.

Ch.15 page 40 Table 15-4 defines the frequencies used in the FSA, from F5 Frequent (up to 52 times per year) to F1 Remote (less than 1 in 1000 years). It is not clear from the definitions whether this spread is meant to cover 5 or 6 orders of magnitude.

In comparison in IMO page 40, it is clear that each Frequency Index increment represents a tenfold or one order of magnitude increment in the frequency of an event.

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Ch.15 Page 40 Table 15-5 defines the consequences of the hazard ranging from C1 Negligible to C5 Catastrophic. Each increment in consequences represents a tenfold increase in the severity of the consequences in accordance with the IMO FSA.

Ch.15 Page 43 Table 15-6 sets out Risk Factors for various combinations of hazard consequences and frequency.

The methodology used in IMO (page 40) recommends that consequences and probability indices are defined on a logarithmic scale. That is each frequency and each consequences increment represents a 10 fold change. This seems to have been followed by Morlais in the definitions of Frequency and Consequences, tables 15-4 & Table 15-5 if we assume that F5 is actually meant to mean 10 times per year.

In IMO page 41, the Risk Index (equivalent to Risk Factor in the parlance of Ref.1) is calculated by summing the consequences and frequency indices, which because each indices increment represents an order of magnitude change, effectively multiplies consequences and frequency. This process enables hazards to be ranked, so that mitigation can be applied to the most onerous hazards.

However in Ch.15 Table 15-6 Morlais do not follow the IMO methodology. For example an event of major consequences such as a single fatality (C4) at a frequency of once per 1000 years (F1) should have a Risk factor of 4+1=5 according to the IMO methodology, rather than just 4 as shown in Table 15-6.

In Ch.15 Table 15-6, the Risk factor for a Minor (C2) event at a frequency of once in 100 years (F1) is 2, the same value for the same consequences (C2) at a frequency 10 times greater at once every 10 years (F3). Clearly these should not have the same outcome; the latter is 10 times more frequent than the former.

3) Because the International Marine Organisation Formal Safety Assessment methodology (IMO) is not followed, Morlais cannot properly rank hazards and determine where to prioritise risk control options for the navigational aspects of the project site.

Ch.15 Page 43 Table in para 45 states that a Risk Number above 7 represents a significant risk, whereas a Risk Number of less than 6.9 is in the ALARP or Low to Negligible Risk region. Therefore according to Morlais, a Risk Number of 7 represents the boundary between the tolerable and intolerable region. According to Ch.15 Table 15-6 a Major consequences (single fatality) C4 event at a frequency of once every year (F4) has a Risk Number of 7.

HSE page 46 para 132 states: ……we suggested that an individual risk of death of one in a thousand per annum should on its own represent the dividing line between what could be just tolerable for any substantial category of workers for any large part of a working life, and what is unacceptable for any but fairly exceptional groups. For members of the public who have a risk imposed on them ‘in the wider interest of society’ this limit is judged to be an order of magnitude lower – at 1 in 10 000 per annum.

IMO page 48 Table 1 also mentions the above example; that the upper bound for the ALARP region for the maximum tolerable fatal risk per year to a member of the public is 10-4.

Review of Morlais Shipping & Navigation Ch15 – Issue 1 Page 3

4) Comparison with the risk assessment in Chapter 15 of the Morlais Environmental Statement (Ch.15) indicates that Morlais calculate a tolerable risk of a fatality to a member of the public some 10,000 times higher than acceptable in the Health & Safety Executive guidance, Reducing Risks, Protecting People (HSE).

Ch.15 Page 51 Table 15-11 provides a list of the potential impacts on Shipping and Navigation that may arise during activities undertaken during each phase of the Project.

In Ch.15 page 62 para 149 contact between unpowered recreational vessels and surface and mid water devices, electrical hubs and other vessels during the construction phase are considered.

Ch.15 page 63 para 150 states: The overall severity of consequences for the construction phase are considered to be minor (C2). The frequency of occurrence is considered possible (F3). This indicates an overall risk ranking of (C2 x F3) = Low.

There are exceptions to the above conclusion – but none feature unpowered vessels except for swamping/capsize deemed C2 x F4. Note also that we do not agree that C2 x F3 represents a low risk nor is C2 x F4 appropriate for capsize of a sea kayak.

Ch.15 page 63 para 151 lists possible mitigation measures to further reduce hazards but none are likely to assist in a kayaker to surface breaking fixed element or other vessel interaction. Morlais have suggested the provision of life saving equipment; specifically ladders and grab chains attached to Project devices (NRA page 91 ID 12). However this proposal is likely to increase the risk of snagging a swimmer or kayaker, rather than reducing the risk to life as pointed out to Morlais by letter (NRA page D16).

5) There are no mitigation measures proposed by Morlais which reduce risks to sea kayakers.

Ch.15page 65 para 161 states: Depending on the tidal device types installed, the recovery and evacuation of persons from the water in the development site would potentially be impacted due to surface piercing superstructure which could complicate recovery operations.

Ch.15 page 74 para 203 considers contact between unpowered recreational vessels and surface and mid water devices, electrical hubs and other vessels during the operational, maintenance and repowering phases of the project.

Ch.15 page 75 para 204 & 206 comes to the same conclusions as para 150 and 151 for risks to and mitigation for unpowered vessels.

6) The most severe consequences of any interaction between fixed surface breaking elements and an unpowered recreational vessel such as a sea kayak is assessed in Chapter 15 of the Morlais Environmental Statement (Ch.15) as a single minor injury (C2). It is noted that this contradicts the findings of the Marico Navigational Risk Assessments (Refs 4 & 5) which accepts that a worse credible accident with an unpowered vessel could be fatal (C4).

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Ch.15 page 80 para 232 states: The impacts presented in this chapter were identified and quantified via a formal NRA process (see Appendix 15.1, Volume III). The assessment included allision / collision risk assessment (including UKC) in accordance with formal safety assessment criteria as adopted by the IMO for all phases of the development, as well as an assessment of cumulative and in-combination effects.

Ch.15 page 81 para 233 states: Table 15-16 collates the determinations of each of the impacts assessed and is presented as a summary of the determinations.

Ch.15 Table 15-16 congregates impacts between unpowered and powered vessels with various structures and vessels. Inspection of the table indicates again that the most severe consequence to a sea kayaker is single major injury (C3) following collision with a commercial ship or a Project vessel (see ID 41 page 87 & ID 52 page 98). All other unpowered vessel interactions with Morlais infrastructure result in no more than a single minor injury (C2).

Ch.15 page 80 para 232 plus other places references Appendix 15.1, Volume III, (NRA V3.0). It was not possible to find NRA V3.0 in the Morlais Statement of Case. However there is an updated Navigational Risk Assessment (NRA) produced by Marico NRA, which it is assumed supersedes NRA V3.0.

NRA states on page ii: The NRA methodology is based on the International Maritime Organisation’s Formal Safety Assessment approach to risk management utilising a combination of data analysis and stakeholder/expert judgement to determine risk levels.

And on NRA page iii it is stated: A total of 85 hazards were identified for assessment in the construction phase and 70 within the operational phase. All hazards were assessed to be ALARP or lower in the baseline risk assessment. Of the 85 hazards assessed within the construction phase 19 were scored as ALARP in the baseline assessment. Of the 70 hazards assessed within the operation phase assessment, 6 were scored as ALARP in the baseline assessment. For those hazards scored as ALARP the implementation of mitigation measures should be considered to further reduce risk. A full list of suggested mitigation measures and the respective phases to which they apply are shown below:

The only mitigation possibly relevant to sea kayaking is the provision of life saving equipment on fixed structures and floating devices. Again this is taken to mean the suggested chains and ladders dismissed above as likely to increase risks to sea kayakers.

NRA page vi states: The Project is therefore assessed to be acceptable in terms of navigational risk assuming compliance with embedded and implementation of suggested additional mitigation measures where appropriate for hazards scoring as ALARP.

