Buttington Quarry - ERF
From Helen Hayes
I am writing to register my objection to this planning application which I consider contravenes national and local planning policies as well as the Well-being of Future Generations (Wales) Act 2015 (the Act).
As you will be well aware the Planning Inspectorate has an obligation to think about people now and in the future when a recommendation is made to Welsh Ministers regarding this planning application.
In my opinion the proposed ERF at Buttington Quarry contravenes aims cited in both the Act and our local plan ie Towards 2040 - the Powys Wellbeing Plan (published 2018).
1. Wellbeing goal: A globally responsible Wales
• Burning residual waste 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;
• Incineration of residual waste is only one level above land-fill in the waste hierarchy;
• Wales has an excellent record on recycling, something of which we should all be proud. However, there is undoubtedly more to be done. However, the availability of incineration facilities is known to dis-incentivise recycling;
• Whilst the ERF would generate heat, there are no existing facilities to use this. No future end users have been identified. The Applicant has a “vision” that generated heat can be utilised in the future, but this is uncertain. It would be more appropriate to locate this ERF where the heat produced can be used immediately.
• The Welsh Government published a new waste strategy in March 2021 (Beyond Recycling) placing a moratorium on any future large scale energy from waste developments 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. This proposal is in direct contravention of this published strategy.
The building in Wales of a such a large scale ERF that is not needed, which will contribute to climate change and which produces heat that is not utilised, directly contravenes the Act’s wellbeing goal of a globally responsible Wales.
2. Wellbeing goal: a prosperous Wales
• Tourism contributes £720million in income per annum;
• The proposed ERF is situated on the A458, a road which in summer months is used by thousands of holidaymakers to access Wales from the West Midlands and beyond. It will be a large industrial facility, operating 24 hours a day, at a key gateway to Wales. A large scale ERF is unsympathetic to the character, and contrary to the aesthetics, of a rural valley. It is not welcoming to visitors seeking to experience Wales’ beautiful countryside.
• Both the construction phase (lasting 3 years) and the operational phase (in excess of 30 years) will increase Heavy Goods Vehicle movements along the A458 between Shrewsbury-Buttington Cross. On its website, the Welsh Government states that for 9km between Buttington Cross and Wollaston Cross (in Shropshire) the A458 is not up to standard. Buttington Quarry is sited within this 9km substandard section.
• An increase in HGV traffic will make existing highway problems worse;
• Existing transport links will be adversely affected;
• The Applicant predicts 30 jobs will be created when the ERF is operational. The facility will operate 24 hours a day so this equates to 10 jobs per “standard” eight-hour working day. The creation of any new jobs is to be welcomed within a rural area. However, I suggest that more jobs would be created if waste was managed higher up the waste hierarchy.
• Mid-Wales is heavily reliant on tourism. Were the proposal to have a significant negative impact on the experience of visitors, there may be more jobs lost from within the local economy than would be created by this proposal.
An ERF will have a negative impact on the rural landscape. Increased HGV numbers on the A458 will have an adverse effect on traffic flow to and from Powys. Tourist numbers may fall. These are factors that will have a detrimental effect on the local economy and thus conflict with the Act’s well-being goal of a prosperous Wales.
3. Wellbeing goal: A resilient Wales
• An ERF neither maintains nor enhances the natural environment which is rural;
• The quality of this natural environment sustains the local economy through a vibrant agricultural sector and through tourism, but it is also precious in its own right through the valuable ecosystems it supports and for the natural landscape we enjoy;
• We need to conserve, protect and enhance the environment for future residents and future visitors.
The proposed ERF therefore conflicts with the well-being goal of a resilient Wales.
4. Wellbeing goal: A Healthier Wales
• Emissions will emanate from the ERF stack and from the exhausts of HGVs accessing/leaving the site. Air pollution is a major issue of public health concern.
• No air pollution is safe. UK targets are less stringent than levels recommended by the World Health Organisation, contributing to deaths.
• I would suggest that the potential air pollution impacts are of particular relevant concern in the case of this proposal, which is located very close to (and will therefore impact on) a busy and vibrant primary school.
• In addition to adverse impacts of air pollution on physical health, mental wellbeing must also be considered. If this ERF is built the perceived adverse effects on physical health will negatively impact the mental health of local communities. Emotional health is as important to wellbeing as physical health.
Air pollution is a major issue of public health concern. The proposed ERF may therefore have significant health implications for future generations. People’s mental well-being will not be maximised because perceived air pollution levels can be just as detrimental to health as factual levels. The proposed ERF therefore conflicts with the well-being goal of a healthier Wales.
5. Wellbeing goal: A Wales of cohesive communities
• The A458 bisects the villages of Trewern and Middletown.
• The A483 bisects the villages of Llanymynech and Pant.
• Any increase in traffic flow will negatively impact the ability of local residents to cross the busy roads. In Trewern & Middletown residents have to do this in order to access facilities such as public transport, the Royal Mail postbox, the pub, the school, the church and to connect with friends.
• The waiting time to safely cross will be increased and more vulnerable residents (the young and the elderly) may find HGVs going past intimidating.
• Residents may therefore feel disconnected from their friends, other residents and key services.
• Pedestrian delay [ ***REDACT***]is not conducive to cohesion within our communities.
• The ability to get around EASILY and SAFELY, underpins the 2040 Powys vision.
• Trewern has a thriving primary school which is situated just south of the proposed ERF. If parents choose to withdraw their children from the school, or not enrol them in the first place, because of air pollution fears, this will negatively impact social cohesion within the village.
The proposed ERF therefore conflicts with the well-being goal of a Wales of cohesive communities.
I object to the proposed ERF at Buttington Quarry because I consider that:
• it is sited at an inappropriate location;
• it contravenes 5 well-being goals as defined in the Well-being of Future Generations (Wales) Act 2015;
• it works against the local objectives of the Powys Well-being Plan;
• whilst it has the potential to create a limited number of jobs, this benefit does not outweigh the adverse impacts which I have detailed.
I ask you to recommend to Welsh Ministers that planning permission is refused.