Buttington Quarry - ERF

Received 22 May 2021
From Paul Campion

Representation

Dear Planning Inspectorate

I wish to record my objections to the proposed incinerator/ ERF at Buttington Quarry in Trewern
Reference: DNS/3214813

My main points of objection to the above application are:
• The proposed incinerator has been born from completely the wrong premise
• There is no requirement for an incinerator in Powys
• The proposed site is in a small village community and an entirely inappropriate location for such a facility
• Inadequate pollution modelling by the promoter and an unnecessary risk to local air quality
• There is currently a moratorium in place, preventing planning permission being granted for new ERF’s in Wales

The proposed incinerator has been born from entirely the wrong premise. [***REDACTION***] Broad Energy Wales Limited was set up [***REDACT***] to develop the quarry site at Buttington into an ERF/ incinerator. It is understood that consideration to alternative sites was made only in late 2020, [***REDACT***].

Incinerators should be the result of a very carefully considered strategy/ solution to a specific waste problem. Decades ago, incinerators were seen as a great solution for dealing with waste. As waste strategies have developed through the years, incinerators are increasingly becoming a ‘last resort’ solution for dealing with waste.

The Buttington ERF has been promoted at the quarry purely as an alternative use of the land as a commercial venture. I have no issue with the owners of the quarry in procuring a venture to make use of their site. But it should be one that is consistent with the Local Development Plan and sympathetic to the surrounding community and environment. An incinerator in this instance is neither of those things and entirely the wrong thing to have in such close proximity to the local school and local housing.

As is evidenced by the very detailed assessment carried out by the Buttington Incinerator Impact Group (BiIG), the air pollution modelling carried out by Broad Energy does not adequately take account of the local, very unique, topography of the area. BiIG have made concerted efforts to provide a very detailed analysis (I refer you to the groups collective submission to the planning inspectorate), which shows that the plume of smoke from an incinerator in the quarry is most likely to travel over the adjacent school and village and across the neighbouring village of Middletown. Because of the unique hilly topography in the area, pollution from the incinerator could settle on these populated areas as well as the nearby countryside, including a site of special scientific interest.

It is imperative that the plume from any incinerator properly disperses. The potentially inadequate modelling carried out by Broad Energy suggests that they may not properly understand the risks of the complex landscape in which they wish to build their incinerator. I ask the inspectorate to please heavily challenge and interrogate this aspect of the application.

Another incinerator in Powys (and indeed Wales) will only harm the Welsh Government’s objectives for promoting the zero waste by 2050 philosophy. Incinerator’s only seek to encourage more waste because they need a constant feed of fuel, for the life cycle of the facility. Powys has taken massive strides to become one of the best counties not only in Wales but in the UK for recycling rates. It would be entirely counter-intuitive to bring a large-scale incinerator into that equation.

The incinerator has not been proposed to deal with just local waste. As per the applicants’ own data, and that provided by Powys local authority in their own consultation response, there is only a fraction of waste being generated in Powys when compared to the capacity of the proposed facility.

Because of the nature of how waste contracts work, the waste could potentially be coming from anywhere in the UK, unnecessarily increasing traffic on the road networks. If Broad Energy intend to source the majority of the waste from the West Midlands in England (as is stated in the application), then surely it would make far more sense for them to find a site that is in or closer to the West Midlands? An incinerator on the M6, M5 or M54 corridor would be much closer to the source of the waste, without impacting overly stretched single carriageway trunk roads such as the A458 and A483.

This also raises a question about the English and Welsh national waste strategies and how the respective governments liaise with each other on such matters. It is something that I know little about, but I hope that in the process of making a decision on the Buttington ERF, due diligence is carried out on how it may affect not only the Welsh waste strategy but also in England too.
I think it is fundamentally wrong that Wales should make decisions on how England’s waste is to be dealt with (and vice versa). In the case of the proposed Buttington Incinerator, this is exactly what would happen if permission was granted by the Welsh Government on a facility that plans to rely heavily on waste from across the border.

I am not suggesting that the nations should avoid collaborating on these matters, on the contrary, I believe it is imperative that they do. But I am pragmatic on the reality of these political decisions and I strongly believe that both nations and their governments should think hard about decisions that could adversely interfere with each other’s waste strategies.

I understand that to refine the Welsh Government’s latest strategy to achieve zero waste by 2050, there is to be a moratorium on the decision for any new incinerators/ ERF’s in Wales. I believe it is paramount that the Welsh Government develop a clear directive, during the moratorium on incinerators, on what quantity/ proportion of England’s waste they intend to allow to be imported into Wales and how much Incineration capacity they wish to therefore provide for England. My personal opinion is that it should be minimal (I accept that aiming for none is impractical) and done in a highly controlled way.

I trust that the moratorium is reason alone for the planning application for the Buttington ERF to be rejected. If any further augmentation was required in this specific case, I point to my earlier comments regarding the proposed incinerator being born from entirely the wrong premise.
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I would like to summarise my objection as follows:

• The requirement for any new incinerators/ ERF’s should be based on a cohesive, national strategy for dealing with waste generated in Wales. Any new incinerators should be located close to the source of waste to minimise impacts of transport and associated pollution. Wales should not build incinerators that will predominantly import waste (from England).

• The Welsh Government has declared a moratorium on the granting of planning permission for any new incinerators to allow time for the updated waste strategy to be detailed. It is therefore untenable for any new incinerators in Wales to be granted permission at this moment in time.

• When a strategy has been finalised, and if it is deemed that further incineration capacity in Wales is required, I believe it is highly unlikely that Buttington Quarry would be a suitable location for an Incinerator/ ERF, for the reasons stated above.

Yours sincerely
Paul Campion
Resident in Trewern, Welshpool.