NRA Table 6.1 page 34 to 37 outline sea kayaker concerns from August 2020, including risk to life arising from interaction with floating and emergent structures.

NRA page 79 states: Key navigational hazards were identified and grouped with the identified vessel types operational in the vicinity of the MDZ to form the list of potential impacts for assessment. The hazards were then assessed as a

Review of Morlais Shipping & Navigation Ch15 – Issue 1 Page 5

factor of likelihood (frequency) and consequence. This approach considered two scenarios; “most likely” and the “worst credible”. The quantified values of frequency and consequence were then combined using the Marico HAZMAN ll software to produce a risk score for each hazard and collated into a “Ranked Hazard List”. Risk control measures were then suggested that may reduce the hazard to ALARP (Section 13).

The significant change from the previous risk assessment described in Ch.15, is that now both “most likely” and “worst credible” outcomes are explicitly described in the document. However this is the only change in methodology. Hence conclusions 3 & 4, that Marico do not follow the IMO SFA recommended methodology so cannot correctly rank hazards and that tolerable risk to an individual is 10,000 times greater than HSE guidance still applies.

NRA page 87 Tables 12.2 & 12.3 lists tolerable hazards identified by Marico to be in the ALARP region (with a risk score above 4 but below 7). No hazards associated with unpowered vessels are included.

NRA page 88 states: While all of the of hazards identified and scored for this risk assessment fell into the ALARP or below categories of risk (see Section 11), further mitigation risk control measures should be considered for the hazards assessed as ALARP or above (>4).

NRA page A8 Table 4-3 (same as Ch.15 Table 15-16) indicates that for a Major incident, single fatality (C4) and a frequency of once every 1000 years (F1) the Risk Factor is 4. However HSE considers that a frequency for a single fatality to a member of the public more frequent than once every 10,000 years is intolerable. Comparison with HSE indicates that a Risk Factor of 3 in Table 4-3 represents a one in 10,000 year risk of a fatality, i.e. this is the true upper boundary of the tolerable ALARP region.

7) Comparison with Health & Safety Executive guidance, Reducing Risks, Protecting People (HSE) indicates that hazards identified by Marico as having a Risk factor >3 are intolerable. There are many hazards identified by Marico with Risk factors greater than 3, even after mitigation.

NRA Annex A explains the Risk Assessment Methodology used by Marico. It is identical to the described in Ch.15 except that both “most likely” and “worst credible” hazards are considered explicitly.

NRA Annex B & C tabulate identified hazards and the associated Risk Score for the construction & Operational phases of the Project.

NRA Annex B ID 6 describes: Contact Un-Powered Recreational Vessel with Surface Device

The most likely consequence is considered to be single minor injury (C2) at a frequency of once per year (F4). The worst credible consequence is a single fatality (C4) at a frequency of once every 10 years (F3)1. It would appear that Morlais now accept that collision between a sea kayaker and a Project surface device could result in a fatality. However there is no justification for the derived

1 Note that in NRA V3.0 (supplied to National Resources Wales in support of a Marine Licence), the same event has a frequency 10 times higher. We have been unable to find an explanation for this order of magnitude reduction in risk presented in the Statement of Case to TWA. Review of Morlais Shipping & Navigation Ch15 – Issue 1 Page 6

frequency of the worst credible outcome and at the frequency quoted, this still represents a risk 1000 greater than that considered tolerable by HSE.

8) For a single fatality consequence (C4) at a frequency of once every 10 years (F3), the Marico Navigational Risk Assessment Table 4-3 (NRA) indicates a Risk factor of 7. However the HAZMAN II computer program calculates a Baseline Risk Score of 3.59. Nowhere is it clearly explained to the reader how the computer program reduces the risk score from 7 to 3.59.

IMO page 6 para 3.3.1 states: The use of expert judgment is considered to be an important element within the FSA methodology.

9) For this Navigational Risk Assessment to be credible, Marico need to provide a simple credible fault tree analysis starting from a sea kayaker surfing in the most affected tide race off Holy Island and ending at a fatal interaction with a surface breaking element of the Morlais Project. Expert professional sea kayaker input should be used to help determine credible frequencies for the various steps in the fault tree.

NRA page ii states, The NRA Addendum updates and extends the previous NRA completed by Marico Marine in 2019

Therefore we have based our response on the assumption that the data in NRA supersedes that in Ch.15.

10) The inclusion of a worse credible hazard outcome in the Marico Navigational Risk assessment (NRA) significantly changes the risk outcomes as described in Chapter 15 of the Morlais Environmental Statement (Ch.15). It is concluded that Chapter 15 (Ch.15) is misleading and should be extensively rewritten and reissued.

11) However the significant conclusion remains: that the risk of a fatal accident to an individual calculated in the Marico Navigational Risk Assessment is 1000 times higher than tolerable under HSE guidelines in Reducing Risks, Protecting People (HSE).

NRA Annex B & C go on to describe various other hazards associated with unpowered recreational vessels. However the results are very similar to ID6 Annex B and so will not be discussed in detail, except to say that not all the outcomes and frequencies are accepted.

12) When compared to HSE guidance (HSE), the Marico Navigational Risk Assessment (NRA) demonstrates that risks to individual members of the public arising from implementing the proposed Morlais Project are intolerable.

IMO page 45 & 46 paras 4 & 4.1.3 state: By using different forms of risk expressions, risk criteria can be created that meet the requirement of different principles. The commonly accepted principle is known as the ALARP principle ……. It states that there is a risk level that is intolerable above an upper bound. In this region, risk cannot be justified and must be reduced, irrespectively of costs.

Review of Morlais Shipping & Navigation Ch15 – Issue 1 Page 7

References.

1. CH.15: MMC 194 Morlais Project, Environmental Statement, Chapter 15: Shipping and Navigation Volume I MOR-MSP-DOC-00 Version F4.0, Sept 20. 2. IMO: IMO Revised Guidelines for Formal Safety Assessment (FSA) For Use in the IMO Rule- Making Process MSC-MEPC.2/Circ.12/Rev.2, 29 April 2018. 3. HSE: Reducing Risks, Protecting People. HSE Decision Making Process 2001. 4. NRA V3.0: Appendix 15.1: Navigation Risk Assessment - Morlais Tidal Demonstration Zone (Marico Marine, 2019) Volume III MOR/RHDHV/APP/0030 version 3.0 dated July 2019. 5. NRA: MMC196 Navigation Risk Assessment Addendum– Morlais Demonstration Zone, MOR- MCO—DOC-001, 18 Sept 20.

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NAVIGATION RISK ASSESSMENT ADDENDUM – MORLAIS DEMONSTRATION ZONE Document Ref MOR-MCO-DOC-001

Review of numerical risk assessment Snowdonia Canoe Club

Summary

We have conducted a review of the Navigational Risk Assessments (NRAs) produced for Morlais by Marico Marine. Our review identified a number of issues:

1. Marico claim to have based the risk assessments on International Maritime Organisation (IMO) guidance. They also claim to use Maritime and Coastguard Agency (MCA) guidance. They then describe a methodology unique to Marico, which is what is actually used. The use of a non-standard approach makes the logic difficult to follow and has resulted in several significant errors.

2. Risks that are below the limit of tolerability may be acceptable provided they are ‘As Low As Reasonably Practicable’ (ALARP). The limit of tolerability implied by Marico’s risk matrix is between 1000 and 10,000 times higher than expected in HSE, MCA and IMO guidance.

3. The initial risk identification process in the NRA Addendum identifies serious risks to members of the public. These are then combined with risks to property, environment and business, which masks their seriousness and, in conjunction with other errors such as the misapplication of ALARP, makes them appear acceptable, which they are not.

