MOR HAFREN BIO POWER PAC REPORT DOC 7
Môr Hafren Bio Power Pre-Application Consultation Report DNS/3236340
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Contents Executive summary ...... 2 1 Introduction ...... 8 1.1 Context ...... 8 1.2 PAC report content ...... 10 1.3 The proposal ...... 10 2 Consultation activities ...... 11 2.1 Introduction ...... 11 2.2 Specific consultation activity ...... 11 2.3 Phase 1 consultation ...... 12 Provision of information ...... 13 Public events ...... 14 Exhibitions September 2019 ...... 15 Exhibitions October ...... 16 Briefings ...... 17 GDPR...... 18 Summary of Phase 1 consultation ...... 18 2.4 Phase 2 consultation ...... 19 2.5 Facebook group ...... 21 3 Feedback ...... 23 3.1 Community Consultation feedback mechanisms ...... 23 3.2 Feedback responses ...... 23 3.3 Public responses – Phase 1 ...... 26 Phone messages, FREEPOST and emails ...... 26 Feedback forms ...... 27 3.4 Analysis of feedback forms ...... 28 Distance home is from the proposed site ...... 29 Are you familiar with the waste targets of the Welsh Government? ...... 31 Do you think waste management is an issue in Wales? ...... 33 If you did attend an exhibition, did it help your understanding? ...... 35 What are your views on the proposals? ...... 37 3.5 Summary of comments left on feedback forms ...... 40 Supportive ...... 40 Climate Change ...... 40
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Emissions ...... 40 Location ...... 40 Technology ...... 41 Transport ...... 41 House value ...... 41 Notes from audio interview from Shirenewton ...... 41 3.6 Changes to the projects following pre-application consultation ...... 42 3.7 Phase 2 - Responses from statutory consultees ...... 42 4 Conclusions ...... 43
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Executive summary This Pre-Application Consultation (PAC) Report, produced in accordance with Article 11 of the Developments of National Significance (Procedure) (Wales) Order 2016 (as amended), summarises the public consultation undertaken on behalf of Môr Hafren Bio Power as part of the planning application for the construction and operation of an Energy Recovery Facility on land off Newlands Road, Cardiff.
Initial consultation began in July 2019 when meetings were held with Cardiff Council ward councillors (3 July 2019), briefing meetings were delivered to the Assembly Member, Vaughan Gething, (10 July 2019) and information was provided to Mr Stephen Doughty MP, who was unable to attend a meeting at the time, but a telephone discussion did take place (12 September 2019).
Prior to the public announcement of the proposed development, the nearby traveller community of Shirenewton was given a face-to-face briefing meeting about the proposal by members of the project team. This was organised through Gypsy and Travellers Wales. The presentation and discussions lasted almost two hours. A few weeks later, arrangements were made for this community to provide their feedback via an audio recording summarising their views. This gave the community members time to further consider the details of the proposals.
Pre-application public consultation was conducted in two phases:
1. Phase 1 – 14 August 2019 to 29 November 2019 – raising awareness and discussing the principles of the development – Public Consultation (107 days) 2. Phase 2 – 19 June 2020 – 31 July 2020 – statutory consultation (43 days)
Consultation activity was delivered via three channels of communication:
• Provision of information – via the website, at events and in the distribution of documents either proactively or in response to questions and requests for further information • Public events – exhibitions where members of the public and other stakeholders could view details of the proposals and ask questions of the development team members • Briefing meetings – face-to-face discussions, both formal and informal, with interested parties
All communications were open and honest and emphasised:
• The nature of the development • The specific planning and consultation process being followed • The feedback routes and sources of further information – especially information from relevant third parties
Phase 1 consultation
Formal consultation began with a public announcement on 14 August 2019, through a face-to-face briefing with local media. Significant media coverage was generated in the South Wales Echo (two pages), Western Mail (two pages) and a main story on Wales On-Line. The coverage publicised the project website (www.morhafrenbiopower.co.uk) which went live on 13 August 2019, providing details about the project and the dates and location of public consultation exhibitions. Immediately before submitting the planning application, the site had received more than 2,500 unique visitors. It was important that the community were aware of the deadline for their feedback to be included within this PAC Report, so publicity identified the initial deadline of 4 October 2019.
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During July and August face-to-face briefings were also held with local businesses who operate near the site and one family who live on Newlands Road within 200m of the site. Leaflets about the proposals and the exhibitions were provided as background.
Provision of information
Information was distributed via mail, the Internet and via face-to-face briefings.
During the course of the Phase 1 consultation process, more than 650 letters and emails, and 9,000 other documents, were distributed. These included documents developed in response to the questions asked at events and briefings, and in response to monitoring the issues being raised on social media. During Phase 1, the consultation team responded to more than 200 individual written questions.
The project website was promoted through all external communications, including leaflets and newspaper advertising, as well as through media coverage and the distribution of letters and other documents.
During Phase 1, the website had 1,727 visits.
Public exhibitions
Given the feedback received during the initial consultation and reactions to previous Energy from Waste (EfW) applications around Cardiff, we anticipated significant public interest in the project. The venue for the exhibitions therefore needed to have sufficient space and time available to accommodate a potentially large number of visitors. To allow those working during normal office hours to attend, the venue had to be available into the evenings and at a weekend. The venue also needed to be near public transport and be suitable for disabled visitors. The only venue we could find which met these criteria was the Beacon Centre, Harrison Drive, Cardiff, CF3 0PJ.
Opening times for the first two days of public exhibitions were as follows:
Friday 6 September 2019 - 2pm to 8pm, and
Saturday 7 September 2019 - 9am to 3pm
The exhibitions were promoted through the project website and media coverage, as well as:
• Two newspaper ads in the South Wales Echo • Distribution of 2,400 leaflets to the nearest houses to the site (distribution was undertaken by a reputable company with the ability to track data on each delivery) • Copies of the leaflet were also given to local businesses, community centres and to a resident who posted it on social media • Local politicians were also made aware of the event and Assembly Member Vaughan Gething visited the exhibition on the first day, 6 September
Total attendance over the two days of the exhibition was 57 visitors.
Given the level attendance and feedback gathered by 16 September 2019, the consultation team decided to extend the Phase 1 consultation process to 4 November 2019 and a second round of public exhibitions was organised. The same venue was used as before.
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Opening times for the second two days of exhibitions were as follows:
Friday 4 October 2019 - 2pm to 8pm, and
Saturday 5 October 2019 - 9am to 3pm
The exhibitions were again promoted through the project website and media coverage, as well as:
• One newspaper ad in the South Wales Echo • Distribution of 5,000 leaflets to the nearest 5,000 homes (distribution was undertaken by the same reputable company used in the first delivery) • Copies of the leaflet were also given to local businesses and community centres • Meetings were held with the organisers of a Facebook protest group, who also publicised the exhibition to their 2,000 members (approximate) • Local politicians were also made aware of the second event and Stephen Doughty MP visited the exhibition on the second day
Total attendance over the two days of the second exhibition was 104, meaning that a total of 161 people attended the exhibitions.
Briefing meetings
At the time of the public consultation there was no Community Council for the area where the proposed development is located. As a result, the consultation team spoke to Cardiff Council and the Planning Inspectorate for Wales to identify alternative approaches to increase contact with the community. It was suggested, and accepted by them, that our approach would be to make contact with community groups in the area. We contacted more than 140 schools, churches, medical centres and local businesses to offer them briefings on the proposals. More than 40 briefing meetings took place during Phase 1.
Community groups who did not want a briefing meeting were sent further information about the proposals, and they were also encouraged to visit the project website to submit feedback or ask further questions.
The nearest residential neighbours to the site live on Newlands Road and are within 200m of the proposed facility. These residents were written to, in the first instance, before a face-to-face meeting was held at their home on 2 September 2019. Later in the consultation process (8 November 2019), three residents from this property were taken to visit a similar facility to that being proposed. Two members of the Môr Hafren Bio Power consultation team took them to visit the MVV Energy Recover Facility in Plymouth, Devon. The residents were given a full tour of the facility and met their community liaison officer and site manager.
