Mor Hafren: Energy Recovery Facility

Received 27 November 2020
From Mrs K O'Shea


Objection to Mor Hafren: Energy Recovery Facility
Planning Inspectorate Reference: DNS/3236340

I wish to object very strongly to the planning application for Mor Hafren to build an incinerator at Wentlooge, Cardiff.

These are some of the reasons why.

I have tried to group my objections by category, which in some cases overlap, however what is clear is that in every instance, the moral argument for refusing the application is enormous.

Where I, my family and many other families live in St Mellons, we are often bothered by bad odours and noise, by day and night from the various commercial activities which occur on the flat area to the south and east of St Mellons, Wentlooge and Trowbridge.

These activities are neither conducive to good sleep, clean healthy air to breathe, or good mental wellbeing. The traffic created increases danger to local people and gives rise to increased pollution and the dirt and dust is unsightly and drags the area down in a visual sense.

The Wentlooge levels, the westernmost part of the Gwent levels, where the proposed site is located plays host to a Site of Special Scientific Interest and the characteristic flatness of the natural area, completely unspoiled by development provides a safe and relatively clean habitat for many species of bird, in particular water birds, mammals, insect, flora and fauna, plus many reptiles and fish in the ancient Roman reens.

The special area of landscape which forms the Wentlooge Levels between Cardiff and Newport is rare in its occurrence in Wales and the wider UK and should be credited with greater value and protected by those in whom the power is vested to do so.
I cannot sit back and say nothing against such a significant proposed development.

It is in our gift to stop such needless development of special sites when there are so many heavily derelict former industrial sites elsewhere (from former steel-working, mining, landfill or even power stations) ripe with opportunities for redevelopment to more valuable use. Alternative, environmentally non-sensitive locations should be considered well ahead of special areas of landscape such as those on and close to SSSIs.


The Gwent Levels are recognised “as a Landscape of Outstanding Historic Interest” by Newport for example it is LDP. Since Welsh Government is committed to improving and enhancing SSSIs, I would be really shocked and saddened if it does not share this view and choose to protect such special and valuable unspoilt areas of wilderness.

The area provides a natural habitat for a plethora of insect and bird life, water creatures living in the reens and small mammals, not to mention the birds of prey which feed in the area, and should be preserved, maintained and afforded the special protection it deserves for the benefit of future generations – of not just humans but many species of wildlife.

SSSI and Special landscape area designations apply to the Wentlooge Levels. CADW have categorised the Gwent Levels as a Registered Landscape of Outstanding and of Special Interest in Wales being “a landscape of extraordinarily diverse environmental and archaeological potential” and “a supreme example of a hand crafted landscape”. It states the Levels are therefore an uniquely rich archaeological and historic resource in Wales, and certainly of international importance and significance”. The Levels have an outstanding rating in numerous classifications on the LANDMAP system.

We regularly see many beautiful goose flights over my home in this part of the levels – using their avian mapping to navigate their way to warmer climes on their migration routes. It is greatly concerning that a building so massive would significantly alter the aerial landscape where these waterbirds fly will have a negative impact on migration routes, of geese and many other kinds of birds including swans, shelduck, lapwing, and other birds. Being very close to the Severn Estuary Ramsar site which is globally important for waterbirds, it is likely that the land currently plays a vital role in the estuary’s birdlife, so such a dramatic alteration to it would inevitably impact on international avian populations.

The negative impact of such an enormous structure on this flat area would be very significant to humans and to wildlife alike.
Such a structure in this area of special marshland, which is rare in the UK, and should be cherished, not built upon, is out of keeping and inappropriate.

To build the incinerator in this location would cause additional danger to wildlife from vehicles, increased dust particles on and in surrounding grasslands and waterways which provide delicate ecosystems and habitats for wildlife and increased air pollution from emissions. Many of these species are in decline and even small disruptions to their habitats can have a devastating effect on their populations.

The native grasses, and site specific flora and fauna which is complex and delicate, unique to marshlands would be harmed by the increased pollution from the site inevitably altering the structure of the soil beneath, preventing these species from flourishing on the site, thereby altering negatively the ecosystem of the land for insects and small water and land dwelling creatures.
This alteration to the soil’s structure would compact the land impacting on the ground’s sponge-like properties which make it such a vital flood preventing asset to the area. The land could never be returned to having the properties it currently possesses.
Building such a development here would in itself reduce the growth of populations of threatened species, but actually cause their rapid decline. By giving such an application the green light, it would also be likely to lead to further development nearby, of an industrial nature, further eroding the environmental quality of the area and exacerbate this issue.

Archaeological/Historical/(and again, moral!)