4. Health and Safety Executive (HSE) and IMO guidance is that for risk to members of the public, the limit of tolerability should be one fatality every 10,000 years. The NRA Addendum calculates that the risk of a fatality involving an unpowered recreational vessel is at least once every 10 to 100 years – a risk to life up to 1000 times higher.

In addition to these concerns regarding the process, we disagree with some of Marico’s consequence and frequency estimates and with some of their Suggested Additional Risk Controls. We have not documented these matters here, as we believe that stakeholder input to the risk assessment is fundamental and should be discussed interactively.

Our conclusion is that the risk assessment in the Addendum NRA demonstrates an intolerable risk, under UK law, to the safety of members of the public. We have used kayaks to illustrate the risk because that is where our expertise is, but our concerns over the risk assessment process apply to all vessels. While we also believe that Marico may have significantly underestimated the risk to kayakers, we emphasise that the risks we discuss here are not our estimates, they are the risks as calculated by Marico, for Morlais.

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1.0 Introduction

We have reviewed the numerical risk assessments as summarised in the Shipping and Navigation Chapter 15 of the Morlais Environmental Statement (ES) and as expanded in the supporting NRA produced on behalf of Morlais by Marico Marine. There are two versions of the NRA. The first version was issued to Natural Resources Wales (NRW) as Vol III Ch15 of the ES. To allow for changes in the arrangement of the Morlais Development Zone (MDZ) to meet navigation concerns for shipping, and following concerns expressed by NRW regarding unpowered recreational vessels such as kayaks, the second version was issued with a revision to Chapter 15 and a NRA Addendum.

The risk assessment in the NRA Addendum follows a similar methodology to the previous version and splits recreational vessels into powered and unpowered classes. Although the risk to recreational vessels is reduced as a result of the inclusion of a 500m zone with no surface breaking devices, it remains significant.

We compare accident outcome results and the risk assessment process used by Morlais with regulator guidance. Our review has identified a number of issues.

To aid understanding, this report presents the findings of our review as a discussion without detailed evidence and referencing. Detailed referenced evidence is presented in a companion document “Review of the Morlais Project Shipping & Navigation Chapter 15”.

2.0 Marico Marine’s Risk Assessment Process.

The NRA Addendum references three different methods of risk assessment: the IMO Guidance for Formal Safety Assessment (primarily intended for shipping), Marico’s own ‘unique’ form of risk assessment ‘specifically adapted for navigational use’ and the MCA guidance for Offshore Renewable Energy Installations (MGN 543).

MGN 543 says it should be read in conjunction with the MCA’s “Methodology for Assessing the Marine Navigational Safety Risks & Emergency Response of Offshore Renewable Energy Installations“. This describes how to produce a navigation risk assessment, for a wind, wave or tidal power project, which meets the expectations of UK law. Marico do not reference this document and there is no indication that it has been consulted.

In practice, the risk assessment process used by Marico does not follow much of the IMO guidance. Risk Control Measures are not grouped into Risk Control Options. There is no cost-benefit analysis and no analysis of the interdependencies between risk controls. Consultation with sea kayak stakeholders only commenced in February 2020 after submission of applications for TWAO and Marine license. We are not aware of any stakeholders being involved in the risk assessment; we were not offered a hazard workshop and have no agreement on the location, nature, severity and frequency of risks to kayaks. The only risk mitigation that has been discussed with us is the addition of ladders and ‘safety’ chains, which we said was counterproductive but has been retained.

There is some similarity between Marico’s approach and that described in Appendix 4 of the IMO guidance. Risk is a combination of the consequences of an accident and the probability of it happening, expressed as a frequency of occurrence. The IMO guidance recommends that the consequences of an accident are measured using a Severity Index, ranging from S1 for minor injury

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to S4 for multiple fatalities. This is based on a logarithmic scale, such that each increment indicates consequences that are ten times as bad. This logarithmic scale is also applied to the estimated frequency of incidents. F7 means likely to occur monthly (considered as 10 times per year), F6 annually, F5 once in ten years, etc, until F1 is once in 100,000 years. The factor of 10 between increments also recognises the difficulty in estimating consequence and probability for future events to better than the nearest order of magnitude.

Marico’s Consequence categories are similar to the IMO’s Severity Index, except for the addition of a ‘Negligible’ band, numbered C1, with the remaining index numbers increased by 1.

In Marico’s Frequency Index, each increment is stated as covering a range of frequency rather than a single value, which makes comparison with HSE and IMO ranges more difficult. It is logarithmic apart from the most frequent band, which covers weekly to annual, a multiplier of 52, and the most remote band, which is open ended at ‘over 1000 years’.

The mathematical properties of logarithms mean that adding the logarithmic index numbers for consequence and probability has the same effect as multiplying the consequence and frequency. Using the IMO process, a risk of one fatality in 10,000 years is represented by a Severity Index of 3 and a Frequency Index of 2, giving a Risk Index of 5. For a given Risk Index, the approximate level of risk remains the same. A risk of multiple (nominally 10) fatalities every 100,000 years would have a Severity Index of 4 and a Frequency Index of 1, again giving a Risk Index of 5.

The confusion arises in Marico’s Risk Matrix, which doesn’t follow this logic but is weighted to give more importance to frequent events and less importance to minor events. Figure 1 below illustrates this, showing the difference between Risk Index as defined by Marico and how it might look with a Risk Index based on the sum of CI and FI, as recommended by the IMO. The highlighted diagonal shows comparable risks.

Marico: NRA Addendum Table 4-3 Risk Index using logarithmic principle

5 5 6 7 8 10 5 6 7 8 9 10

) )

4 4 5 6 7 9 4 5 6 7 8 9

CI CI

( (

3 3 3 4 6 8 3 4 5 6 7 8

Index

Index 2 1 2 2 3 6 2 3 4 5 6 7

Consequence Consequence Consequence 1 0 0 0 0 0 1 2 3 4 5 6 1 2 3 4 5 1 2 3 4 5 Frequency Index (FI) Frequency Index (FI) Figure 1 Marico Risk Matrix and a logarithmic equivalent Risk weighting is normal for ranking of risks during the initial concept stage of a project. The degree of weighting may be chosen by the developer to prioritise the types of risk that they wish to address early in the project development, to avoid abortive work and expensive changes. In this case, however, the project concept has already been decided. The present risk assessment should demonstrate that risks to Health and Safety are within legally accepted limits. Disproportionate weighting is not helpful in this situation.

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3.0 Comparison of ALARP ranges

The ALARP principle is well established internationally and first arose from UK law. A range of risk is identified, typically spanning two orders of magnitude. Risks higher than this are considered not to be tolerable at any cost. Risk within the ALARP range can only be accepted if it is not ‘reasonably practicable’ to reduce it. That is, there is no way to reduce the risk without incurring a cost which is grossly disproportionate to the benefit. In the UK, the HSE will expect the party creating the risk to demonstrate this by reference to relevant good practice or cost-benefit analysis. Risks lower than the ALARP range are ‘broadly acceptable’. In the UK, risks in the ‘broadly acceptable’ range must still be reduced to ALARP but that does not need to be demonstrated to HSE in advance.

The level of risk which is considered tolerable, and the upper limit of ALARP, depends on who is at risk. People working for the risk owner are considered to have had some degree of choice, in accepting the job, while the general public have the risk imposed on them. For this reason, the limit for tolerability of risk to a member of the public is 10 times lower than for workers.

Marico’s risk assessment process does not separate risks to the public from risks to workers.

Our concern as sea kayakers is as members of the public, and we have compared the tolerability limit implied by Marico with that recommended by IMO, expected by HSE and referenced by MCA. The point at which this is typically defined is the frequency of a single fatality.

In Marico’s Risk Matrix, a fatality is consequence level 4, and the Risk Index at which this becomes intolerable is 7. This corresponds to a frequency of 1 to 10 years. HSE define the limit as 10-4 per year, which is 1 in 10,000 years. Marico’s definition of ALARP for risks to a member of the public is therefore between 1000 and 10,000 times too high. Since the ALARP range covers two orders of magnitude (100) many of the risks identified by Marico as below the ALARP range (Low Risk) are actually above the limit of tolerability.

