Buttington Quarry - ERF

Received 23 May 2021
From Marion Hayes


Re: DNS/3214813 – Buttington Quarry ERF

I have neither the technical expertise nor the erudition of the Buttington Impact Incinerator Group (BIIG) but having read their document (your reference DNS/3214813-000110) I wish it to be known that I fully endorse their conclusions.

I have read the Applicant’s Non-Technical Summary and I wish to express my objection to this planning application.

Buttington Quarry is an inappropriate location for an ERF because:

1. The Welsh Government has placed a moratorium on any future large scale energy from waste developments (defined as a waste facility generating more than 10MW) as the increase in recycling and reduction in waste already seen means that we will not need any new large scale energy from waste infrastructure to deal with the residual waste generated in Wales. There is therefore no local, regional or national need to build this facility within Wales.

2. It disregards the “proximity principle” for waste management developments which states that waste should be dealt with as near to its source as possible. To source sufficient residual waste to efficiently feed the ERF the Applicant has twice extended the waste catchment area. The latter now stretches, in Wales from Anglesey to Pembrokeshire. It also includes Cheshire, Shropshire, the West Midlands and Herefordshire in England.

3. The alternative sites evaluated were all within Powys
I consider that alternative sites within the large catchment area should have been considered as there is no local need for this ERF to be situated within Powys.

4. It will have a negative impact on climate change
Burning residual waste, particularly plastics, in an incinerator produces more CO2 than burning coal. CO2 emitted from the ERF stack together with exhaust emissions from the numerous HGVs accessing/leaving the site during both the construction and operational life of the ERF will contribute towards climate change. The Welsh Government is committed to reducing CO2 emissions in order to meet climate change targets.

5. The proposed ERF will have major visual impact on the landscape
This ERF would be a large industrial building, operating 24 hours a day, with a 70m high stack sited amidst the open countryside of the Severn valley. The ERF building and stack is completely out of keeping with the surroundings and contrary to the rural character of the valley. The plume emanating from the top of the stack will catch the eye. The picture on the cover of the Applicant’s Public Consultation Document 14 Sept 2020-26 October 2020 illustrates this. There are no other tall structures in the picture!
Positioned near the English/Welsh border it will be unwelcoming to visitors coming into Wales by road and by train. The plume will be even more visible at night when it will be highlighted by an aircraft warning light.
Our rural environment sustains our local economy through agriculture and tourism. It is precious in its own right through all the life it supports and for the natural landscape we enjoy. The presence of an ERF will neither maintain nor enhance the environment which should be conserved for future residents and future visitors.

6. It will exacerbate highway safety issues
The A458 between Shrewsbury – Buttington Cross is single carriageway road in each direction. There are few opportunities to overtake. This is frustrating for both local residents and visitors. There are two narrow bridges, hidden dips and a level crossing on the route. In Summer slow moving farm traffic, numerous vehicles towing caravans and motorbike riders who frequently arrive in groups cause further road safety problems. I would suggest that the increase in HGV traffic associated with this ERF is avoidable by refusing the planning application.

7. It may cause the bioaccumulation of pollutants within the food chain
Having a background in biology I am very concerned that nothing is known about the long-term effects of the bioaccumulation of toxins emitted into the atmosphere by a waste incinerator sited in a rural location. This proposed ERF is in a very rural environment. The 48 existing incinerators in the UK are all urban, close to high density residential and commercial developments which produce the waste. An ERF at Buttington will be surrounded by farms growing crops for human consumption and animal fodder. Dairy and beef cattle graze the grassland, as do sheep. Free-range chickens produce meat and eggs. If agricultural land becomes contaminated by air pollutants we will not know how the food chain is impacted and how this will affect human health for many years. Future generation may be negatively impacted.

8. It will have a negative impact on local communities
Ever since I attended a drop in session held at the village hall, Middletown in July 2019 I have worried about the impact of this ERF on our lives. It will have a negative impact on the well-being of local communities.
a) I live in Middletown which, because of the hilly landscape, lies at the height of the top of the stack. The prevailing winds are from the west. How would the health of residents be affected by this development??
b) I am particularly concerned about air pollution. No air pollutions is safe. There can be no doubt that the air quality immediately around the ERF will be more polluted than would be the case if it wasn’t there.
c) Pollutants emitted from HGV exhausts are also health hazards.
d) The site is designed so that HGVs must reverse in order to tip their cargo of residual waste into a hopper. I know from personal experience how intrusive the sound of reversing alarms can be. This noise from 7am -7pm will be detrimental to the amenity of residents living close to the site.
e) The villages of Trewern and Middletown are bisected by the A458. Residents of both villages have to cross the A458 when using public transport. I have to cross-over the road to reach the church in Middletown, residents in the other half of the village have to cross the road to reach the Royal Mail postbox, the mobile library bus and the village pub. In Trewern families wishing to access the school from the Pentre Gwyn Estate have to cross the A458 and then walk adjacent to it along the pavement. These are frequently mothers with babies in prams and pedestrian toddlers. During the recent building of the Newtown by-pass I found the construction lorries very intimidating. It took longer for a gap in the traffic flow to occur so I could cross the road. Now we may once again face the noise and vibration of heavy construction traffic thundering past.
f) I look out of my kitchen window and sometimes see clouds drifting along the valley bottom. I think this is called atmospheric inversion. If the ERF is buiIt I will worry about what pollution is contained within and underneath the cloud.
g) The thriving primary school at Trewern is adjacent to the A458, close and downwind of the proposed ERF The children’s playground apparatus adjoins the road. The undeveloped lungs of young children are particularly vulnerable to key pollutants in exhaust fumes (NO2 & fine particulate matter) and similar pollutants from industrial processes. How will their health be affected?? If parents choose to withdraw their children from the school or not choose to enrol them because of air pollution fears, the school will suffer. A school is socially important to a village community.

[***REDACT***] After reading the possible Short Term & Long Term Health Impacts in the planning application (paragraphs 15.2.1 – 15.2.7 and paragraphs 15.3.1 – 15.3.6 respectively) [***REDACT***] Perceived adverse effects on physical health may negatively impact the mental health of local communities.

I object to the proposed ERF at Buttington Quarry. I have detailed my reasons and concerns. I hope that you recommend to Welsh Ministers that they reject this planning application.

Marion Hayes (Mrs)