Mor Hafren: Energy Recovery Facility

Received 26 November 2020
From Stephen Doughty MP


Dear Sir/Madam

Objection to Planning Application
Reference: DNS/3236340
Developer: Môr Hafren Bio Power

I would be grateful if you could consider my objection in the strongest possible terms to the proposal from Môr Hafren Bio Power to build a waste incinerator in the Wentloog area adjacent to Trowbridge / St Mellons and Rumney. I concur entirely with the objections made by hundreds of local residents, and other elected representatives including our local Councillors.

I objected to the previous application and would appreciate if my previous objection reasons could be taken into full consideration again, in addition to the points below.

Since that time I have heard from a great number of constituents across the East of Cardiff, raising continued concerns, which I fully endorse.

Over-arching these specific concerns, I contend that the development, using out-dated technology and locking in significant carbon emissions and other pollutants, is entirely incompatible with the Well-Being of Future Generations Act 2015, the commitments of the Welsh and UK Governments under the Paris Climate Change Agreement, and directly undermines the One Planet Cardiff strategy of Cardiff Council.

Specific additional concerns include:

• The proposed increase in HGV traffic and associated emissions near to a residential area and multiple schools.
• The fact that the local area already has two similar facilities - at Barry, and Splott and others located across the Severn, with proposal for a Biomass plant in addition in Splott.
• Given significant concerns about both climate emissions and local air quality - so many facilities being located in close geographical proximity cannot be justified.
• Mor Hafren state that they have contracts with companies to take the waste that they will burn in this facility and that it will be sourced locally. To my knowledge - they still refuse to name the customers and more alarmingly the type and nature and origins of the waste streams. In view of the fact that Mor Hafren seem to not want to disclose the makeup of the waste streams, due diligence and caution again needs to be exercised.
• When I personally spoke to Mor Hafren representatives - one admitted to me that they would not want this facility near their homes - I don't see why my residents should have to put up with it either
• Mor Hafren have deliberately sought to downplay community concern throughout the process with a series of highly flawed consultations which they were forced to amend and extend after criticism. As one resident tells me "The leaflet was inside a Domino's Pizza menu and put through their letter box with other "Junk mail/flyer items". This initial leaflet did not suggest or even use the word Incinerator or burning of waste."
• The proposed size and design of the facility is completely out of keeping with the local area, will ruin views for local residents towards the Severn Estuary and dominate the skyline in a largely residential and low-rise area, known as the "levels" for that reason. This facility will be more than 3 times larger and substantially higher than the nearest building - the Aldi Distribution Centre.
• The area is an SSSI and it seems utterly absurd to propose locating such a facility with the related air and water pollution risks that accompany it
• There is significant overcapacity in the incineration market, and with Wales performing so strongly on its recycling targets - it is likely waste would need to be imported from beyond the local area, including England - increasing emissions and local air pollution
• The existing 42 incinerators in the UK generate over 11 million tonnes of CO2 - given the impending climate crisis and the declaration of a climate emergency by the Welsh Government on 29 April 2019 - it cannot be compatible to build another of these facilities in Wales, not least as it would block the carbon neutral by 2030 pledge by producing roughly the same amount of CO2 as roughly 12,000 cars driving from Cardiff to London every Day (650 tonnes of CO2 every day)
• The developers will not have to report, capture/filter or pay for any of the CO2/Carbon that they release through the burning process - it has been estimated it will produce more than 200,000 tonnes of CO2 every year.
• Projections of the smoke plume from the chimney, based on attributes such as local weather data, smoke composition and terrain (sourced from Plume-Plotter) show nitrous oxide at ground level and indicates a 30% increase to surrounding areas given the combined impact of the CF3 and Splott incinerators - and is likely to cause a significant detriment to health in the community.
• The health assessment produced is also rather worrying for families with infants and shows that this incinerator will produce 32% of “weekly tolerable daily intake” for infants from exposure to Dioxins and PCBs).
• Not least in the current Covid-19 pandemic which thrives in weak respiratory systems - this cannot be justified on health grounds alone.
• Flood risk - we are all too aware of the increase in instances of flooding due to climate change. Such a facility will not only contribute negatively to the climate change that is behind recent flooding events, but in building on such a site removes absorbent grounds for increased precipitation in an area that is already at significant risk of coastal flooding. Concreting and tarmacing the site will mean more water run-off. Additionally, constituents fear this would increase contaminants in the reen network, thus causing further damage to the wildlife inhabitants there.

I furthermore agree with the Chairs of the Senedd Health and Environment Committees that there should be a wider moratorium on building these facilities, which further lock us into outdated and unsustainable technology for decades.

Yours sincerely

Stephen Doughty MP
Cardiff South and Penarth