Figure 2 Marico Risk Matrix and ALARP calibration extended to compare with HSE

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4.0 Combination of Health & Safety risk with other risks

Marico’s risk assessment process combines risks across the four categories of People, Property, Environment and Business. As with risk weighting, this is an acceptable approach for risk ranking in order to identify areas of a project where efforts should be concentrated during the concept stages but it is not valid in demonstrating that Health &Safety risk is acceptable.

In the risk assessment tables in Annexes B and C of the Marico NRA, for all events involving unpowered recreational craft, the ‘People’ risk is the highest or joint highest. Any averaging with the other risks will therefore reduce the risk score. To comply with UK Health &Safety law, ‘People’ risk must be considered independently.

Marico’s process uses concepts of “Most Likely” and “Worst Credible” risk. This seems appropriate and reflects uncertainty in estimated outcomes.

The risk scores across the four areas and “Most Likely” and “Worst Credible” are combined in Marico’s proprietary HAZMAN II computer program to calculate a Baseline Risk Score. The algorithm used by the software is not described.

The Baseline Risk Score is then modified, presumably though further use of HAZMAN II, to produce a Residual Risk Score, taking account of the “Suggested Additional Risk Controls”. There is no indication of how this is done.

The combined risk scores from each scenario are reviewed against Marico’s ALARP criteria. This would not be correct, even if the ‘People’ risk had been separated out. The criteria for tolerability and ALARP apply to the total risk from the project to each class of persons at risk. The risk from all scenarios affecting unpowered recreational vessels should be added together (not averaged), before comparing against criteria for acceptability. Hence the risk of collision with a surface device, a mid water device, an electrical hub, a Project vessel and potentially another vessel forced into close contact would need to be summed.

For risks which are in the ALARP region, there should normally be a demonstration that the project follows relevant good practice or that risk cannot be reduced except at grossly disproportionate cost. It is not sufficient simply to list Suggested Additional Risk Controls (on which we comment below). For the Morlais project, however, there is no relevant good practice for reducing risk to recreational craft, as this is an unprecedented situation. So far as we know, no large scale, surface breaking, inshore, tidal energy project overlapping an area of major recreational activity has previously been proposed.

We do not consider that all the “Suggested Additional Risk Controls” are valid justification for reducing the Residual Risk Score, as they must have been included in the original concept, so would not be additional. For example, “Appropriate alignment and spacing of devices”, “Check device surveys” and “Temporary navigation aids as required by Trinity House”. Surely, it was never intended to use inappropriate device spacing, to not check that devices were at the correct depth or to fail to meet Trinity House requirements?

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5.0 Risks to Unpowered Recreational Vessels.

Marico consider a range of outcomes from navigational accidents, including contact between unpowered recreational vessels and a Morlais Project surface device, a mid water device, an electrical hub or various other vessels including a Project vessel. Marico consider both “Most Likely” and “Worst Credible” outcomes arising from a navigational accident.

Consider just one such accident scenario, NRA Addendum Annex B ID6. This describes contact between an unpowered recreational vessel, possibly a sea kayak, and a Morlais surface device. Marico’s analysis of the “Worst Credible” outcome resulting from this hazard is a single fatality at a frequency of once every 10 to 100 years. This may well be a realistic estimate of the risk faced by a kayaker who capsizes whilst surfing in or transiting through one of the three adjacent tide races and is swept by the tide and/or wind into the area of surface breaking devices. A fatal outcome is indeed credible if one or more kayakers, in a kayak or in the water, are swept into an array of devices fixed in the tidal stream. A sea kayaker is likely to be the member of the public most at risk from the Morlais development, based on both the number of kayakers using the area and their vulnerability. HSE guidance explains that for members of the public who have a risk imposed upon them in the “wider interest of society” the limit of tolerability is judged to be 1 in 10,000 per annum. This is referred to specifically in the MCA methodology supporting MGN 543. The risk calculated by Marico for this one scenario is 100 to 1000 times greater than is considered tolerable under HSE guidance.

The total risk imposed on a sea kayaker or other unpowered vessel by the Project will be even larger. It will be the sum of the risks from each hazard described in NRA for unpowered recreational vessels.

6.0 Conclusion and recommendations

The only acceptable risk reduction measure we can identify is for no tidal devices or project infrastructure to be placed in parts of the MDZ to which unpowered vessels may be swept or blown. This may not be limited to surface breaking items, as we have seen no information on the surface effects of devices that are below the surface. We do not accept that the “Suggested Additional Risk Controls” will significantly reduce the risk to kayakers swept into the MDZ.

There is no evidence that the Project has made any reasonable efforts to determine where the tidal streams from the kayaking areas might run to. We have previously explained, in detail, our concerns over the relevance and accuracy of the metocean modelling.

We suggest that Morlais produce a verified assessment of tidal streams running from the tide races towards the MDZ, including the effect that submerged devices might have on the surface flow. This, and interaction with stakeholders, will allow a more refined and credible navigational risk assessment that covers the specific vulnerabilities of each category of watercraft including, for example, credible wind effects on a kayak. If potential interaction between kayakers and surface breaking devices is demonstrated, the results will inform the proposed placement of the tidal array to avoid kayaker interactions and deliver an acceptable risk to life from the Project.

Until such assessments have been completed, however, we remain seriously concerned that the risk to kayakers will be such as to result in cessation of all organised kayaking in the area. We therefore recommend, based on current information, that no tidal devices or project infrastructure that affects the sea surface should be placed with 1.5 nautical miles of the coast.

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Scoping the socio-economic significance of sea kayaking on Anglesey

October 2020

Snowdonia Canoe Club

Contact email: [email protected]

This report has been prepared by Snowdonia Canoe Club (SCC) as a more in-depth analysis of data collected by the online surveys of paddlers and kayaking guides undertaken in August-September 2020 and reported as part of the SCC Statement of case1. It is intended to demonstrate the scale and scope of potential socio-economic impacts on sea kayaking interests of the development of the Morlais Demonstration Zone (MDZ). It is not itself an assessment of these impacts as the survey data is limited, valuation was not attempted, no monetary information was collected and a cost-benefit analysis has not been conducted. However, it does indicate the significance of sea kayaking activities and that the potential of the Morlais proposal to disrupt these activities warrants a formal baseline survey and a full assessment of impacts within the Environmental Impact Assessment (EIA).

1 Anglesey sea kayaking surveys. Report from two surveys: sea kayakers who visited Anglesey in 2019 and the sea kayaking businesses. September 2020. Including in SCC Statement of Case [Annex 2 in Document SOC011] Contents Introduction ...... 2 Data sources ...... 3 Paddler trips to Anglesey ...... 3 Sea kayak businesses ...... 8 Guides ...... 11 British Canoeing sea kayak awards ...... 12 Morlais approach to socio-economic impact assessment ...... 13 Conclusions ...... 14 Annex: British Canoeing sea kayak awards ...... 15

Figure 1: RNLI guide to Kayaking around Anglesey (RNLI guide) ...... 3 Figure 2: Representation of clubs, paddlers and coaches by travel time to Porth Dafarch in 2019 ...... 5 Figure 3: Direct total spend for 163 paddlers visiting Anglesey in 2019 ...... 7 Figure 4: Seasonal distribution of paddlers visiting Anglesey...... 8

Table 1: Respondents kayak club affiliation and approximate travel time from Porth Dafarch ...... 4 Table 2: Numbers of paddlers and average activities undertaken ...... 6 Table 3: List of sea kayak-related businesses local to Anglesey ...... 8

Box 1: Kayak manufacturer and coaching provider ...... 9 Box 2: Free-lance guide ...... 10 Box 3: Specialist accommodation provider...... 10