Facebook group
Around the time of the announcement of the extension to the consultation period, a Facebook group against the proposals was established (14 September 2019).
Members of Môr Hafren Bio Power’s consultation team organised a meeting with the moderators of the Facebook page on 19 September 2019, and a further meeting on 20 September with three residents who had been actively posting on the Facebook page.
These meetings were detailed and lasted more than six hours. They were followed up with the provision of additional information in writing. In response to the meetings and comments on
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Facebook, the consultation team also produced two detailed documents which were sent to the moderators to clarify issues and address questions raised on the group’s Facebook page. The Facebook group also promoted the second round of exhibitions.
Generating awareness of the proposal
Making the community aware of our proposals is an important part of pre-application consultation. At the end of the consultation process, the feedback received was analysed to ensure that our methods were being effective in raising awareness across the community nearest to the site. Initial analysis shows how residents found out about the proposals and exhibitions (some residents identified more than one route):
Word of mouth - 497
Social media - 208
Media stories - 338
Leaflets - 471
Media advertising - 23
Cardiff or Parish Council - 51
Protest group activities - 12*
Other - 17
*As specified within the feedback, although the protest group also ran most of the social media.
Analysis of feedback identified that we had obtained a good geographical spread across the area (see map 1, section 3.2.6), demonstrating an effective reach for the consultation process. Following the second round of exhibitions and contact with community members, it was decided to extend the public consultation period to 29 November 2019. This allowed the consultation team time to target isolated properties in more rural locations and residents living in flats, which were difficult to target with leaflet distribution.
Further consultation
An attempt was made to hold an informal drop-in session at Eastern High School on 19 November 2019, but this was subsequently abandoned 30 minutes early, due to verbal abuse directed at the consultation team by a resident and members of the Facebook protest group.
The Phase 1 pre-application consultation period ran from 14 August 2019 to 29 November 2019 – a total of 107 days.
Feedback
A feedback form was used to collect information and views of residents who visited the website, exhibitions, or were briefed as part of the consultation process. The purpose of this feedback form was to review what residents thought about the information provided by Môr Hafren Bio Power regarding the proposals.
It was unfortunate that the Facebook protest group ‘CF3 against Incineration’ simply promoted the link to the feedback form (on SurveyMonkey) rather than encouraging people to access the project website where they could respond after reviewing the information provided. A lot of the completed
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feedback forms therefore demonstrate public attitudes towards the debate on Facebook, rather than details about the proposals provided on the project website or at exhibitions. This undermines the value of the analysis of feedback; however, this feedback did help to identified areas of greatest concern to the Facebook community, which included:
• Atmospheric emissions and health implications • Impact on traffic/highways • Visual impact • Proximity to schools, houses and SSSI
Other issues raised related to the choice of technology, with recycling and waste minimisation being a preferred option. Questions were also raised about the whole approach of the Welsh Government’s waste management strategy.
Finally, questions were also raised about the consultation process, claiming that the Môr Hafren Bio Power team deliberately tried to hide the development, did not answer questions and failed to raise awareness of the proposals. Understandably, given the level of consultation activity undertaken, the project consultation team rigorously refute these claims.
Following the completion of Phase 1 consultation on 29 November 2019, the development team at Môr Hafren Bio Power reflected on the feedback and made a number of changes to the project, including conducting additional studies as part of the Environmental Impact Assessment (EiA) and reviewing some aspects of building design. For example:
• An additional traffic survey was conducted • Additional evaluation of emissions modelling was undertaken • Refinement of the colour and the pattern of paintwork on the building was considered • Ensuring the Environmental Impact Assessment includes specific animal species identified by local residents
Phase 2 Statutory consultation
The draft planning application and support documents were published on the project website on 19 June 2020, along with a feedback deadline of 31 July (43 days).
The project website was updated accordingly, and some stakeholders, contacted during Phase 1 of the consultation process, were informed of the start of Phase 2 – Statutory consultation.
As part of the statutory consultation process, the following activates were undertaken:
• Site notices were erected (5) • Letters were served on the landowner and all owners of land adjacent to the proposed development site • Copies of all necessary documents (planning application, design and access statement, EiA etc) were made available on the development website (www.morhafrenbiopower.co.uk) • An agreed list of specific statutory consultees was written to and asked for feedback (23) • A formal notice was placed in an appropriate newspaper, and a press release was issued to regional media
In addition to the statutory requirements for Phase 2 consultation, the project website was updated with the latest information about the project, and two new videos were uploaded; one summarising
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what statutory consultation, while the other provided further information on some issues raised by residents in Phase 1.
Natural Resources Wales (NRW) asked for additional time to respond to the consultation, as the COVID-19 pandemic had resulted in a delay in passing the relevant documents to the appropriate team members to respond. We were happy to accommodate the additional time, and a response was received on 13 August 2020. NRW specified four requirements which needed to be met before planning permissions should be granted, and also recommended nine conditions to accompany any planning application. Môr Hafren Bio Power is happy to accept the full list of proposed planning conditions, subject to minor changes to one, as most are typical of what would be expected for the approval of an EfW facility. Môr Hafren Bio Power also replied to NRW about the four requirements simultaneously with the planning application submission.
Local political stakeholders who were contacted during statutory consultation all opposed the proposed development, as did the nearest residential neighbours on Newlands Road.
Conclusions
A genuine attempt was made to provide clear and easy-to-understand information suitable for a pre-application consultation process for a proposal going through the Developments of National Significance (DNS) planning application procedure. The intention was to gather responses from the public once they had seen information either at one of the exhibitions or on the development website. The consultation process was not intended to elicit support from the general public, but rather to inform them about the proposals and, where possible, answer any questions they may have had – often with relevant information from a third party. The consultation team behaved in a professional manner throughout the consultation process, under very difficult circumstances on some occasions.
The purpose of pre-application consultation is to increase awareness of the proposals early in the process, so the community and technical consultees have an opportunity to make constructive suggestions or ask questions about the proposals before a planning application is submitted. Early consultation also allows the development team to understand areas of concern for residents and to gain local knowledge about the environment provided by the community. This was the case here, with some changes being made to the proposals before submission of the final planning application.
The development consultation team believes that the consultation process did result in significant awareness of the proposals and that the feedback gathered helped to enhance the proposed design of the main building, as well as identify areas where further work was required to enhance the Environmental Impact Assessment.
Some of the coverage on social media has worried local residents and as a result, additional technical reports were generated to address some of the issues raised. It was hoped that the additional information would reassure residents that the proposed facility would perform to the highest environmental standards and would not cause the problems claimed on social media.
The majority of feedback received was opposed to the proposal.
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1 Introduction
1.1 Context
1.1.1 This consultation report summarises the pre-application community engagement activity undertaken for the proposed development of an Energy Recovery Facility (ERF) on Newlands Road, Cardiff. This pre-Application (PAC) report was produced in accordance with Article 11 of the Developments of National Significance (Procedure) (Wales) Order 2016 (as amended) (DNS) process. The proposed development would have a power output of more than 10 MW, making the application a Development of National Significance (DNS) under the Developments of National Significance (Procedure) (Wales) Order 2016 (as amended).
1.1.2 Part 2 Article 8 and 9 of the DNS (Procedure) (Wales) Order 2016 (as amended) states that the applicant (Môr Hafren Bio Power) is required to undertake pre-application consultation for a period of not less than 42 days.
1.1.3 The minimum requirements for pre-application consultation for a DNS project, as defined within the legislation, are:
• Notify the relevant planning authorities of the proposed application • Publicise the proposed application for a minimum of 6 weeks (42 days) • Consult with specific community consultees, specialist consultees and any relevant persons (as specified within the legislation) • Serve written notice on owners and occupiers of land adjoining the site • Display site notices in at least one place on or near the site • Hold at least one public event where members of the public may make comments on the proposed development; • Publish the following in an appropriate local newspaper promoting the consultation:
▪ A description of and the location of the proposed development;
▪ Details of where further information can be obtained;
▪ The date and place of the public event;
▪ A statement explaining how, and by when, persons wishing to make comments on the proposed development can do so.