The special archaeological value includes ancient forests and other treasures and artefacts of huge historic value buried beneath the soft peaty earth; not to mention the ancient drainage ditches dug in Roman times, many of which survive, to this day. As was the intention when SSSI status was granted to the Wentlooge Levels, this area should be left undisturbed, save for sensitive agriculture.

What is the point in designating areas as SSSI if we are not prepared to fulfil our public and statutory duty to uphold that designation and protect them for the reasons the land was deemed SSSI in the first place – ie of archaeological interest and its unique and special environmental characteristics?

Were this proposal to be allowed to proceed, even if the project’s lifespan were to be “temporary” –over 25-40 years, its massive scale on such a sensitive area would have had a significant detrimental effect, likely to be irreversible for many species of birds, insects, water creatures and mammals, which may never return to the site, e.g. shrill carder bee, lapwing, and hazel dormouse – all of which are rare and at risk and must be protected to help prevent their journey towards extinction.

By approving such a development so close to such a natural beautiful landscape, its character would be significantly altered. Such major alteration over several generations’ memory (the lifetime of the plant), that the most likely next step would be that it would be developed by an even dirtier industry, if that is in fact possible! In this regard, the special landscape which goes to make up the formation of SSSIs in the area would have disappeared forever.

Contribution to Increased Risk of Flooding

It is well known and documented that flooding is a problem in this area, since it is so flat and so near to sea level. This has been an issue which the Romans resolved very cleverly by digging reens to drain the peaty soil so that the land could be sensitively farmed. Sensitive farming does not equal large scale development – not for waste processing sites, solar farms, business parks or railway stations! The reens manage ordinary rainfall fairly well, but struggle in a deluge and occasional flooding occurs.
This would be massively exacerbated by any large-scale industrial development of the land, at a time when rainfall is increasing and extremes in weather are more frequent. I would worry for not just the homes of people in the area, but also for animals which inhabit the land too. An additional worry would be the stored waste on the land, and how such materials could irrevocably pollute the sensitive landscape and habitats were they to become overwhelmed by floodwater causing any kind of seepage of toxic chemicals or acids. It seems reasonable that a risk of fire or explosion could also be posed by major flooding.

Amenity and Character of the Area

That which is harmful to wildlife is also harmful to humans. Currently the levels are enjoyed by many for the leisure amenity they provide. This would be dramatically eroded by the industrial blight of the landscape.

By changing so significantly the character of the area, such a development would set a precedent for other development across this special landscape, possibly of an even more harmful nature, that would be the thin end of the wedge for the total eradication of this very special unspoilt landscape, which perhaps appears invisible to many due to its relative flatness.

Due however to the unusual and peaceful nature of the land, it is a rural amenity enjoyed by many people seeking active pursuits, like cycling, running, horse-riding, walking, as well as watching and photographing birds, yet such a massive change to the landscape by an uncharacteristic solar farm with its associated tall high-security perimeter fences, locked gates, and large shipping-container-size power storage facilities would create an unwelcome blight on the countryside and the character of the land.

Inappropriate Location

Although the planned development is on a brownfield site, north of Newlands Road and to the south of the Cardiff / Newport railway line – shown on the developer’s map, next to Pinewood Studios and near to several local schools, housing and within the Gwent Levels Site of Special Scientific Interest – this does not make it acceptable.

It is not appropriate to site an incinerator to burn 200,000 tonnes per year of non-recycled waste in such close proximity to the Gwent Levels, an SSSI, such large areas of population and on such a flat historical, and environmentally special area, so close to highly populated areas where there is an area of multiple deprivation. There is nothing right about this location or this application.
Even if in every other way permissible, it is morally wrong to build such a structure, housing such an activity on the Gwent Levels and in such close proximity to an SSSI. This SSSI is one of Wales’ most special natural sites and is normally afforded legal protection. Just because Natural Resources Wales admitted to having no strategy for monitoring or maintaining them, it doesn’t mean we should allow them to be destroyed by development projects, instead, we should tighten our grip on proper monitoring and develop a strategy for long term protection and maintenance.

Visual Impact

This very large industrial building for storage and treatment of waste, with its 70 metre tall chimney and an almost 50 metre tall discharge vent (nearly 2metres wide) is so huge, it would be visible for literally miles around – up and over the hills towards Michaelston-y-Fedw to the north east and right across the Severn Estuary, probably even from Clevedon, Weston-super-Mare and Portishead. This chimney and building would be clearly visible from the Wales coastal path and would detract significantly from the unspoilt landscape in the levels.

The characteristic flatness of this part of the celebrated and in part legally protected Gwent Levels would be ruined forever by a development of such excessive and massive scale. It is simply not appropriate for this very special historic natural landscape. Its appearance is in no way in keeping with the Gwent Levels SSSI.


