Gwehelog Fawr Council has considered the planning application DM/2018/01641 and objects to the application on the following grounds:

1. Change of Use by Intensification

The multiple planning applications related to this project have certainly changed the use of the proposed plant out of all recognition from the initial project of 2007, in terms of both scale and activity. No longer is this an auxiliary generator to ensure continuity of electrical power to animal sheds. It must be considered as an industrial incinerator burning various fuels including waste, some of which is classified as toxic. This has not been addressed by planning officers. The history of planning applications for this project demonstrates this point.

2007 (DC/2007/01200) The developer applied for planning permission for an auxiliary generator to provide uninterrupted heat and electricity to poultry sheds. The generator would be powered by burning excess rapeseed oil from the farm. The application was approved by planning officers on the grounds of agricultural diversity. This involved a building with a footprint of 360 m2.

2008 (DC/2008/01424) Retrospective planning approval was given by planning officers because the plant built had exceeded the size of the original application and measured 520m2.

2010 (DC/2010/00437) Planning approval for an extension of the building size to 628m2 was given by planning officers.

2011 (DC/2011/00373) An additional extension taking the size of the whole to 978m2 was approved by planning officers. This was on the condition that the additional space would be used for agricultural use only, specifically for drying and storing straw.

2013 (NO APPLICATION) Changes were made to the fuel-stock (which had already switched from rapeseed oil to palm oil), to using wood. Planning officers have since advised local residents that no planning application was required ‘as the use class remained the same’. At the same time, gasification technology was introduced to the plant, also without any planning application. The type of wood – virgin or waste wood - was not specified, although subsequent applications refer to waste wood chips from reclaimed wood. The quantity to be burnt was not specified. There was no transport management plan specified. No detailed information on the removal of char was given. There is no indication that an operating permit by either County Council or by Natural Resource (NRW) had been granted; in fact, both agencies have confirmed they have never monitored the plant.

2016 (DC/2016/01465) A further application for a plant operating 365 days a year, with a change to using virgin wood as fuel-stock, and requiring a chipping building, 3 silos, a dryer building with a 17m 1 high exhaust stack, and an emergency flare stack, also 17m in height. This application was approved under delegated powers by planning officers in 2017.

2017 (DC/2017/01078) A further application for the plant – to double the height of the generator building, introduce a 22 M stack and use waste wood as fuel - was submitted but then withdrawn.

2018 (DM/2018/01641) The current application was submitted. This is described as “erection of a fuel storage building to replace existing open storage compound, and relocation of 2 no. portacabins together with parking provision”. The storage building is very large: capacity measuring 42.5m x 30m x 9.5m (footprint of 1275m2). This is more than doubling the footprint of the site from that approved in 2011 and does not include the storage barn approved in 2012. The application description does not mention the proposed new flue stack, a critical part of the plant; a further 17m flue stack will be required to replace the existing 9 short vents on the roof of the generator building in order to disperse emissions (detail on potential noxious substances is supplied below). So that the plant will have permissions to erect 3 x 17m high stacks, two have already been approved plus this further flue stack. In addition, office portacabins will be relocated and parking facilities will be provided.

We consider that these applications demonstrate that this is change of use by intensification and object to it.

2. Agricultural Diversification

If approved, this application is overt industrialisation of an agricultural site in open countryside in a beautiful location.

We consider this not to be agricultural diversification. This proposal has nothing to do with agriculture and is green field industrialisation. We object to it for this reason.

3. New Build in Open Countryside

If approved, the proposal will create an enormous industrial plant with 3 large chimneys operating in open countryside in the valley of the river close to a SSSI /SAC site, and an area appreciated by all for its beautiful landscape. Visitors come to the area for this reason and contribute to the local economy.

We object to this proposal because it is industrialisation in open countryside.

4. MCC Climate Emergency Declaration

Any development plans should conform to a net zero carbon target within a specified time frame. This plant is likely to have a working life of 25 to 30 years. Over its lifetime, it will emit significant amounts of carbon. Incinerating wood or refuse derived fuel does not produce renewable energy – indeed carbon emissions from the plant could be comparable to those from a coal fired power station. The Committee on Climate Change, which advises the UK government, recommends the phasing out of biomass as a fuel for power. Furthermore, the Welsh Government’s recently published Prosperity for All: A Low Carbon Wales (2019) notes that power generation is responsible for 34% of all of Wales’ emissions whilst stressing 2 the need to rapidly shift to alternative, renewable and sustainable forms of energy production.

This application is contrary to MCC’s own stated policy on climate change alongside national policy aims and we object to it for this reason.