1.1.4 In addition to the minimum requirements set out in regulations, the applicant undertook extensive community consultation in a two phased approach. Phase 1 – community consultation - ran for 107 days, followed by Phase 2 – statutory consultation – which ran for 43 days, resulting in 150 days of consultation overall. On completion of both phases of consultation, the applicant reflected on the feedback before submitting the final planning application.
1.1.5 The pre-application consultation report (PAC Report) has been prepared by Proteus Communications Group on behalf of Môr Hafren Bio Power in support of the DNS
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application procedure. The PAC Report is Document 7 on the submitted application document reference list.
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1.2 PAC report content
1.2.1 This PAC report outlines the activities undertaken as part of the public consultation process and will:
• Specify who has been consulted
• Set out what steps were taken to comply with the statutory requirements and those of the planning authority
• Set out how the applicant has responded to the comments made, including the extent to which the proposals have changed as a result of the PAC
• Provide appropriate evidence that the various prescribed steps have been undertaken – for example, copies of advertisements of the public events and reference to material made available at such events
• Demonstrate that steps were taken to explain the nature of PAC, in particular that it does not replace the application process whereby representations can be made to the planning authority.
1.3 The proposal
1.3.1 The proposed Energy Recovery Facility would use traditional moving grate technology that combusts commercial and industrial wastes in controlled conditions, using a steam-raising heat recovery boiler. Steam would then drive a condensing steam turbine generator to produce electricity.
1.3.2 If approved, the facility would take approximately two years to build, generating around 300 construction jobs. When complete the facility would process up to 200,000 tonnes of waste annually and generate up to 15 MW of electricity annually, enough to power approximately 30,000 homes each year. There will also be provision in place to provide an outlet for a heat network, if one became viable.
1.3.3 The emissions from the facility would meet the standards as outlined by the European Union Industrial Emissions Directive 2014, (regardless of the outcome of Britain’s exit from the European Union). New more stringent emissions standards are under development, and it is the developer’s intention to design the plant to meet these tighter standards. Any environmental effects will be outlined in a detailed Environmental Impact Assessment.
1.3.4 A full description of the proposal can be found in the Design and Access statement (DAS) (Document 8) and Planning Statement, (Document 9) which should be read in conjunction with this PAC Report.
Môr Hafren Bio Power intends to have one main fuel contractor who would collect the commercial and industrial waste, remove recyclable materials before sending the residual material, otherwise destined for landfill, to the facility to generate energy.
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2 Consultation activities
2.1 Introduction
2.1.1 Following the public reaction to the development of the Cardiff Energy Recovery Facility (Trident Park) and the Barry Biomass plant, it was decided to begin consultation early to put the development into context and to be as open as possible with the community about what was being proposed.
2.1.2 As such, the approach to the public consultation was to establish an informative and open dialogue between the developers and the local community. The purpose of the approach was not to ‘sell’ the project to community, but to make them aware of the proposal and to outline the development in principle. It was also important to explain the planning process being followed, so that residents were clear on the options available to provide feedback during this and subsequent processes.
2.1.3 Due to the nature of the Pre-Application stage of consultation, the consultation team tried to ensure that stakeholders understood that we could not go into many technical details at this stage, as many of the likely areas of concern were being evaluated as part of the Environmental Impact Assessment and other supportive document necessary for the submission of the planning application. This also included making stakeholders aware of further public consultation which would take place as part of the DNS planning and permitting processes.
2.1.4 The approach to pre-application consultation was driven by the experience of Proteus Communications Group and best practice guidance based on the Welsh Government’s Pre- application community consultation: Best Practice Guidance for Developers November 2017. Completion of statutory consultation followed guidance outlined in the Planning Inspectorate’s document; Development of National Significance – Procedural Guidance, Version 2.1 June 2019.
2.1.5 As such, consultation is seen as an iterative process whereby the consultation activity and provision of information are adjusted as the project progresses.
2.2 Specific consultation activity
2.2.1 The pre-application consultation was undertaken in a two phased approach. Engagement with the public and neighbours on the principles of the development in Phase 1 (14 August – 29 November 2019 - 107 days), and the statutory consultation process in Phase 2 (19 June – 31 July 2020 – 43 days). This provided a total of 150 days of pre-application consultation.
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2.2.2 Consultation activity was delivered by three channels of communication:
• Provision of information – via the website, at events and in the distribution of documents either proactively or in response to questions and requests for further information • Public events – exhibitions where members of the public and other stakeholders could view details of the proposals and ask questions of members of the development team, and • Briefings meetings – face to face discussions, both formal and informal, with interested parties.
2.2.3 All communications were open and honest and emphasised:
• The nature of the development, • The specific planning and consultation process being followed, and • The feedback routes and sources of further information – especially information from relevant third parties.
2.3 Phase 1 consultation
2.3.1 Before starting public consultation a number of activities were undertaken to help shape the content of the consultation process. Pre-public announcement activity included:
• Discussions with planning officers at both the Welsh Government and Cardiff Council • Briefing Cardiff Council Ward Councillors and Welsh Assembly Member with the proposed development site within their constituency. The Member of Parliament was also offered a face to face briefing but opted for a short telephone discussion • Engagement with Gypsies and Travellers Wales (an independent organisation that works with the Welsh Government and Cardiff Council as a liaison) who helped organise a briefing meeting with the traveller community based at the Shirenewton site • Launch of the project website (www.morhafrenbiopower.co.uk)
2.3.2 At the briefing meeting with members of the traveller community, it became clear that they did not want to provide written feedback on forms or in letters. So, working with Gypsies and Travellers Wales, an audio recording was organised so their views could be recorded.
2.3.3 Formal consultation began with a public announcement on 14 August 2019, through a face to face briefing with local media. Copies of the announcement media statement can be found in Appendix A.1. Phase 1 was originally set to run for 52 days until 4 October 2019.
2.3.4 Phase 1 was extended by the consultation team to give more time for the community to access information about the proposals and raise any questions they may have. The first extension was to 4 November 2019 after approximately five weeks of consultation and the first exhibitions. The consultation team decided that insufficient feedback had been received for a DNS project. The Phase 1 consultation deadline was later further extended until 29 November 2019 to give time for the consultation team to target residents and businesses in more difficult to reach locations such as flats and more rural areas.
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2.3.5 At the start of Phase 1, the media briefing generated significant media coverage in the South Wales Echo (two pages), Western Mail (two pages) and a main story on Wales On-Line. Copies of all the coverage can be found in Appendix A.2.
2.3.6 The coverage publicised the project website (www.morhafrenbiopower.co.uk) which went live on 13 August 2019, providing more details about the project along with the dates and location of the first round of public consultation exhibitions.
Provision of information
2.3.7 A key element of the consultation was to provide factual information, supported by independent information from third-parties where possible. During pre-application consultation, information was distributed via mail, the internet and via face to face briefings.
2.3.8 The project website (www.morhafrenbiopower.co.uk) was promoted through all external communications including leaflets, newspaper advertising and editorial, and through the distribution of letters and other documents.
2.3.9 The website was designed to provide clear details of the proposal and the consultation process. The website was made available in both Welsh and English. The site included details on the following sections:
• Waste strategy in Wales • How EfW diverts waste from landfill • What the plant could look like • The proposed technology and emissions regulations • Transport of wastes and infrastructure • Environmental Impact Assessment • The project timeline • Details of public events • Documents – maps, Artist’s impressions, exhibition panels etc • Feedback link – an online form so residents could say what they thought of the proposal
2.3.10 The website was refreshed on 17 October 2019 following a review of feedback received at that time. The adjustments included changes to some of the emphasis of the key messages and adding additional content. Changes included:
• Adding additional documents as they became available e.g. scoping report etc • Posting information such as questions and answer documents, as well as further information developed in response to feedback at the public exhibitions and reviewing issues raised on social media • Adjusting some messages to make them clearer for some audiences e.g. changing the emphasis of references to the Welsh Government’s Waste Strategy and lorry movements.
