Buttington Quarry - ERF

Received 21 May 2021
From Paul Wixey

Representation

I find the Traffic Impact Assessment (TIA) in this application over simplistic and further fails to take account of local road conditions.

The low carbon energy claims cannot be supported by evidence.

The claimed employment generated by the operating of the plant cannot be substantiated.

TIA
The Applicant claims the development will require 50 Artic vehicle movements per day to provide the feed stock for the incinerator. At first glance this would imply just over 2 extra vehicles per hour in a 24 hour period.

This does not represent reality.

These will need to depart, therefore this is a total extra HGV vehicle movements of 28,600 per annum on the A458.

Their calculation relies on waste deliveries being spread over 5 ½ days per week. Waste is only collected 5 days per week so it is reasonable to conclude that it will only be delivered to the incinerator 5 days per week.
5 x 52 weeks per annum =260 delivery days
This gives us extra vehicle movements of 28,600/260 = 110 per day.
The nature of waste collection is that the collections are usually completed and the refuse collection vehicles (RCV) have been unloaded by 2pm. Broad Energy expect to draw waste from up to a 2 hour driving time from Buttington. This would imply locally generated waste such as Welshpool would start arriving on site about 2:30pm with the most distant vehicles arriving around 4pm. If we allow the vehicles to be on site for a maximum of one hour, this would have the effect of bunching the 110 vehicle movements into a 2 ½ hour window or 44 movements per hour between 2:30 and 5pm.
These movements would coincide with the local traffic peaks of school pick-up and end of working day rush hour and on a Monday joined by HGV traffic carrying animals from Welshpool Livestock Market.
This development is approximately a half mile from a new Industrial Estate (Offa’s Dyke) which is still expanding and will bring further HGV movements in the area.
The development is located approximately halfway between two pinch points on the A458 – Buttington Cross Bridge and Buttington Railway Bridge. Buttington Cross Bridge over the River Severn is not easily passable by two HGVs travelling in opposite directions simultaneously and is frequently hit by HGVs causing local delays. Buttington Railway Bridge already has a 20MPH speed limit on it due to the small radius of the bends on the approach roads and is similarly damaged on a regular basis, the last incident included traffic light controlled single lane working for 6 months with associated tailbacks.
In this area there is also Buttington Railway Level Crossing. Transport for Wales’ plans for the future include an increase in the frequency of services on this line raising the crossing closure to road traffic to twice per hour.
Highways England have recently pulled out of the joint Wales/England plan to improve the A458 between Welshpool and Shrewsbury and the project to improve the road has been put on hold.
From a purely traffic point of view this is a development in the completely wrong place.
LOW CARBON
The Transport and Road Research Laboratories have calculated that a single articulated Euro V engined lorry produces an average 424g of CO2 per kilometre. So, 110 vehicles each day travelling the 1km in either direction to or from the incinerator would generate 93.28 Kg of CO2 in the 2 ½ hour period in the local atmosphere. This generated whilst passing a primary school where the young children’s lungs are still developing.
On a 2 hour journey to the incinerator a single HGV would emit approximately 54.72Kg of CO2 (or 3.648 Kg per tonne of waste delivered). If we assume an average journey time of 1 hour to the site for all HGVs delivering waste there this would total 110 vehicles x 60km x 0.424Kg/km x 260 days = 727.584 tonnes of CO2 per annum.
Bernt Johnke1, in a paper for the Intergovernmental Panel on Climate Change, identified in 1998 that for every tonne of municipal waste incinerated 0.7 to 1.2 tonnes of CO2 is released to atmosphere. And the typical municipal waste incinerator electricity generation only plants were about 25-27% efficient, this puts municipal waste incinerators in the same ballpark as coal fired power stations for CO2 emissions per Kwh of electricity generated. By the time the transport CO2 emissions are added his is not low carbon waste disposal.
The total CO2 produced by Buttington ERF would be in the region of 200,000 tonnes per annum compared with Ratcliffe on Soar coal powered power station which emits 61,436 tonnes of CO2 for 13MW output. (Ratcliffe figures from ‘campaign to close Ratcliffe power station’.)

EMPLOYMENT STATISTICS: OVERSTATEMENT OF FUTURE EMPLOYMENT PROSPECTS
As a comparator Nottingham Eastcroft Municipal Waste Incinerator is about twice the capacity of the proposed Buttington Plant. It accepts waste direct from the RCVs rather than transfer to larger vehicles for delivery so probably handles nearly three as many vehicles per day. As well as electricity generation it feeds heat into a district heating scheme supplying some 2,500 homes. It was built in the early 1970s. It employs 40 full time staff.
I do not believe that a modern incinerator with much greater automation will provide 30 full time jobs. It would be closer to 17, viz., 1 manager, one administrator, 3 day technicians, 3 day plant operatives, 3 night supervisors, 3 night technicians and a 3 semi-skilled operatives (on a 12hr shift pattern).
I object to this proposal as it is in the wrong place and provides none of the benefits claimed in the planning application.

1. EMISSIONS FROM WASTE INCINERATION This paper was written by Mr. Bernt Johnke (Germany) and reviewed by Robert Hoppaus (IPCC/OECD/IEA), Eugene Lee (US), Bill Irving (USEPA), T. Martinsen (IPCC/OECD/IEA), and K. Mareckova (IPCC/OECD/IEA).