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Introduction Modern sea kayaks are direct descendants of the craft first developed by the Inuit, Yupik and Aleut tribes at least 4000 years ago2. With the introduction of modern materials and innovations in design kayaks have evolved into sleek, agile personal watercraft. Kayaks are employed for long expeditions (e.g. self-supported circumnavigations of Britain), relaxed day trips and high adrenaline ‘play’ surfing on waves in tide races and overfalls. A competent sea kayaker must acquire many skills including offshore navigation, VHF radio licence, outdoor first aid, self-rescue, the ability to rescue others and be competent to handle their kayak in waves, tides and winds. Safety comes in numbers and sea kayaking is a social activity with groups paddling together often on trips arranged by clubs affiliated to Canoe Wales or one of the other national governing bodies. Training and mentoring to develop skills is well developed with the British Canoeing awards for personal skills, leadership and coaching recognised worldwide. Recreational trips are to spectacular locations featured in an expanding range of sea kayak guidebooks to the coast of the UK and other parts of the world. Professional guides offer trips to many of the more serious locations either as advertised expeditions or engaged directly by groups of paddlers. The UK has long been a centre for sea kayaking with innovations in design and manufacture of kayaks, paddles, specialist equipment and clothing.

Over the past 40 years Anglesey has grown to become the centre of sea kayaking in the UK. This is a consequence of the combination of tide races, spectacular wild coastline, shelter, if needed, from winds from any direction and abundant wildlife. All within easy reach with good transport links along the A55, mainline train to London, ferries to Ireland and close to Manchester International Airport. Holyhead is also home to several internationally renowned kayak and paddle manufacturers, specialist retail and accommodation providers and is home to arguably the highest concentration of top level sea kayak coaches in the world. There is no other location in the UK, and indeed Europe, which can offer so much.

Figure 1 is a guide prepared by the RNLI which gives an overview of sea kayaking resources around Anglesey. There are few sheltered locations for beginners, two areas for intermediate paddlers with the majority of locations experiencing significant tides and indicated for advanced paddlers. The area known as the Stacks from Porth Dafarch to Soldiers’ Point at the westernmost point of Holy Island is the jewel in the crown of Anglesey sea kayaking. It boasts three tide races, Penrhyn Mawr, South Stack and North Stack set against high cliffs, caves, arches and stacks populated with sea birds with inquisitive seals, overlooked by two historic lighthouses. These races are particularly well suited to training and play as they have safe run outs into inshore eddies or unobstructed deep water. While in good weather at slack water, with appropriate experience or in the company of a guide the area can be enjoyed as a spectacular less challenging paddle. There are relatively few areas of Anglesey which can be considered to be truly ‘sheltered’ but there are extensive stretches of coast which support moderate or advanced conditions (Figure 1). Being a roughly square island, there is nearly always somewhere sheltered from the wind which means kayaking is feasible in all but the most extreme weather conditions, all year round.

2 https://seakayakexplorer.com/history-of-kayaking/

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Figure 1: RNLI guide to Kayaking around Anglesey (RNLI guide)

Data sources Two online surveys were disseminated using social media and word of mouth to sea kayakers concerned about the development of the MDZ to collect evidence for the SCC Statement of case. The Paddler survey was directed at individual paddlers and was open from 19 August to 11th September 2020 and garnered 172 responses. The second survey was directed at sea kayak businesses with a focus on coaching on Anglesey and was open from 13-17th September 2020 and gave 15 responses. These surveys are described in more detail with the overall results in the report “Anglesey kayaking surveys” presented as Annex 1 to the SCC Statement of Case [SOC011].

Paddler trips to Anglesey Knowing that many paddlers visit on official club trips we asked respondents to the Paddler survey to indicate if they belonged to a formal canoe club. There are 46 canoe clubs in Wales with 24 of these listing sea kayaking as an activity - our sample includes members of six of these clubs. There are 380 canoe clubs in England with members of 29 of them in our sample. So our sample covers around 10% of canoe clubs in England and Wales.

Using the estimated travel time from the club HQ to Porth Dafarch allows us to examine how far people are coming as shown in Table 1. Travel time is an important metric in valuation of recreational activities and visits.

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Table 1: Respondents canoe club membership and approximate travel time from Porth Dafarch

Travel time Places within scope Clubs (driving) from Porth Dafarch 1 hour Caernarfon, Llanberis, Fflint Amlwch Canoe Club (0 to 1 ½ hrs) Bangor University Canoe Club Snowdonia Canoe Club 2 hours Aberystwyth, Liverpool, Aberkayakers (1 ½ to 2 ½ hrs) Manchester, Shrewsbury Liverpool Canoe Club Llangollen Canoe Club Macclesfield and District Canoe Club Manchester Canoe Club Shrewsbury Canoe Club 3 hours Hereford, Derby, Halifax, Broomhall Canoe Club (2 ½ to 3 ½ hrs) Lancaster, Dublin East Coast Sea Kayak Club (IE) Halifax Canoe Club Hereford Kayak Club Irish Sea Kayaking Association (IE) Lower Wharf Canoe Club Midand Canoe Club Northampton Canoe Club Ribble Canoe Club Tamworth Canoe Club Wyre Forest Canoe Club 4 hours Haverfordwest, Cardiff, Bristol, Avon Outdoor Activity Club Grimsby, Grimsby and Cleethorpes Canoe Club (3 ½ to 4 ½ hrs) Haverfordwest Kayak Club Northampton Canoe and Kayak Club Rutland Canoe Club Swaledale Canoe Club 5 hours London, Cambridge, Newcastle, Adventure Club (IoM) New Forest, Isle of Man Cambridge Canoe Club (4 ½ to 5 ½ hrs) Chelsea Kayak Club Chiswick Pier Canoe Club New Forest Kayak and Canoe Club Wansbeck Paddlesport Club 6+ hours Scotland, Devon, Cornwall, Bideford Canoe Club Northern Ireland, Channel Isles Castle Craigs Canoe Club (more than 5 ½ hrs) Exeter Canoe Club Ipswich Canoe Club Jersey Canoe Club Kyle Canoe Club Maidstone Canoe Club Penzance Canoe Club Poole Harbour Canoe Club Southbourne Canoe Club Flight Finland, Iceland, Germany, Kayakklubburinn (IS) Switzerland, Portugal, USA, Kirkkonummen Melojat (FI) Netherlands, Sweden Melanväntääjat (FI) Salzwasserunion (DE) Teleger Kanu Verein (DE)

The survey also included paddlers who are unaffiliated with a club while notes included in the survey indicate that the sample also included guides (coaches) who are estimated as ~12% of respondents.

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Figure 2 illustrates the number of clubs, independent paddlers and guides represented in the survey within 1 hour travel zones of Porth Dafarch. Here we see that the number of clubs visiting is more likely to be related to population density (see Table 1) than difficulty of getting to Anglesey. The 20% of clubs travelling more than 6 hours appear to be mostly sea kayak clubs located on the coast and presumably seeking the particular thrills of paddling around Anglesey, advanced coaching or British Canoeing award assessment (see Annex).

14

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0 1 hour 2 hours 3 hours 4 hours 5 hours 6+ hours Flight Travel time (1 hour intervals centred on hour

Clubs Unaffiliated paddlers Guides

Figure 2: Numbers of clubs, paddlers and coaches by travel time to Porth Dafarch in online survey

Sea kayaking is most often done in groups, especially in seas which require more advanced skills in navigation and rescue procedures and mentoring of less confident paddlers. Organised canoe club- based trips to Anglesey are a regular feature in the calendars of many canoe clubs from across the UK and even for a few from outside the UK. Club trips to Anglesey may take place several times a year and can involve up to 30 paddlers. Club paddlers on the water around Anglesey are usually led by an experienced paddler holding at least a British Canoeing (BC) Sea Kayak Leader Award with a ratio of Leader to paddler of 1:6 (or insurance invalidated). Clubs which do not have sufficient leaders or are less familiar with Anglesey will hire guides and many of those coming in from further afield e.g. fly in will also hire kayaks from a local provider.