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2.3.11 Copies of the website pages can be found in Appendix A.3. By the end of the Phase 1 consultation process the website had been visited 1,727 times.
2.3.12 A consultation newsletter in Welsh and English was produced, with more than 1,000 copies distributed to members of the public, schools and local businesses. The purpose of the document was to raise general awareness of the proposal and feedback routes. A copy of the Newsletter can be found in Appendix A.4.
2.3.13 During the course of the Phase 1 consultation process more than 650 letters and emails were distributed. A sample of the letters distributed can be found in Appendix A.5 and B.6.
2.3.14 During Phase 1, the consultation team responded to more than 200 individual written questions. A lot of the questions raised were similar to those discussed at consultation events, briefings, and on social media. As a result, the consultation team produced two documents; a Further Information Note (Appendix A.6) and a shorter summary question and answer document (Appendix A.7). Another document (Appendix 6.1) was also produced to specifically address issues raised on Facebook which was sent to the Facebook moderators and posted on the development website. These documents were given out at the second round of public exhibitions, briefing meetings and with letters and responses to questions received.
Public events
2.3.15 Giving the public an opportunity to attend an exhibition with further information about the development is important as it allows the development team to learn from the community about the area as well as hear their views about what is being proposed.
2.3.16 Given the complexity of the development, the exhibition needed to cover a number of different subjects to help visitors understand what was being proposed. The exhibition panels were presented in Welsh and English covering the following subjects:
• Introduction – Background • Waste in Wales – Context of waste management • The proposed facility – Description of the facility • How the facility would work – The operational processes • Emissions Control – Regulations and control processes • Environmental Impact Assessment – Scope and content • How would the fuel be transported to the site – Lorry numbers and routes • What Happens Next – Likely timeframe and process steps
2.3.17 In a separate section of the exhibition there were five photo montages of an artist’s impression of the facility displayed within the local landscape. A map was also provided to show where the specific viewpoints for each image was taken. The montages were produced and displayed in accordance with the recommendations given in The Landscape Institute advice note 01/11 and the Scottish Natural Heritage (SNH) Visual representation of windfarms guidance version 2.2.2017. These give advice on how the images are recorded and how they should be viewed for the most realistic representation of how the development would actually look, if built.
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2.3.18 All stakeholder meetings before the exhibitions included feedback suggesting that we should anticipate a significant reaction by residents to the announcement of the proposals.
2.3.19 Given the level of opposition to previous planning applications for Energy Recovery Facilities in the area, it was decided to have a consultation team of five people in attendance at the exhibitions. With such an exhibition and number of team members, a large venue was required and, from a logistics point of view, it was important that the exhibition could be left in place for several hours and ideally overnight. The venue needed to have good public access, be suitable for disabled visitors, be available for a minimum of four hours including into the evening and over weekends to enable those working during normal working hours to attend, and near to public transport links.
2.3.20 The consultation team reviewed a number of venues including the Beacon Centre, the St Mellons Community Hub, Rumney Partnership Hub/Hyb Partneriaeth Tredelerch, Eastern High School and the Eastern Leisure Centre.
2.3.21 On the advice of the local ward councillors, the St Mellons Community Hub was identified as a good location. However, due to the opening times and the high demand for rooms, the exhibitions could not take place during the desired times at weekends, evenings or for sessions of more than two hours.
2.3.22 The Beacon Centre was therefore the only option which could facilitate the exhibition for the duration needed and at the times required to make it as easy as possible for residents to attend.
Exhibitions September 2019
2.3.23 The first round of public exhibitions was held on Friday 6 September (11:30-16:30) and Saturday, 7 September (9:00-15:00).
2.3.24 The exhibition consisted of eight information panels, in Welsh and English, and five artist’s impressions showing the visual impact of the proposal (copies of the exhibition panels can be found in Appendix A.8).
2.3.25 The exhibitions were publicised through:
• Two newspaper adverts in the South Wales Echo on 30 August and 5 September (Appendix A.9) • Distribution of 2,400 leaflets to the those houses nearest to the site on 28 and 29 August (distribution was undertaken by a reputable company with the ability to track data on each delivery). (Appendix A.10) • Copies of the leaflet were also given to local businesses, community centres and to a resident who posted it on social media. • A separate notice was also published in the South Wales Echo Events Diary (Appendix A2)
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• Local politicians were also made aware of the event and Vaughan Gething AM posted details of the exhibitions on his Facebook page on 6 September and visited on the first day of the exhibition, 6 September.
2.3.26 The exhibition leaflet was distributed to nearest 2,400 homes on the 47 streets identified by the distribution company, following our brief to target as many of the nearest residential properties as possible (See Appendix A.11). Leaflets were not left at properties if:
• There was a sign stating that the occupier didn't want free post • There was no accessible letter box • There was evidence (audible) of a dog either in the garden or immediately behind the front door.
2.3.27 It should be remembered that given the feedback received about the likely level of public reaction, the package of promotional activity was considered appropriate to increase awareness of the exhibitions at this stage. Experience also demonstrates that promotion of the exhibitions cannot rely of leaflets alone. As a result, we undertook a package of promotional activity. Feedback received demonstrated that residents found out about the proposals through a variety of these routes.
2.3.28 Newsletters and feedback forms (the same content as the online feedback form) were given to all visitors to the exhibitions. They were encouraged to complete the forms at the event but were also made aware of the freepost facility (Copies of the paper feedback forms can be found in Appendix B.2).
2.3.29 In total there were 57 visitors over the two days, and 18 feedback forms were received at the exhibitions.
2.3.30 Following a review of feedback and the attendance at the first exhibitions, it was decided that we needed to extend the consultation process, as we believed we needed further input from the community for a DNS development. As a result, during week commencing 16 September 2019, we announced an extension to the consultation process, initially to the 4 November 2019, but then to 29 November 2019.
2.3.31 During this extension period, additional meetings were organised, reaching a wider number of community groups and organisations. We also organised a second series of public exhibitions for early October.
Exhibitions October
2.3.32 Two exhibitions were held on Friday, 4 October (2.00pm – 8.00pm) and Saturday, 5, October (9:00am - 3:00pm), again at the Beacon Centre. These dates were promoted via: • An advertisement in the South Wales Echo on 27 September (Appendix A9) • Generation of further media coverage in the South Wales Echo, Western Mail and Wales On-line (See Appendix A.2) • Further promotion on the project website and in documents circulated before the exhibitions • Distribution of a further 5,000 leaflets on 30 September and 1 October (See Appendix A.11)
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• Promotion of the exhibitions via social media, including via the CF3 protest group Facebook pages (Appendix A14)
2.3.33 There was a lot of social media activity from mid-September onwards, particularly on Facebook following the formation of an anti-Môr Hafren Bio Power Facebook Group called ‘Residents against the CF3 Incinerator’ (www.stoptheburner.com). The Facebook group had approximately 2,000 members by the second round of public exhibitions. By 25 November membership of the group had risen to 2,957.
2.3.34 The exhibition content remained broadly the same as before, with three panels being updated as a result of reviewing feedback from the first exhibition and activity on social media. There was also a consultation team of five being in attendance for both days.
2.3.35 Given some of the comments on social media by residents claiming they did not receive leaflets for the first exhibitions, it was decided to more than double the number of leaflets distributed for the second round of exhibitions, although the consultation team did not believe that this, on its own, would significantly increase the numbers of people attending the exhibitions. A total of 5,000 leaflets were distributed to the same streets as used for the first exhibitions as well as more streets further away from the site – a total of 5,000 homes across 65 streets (See Appendix A.11)
2.3.36 The additional publicity and considerable social media coverage resulted in attendance at the second round of exhibitions rising to 101 people (compared to 57 at the first exhibitions), with 30 feedback forms completed over the two days (compared to 18 at the first exhibitions).
2.3.37 Mr Stephen Dougherty MP attended towards the end of the second day and, after speaking to the consultation team of a couple of minutes, was shown round the exhibition by members of the public who may have been members of the CF3 protest group.
