Extended Relevant Representations.

Neath Port Talbot Country Borough Council considers that the project has the potential to have significant effects both positively and negatively upon this complex and highly dynamic coastal environment, as well as the associated communities, biodiversity and economic interests associated with it. As such, the Authority would wish to see the following relevant issues appraised through the examination process:

1) Coastal Processes and Biodiversity: These are extremely complex issues, with the project having the potential to impact directly and indirectly upon both the terrestrial and marine environments, as well as commercial and tourism economies of the area. Concerns remain about the potential uncertainties within the applicant’s submitted assessments, proposed monitoring and potential mitigation measures. Adverse impacts due to coastal processes could affect the navigable status of the River Neath through the potential requirement for addition dredging, erosion of sands from Aberavon, Port Talbot and Margam beaches, as well as the potential impacts upon the protected habitat areas of Crymlyn Burrows (SSSI) and Kenfig (SSSI, SAC and NNR).

2) Sewerage Outfall: We are concerned about the potential associated risks with the developer’s apparent preferred option to retain the sewerage outfall within the confines of the lagoon. Any failure of the proposed system would adversely impact upon water quality, but could also irreparably damage the reputation of Swansea Bay as a tourism destination. In addition such potential events would jeopardise the lagoons chances of becoming a regional resource for water sports, tourism and leisure activities as well as the proposed use of the area for shellfish farming.

3) Flood Risk: The project information has identified that there would be a potential increase in wave height associated with the lagoon walls. Briton Ferry has been identified by NRW as an area at risk from tidal flooding,

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Neath Port Talbot County Borough Council.

increased wave heights associated with the project would potential exacerbate this existing problem further. The potential scale and repercussion of this affect must be fully understood and assessed.

4) Cabling and Grid Connection: These are shown to pass along the existing Fabian Way corridor, within a constricted area already carrying significant fibre-optic cabling, which were recently added to by the Swansea University Campus development. Additionally, the proposal is for the cabling to cross through Crymlyn Burrows (SSSI). The applicant’s have identified that a 10m wide working corridor would be required and that access would have to be retained for maintenance and testing especially of the joint bays. The applicants have also identified that there is a potential option to run the proposed cabling within the existing former BP pipes which run beneath the River Neath. There does not appear to have been any assessment of the former use of these pipes, their current condition or potential contamination risks from pollution associated with the use of this facility. The potential impacts upon both the existing fibre-optic network, as well as the ecological and ground contamination issues associated with the proposed cabling to facilitate the grid connection need to be fully considered.

5) Highway Network: The Tidal Lagoon has the potential to become a significant tourism destination in its own right, hosting regional water associated events. The impact upon the highway network needs to be fully assessed over both the short term, associated with the construction phase and the long term impacts associated with its tourism draw. Detailed consideration should be given to the potential arrangement to accommodate visitor traffic during major events, when it has been indicated that the facility’s 300 space parking area could be potential closed to all, but participants.

6) Ground Contamination: The area has a long industrial history resulting in both known and unknown potential for ground contamination. The Authority has a duty to ensure the health of future users and construction workers is protected. While it is known that some significant remediation

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works have taken place, there are other areas which need further consideration, such as the use of the existing BP pipes to run the cabling across the River Neath, as well as the development’s impact upon previously remediated areas. It is understood that the dredging exercises within the bay to form the lagoon walls could potentially release pollution from the sediment, which may have a resultant impact upon water quality.

7) Socio-economic Impacts: Undoubtedly during the construction phase the development would have the potential to be a major economic generator. Issues associated with water quality, particularly in relation to the sewerage outfall could adversely impact upon the wider Swansea Bay reputation thereby adversely affecting the existing tourism economy of the area. Potential increases in sedimentation within the River Neath would result in an increased need for dredging on a more regular basis to maintain the current navigable channel and the business that it supports. While it is acknowledged that the lagoon would provide increased facilities for people to enjoy water sport activities within Swansea Bay, the lagoon’s size and location, plus its impact upon currents and water velocity could potentially have adverse impacts upon the amenity of those who already enjoy the use of this area, such as divers, angling and users of smaller sailing and water craft, may of who use the marina at Earlswood.

8) The Authority also has significant concerns about the potential risks associated with the failure of the project to complete construction and the unpredicted impacts that partial completion could have upon biodiversity, coastal processes, navigable waters, tourism and commercial economies and the visual amenity of the wider area. As the project will be one of the first of its type, together with the complexity and interrelationship between many of the potential impacts identified above, the financial failure of the project is possible great than that which would be associated with of the large scale infrastructure projects of this type. Therefore the Authority would like the examination to consider the possible merits of requiring a bond or insurance to ensure that appropriate measures are

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available to deal with any resultant impacts or development should the project or a significant contractor or funding source fail.

9) In addition to the above direct impacts, the Authority is concerned about a number of articles within the DCO, which require further examination. It is also noted and extremely disappointing to see that the developers are not proposing a community benefit fund which could seek to mitigate some of the potential adverse impact the proposed development would have upon the wider communities affected by the proposal.

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Neath Port Talbot County Borough Council.