Many of the apparently independent paddlers belong to groups such as the North West Sea Kayakers and Yorkshire Sea Kayakers who paddle informally as peer groups. There are paddlers who belong to more than one club and may join clubs local to where they wish to paddle but live some way away. Guides and elite paddlers also tend not to belong to clubs. Unaffiliated paddlers are most common from 2-3 hours away and also flying in from overseas. Coaches up to 1 hour away are local while those coming in from further afield may be coming to coach for an Anglesey business, may be bringing a group of clients with them or coming for advanced training or on a sociable busman’s

Page | 5 holiday. Sea Kayaking UK (SKUK) reported that they bring in up to 25 overseas guides to assist with the Anglesey Sea Symposium and as freelance coaches on courses.

Estimating a total number of paddlers visiting Anglesey and the Stacks from our data is not feasible as the respondents were self-selecting and the data are not a statistically representative sample. Nevertheless, the clubs represented in the sample between them around 6,000 members with an average of around 25% engaging in sea kayaking. The 426 clubs in England and Wales between them have 61,000 members. This suggests that there are likely large numbers of sea kayakers in England and Wales, plus those coming from further afield which illustrates the scale of the market for sea kayaking.

Use of Anglesey and the Stacks area for sea kayaking

The 168 paddlers who reported the number of paddling days on Anglesey spent more than 3,000 days on the water in 2019 with an average of 18 paddling days per person spread over multiple visits. Of these paddling days 44% were spent in the Stacks area (which is 10% of the coastline). Paddling trips involved overnight stays for 156 paddlers (> 90%) who between them had 2,000 bed nights on Anglesey. Around 34% of paddling days were led by a guide giving up to 1,000 days of employment to a professional guide. Table 2 summarises the survey data by travel time to Anglesey and shows there are distinct trends with distance with generally fewer trips, longer stays, greater dependence on guides or are visiting guides by people further away who have greater interest in the Stacks. These data are from a small sample and should not be taken as representing total numbers from each travel zone. Nevertheless, the general patterns are likely correct with significant numbers of visiting paddlers coming from e from 2-3 hours away who are likely to be from the densely populated areas of North West England and the West Midlands and tend to stay for 1 or 2 nights per trip consistent with frequent weekend visits .

Table 2: Summary of paddling activity reported to online paddler survey for 2019

Travel time to Number of Average per paddler visiting Anglesey Porth Dafarch paddlers Trips Overnights Paddling Stacks Guided days days days 1 hour 29 48.0 N/A 47.2 17.4 14.5 2 hours 34 16.2 18.5 23.3 9.8 3.8 3 hours 43 7.1 14.4 14.5 7.7 5.1 4 hours 17 4.3 14.2 13.8 7.0 4.0 5 hours 16 3.8 10.3 9.7 5.4 6.2 6+ hours 17 2.9 11.9 10.2 5.1 9.7 Flight 13 1.9 10.5 9.1 5.8 6.9 All paddlers* 170 14.1 13.6 20.6 9.3 8.3 *Including those for whom it was not possible to determine travel time.

A proxy for the economic contribution of kayaking visits is to consider the number of overnights and coached days. If we take the average cost of an overnight stay as between £5 for tent up to £60 for Travel Lodge – say average of £70 to include food. Joining a training course is around £200 for a two day course in advanced water and £160 for moderate water with bespoke one-on-one sessions at £180 per day (take £90 for a single coach day as part of a group of four) per day then we see that the total direct contribution to the local economy is as in Figure 3. This shows that the greatest contribution comes from paddlers based 2-3 hours travel time i.e. from North-West and the West

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Midlands of England and this mostly represents costs of several weekend visits. There is certainly enough income here to verify the claim made by one business3 of annual of a £45,000 annual turnover and from another guiding business that they generated income of £11,970 taking 126 clients to the Sacks on 27 days in 20194.

£70,000

£60,000

£50,000

£40,000

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£0 1 hour 2 hours 3 hours 4 hours 5 hours 6+ hours Flight Travel time to Porth Dafarch

Overnight Paid by client to coach

Figure 3: Direct total spend for 163 paddlers visiting Anglesey in 2019

The distribution of the visitor spend through the year is an important component of its economic significance. The ideal is for spend throughout the year to support full-time employment. Figure 4 shows that paddlers visit all year round and that although activity is highest in the peak summer season (July – August) that the numbers of visitors holds up well through the rest of the year. There is also no differentiation by distance from Anglesey with people coming from all locations all year.

3 Representation 71 to NRW Marine Licence public consultation [MMC163] 4 Personal communication.

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Numberpaddlers of per month 10

0 Jan-Mar Apr-Jun Jul-Aug Sep-Dec Season

1 hour 2 hours 3 hours 4 hours 5 hours 6+ hours Flight

Figure 4: Seasonal distribution of paddlers visiting Anglesey from online survey responses Sea kayak businesses The second online survey collected information from 15 sea kayak businesses operating local to Anglesey. Of these, five were freelance, self-employed guides and nine are more formal businesses with employees who have guiding as at least part of their offer and one was an accommodation provider. Between them these 15 businesses indicated that they support around 68 local jobs5 and provide opportunities for at least 25 visiting guides. This is only a sample of the local kayak-based businesses and the actual number of jobs will be higher than this at a rough estimate as many as 85 jobs. Table 3 lists the main local businesses directly dependent on sea kayaking but does not include free-lance guides nor the many guides who are from outside the area but bring groups to Anglesey who also contribute to the sea kayak economy.

Table 3: List of sea kayak-related businesses local to Anglesey

Location Type of business List of businesses Holyhead Manufacturers Sea Kayak UK (see Box 1) Rockpool Celtic Paddles Holy Island Specialist accommodation Anglesey Outdoors (see Box 3) providers Outdoor Alternative Holyhead Retail Summit to Sea Local to Anglesey Specialist sea kayak guide Adventure Elements businesses Blond Beard Sea Kayaking (Tend to work with higher Coastal Spirit ability paddlers who want Kayak Essentials to access tide races and North Wales Sea Kayaking tend to operate Sea Kayaking Anglesey

5 This is difficult to estimate as there may be some double counting of freelancers and some businesses are part-time. However, the overall numbers do correspond with expectation based on SCC knowledge of the local sea kayak scene.

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throughout the year) Sea Kayaking Wales Sea Môr Kayaking Tidal Waters Diversified guiding Acwaterra businesses (offer sea Anglesey Adventures kayak guiding alongside Arete Outdoor Centre other offers) B-Active@Rhoscolyn Môn Active Môr a Mynydd Outdoor Active Sports Plas Menai Plas y Brenin Rock & Sea Adventures Snowdonia Watersports Outside Wales Guides advertising courses Creek & Climb in Anglesey but based Embrace the Elements elsewhere Explore Big Blue Green Adventures Zoe Newsam Guiding

These businesses form a cluster at the hub of a dense network and can hardly be disentangled. For example the SKUK kayak manufacturer SKUK (Box 1) makes and sells kayaks internationally through dealers who are treated to an annual invitation to Holyhead to try out new designs, play in the tide races and place orders, make arrangements for expeditions and build loyalty. Be-spoke boats are often picked up in person and combined with paddling trips rather than shipped and the retailer Sea to Summit runs popular demonstration weekends so prospective sea kayak buyers from across the UK can try out boats on the sea before buying. Popular annual events such as the long-running Anglesey Sea Symposium provide work for guides (Box 2), fill accommodation (Box 3) and serve as shop windows for the island and local kayak businesses. Furthermore, it has created and maintained a global network of active sea kayakers which draw people into Anglesey but also export skills and boats around the world. All of this creates dense networks of support between manufacturing, retail, guiding and accommodation providers which have proven to be durable and resilient and is continuing to grow and develop.