Odours and the quality of the air we breathe is already cause for concern as is evidenced by the many people who complain about them on social media sites in the St Mellons, Trowbridge and Rumney areas, but it is significant in the north eastern part of St Mellons, where the land is higher, since the wind direction causes odours and emissions to flow in this direction.
It is alarming that further odours would be discharged from the plant at a rate of more than 111,000 odour units per second, at a concentration of 2,500 odour units per cubic metre.

Whilst it is acknowledged that the areas most affected by odours would be in and around: Newlands Road, Newton Road, Valley View, Brynbala Way, Trowbridge, Shire Newton, Wentloog Road, despite a tall chimney, because of wind direction, the 'plume' from the incinerator would blow in an easterly and north easterly direction, carrying it over Hendre Lake and beyond to parts of St Mellons and Trowbridge (as shownn on a map in the developer's planning application). This would impact on many, many more families than are currently aware they would be affected, since we know from experience that the odours of existing lower level activities already reach us.

Furthermore, the activities involving moving the material to, from and around the site also produce odour, so those living, working and commuting near roads leading to and from the site would also be adversely impacted.
I note that odour levels would increase during periods of planned maintenance when the plant would shut down, and yet deliveries would continue, meaning more waste would be stored on site, and unacceptably, the unbelievable 175 times every year that the plant is allowed to exceed permitted odour emission limits!

Air Quality/Co2

UKWIN say the plant, if built could emit 105,000 tonnes of CO2 per year. The lack of restriction on CO2 emissions from the site, is worrying since Cardiff has declared a Carbon emergency because of the large amounts of CO2 already in the environment.
Air quality would suffer further, from vehicle emissions, from the activities on the site itself and from the plume, which could affect people's health, and impact detrimentally on the wildlife in the area. The report mentions Cadmium, Carbon Monoxide, Hydrogen Chloride, Hydrogen Fluoride, Mercury, Nitrogen Dioxide, Oxides of Nitrogen, Lead, Sulphur Dioxide, Thallium.

No “Need”

Despite the developers claim that the plant would contribute 15Mw of electricity to the national grid, this is not needed. Also, the plant would generate more CO2 than a coal or gas fired station producing similar amounts of electricity.
There is little evidence to support the local availability of suitable waste for this incinerator, suggesting that ultimately, waste would be brought in from much further afield for burning.

Traffic and Noise

Since it would be anticipated that every day, 42 heavy lorries would bring odorous waste to the site, about 200,000 tonnes each year from local waste management activities and those same 42 vehicles would then leave every day too, this is a significant vehicular increase on local roads, and those further afield from where the waste is brought. This dangerous toxic waste being taken to be dumped would cause a significant concern on local and regional roads. Adding to air pollution caused by the lorries’s emissions, would be exhaust fumes from another 18 cars arriving and leaving daily.

There would be a significant increase in (largely heavy, noisy, slow moving) traffic on already congested local roads leading to and from the site. 120 two-way vehicle movements every day (60 inbound, 60 outbound (18 light vehicles (cars and vans) and 42 heavy lorries (3.5+ tonnes) along Wentloog Avenue and Newlands Road. It would increase danger to other vehicle occupants and pedestrians; congestion on already clogged up roads; air pollution from emissions; dirt to roads, pavements, and nearby buildings, and open spaces; noise pollution from the sound of hydraulic air brakes; and light pollution from headlights. It would also produce major wear and tear on roads that are frankly worn out!

Although deliveries would be during daytime hours, tipping, craning and shredding waste would generate significant levels of noise.

If an argument as to why this waste would need to be transported by road rather than the very nearby freightliner had been made, it was not apparent.

Danger/Safety Risk

If there can be an explosion and fire at a highly regulated steelworks as occurred recently, and others at storage depots in East Cardiff and further afield, also in the last 12 months, there can surely be one at a plant where 3-4 days worth of waste would be stored on site, facilitating the plant’s 24 hours, 7 days a week operation, especially when temperatures of 850 degrees C are used in the process. If not an explosion, so close to such a highly built up residential area, where there are countless social problems, there is definitely scope for deliberate arson, if security on the site is not incredibly tight. An explosion or fire on a site like this would be cause an environmental catastrophe and also risk fatalities.


Although waste energy would be reclaimed, the local area wouldn't see any direct benefit from this activity, not even could it be guaranteed that local people would be the ones employed in the handful of jobs at the site.
There would be no socio-economic benefit to local people from the development, only downsides, an eye-sore, health risks, increased flood risk, and property blight.

I strongly call for the application to be refused.