Briefings
2.3.38 The consultation team identified the lack of a Community Council within the area of the proposed development. As a result, the consultation team spoke to Cardiff Council and the Planning Inspectorate for Wales to identify alternative approaches to increase contact with the community.
2.3.39 The consultation team suggested that under such circumstances, we would suggest making contact with community groups in the area. This suggestion was accepted, and as a result, we contacted more than 140 schools, churches, medical centres and local businesses to offer them briefings on the proposals.
2.3.40 A full list of the groups identified and contacted can be found in Appendix A.12. We targeted the groups to ensure that they were aware of what was being proposed and had contact details of the consultation team for further information. Schools were contacted to ensure that Headteachers and Governors were briefed on the proposals. Churches were contacted as an important community hub to ensure they knew who to contact if their congregation members had questions or required further information. Local businesses were contacted either because they were close neighbours or to provide information for
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employees. Medical centres were contacted to ensure staff were aware of the proposed facility and to provide a link for more detailed information on emissions if the medical practitioners wanted it.
2.3.41 More than 40 briefing meetings took place. Where appropriate, many briefings were accompanied by a standard presentation to help present consistent information about the proposed development. Copies of the standard presentation can be found in Appendix A.13.
2.3.42 Community groups who decided they did not want a briefing meeting were sent further information about the proposals, and were offered briefing meeting, again. They were also encouraged to visit the project website to provide feedback, ask questions or request further information.
2.3.43 The nearest residential neighbours to the site live on Newlands Road and are within 200 m of the proposed facility. These residents were written to, in the first instance, before a face- to-face meeting was held at their home on 2 September 2019. Later in the consultation process (8 November 2019), three residents from this property were taken to visit a similar Energy Recovery Facility to that being proposed. Two members of the Môr Hafren Bio Power consultation team took them to visit the MVV Energy Recover Facility in Plymouth, Devon, which operates within 100 metres of homes. The visit included a full tour of the facility and a meeting with their community liaison officer and site manager.
GDPR 2.3.44 A resident raised a GDPR issue with consultation team members at one of the second round of public exhibitions. The issue related to a registration book where visitors to the exhibition were encouraged to leave their name and address, so a record was kept of visitor. The registration book showed a maximum of up to seven names and contact details. The majority of visitor did not register. However, this style of public register does not conform with GDPR guidelines.
2.3.45 As a result, a formal internal review was conducted which concluded that a breach had taken place. The issue was raised with the GDPR authorities who stated that the breach was minor, and the risk posed extremely low and as a result we did not need to report the incident or take further action. However, Proetus Communications, the data controller, did formally report the incident to the GDPR authorities who formally concluded that no further action was necessary, but did make some recommendations which have been subsequently implemented. A statement was also put on the development website and copy of which can be found in Appendix A15.
Summary of Phase 1 consultation 2.3.46 The Môr Hafren Bio Power’s first round of consultation included:
• Holding public exhibitions on four days • Promoting the exhibitions and the website via three newspaper adverts and substantial editorial coverage, publishing details on social media, increasing awareness by briefing stakeholders and distributing 7,500 leaflets • Generating more than seven pages of local press coverage, as well as additional online media coverage
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• Directly contacting more than 130 nearby businesses, schools, churches and health centres and holding briefing meetings with more than 40 different organisations, as well as visiting and leaving information with businesses on the Wentloog Corporate Park, Capital Business Park, Spring Meadow Business Park and the St Mellons Business Park. • Updating the project website with further information and publishing specific documents that address issues raised by residents and other stakeholders. The website has been visited 1,727 times to date.
2.4 Phase 2 consultation
2.4.1 Under Welsh planning regulations, this project is considered a development of National Significance (DNS) which means that the final planning decision will be made by the Welsh Government in consultation with statutory stakeholders specified within DNS guidance. The DNS Procedural Guidance Version 2.2 (October 2019) states that the pre-applications statutory consultation involves consulting specific organisation and individuals including:
• Specific community consultees, such as councillors • Specialist consultees, such as Natural Resources Wales (NRW), Highways Authorities, Health and Safety Executive etc • Relevant persons, such as Welsh Ministers, local planning authorities etc • A full list can be found in the planning Inspectorate’s Procedural Guidance document V2.2 October 2019, section 2.10.
2.4.2 Phase 2 was always intended to be the formal statutory consultation period that would be informed by a review of the feedback received during Phase 1 which ended on 29 November 2019. It was clear from feedback received that the key issues concerning local residents included emissions, traffic and environmental effects. As a result, Môr Hafren Bio Power commissioned additional traffic surveys and emissions modelling, as well as ensuring that the Environmental Impact Assessment included evaluation of specific species identified by local residents e.g. dormice etc.
2.4.3 Following discussions with local residents, a number of minor changes were made to the design of the facility, such as using non beeping (white noise) reverse warnings on lorries visiting the site. Also, a review and partial redesign of the paintwork patterns on the main buildings was undertaken to help reduce the visual impact of the proposed facility.
2.4.4 Phase 1 pre-application consultation ended on 29 November 2019. Phase 2 started on 19 June and ran until 31 July (43 days). The delay in starting Phase 2 was partially caused by the occurrence of the Covid 19 pandemic and its subsequent restrictions on people movement. The development team consulted the DNS planning authorities to discuss its implications on statutory consultation. It was agreed that the start of this phase of consultation should wait until appropriate emergency planning legislation was introduced by the Welsh Assembly. Once the legislation was in place, we were advised to continue our pre-applications process.
2.4.5 As part of Phase 2 consultation the Môr Hafren Bio Power consultation team conducted the following activity:
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• Publicised the availability of draft planning documents, the proposed application, and the Environmental Impact Assessment and supporting technical appendices – including making them available on the project website. • Followed guidance for publicising and conducting statutory consultation activity for a minimum of 42 days, including placing five notices around the site on 19 June, placing a formal notice in the leading regional newspaper (South Wales Echo on 19 June 2020) and writing to immediate neighbours. • Followed guidance an agreed list of statutory consultees was contacted. This included specific community consultees, specialist consultees and other relevant persons as identified in section 2.10 (page 8) of the procedural guidance document.
2.4.6 Copies of a full list of statutory consultees and the statutory notices can be found in Appendix C including:
• Site notice itself, (Appendix C1) • Images of the site notices on display at the proposed development site on Newlands Road (Appendix C1) • Copy of regional newspaper advertisement (Appendix C4), • Copy of the advertisement within the South Wales Echo Appendix C4), • Copy of Signed Declaration concerning site notices (Appendix C3), • Copies of letter sent to near neighbours (Appendix C12), and • Copies of letters sent to statutory consultees Appendix C14).
2.4.7 In addition to the statutory consultation for a minimum of 42 days described above, the Môr Hafren consultation team also conducted the following activities:
• Issued a press release to all regional media at the start of Phase 2 - they chose not to publish this information (Appendix C5) • Wrote to Moderators of Facebook group with an update on the development process, confirming Phase 2 timescales, changes to the proposals as a result of Phase 1 consultation and outlining the procedures for feedback in Phase 2 and subsequent procedures in the DNS system (Appendix C15) • Updated the project website with new information about the proposals and specifically addressing the public’s four key issue areas of concern: emissions content, emissions impact on health, traffic impacts and the nature of waste to be used as fuel (Appendix C6) • Two videos were also uploaded onto the website, one covering the purpose and process of statutory consultation and a second video that provided further information concerning the four key areas raised by residents, with additional information made available form appropriate third-party organisations (Appendix C9). • A summary update document of the whole process was also made available on the website (Appendix C8).
2.4.8 Copies of non-statutory consultation documents used in Phase 2 can be found in Appendix C8.
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2.4.9 A member of the Môr Hafren planning team visited the site on 20 July 2020 to check site notices and discovered that four notices had been deliberately been removed – the remains of cable ties used to secure the signs were found showing that they had been cut. The missing signs were then replaced with new signs. (See Appendix C3)
2.5 Facebook group
2.5.1 A Facebook group against the proposals was established around 14 September 2019. The initial positioning of the group appeared to be concern about a lack of knowledge of the proposal. Many of the early members of the group were from the St Mellons area, much of which was not included within the initial leaflet mailing for the first public exhibition in September 2019.