Box 1: Kayak manufacturer and coaching provider

SKUK are the largest manufacturer of composite sea kayaks in the UK and offers 21 models based on the Greenlander, Romany, Explorer and Pilgrim designs with new designs always in development. All boats are hand built in Holyhead by a team of 18 full time employees. SKUK kayaks are exported to 30 different countries though a global network of dealers.

Unique among kayak manufacturers, SKUK also offers training and British Canoeing assessment specialising in the advanced water conditions found of North and South Stack together with the races found off Porthdafarch. SKUK also supports a global network of 23 Expedition Centres.

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In addition, SKUK has organised and run the Anglesey Sea Symposium for some 37 years based out of Porthdafarch Beach. The symposium is the longest running in the UK and has been held across the May Bank Holiday weekend annually (sadly cancelled due to Covid for 2020) and is based at Anglesey Outdoors at Porth Dafarch. The Symposium offers guided trips around the Anglesey coast, coaching for advanced water conditions and BC training opportunities for 150 participants. Local guides are joined by 25 international guides to cover the large numbers of paddlers. The event serves as a shop window for local business and kayak manufacturers’ who provide hire and demonstration boats. In the evenings there is music, film and talks at the Ucheldre Centre in Holyhead. For those staying on for the week following the Symposium there are guided day trips around the Anglesey coast, coaching in advanced water conditions and BC training and assessment courses.

Box 2: Free-lance guide

I have lived in Anglesey for 36 years and as part of that in Holyhead for 11 years. I am a self-employed local resident. For the past 10 years I have been operating as a sea Kayak coach, leader and guide. I am invited to coach worldwide and recently was endorsed by British Canoeing, my National Governing Body, as a National Trainer Provider. I assess NGB endorsed sea kayak awards and assessments which includes a substantial element of coaching and assessing leadership in the moderate to advanced water environment. I also work as a free-lance coach for many of the local providers including the English National Centre, Plas y Brenin. I am one of a small handful of top qualified female coaches in the U.K. and in fact in the world. 75% of my clientele who visit Holyhead and to have coaching with me come from overseas – from a list of 17 countries, mostly from Europe but also from Israel, USA, Japan and Chile.

Most clients come as a group of six and stay for a week or longer and want to visit and learn and (we use the term “play”) to experience the tidal flows at the tide race to improve their skills as a safe and competent sea kayaker and sea kayak leader. The main attraction is the area from Porth Dafarch to Soldier’s Point including the races of Penrhyn Mawr, South Stack and North Stack. I will use this area 3-4 times a week during the months of April - October. Over a season this would come to around 200 paddle days through my private business alone.

Taken from public representation number 4 to the NRW Marine License consultation

Box 3: Specialist accommodation provider

At Anglesey Outdoors approximately 70% of our non-academic residential guests are sea kayakers. Sea Kayakers are year round customers to the centre and over the last 5 years this has increased significantly and means as a business we are now open 12 months of the year which we were not before. This has meant that our 20 staff have been retained on 12 month contracts rather than seasonal.

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In winter months 80% of the sea kayakers staying with us are from abroad. They are contributing to the wider local economy in the quieter times with car rental, eating out, shopping, Christmas events etc..

Guides As shown in Table 3 the majority of sea kayak businesses are guides. These guiding businesses offer a wide range of products from taster days through skill development, training, assessment of BC awards to expeditions to other kayaking destinations such as Greenland, Chile, Shetland and Iceland. They also organise and contribute to several Symposium-style events which mix training during the day with evening social events over a weekend or longer.

The online business survey contains responses from 13 guides. Of these 12 indicated the level of British Canoeing award they hold. All are Sea Kayak Coaches, one for Moderate water and 11 for Advanced water. According to figures provided by British Canoeing and Canoe Wales there are 83 Advanced sea kayak coaches in England and Wales – our sample of approximately half of the local guides accounts for 10% of these coaches – we might reasonably expect that the other guides are similarly qualified which suggests that Anglesey supports 20% of top sea kayak coaches in England and Wales.

Guiding is a mix of advertised courses, expeditions such as a multi-day circumnavigation of Anglesey and client-led hiring of guides. Although guiding can be at any level, there is a focus on more advanced conditions with “rough water” days alone accounting for 800 paddler days. However, it's not all just about high adrenaline, as in recent years there has been increasing interest and provision of quieter guided trips with a focus on observing wildlife, geology and history. For this type of trip, Anglesey has a lot to offer with the GeoMôn (UNESCO global geo park http://www.geomon.co.uk/), Dark skies designation, bird colonies, seals, dolphins and historic lighthouses. This includes trips around the Stacks area using careful tidal planning to ensure a different and less extreme experience.

The guide to paddler ratio in advanced water is low (1:4) which means larger groups and clubs require several guides. The need for businesses to bring in extra guides has led to a synergistic and fluid network of businesses and freelance guides who co-operate to serve the needs of everyone from individual clients to large groups. Like much else about the local sea kayak scene these networks are international in scope.

This fluidity also provides opportunities for diversification of incomes: 70% of the businesses are full time and 30% part-time. This in turn provides a relatively secure route into commercial guiding for aspirant guides. All of the business and guides in the survey responded affirmative to the question: “Does your business sometimes provide opportunities for up and coming sea kayak coaches and leaders to assist and observe on courses?” A route for local paddlers into employment is supported by the Outdoor Partnership (https://partneriaeth-awyr-agored.co.uk//) who provide mentoring and funding for local club volunteers to gain national governing body qualifications including the BC Leader and Coach Awards. In 2017 the Outdoor partnership supported training for 416 people in 55 outdoor clubs which helped 56 unemployed people into employment as guides. Snowdonia Canoe Club is a member of the Outdoor Partnership and our members have benefited from training

Page | 11 towards BC awards. At least three of these have since moved into part-time employment as sea kayak guides in the past few years.

British Canoeing sea kayak awards Anglesey is a major venue for training and assessment for sea kayak awards. An understanding of these awards helps to demonstrate how important Anglesey is to sea kayaking and how much takes place. There are three categories of BC sea kayak awards which are design to develop:

● personal skills and performance ● leaders for groups ● coaches

Each is a graded progression of skill development from beginners in sheltered water through moderate water to advanced water. Appendix 1 gives an indication of the remit for Sheltered water which is used by novices and those looking for a gentle day on the water and gives the sea conditions considered ‘moderate’ and ‘advanced’ by British Canoeing – these are much more serious. As conditions become more serious the ratio of guides to paddlers decreases from 1:8 for sheltered water, 1:6 in moderate water to 1:4 in advanced water.

As is evident from Appendix 1, building sea kayak skills and progressing to become a leader and to take on coaching as a livelihood is a protracted process. Progressing between levels requires greater amounts of training (from 2 days instruction to 49 days guided learning) and assessment while skills have to be consolidated with lots of paddling in increasingly advanced “conditions” which is expected to take several years. Paddlers progressing through this training with Anglesey providers will therefore need to return frequently thus building up a relationship with coaches, their fellow students, accommodation and hospitality providers. This creates a dispersed community of sea kayakers who consider Anglesey and especially Holyhead their “home” waters. The BC awards are widely recognised around the world6 and aspirant coaches come from all over the world for training, mentoring and to build their experience of tide races while Anglesey guides travel abroad to deliver training. For advanced paddlers, the Stacks is the undisputed attraction and the sea kayak community based around Holyhead extends around the world. This in effect ‘exports’ sea kayaking skills and contributes to the promotion of Anglesey as a world-class active tourism destination.

