Buttington Quarry - ERF

Received 19 May 2021
From Christine Anne Ashton

Representation

Large scale incinerators such as the one proposed, should be located in areas which produce the waste, with good road access e.g. at a motorway junction on an industrial estate, on flat land, away from residential areas. This Quarry location fulfils none of those criteria.

Thousands of miles of unnecessary HGV transport will be clocked up in transporting waste from distant areas (generating additional PMs and CO2 emissions). Only 20,000 tonnes (max) of the 167,000 per annum proposed, is produced in Powys.

The area’s road quality and network are totally unsuitable for 100 extra lorries per week. There are extensive traffic jams in the tourist season and several traffic accident ‘black spots’. The Cefn Bridge is regularly damaged and limited to one-lane traffic. That will happen even more often.

The A458 is the Gateway to Wales – for tourism and fresh air. This industrial development will be an eyesore and detract from several businesses currently gaining from tourism in the scenic local area.

The extra jobs envisaged in Broad Energy’s application will largely be temporary. It will be difficult to accommodate 300 itinerant workers. The permanent jobs to follow will be more specialised and are likely to be filled by people from outside the area. There are far more cost-effective ways of providing employment than this capital-intensive proposal.

The landscape is so complex that the flue cannot do the job it is designed to do: the fumes will ground on the surrounding slopes of The Breidden Hills SSSI, camping & caravan sites, housing areas at Trewern and Middletown, Trewern School, and farmland. This has been confirmed in independent modelling. The shape of the landscape i.e. the high relief and the valley funnelling the South West winds along it, ensures that these areas will get a continuous stream of pollution. Just look at the climate statistics and the shape of the land. In contrast the Shrewsbury incinerator discharges over flat land to the north away from the city.

In anticyclonic weather conditions, the frequent temperature inversions will concentrate polluted air which drains into the depression at Trewern. Also, people who live at altitude observe that the inversion boundary can be at over AOD 200m i.e. overwhelming the proposed flue. The modelling of plume behaviour by ECL should not be accepted as it stands. The unique geography and microclimate has not been satisfactorily accounted for.

Wales has a commitment to protect future generations. This incinerator will pollute the local population – and the school – with toxic heavy metals such as CrVI – where there is no safe limit on WHO standards. Microparticles (PM2.5 and even smaller) are known to cross boundaries within the body and cause long term damage. Professor Mary Philipps-Jones comments: ‘Based on more recent WHO guidelines, PM2.5 and SO2 concentrations should also be urgently re-assessed, especially as (1) little analysis of the effects of 24 hour exposure to PM2.5 was undertaken by BE, and (2) using updated WHO guidelines, annual exposure limits are now exceeded.’

Even though the modelling appears to comply with current ‘environmental standards’ this is no guarantee that the emissions are safe for people who are exposed to them all the time, for many years to come. Patterns of disease indicate higher rates of ill health down wind of incinerators e.g. ‘Health Effects due to Emissions from Energy from Waste Plant in London’ [commissioned by the Greater London Authority, 2020].

Wales has a long-term reduce, recycle, re-use policy. Refuse should be managed where it is produced. The Zero Carbon Wales policy means that our recycling rates - already in the top 5 in the world – will be improved still further. What is the point of importing refuse into Wales when it should be better managed at source?

Incineration produces at least 1 tonne of CO2 per tonne of refuse (2 tonnes in the case of hard plastics). We need to reduce GHG emissions. Broad Energy’s claim for ‘low carbon’ energy cannot be substantiated by national carbon intensity figures around 220g CO2 per kWh compared with 509 for ERFs (figures from Zero Waste Scotland Technical Report, 2018).

Nor does incineration necessarily save on methane emissions. The Zero Waste Scotland report concludes that well-managed landfill sites emit lower equivalent GHG than ERFs. Separating food waste in Wales ensures that is the case, and well managed landfills are capped to store and utilise methane.

Alternative lower temperature technologies are being developed to recycle mixed plastics. This could make much incineration redundant. Also, on Defra figures, incinerator capacity (on current figures) will be over-subscribed by 2026. Within the UK, we do not need more capacity for incineration whilst recycling rates are being improved.
This application is not viable.

Christine Ashton 19.05.2021