Buttington Quarry - ERF

Received 04 May 2021
From Ian Thompson

Representation

I have previously submitted my comments but have not received acknowledgement. I therefore attach my personal comments once again.

Re Planning Application Ref. DNS/3214813
I wish to register my formal objection to the current Broad Energy planning application (ref DNS/3214813) on the following grounds:
- the proposed size/capacity of the facility is entirely disproportionate to any measure of local need. It is manifestly the case, based on published data, that the bulk of the waste to be incinerated would have to be sourced from beyond Powys (and indeed Wales). The catchment identified by the applicant incorporates a significant swathe of England, not least the West Midlands and Staffordshire. It thereby fails to satisfy key formal planning approval criteria that are based on “proximity” to the sources of waste.
- the facility as proposed would be visible for miles around and would have a significant visual impact on what is predominantly a rural landscape that is also promoted as “the gateway to Wales”. This point has been recognised in comments made by the Design Commission For Wales that are in the public domain following a meeting held with the applicant in July 2020.
- the valley between the Breidden Hills and the Long Mountain/Cefn Digoll creates its own micro-climate with frequent observable “temperature inversions” whereby cold air descending from the surrounding hills condensates and is trapped in the valley. Regardless of the height of the proposed stack, local experience is that emissions from the proposed incinerator would inevitably be driven down into the valley to the detriment of the village of Trewern with its primary school and the village settlements further to the east. There is therefore a significant concern in relation to public health.
- the key highway network that would be used by heavy vehicles accessing the proposed site is recognised as being over-stretched and in urgent need of significant up-grade. The proposed facility would increase the pressure on the existing road network to the further detriment of the village settlements through which the key trunk roads pass.
- recent published studies indicate that incineration plants are not “low-carbon” [***REDACT***] but rather are likely to produce one tonne of carbon for every tonne of waste incinerated, always depending on the mix of waste to be incinerated.

Furthermore, it is clear from nationally published data that the UK is in danger of incineration capacity exceeding available waste within the next 5-10 years with the clear implication that this will create a dependency on continued incineration to the detriment of increased recycling and the “circular economy”. This is in direct conflict with stated Welsh Government policy. Indeed the stated Welsh Government policy of placing a moratorium on any further large-scale incineration capacity should ensure that this application is rejected out of hand.

[***REDACT***]

I contend that for the reasons stated above that this application should be rejected.
Ian Thompson
4th May 2021