As explained above, coaching and assessment for the BC awards are multi-day undertakings. The ten guide businesses who reported offering BC courses in 2019 delivered 1206 student days for moderate water (maximum of coach 1:6 students) and 560 student days for advanced water (maximum of coach 1:4 students). Around 85% of these courses are delivered as multi-day courses – mostly over a weekend (2 days) or a week (4-5 days). Students on these courses come from across the UK and as already seen in the paddler survey also from outside the UK. Just from our survey the list of visitors is long and includes: Netherlands, Norway, Sweden, USA, Spain, Italy, Argentina, Denmark, Germany, Hungary, Italy, Poland, Singapore, Finland and Switzerland.

6 e.g. Singapore Canoe Federation awards are closely modelled on the old British Canoe Union star awards http://scf.org.sg/disciplines/sub/personal-skills-star-award-course and Sea Kayaking Baja, Mexico https://seakayakbajamexico.com/kayak-courses/bcu/ https://seakayakbajamexico.com/kayak-courses/bcu/ and Maine, USA https://maineislandkayak.com/bcu-5-star-training/ just as examples

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Morlais Demonstration Zone and sea kayaking at The Stacks The survey of kayaking guides asked questions about the impact on the businesses responding if increased risk for sea kayaking were to be an outcome of the Morlais development. In response to the question “If a navigational risk assessment were to show that the tide races at North Stack, South Stack and Penrhyn Mawr were unsafe for sea kayaking after the installation of the proposed devices, would this have a significant adverse impact on your business?” only one respondent said ‘No’ and in response to the question “Would there be a knock on effect on your business if there were a reduction in local coaching and guiding businesses?” 12 replies said ‘Likely’ and 2 ‘Unlikely’. Both of these questions are open to interpretation but taken together there is a strong impression that the loss of the Stacks as a safe sea kayak venue would be keenly felt by the majority (~80%) of active businesses.

It is noteworthy that this questionnaire was distributed with very short notice and it is an indication of the strength of feeling about the need to protect the Stacks and their livelihoods that when the link was sent out to a mailing list of 25 contacts, 15 completed questionnaire were returned within three days.

Morlais approach to socio-economic impact assessment Morlais has produced a series of reports which include kayaking. These are the Supplementary Tourism and Recreation Assessment [MMC 132] and the Supplementary socio-economic assessment [MMC133] issued in March 2020. These were reviewed in the SCC Statement of Case. In September 2020 a further report Supplementary Kayaking and Sailing Activities Assessment was issued. This report adds very little data but outlines Morlais’ commitment to include the recreational boating economy in the monitoring and mitigation activities for socio-economic effects. The report suggests that key performance indicators should seek to capture changes in the number of participants and the activities they participate in resulting from changes in Holy Island’s offering as a location for kayaking and sailing activities. Measures for this are given as number of participants and “sentiment of marine recreation activities” which are to be acquired through interviews over the next two years (i.e. according to Morlais’ timetable after consenting and during construction) then annually for the following five years (i.e. during phase I when the scheme is small scale) then biennially (i.e. at lower intensity as the project grows larger). Negative impacts are to be identified by significant deviation from trends extrapolated from baseline which can be attributed to Morlais according to the judgement of Morlais and IoACC. If all these conditions can be met then Morlais is prepared to offer mitigation and has suggested actions to promote marine recreation in the area.

Good practice would suggest at least consultation with representatives of the kayak and sailing communities on the identification of suitable key performance indicators and measures to be monitored. The success of our online survey suggests that quantitative survey is feasible while records of courses held and awards made could be made available by BC and CW.

However, the main failing of this approach is that it is post-hoc with the identification of negative impacts after they have happened and livelihoods have been compromised and with only Morlais and IoACC to make this judgement. The mitigation offered is desultory and does not provide any meaningful compensation for lost or compromised livelihoods and lost revenues associated with any potential reduction in visits by kayakers.

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We reiterate that there is ample good practice in socio-economic assessment of marine recreation and established protocols with EIA to deal with compensation and resettlement of livelihoods. We suggest that Morlais look to adopt a more robust and participatory approach to a pre-construction baseline survey, cost-benefit analysis to inform consenting with robust monitoring reporting to a stakeholder forum and with timely mitigation and compensation plan.

Conclusions We have shown that sea kayaking is a significant active outdoor activity which supports a small, but well established and growing contribution to the recreation economy of Anglesey. Nevertheless, sea kayaking has been generally overlooked as a small component of overall outdoor recreation and tourism. This partially excuses the initial omission of kayaking from the Morlais EIA. However, Morlais’ assessment of the impact of the proposed development on recreational kayaking after our representation to the TWAO application remains inadequate and does not address our concerns.

We remain concerned that development of the MDZ as proposed by Menter Mon could compromise these business and revenues and this needs to be properly accounted for in the socio-economic appraisal of the project prior to consenting.

We consider that a full socio-economic study including cost-benefit analysis, scenario modelling, mitigation plan and resettlement plan if needed are required by the legislation and this has not been undertaken.

It is also important to note that any baseline study undertaken in 2020 and indeed 2021 will not represent normal conditions as there is considerably reduced use of the area because of the Covid- 19 restrictions. In addition, there is also a concern that the perception of future risk will impact on individuals or businesses considering starting or expanding sea kayak enterprises in Holyhead now because of the uncertainty and threat to their use of these waters. The report for instance proposes a base-line study post consenting, however if the base-line study and the impacts are only considered after the development is approved and goes ahead this could be too late to ensure that the recreational and business use of the area for sea kayaking is preserved. The mitigation includes proposals to install changing facilities at appropriate locations but this mitigation, while welcome, is dependent on there being a coastline which is perceived as safe for the businesses and their customers to navigate and to use for training.

The responses to our survey are based on known current use of the sea around the Stacks. The success of the Morlais development working together with the sea kayaking community will be dependent on the Navigational Risk Assessment being sufficiently detailed and appropriate to ensure that the area as used by kayakers is safe and unobstructed. Clearly there will be other matters that will impact on the use of the area by visiting kayaking including seascape and the access to a wild coast and wildlife encounters which will need to be considered but the safety issue will be paramount.

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Annex: British Canoeing sea kayak awards Personal performance Remit Training Sea kayak Sheltered Winds F3 Paddler works towards achievement of water Tides 1 knot graded skills with an award Provider Coastal sea kayak Winds F4 who would usually hold a coach award. Tide 2 knots Ratio of coach to paddler can be 1:8 in Advanced sea kayak Winds > F4 sheltered water (tides less than 2 Tides > 2 knots knots) Open crossings > 2 Nm Leader Sea conditions required for Required for award training/assessment Sea kayak leader Moderate water Coastal navigation and tidal planning course First Aid 2 day training course 2 day assessment Advanced sea kayak Advanced water Sea kayak leader award with 3 years’ leader experience 2 day training 2 day assessment Coach (regulated Sea conditions Required awards) Sea kayak coach Moderate or Advanced to suit Sea kayak leader / Advanced sea kayak + Moderate/ level of endorsement leader Advanced water Guided learning: 24 hours endorsement Total qualification time: 34 hours Performance sea Moderate or Advanced to suit Sea kayak coach / Advanced Sea kayak kayak coach level of endorsement coach + Moderate/ Guided learning: 49 hours Advanced water Total qualification time: 129 hours endorsement Postgraduate Full range of conditions 2-3 year programme with BC and coaching Diploma University of Stirling

Sea conditions recognised in British Canoeing sea kayak awards

Endorsement Sea conditions Moderate water Minimum sea state 3-4 or tidal flow creating similar conditions Tide 2 knots but not involving tide race or overfalls Wind not exceeding F4 Rocky coastline with landings at least every 1-2 miles Launching and landing through small surf (< 1 m) Ratio of leader/coach to paddlers 1:6 Advanced water Tidal areas with tide races, overfalls or open crossings which cannot be avoided Rocky coastline with landings or difficult landings Winds with periods of no less than F5 Launching and landing in surf (up to 1.5 metres trough to crest height). Ratio of leader/coach to paddlers 1:4

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