Mor Hafren: Energy Recovery Facility

Received 27 November 2020
From Hannah Oxenham


I strongly object to the proposed construction and operation of this facility for the following reasons:

Bio Diversity and Environmental impact - This site lies alongside a SSSI. I have concerns about potential damage to the SSSI, which is sensitive to pollution both air borne and from any effluent/spillage leaking into the reens, both during the construction of the site and the ongoing day to day running of it. Biomass is a counter productive and flawed form of energy production. Generating a unit of energy from wood emits between 3% and 50% more CO2 upfront than generating it from coal. Burning wood emits similar levels and a similar range of pollutants as burning coal, including CO2, sulphur dioxide, mercury, Volatile Organic Compounds and small particulates such as PM2.5; all of which can be detrimental to our health and environment. We should not be advocating this type of facility over newer more green renewable options. Cutting down trees to burn both releases the CO2 back into the atmosphere instead if the trees absorbing it and it further reduces our ability to capture CO2. Cardiff is the 6th most at risk city in the world to sea level rises - Cardiff Council should reject this application in favour of encouraging investment in clean, renewable forms of energy.

Air quality/ physical health impact - While emissions may be within deemed 'safe limits', the area is a deprived (previously Communities First) area which has had limited investment in green spaces and much investment in pollutants, including the Viridor incinerator to which I as a local resident objected some years ago. Local residents did not want the previous incinerator built in our locality and we do not want the air quality and our future health as individuals and a community to be further detrimental impacted by yet another incinerator. This build will negatively impact our health and the health of future residents and communities in this rea when we should be actively investing in improving this in the east of Cardiff.

Equality and equal access to clean air - Cardiff has declared a Carbon Climate Emergency and is currently consulting on its own One Planet strategy. Building this incinerator is in contrast with the strategic aims of this document. Once again, residents in a more deprived and impoverished area of Cardiff, have been targeted to further disadvantage, rather than acknowledging that air quality is already at its worst in this area of the city. Since the Viridor incinerator has built, the air quality has noticeably dropped for residents. It smells different. Please do not further disadvantage us by violating yet another large polluting business on our doorstep. I do not feel that the measures being taken by Mor Hafren to reduce the toxicity of the gases released are adequate to protect me or my family as local members of the community. There has been no monitoring of small particulates (PM10 and PM2.5) in the locality, despite the nearby steel works, the existing waste incinerator, and the proposal for a second in Wentloog. It is therefore surely impossible to know whether legal limits are already being approached or even exceeded and what the true impact will be on us as residents. Splott already has one waste incinerator, and with proposals for another in Wentloog, the east of Cardiff is at risk of three incinerators within close proximity to our homes and to schools in Splott, Tremorfa and Pengam Green.

Alignment to current Cardiff Council and Welsh Government policy - Welsh policy focuses on cleaning up the environment not increasing air pollution in areas which are already identified as having worse air quality than other areas of the city. Cardiff Council has made policy commitments around Carbon neutrality by 2025. An Environmental Aspect Assessment and Strategic Environmental Assessment and sustainability appraisal should be undertaken with regard to this plant. Cardiff Council and Welsh Government have announced they are resolved to fight against the current climate emergency, and approving this application will not support achieving that goal and will in fact have an adverse impact on its success for residents in east Cardiff.

Best technology available - it appears that the incinerator is not using up to date technology so would not be efficient. CoGen are also not looking to create a local heat network to make use of steam and hot water produced, which given the current climate crisis is not efficient or corporately responsible.

Need demonstrated - I would query whether there is enough demand for this facility given there is another incinerator which has relatively recently been built very nearby in the same locality. I am concerned that this will result in waste being transported from areas further and further away, including outside of Wales and the UK, which should be processed as close to its origin as possible. Often wood is shipped in from abroad which furthers the deforestation and climate crisis across the world.

Traffic and roads - nearby roads are already congested and local children feel that roads are unsafe for them. We as residents in a disadvantaged community will be subjected to increased heavy industrial traffic with all the environmental and health risks that poses in addition to congestion. We have suffered on an ongoing basis from increased heavy industrial traffic since the Viridor incinerator was built. The promise that no HGVs would use this route was empty, not enforced, and did not decrease HGV traffic. Our windows and doors now shake when a HGV goes down our road and homes are experiencing potential subsidence from HGVs hitting into the speed bump outside of our house. I have directed numerous HGVs who are lost or stuck trying to get around corners around which they cannot fit due to residents' cars being parked outside their homes, at all hours, including when children are coming to and from school.

Noise disturbance - I do not believe noise disturbance has been adequately or effectively assessed for local residents either through the build process or an ongoing basis. We still experience noise pollution from the current incinerator in the area, as well as other issues as local residents such as swarms of flies in the summer when they had issues with refuse at the Viridor site.

Visual impact - the building proposed is huge, being an excessively tall building on 'The Levels' which will have a massive e impact on the local landscape.

Planning blight - an extension of planning permission would be likely to result in continued uncertainty over the use of the site which has no clear timeframe for completion. Under the Cardiff Local Development Plan, this site could be better used.

Approving this application will negatively impact on the health and wellbeing of local residents of Splott, Tremorfa, Pengam Green and wider East Cardiff. There will be negative impacts on environmental, noise, air, traffic, visual aspects and it will detract work outlined through local and national policy. It will not be efficient or effective in the context of a climate crisis.