2.5.2 Members of the Môr Hafren Bio Power consultation team made contact with the original moderators of the Facebook group and organised a meeting with two representatives of the group on 19 September. The consultation team also contacted a number of the individuals who were posting significant numbers of comments on the Facebook page. A meeting was held with three residents on 20 September.
2.5.3 Both meetings were detailed and lasted more than six hours. The meetings were then followed up with the provision of a ‘Further Information’ note addressing the issues raised by the moderators, and a ‘Response to issues raised on Facebook’ summary (Appendix A6 and Appendix A 6.1). The latter was developed following the meeting with the residents and after reviewing other posts on the group’s Facebook page. These two documents addressed the many questions raised, although there were still some issues where we did not have the detailed information requested, as we were too early into the development process. These documents were sent to the residents we had met and were also published on the proposal’s website.
2.5.4 The consultation team observed activity on social media to see the nature of the issues being raised and identify what additional information needed to be made available. As a result, three further documents were produced and distributed:
• Further information note – sent on 24 September (Appendix A6) • Response the issues raised on Facebook – sent on 27 September (Appendix A6.1) • Concise summary of key issues raised – 18 October (Appendix A7)
2.5.5 These documents were made available to the Facebook group who posted them to their page. The consultation team asked if these documents could be ‘pinned’ to the Facebook group page, which would have meant that everyone visiting the site would get to see the Môr Hafren documents as soon as they land on the group’s page (whereas standard posts are pushed further down the group’s page when new posts are made, making the documents difficult to find), unfortunately this was not implemented by the Facebook page moderators.
2.5.6 The first two documents were made available at the second round of public exhibitions and during meetings with community groups and businesses, as well as being included in letters sent to interested residents and businesses.
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2.5.7 Over the course of a few weeks there was regular contact with the moderators of the Facebook group who also promoted the second round of consultation exhibitions (Appendix A14). The week before the second round of public exhibitions there were a lot of posts about the exhibitions increasing awareness – at the time the Facebook group had 2,000 members.
2.5.8 After a few weeks of ongoing dialogue, it became clear that the group were not fully sharing our responses to questions they raised and instead were promoting a direct link to the online feedback form. This meant that many residents were responding to issues raised on Facebook rather than reviewing the consultation information available on the project website. This means that a lot of the feedback does not show public attitudes to the detailed information on the proposal but represent public views of issues raised on Facebook.
2.5.9 On 23 November, members of the CF3 group, Barry Biomass Action Group and other interested residents took part in a protest at The Senedd. Following a lot of social media activity about the protest, approximately 100 people attended the event – according to media who attended (Appendix A2).
2.5.10 By mid-November the CF3 Facebook group had 2,957 members, but despite a lot of discussion online, this was not reflected in attendance at events, with 101 people attending the second round of public exhibitions, roughly 40 more than attended the first exhibitions.
2.5.11 A petition against the proposals was organised by the CF3 group generating 2,225 signatures. After asking for additional information, which was provided by the Môr Hafren Bio Power Consultation team, the petition was reviewed by the Welsh Assembly’s Petitions Committee, but no further action was approved.
2.5.12 The Facebook group also distributed many thousands of posters against the proposals, with technical inaccuracies which had previously been pointed out to the group, which also helped to spread awareness about the proposals. However, the Facebook group pages included a lot of misinformation about EfW and the proposals, as well as driving members directly to the Feedback survey rather than the project website. The group also encouraged the view that the consultation process was flawed, suggesting that the Môr Hafren Bio Power Consultation team were somehow trying to hide the development and avoid consultation or responding to questions being raised. This clearly was not the case.
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3 Feedback
3.1 Community Consultation feedback mechanisms
3.1.1 Throughout the consultation process the feedback routes for interested parties were heavily promoted. The following feedback routes were promoted:
• E-Mail – via the link on the project website (47 email chains with 30 providing feedback) Appendix B6 • FREEPOST – FREEPOST MÔR HAFREN BIO POWER CONSULTATION (31 responses, including eight feedback forms) Appendix B4 and 5 • Freephone – 0800 021 9105 (18 calls, nine left messages) Appendix B7 • Feedback forms on the project website (1,309 forms) Appendix D • Feedback forms handed out at the exhibitions (47 forms) Appendix B2 • Total feedback items received was 1,426, including an audio recording
3.1.2 A standard feedback form (English – See Appendix B.1) was used to collect information and views of residents who visited the website, exhibitions, or were briefed as part of the consultation process. The purpose of this feedback form was to review what residents thought about the proposals once they had reviewed the information provided by Môr Hafren Bio Power.
3.1.3 It was unfortunate that the protest group ‘C3 against Incineration’ simply promoted the link to the feedback form rather than encouraging people to access the project website where they could find out more details about the proposals. Instead some feedback simply responded to the information and positioning provided by the protest group. This approach has reduced the value of this feedback mechanism as a route to provide objective comments about the proposals to help shape the proposals as the project develops.
3.1.4 As a result, the PAC report breaks down feedback into the following three categories:
1. Total feedback – all feedback 2. Feedback from start of phase 1 – 13 September 2019 up to the end of the first public exhibitions and launch of CF3 protest group 3. Feedback after 13 September until 29 November 2019.
3.2 Feedback responses
3.2.1 Making the community aware of our proposals is an important part of pre-application consultation, so as the community engagement developed the consultation team reviewed the feedback received to ensure that the consultation methods were being effective at raising awareness in general, and also to ensure a good geographic spread of awareness across the whole community.
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3.2.2 Analysis of all feedback forms received shows how residents found out about the proposals and exhibitions (some residents identified more than one route):
Cardiff Social Leaflet Internet Media Newspaper Parish Word of PROTEST Other MPS Council Media story advert Council mouth GROUP Start-13 0 13 10 0 8 0 1 13 0 2 0 September 14 September 41 195 461 12 330 23 9 484 12 12 3 to end September 0 5 5 0 4 0 1 2 0 1 0 Exhibitions October 1 7 4 1 11 0 0 15 0 1 0 Exhibitions Total 41 208 471 12 338 23 10 497 12 14 3 Percentages 2.5 12.8 28.9 0.7 20.8 1.4 0.61 30.5 0.7 0.9 0.2
3.2.3 Copies of all feedback can be found in Appendix B6 and D.
3.2.4 Analysis of feedback identified that we had obtained a good geographical spread across the area (see Map 1 below), although there were also some outliers from other parts of the UK (see Map 2 below).
3.2.5 The maps demonstrate an effective reach for the consultation process.
Map 1 Map showing location of post codes from completed feedback forms. NOTE, these are post codes only and not addresses, location icons are in the middle of the roads of the respective post code
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3.3 Public responses – Phase 1
Phone messages, FREEPOST and emails
3.3.1 The freephone line received 18 calls over Phase 1 – see Appendix B.7.
3.3.2 A total of eight callers left no message and one person called three times. As a result, there were nine calls recorded for feedback. Two residents simply wanted to have their opposition to the proposals recorded – which it duly was. All other callers were responded to either with a telephone call or by sending them the information they requested. One caller was abusive to the consultation team member on the telephone during the call back.
