Buttington Quarry - ERF

Received 23 May 2021
From Montgomeryshire Constituency Labour Party

Representation

RESPONSE TO THE PLANNING APPLICATION FOR THE PROPOSED BUTTINGTON INCINERATOR

On behalf of Montgomeryshire Constituency Labour Party (CLP)

OVERVIEW
Montgomeryshire Constituency Labour Party has kept an eye on the proposed Buttington Incinerator for a number of years and initially approached Broad Energy for a meeting, which was declined by the company who just pointed us at their website for information.

We have also taken an active interest in Waste Management in Wales, the plan for a Zero Waste Wales and in the issues around the management of the Llanidloes landfill site. We have met the Buttington Incinerator Impact Group and also taken advice from local experts in our Party. After examining the evidence, Montgomeryshire CLP took a position of opposition to the Incinerator.

We raised the issue with Labour Members of the Senedd and we also submitted changes to Welsh Labour Policy which resulted in the moratorium on large incinerators in Wales. Buttington is classed as a large incinerator.

We fully support the submission by the Buttington Incinerator Impact Group.

IN SUMMARY
We oppose the incinerator on the grounds that :-
• There is a moratorium on such incinerators in Wales
• That there is no local need being served
• That the proposal is in contravention of the Welsh Government’s policy goal of a Zero Carbon Wales as it will significantly increase the carbon footprint of Wales.
• Welsh Government is committed to a Clean Air Act in Wales to embed WHO guidance
• That the local road infrastructure will not support the additional traffic
• That the proposal is in contravention of the Welsh Government’s policy goal of a Zero Waste Wales

MORATORIUM
The Welsh Labour Manifesto commits Welsh Government to “enforce a moratorium on the consenting of all large incineration facilities in Wales.” In the Senedd legislation, large is defined as over 10MW. Please note that incinerators under 10MW can only take local waste – e.g. hospital incinerators. The associated Final Policy Document (2021), specifically mentions the proposed incinerator at Buttington.

We request that the Planning Inspectorate enact the Moratorium on Large Incinerators in Wales which went into law in March 2021 and reject this application.

LOCAL NEED
Powys County Council have already stated in their submission that there is not a local need for an incinerator.

We note that, due to past problems at the Llanidloes landfill site, the correction and stabilisation at the site will mean that at least the next 5 years of local landfill waste will be required on this site in order to stabilise it. This further reduces any local waste for an incinerator.

Labour has just been elected to form Welsh Government for another 5 years. Welsh Government is therefore committed to deliver its manifesto which will abolish the use of more commonly used single use plastics; further reducing the available local fuel for any incinerator.

We request that the Planning Inspectorate rejects this application on the grounds that there is no local need for it; which is the condition in Welsh Law for having an incinerator of less than 10MW.

ZERO CARBON WALES
Welsh Government is committed to a radical transition to a Zero Carbon Wales. Broad Energy’s planned incinerator at Buttington will significantly add to the carbon footprint of Wales. Waste to Energy has been shown to create more carbon than gas fired power stations. Some carbon calculators also place waste to energy in the same bracket as coal fired power stations in terms of their carbon footprint (e.g. Stamford University’s calculator). We also do not believe that the additional carbon footprint of the delivery vehicles is fully taken account of in Board Energy’s calculations for the plant.

[***REDACT***]

We request that the Planning Inspectorate rejects this application on the grounds that it is in contravention of Welsh Government policy to achieve a Zero Carbon Wales.

CLEAN AIR ACT
As can be seen in other submissions in this consultation, there are issues created by the exhaust plume from the incinerator which are complicated by the local geography. Due to the local microclimate, cloud hangs on the hills and it is likely that the particulates from incineration will also do this. The site is situated 0.6 miles from Trewern School,
thus creating the potential for associated long term damage to developing lungs.

Equally, because there is not a local need for the incinerator, it is clear that waste must be trucked in for as far afield as Worcestershire and Stoke-on-Trent. A journey time of 2 hours will allow the incinerator to take waste from much of central and Northern England. This will significantly add to road traffic and the resulting associated air pollution. Again, many of the additional 110 truck journeys a day from vehicles delivering to and leaving the incinerator will pass by the school at Trewern.

Welsh Government is committed to setting the highest standards of air quality into law in a Clean Air Act for Wales. This will be consistent with the advice and guidance from the World Health Organisation. The provision of air quality monitoring will be extended to ensure we eliminate pollution at source. Particular protection is planned for school environments.

We request that the Planning Inspectorate rejects this application on the grounds that the Buttington Incinerator will create additional air pollution [***REDACT***] which will be in contravention of the direction of travel of the Government.

ROAD TRANSPORT
The English authorities have currently pulled out of a scheme to improve the A458, road between Shrewsbury and Buttington / Welshpool. Since Broad Energy proposes that a great deal of the waste to feed the incinerator will come from England, all the transport delivering this waste will have to use the A458.

The incinerator site is on the A458 trunk Road. This is a single lane road which is heavily used particularly in the tourist season. There is a notorious accident black spot at Cefn Bridge within a few hundred yards of the site entrance.

We request that the Planning Inspectorate rejects this application on the grounds that the Buttington Incinerator will add a significant additional load of vehicles onto inappropriately designed roads with the likely additional risk to other road users.

ZERO WASTE WALES
Welsh Government is committed to achieving a Zero Waste Wales. This will build on the excellent recycling levels in Wales, fund Repaid and Reuse hubs in 80 towns and create a circular economy.

The proposals Board Energy have put forward for Buttington are an outdated solution to dealing with waste which has no place in this future vision. Incineration causes pollution and breaks the circular economy by destroying valuable resources which could be recycled now or in the future as technology advances. It also adds substantially to the carbon footprint of Wales around a tonne of carbon for every tonne of waste burnt. This figure does not include the carbon expended in bringing the waste to site. Incineration also disincentivises recycling.

We request that the Planning Inspectorate rejects this application on the grounds that the Buttington Incinerator is the wrong solution, does not fit into Welsh Government strategy for dealing with waste and adds to the carbon footprint of Wales.

The Buttington Incinerator is an outdated solution, supports no local need, has been proposed in the wrong location and is in completely contrary to Welsh Government policy. We therefore oppose this application in its entirety and ask that the Planning Inspectorate reject it.