3.3.3 31 documents were sent via the freepost service over Phase 1 – see Appendix B.4. In addition, a protest Christmas card and a Valentines days card, along with a number of printed protestor post cards were also received via freepost (See Appendix B.5)
3.3.4 A total of eight paper feedback forms were returned via this route. This feedback is included within the analysis of all feedback forms. A total of 21 CF3 anti incinerator postcards (Appendix B.5) were sent in objecting to the proposals, but they also identifying other issues such as:
Emissions impacts including on health, climate (CO2) and wildlife
• HGV movements • Toxic ash generation • Proximity to schools and homes • Too much development in the area, especially within a SSSI and more waste management activity • Visual impact • Nuisance issues including smells and noise
3.3.5 Two objection letter was received from a resident which can be found in Appendix B.4.
3.3.6 A total of 47 email chains were received via the [email protected] email – see Appendix B.6.
1 = test by the consultation team,
2 = admin emails from the email service provider,
6 = were standard mailers from Greenpeace or Friends of the Earth,
3 = a resident looking for employment and two local business looking to bid for construction contracts,
1 = a resident’s solicitor formally stating their client’s opposition to the proposals,
22 = Residents raising questions and issues
2 = Media enquiries
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2 = Cardiff planning department
1 = Local business providing further feedback following a face to face briefing
1= An open letter to the CEO of Cogen
1 = GDPR
2 = Issues with website
2 = Conference speaking opportunities
1= Request for information on posting site notices
3.3.7 All emails were responded to, although one email included an attached letter to the CEO of CoGen (who are leading the development for Môr Hafren Bio Power). The letter was forwarded to the CEO.
3.3.9 The consultation team worked with Gypsies and Travellers Wales to collect audio feedback from the Shirenewton traveller community. In the end, one traveller collected the views of many within the community and gave an interview which was recorded identifying their key issues. The key issues of concern included similar concerns raised elsewhere such as traffic, emissions, another waste facility in the area. However, they also had some concerns which were unique to them:
• Affected more than people who live in houses • Complaints about effect of noise pollution from the nearby wind turbine
3.3.10 A copy of the audio feedback can be found in Appendix B.8
Feedback forms
3.3.11 A total of 56 paper feedback forms were received as follows:
Exhibition on 6 September - 6 forms
Exhibition on 7 September - 12 forms
Exhibition on 4 October - 16 forms
Exhibition on 5 October - 14 forms
Feedback forms via Freepost - 8 forms
Total 56 forms
3.3.14 The paper feedback forms represented feedback following briefings or attending public exhibitions.
3.3.15 A total of 1,446 electronic forms were started but only 1,309 electronic forms were submitted over Phase 1. Note that some respondents did not answer all questions so the total number of responses may be different to the total number of forms returned.
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3.3.16 Copies of the 56 paper feedback forms received during Phase 1 consultation at the public exhibitions and via the freepost return system can be found in Appendix B.2.
3.3.17 Copies of the 1,309 electronic feedback forms received during Phase 1 can be found in Appendix D.
3.4 Analysis of feedback forms
3.4.1 All feedback forms have been included within the PAC Report and have been broken down into three categories: 1. Total comments 2. All comments collected from the start of Phase 1 up to midnight on 13 September 2019 3. All comments collected from 14 September 2019 up to the end of Phase 1
0-2 3-5 5-10 More Total miles miles miles than 10 miles 14 August - 13 September 2019 34 12 2 0 48
14 September - 29 November 2019 889 357 51 20 1317 Total feedback 1365 923 369 53 20
3.4.2 The reason for this breakdown is to demonstrate a formal record of all feedback and attitudes following briefing at events. The final breakdown was to separate feedback before and after the CF3 protest group publicised the electronic link to the feedback form online, rather than the project website. This meant that anyone following the link provided via social media went straight to the feedback survey platform (SurveyMonkey.co.uk) and did not access the form having reviewed the information that was made available by the developer. This undermines the value of this feedback mechanism as it is dominated by opinions based on the posts on Facebook. However, we have continued to provide a review of the feedback as some of those who did follow the link to the survey will have also looked at the website on other occasions and their feedback is valued by the developer.
3.4.3 Responses to the question concerning how people found out about the proposals has already been discussed and presented in section 3.3.2.
3.4.4 The feedback is presented in the same order as recorded in the form, with a final section summarising the key issues raised.
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Distance home is from the proposed site
3.4.5 A total of 68% of respondents identified that they lived within two miles of the proposed site, which included the communities of Trowbridge, St Mellons, Old St Mellons, Llanrumney and Rumney.
Distance home is from the proposed site
Total feedback
1%
4% 0-2 27% (3-5)
(5-10) 68% more than 10
How close is your home (14 August-
13 September) total
0%
4% 0-2 25% (3-5)
(5-10) 71% more than 10
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How close is your home (14 September-29 November) total
4% 2%
0-2 27% (3-5) (5-10) 67% more than 10
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Are you familiar with the waste targets of the Welsh Government?
Yes No Unsure Total 14 August - 13 September 23 16 9 48 14 September - 29 November 468 420 430 1,318 Total feedback 491 436 439 1,366
3.4.6 This question was intended to identify how many residents were aware of the waste strategy to see if they might understand the context behind the need for the proposed facility. Compared to feedback from communities near other proposed EfW facilities, awareness of the Welsh Government’s strategy was quite high, with more than a third of respondents aware of the strategy.
3.4.7
Total feedback
32% 36% Yes No Unsure
32%
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Are you familiar with the waste targets of the welsh government (14 August-13 September) Total
33% Yes 48% Unsure No
19%
Are you familiar with the waste targets of the welsh government (14 September-29 November) Total
32% 35% Yes Unsure No
33%
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Do you think waste management is an issue in Wales?
Yes, it's a It's neither There is no Total major issue important nor issue unimportant 14 August – 13 September 38 5 5 48 14 September - 29 November 952 286 76 1314 Total feedback 990 291 81 1362
3.4.8 Overall, 73% of people providing feedback felt that the issue was significant, but this rose substantially at the exhibitions to an average of 95% believing it was a major issue.
Do you think waste management is an issue Total
6% Yes, it's a major issue 21% It's neither important nor unimportant 73% There is no issue
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Do you think waste management is an issue 14 August-13 September (total)
Yes, it's a major issue 10% 11% It's neither important nor unimportant 79% There is no issue
Do you think waste management is an issue 14 September-29 November (total)
6% Yes, it's a major issue 22% It's neither important nor unimportant 72% There is no issue
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If you did attend an exhibition, did it help your understanding?
Yes No Total
September exhibitions 18 0 18 October exhibitions 21 5 26 Total 39 5 44
3.4.10 The responses reviewed here only relate to those people who left feedback on paper forms collected at the exhibitions and either given back at the exhibitions or returned via Freepost. It is interesting to note the difference between the first and second exhibitions. The exhibition format content and responses to questions were the same. The consultation team who attending the exhibitions was the same but noted that many residents attending the second exhibition had a clear view against the proposals from the start of discussions.
If you did attend did it help your understanding: Total
11%
Yes No
89%
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If you did attend an exhibition, did it help your understanding?
If you did attend did it help your understanding( September)
0%
Yes No
100%
If you did attend did it help your understanding (October)
19%
Yes No
81%
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What are your views on the proposals?
Strongly Support No Oppose Strongly Total Support Opinion oppose 14 August - 13 September* 5 6 1 3 32 47 14 September – 29 November* 15 4 10 68 1221 1318 September exhibitions 4 6 0 2 5 17 October exhibitions 0 2 2 1 25 30 Total 20 10 11 71 1253 1365 Percentage 1.5 0.7 0.8 5.2 91.8 * Includes exhibitions
3.4.11 The majority of the people who responded to this question were against the proposals
What are your views: Total 1% 1%
1% 5%
Strong support Support No Opinion Oppose Strongly oppose 92%
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What are your views on the proposals?
What are your views on the proposal (14 August-13 September) total
11% Strong support 13% Support 2% No Opinion
68% 6% Oppose Strongly oppose
What are your views on the proposal (14 September-29 November) total 0% 1%
1% 5% Strong support Support No Opinion Oppose 93% Strongly oppose
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What are your views on the proposal September exhibition
Strong support 24% 29% Support No Opinion Oppose 12% 35% Strongly oppose
What are your views on the proposal October exhibition
7% 7% Strong support 3% Support No Opinion Oppose 83% Strongly oppose
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3.5 Summary of comments left on feedback forms
3.5.1 As well as answering questions, there were opportunities for residents to make statements about the proposals. Many have done so, all comments and all forms received before midnight on the 29 November are included in Appendix B2 and Appendix D. However, we have included some examples of typical statements below, the wording and spelling has not been changed. Supportive
3.5.2 Something needs to be done and this is a carefully designed plant to solve a big problem.
3.5.3 If it can be efficiently built and run - could be exactly what UK needs for the huge problem of waste in this era with so much available.
3.5.4 Shops like "WHAT" bringing in so much plastic unrecyclable waste at very cheap prices encourages general public to purchase unnecessary items of single use, creating the problem
Climate Change
3.5.5 At this time of Climate Emergency and being close to residents’ homes, this is absolutely unacceptable and it frightens me that this incinerator might be built here in East Cardiff.
Emissions
3.5.6 Not good for local residents in terms of air quality. Will reduce house prices, the environment will smell awful, increased traffic & pollution, eye sore.
3.5.7 I live far too close. Do not put my health or my children's health in danger from this disgusting plant. Put is out of the way from residents and children!
3.5.8 I do not wish to suffer the adverse health effects on myself or my family if this incinerator goes ahead. No matter how small the risk I am not willing to accept it. I also object to the additional traffic the incinerator will be producing.
Location
3.5.9 This site is far too close to our homes. This will not only be an eye sore but will be a huge health risk to ALL local residents & our children.
3.5.10 I do not support the proposal it’s too close to residential area the air pollution is bad enough already we already have to put up with swarms of flies during the summer due to the lack of pest control at the Lamby tip more waste being brought into this area is going to affect everyone and probably the housing market.
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3.5.11 Toxic waste. Too close in proximity to residents and schools. Larger congestion from waste transport. Detrimental to the environment.
Technology
3.5.12 Firstly, I object to an incinerator in principle. We need to reduce our waste in the first instance and we need to recycle next. I think that incinerating the waste doesn't help us to prioritise those other objectives. Cardiff already has an incinerator which deals with our waste and that of neighbouring authorities. If this facility must be built, I think it should be somewhere else because as a community we have put up with enough.
3.5.13 For all the information I have seen on Facebook, I do not what the pollution thank you, I like recycling.
Transport
3.5.14 Being a chronic asthmatic an increase in traffic will pollute the air and contradict the plans of helping the environment.
3.5.15 Increase in traffic in this area that is already bad for local residents and businesses alike. A worry about ongoing airborne toxins al
3.5.16 I don't oppose the facility but I do oppose the increase in traffic and traffic pollution it will inevitably bring.
3.5.17 The huge increase in HGVs on roads that are already overused and the impact on other roads. The transport of hazardous waste. Already an incinerator in Splott, and Barry.
House value
3.5.18 I have been told that this development will decrease the value of my property and there will be severe effects on the environment.
Notes from audio interview from Shirenewton
3.5.19 The main concerns are:
• The potential smell from the lorries and the increased traffic on roads • This isn’t a suitable location as there are people living nearby and there are already lots of waste treatment facilities in the area • Concerns about waste being burnt – e.g. bones and shop waste • The risk of rats being attracted to the waste • Concerns about the waste coming from England • They are not saying can’t have the technology, just not near families
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• Noise concerns from operations, they already have issues with noise from the wind turbine
3.6 Changes to the projects following pre-application consultation
3.6.1 Following the completion of Phase 1 consultation on 29 November 2019, the development team at Môr Hafren Bio Power reflected on the feedback and made a number of changes to the project, including conducting additional studies as part of the Environmental Impact Assessment and reviewing some aspects of building design, for example:
• An additional traffic survey was conducted • Additional evaluation of emissions modelling was undertaken • Refinement of the colour and the pattern of paintwork on the building were considered and changes made • Ensuring the Environmental Impact Assessment includes specific animal species identified by local residents
3.7 Phase 2 - Responses from statutory consultees
3.7.1 A full list of the statutory consultees contacted can be found in Appendix C.11.
Responses from the statutory consultees can be found in Appendix C.14 including a detailed response from Natural Resources Wales (NRW). Other feedback received during the statutory consultation phase can be found in Appendix C.15.
3.7.2 9 statutory consultees responded to the phase 2 consultation.
3.7.3 Natural Resources Wales’ (NRW) detailed response identified a number of serious concerns which they wanted to be addressed before submission of the planning application (Appendix C.16)
3.7.4 They also specified four requirements (areas where action was required before submission), and nine conditions (issues they would be recommending for inclusion as conditions associated with any planning approval given by the planning authorities).
3.7.5 Môr Hafren Bio Power has provided a detailed response to these points at the same time as the application is submitted (Appendix C.16), which provides the developer’s views on the four requirements and acceptance of the suggested planning conditions (subject to a minor change to one), most of which would be standard requirements for a development such as that proposed.
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4 Conclusions
4.1 A genuine attempt was made to provide clear and easy to understand information suitable for a pre-application consultation process for a development going through a Development of National Significance (DNS) planning application. The consultation process was extensive and responsive, using a large number of different techniques to allow as many people as possible to be made aware of the proposals and to give them an opportunity to give feedback at an early stage in the process. The consultation process never intended to elicit support for the proposal from anyone, but rather to inform them about what was being proposed and, where possible, answer as many questions as possible – often with third party sources of information.
4.2 The purpose of pre-application consultation is to increase awareness of the proposals early in the development process so that the community has an opportunity to make constructive suggestions about the development. Early consultation also allowed the development team to understand issues of concern and specific details about the local environment from the community.
4.3 The development consultation team believes that the consultation process did result in significant awareness of the proposals. Feedback helped to enhance the proposed design of the main building and identify areas where further work was required to enhance the Environmental Impact Assessment. Coverage on social media has worried many local residents, and additional technical reports were generated to address some of the issues causing concern. It is hoped that the additional information reassured residents that the proposed facility would perform to the highest environmental standards and would not cause the problems mentioned on social media.
4.4 Feedback received showed that the consultation process had a good geographical spread around the area near the site with almost 70% of respondents living within two miles of the proposed site. The range of techniques used to increase awareness clearly worked, with many respondents identifying that they heard of the proposed development from more than one communication route.
4.5 The feedback showed that more than 70% of respondents recognised that waste management was a significant issue that needed dealing with, but many preferred increasing recycling rates instead of energy recovery.
4.6 The consultation process was highly responsive to issues raised by residents. However, there was a lot of misunderstanding about the proposed development which was circulated on social media. As new issues and questions were raised – either directly with the consultation team or by observing issues being raised on social media - new response documents were produced by the consultation team to address the issues. These documents were published on the project website, as well as being used in face-to-face briefings and sent out to contacts. The project website also had three major content updates. The consultation team responded to more than 200 written questions and distributed more than 650 letters and emails and 9,000 other documents.
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4.7 A number of different consultation techniques were used during the Phase 1, with four days of public exhibitions, distribution of documents by post and by hand – in an attempt to ensure that even residents in difficult places to reach such as flats and isolated rural homes received the material. The consultation process also involved sending information to more than 140 schools, churches, medical centres, local businesses and community centres, and holding more than 40 face to face briefing meetings.
4.8 The consultation programme was proactive in briefing the media about the proposals generating significant media coverage for a development of this size. Specific meetings were held with the Shirenewton Traveller community and, to assist them in providing their feedback, arrangements were made for them to provide an audio recording summarising their views.
4.9 One family live on Newlands Road and they were given a face-to-face briefing about the proposals. Communications continued with the family and a visit to a similar facility, in Devon, was organised for three members of the family so they could see first-hand how these facilities operate.
4.10 Contact was made with the Facebook protest group (CF3 against the incinerator), two detailed meetings were held, and contact was maintained during the consultation process.
4.11 The pre-application consultation activity received a total of 1,351 objections to the proposal during the Phase 1 public consultation phase.
4.12 Some residents raised concerns about the consultation process, claiming that the development team was trying to hide the proposals and not respond to concerns raised. This was clearly not the case. The consultation team behaved in a professional manner throughout the consultation process, under very difficult circumstances on some occasions.
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