5. Environmental Health

The developers have provided the detail of the proposed fuel-stock on the planning portal. The fuel-stock will include forestry waste, waste wood and refuse derived fuel (RDF) from municipal waste (which will include plastics). Using standard waste codes provided by the Environment Agency/Natural Resources Wales etc. NRW has indicated in a letter on the portal (24 June) that 2 of the fuel stock codes (EWC19/12/10 and EWC/03/01/04)* are for hazardous materials; they note that ‘if any hazardous waste, no matter how small a quantity, is used as a fuel then S5.1.(a) [of the Environmental Permitting Regulations 2016] would be applicable’. *Our addition.

Particulate matter (PM10/2.5) will also be emitted. These are known to be highly dangerous to human health and can travel for miles on prevailing winds. Emissions may include:

 Oxides of Nitrogen (NOx), expressed as NO2  Carbon Monoxide (CO)  Total Dust (as PM10 and PM2.5)  Gaseous and vaporous organic substances, expressed as Total Organic Carbon  Sulphur Dioxide (SO2)  Arsenic process contributions  Hydrogen Chloride (HCl)  Hydrogen Fluoride (HF)  Metals (Cadmium, Thallium, Mercury, Antimony, Arsenic, Lead, Chromium, Cobalt, Copper, Manganese, Nickel and Vanadium)  Polychlorinated dibenzo-para-dioxins and polychlorinated dibenzo furans (referred to as dioxins and furans)  Polycyclic Aromatic Hydrocarbons (PAH, as Benzo[a]pyrene)  Polychlorinated Biphenyls (PCBs).

Local health experts have publicly expressed significant concern in respect of this aspect of the project. A proposal of this size and nature should, in the view of the Council, require the completion of a comprehensive health impact assessment. Moreover, this proposal directly contradicts the stated objectives of the Welsh Government’s Well-being of Future Generations Act (2015), violating several of the Seven Well-being Goals, including: (1) a resilient Wales, (2) a healthier Wales and (3) a globally responsible Wales. Furthermore, the application defies the aims of Planning Policy Wales with regards to placemaking.

On health grounds we object to this application.

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In addition, Gwehelog Fawr Community Council wishes to make the following three observations on the application:

1. Operational History of the Generator

In the description of this application for the MCC planning committee meeting scheduled for 5 March 2018, Ms Kate Bingham mentions the generator thus in para 1.3:

“The site which has been in its current configuration since 2013, operates as a Combined Heat and Power Plant, capable of producing electricity 24 hrs a day - 365 days a year, and gained Government ROC (Renewable Obligation Certificate) accreditation in 2013 to export up to 6MWe per hour of electricity to the National Grid. It has operated successfully but intermittently over recent years.”

Gwehelog Fawr council challenges this assertion because they cannot see any evidence to support it. We can find no evidence of an operating permit from either MCC or NRW. Both bodies have confirmed that they have never monitored the plant. The plant was registered with Ofgem in 2013 to receive Renewable Obligation Credits (ROCs). Since that date we can find no evidence that the plant has received any ROCs for the generation of electricity. Residents living close to the generator have indicated that they have seen little or no activity at the plant in the last few years. Neither the developer nor MCC planning department have provided this evidence so Gwehelog Fawr do not accept Ms Bingham’s assertion of continuous commercial power generation over the past 6 years. This is important because a number of assumptions made by other departments at MCC and NRW are based upon its accuracy. We refer to these in the Traffic Management plan and Environmental health sections under Omissions.

2. Omissions

The application does not include several key pieces of information which in our opinion must be available before MCC planners can take a considered decision on the project. These are as follows: a) Inadequate Traffic Management Plan

MCC highways department has approved a route (report dated 9/7/2019) for heavy traffic into and out of the plant. The Highways department have based their comments on the premise that the plant has been operational commercially for some years:

“It is understood that the site has operated for approximately 6 years producing electricity for the site and the national grid. It is also understood that the site has operated somewhat sporadically over the years and the explanation for this is that the material stored in the open is sometimes wet and not of a standard size. The highway authority acknowledge that the erection of the building may well lead to an increase in electricity production and subsequent deliveries of fuel feedstock material to the site.”

We do not accept that this premise is correct; we do not believe that the plant has operated continuously or on a continuous basis and that any problems are related to wet fuel - see above under operating history. 4

The Highways department make another disingenuous statement based upon the false premise of plant continuity:

“The highway authority accept the principles of the Route Management plan but would emphasise that compliance is down to the vehicle driver and adherence cannot be guaranteed but the highway authority accept that the provision is an improvement on the current arrangement and actively encourage its introduction and maintenance thereafter.”

The current arrangement is that the plant is not operating commercially, and highways have no basis to make this statement. It is of interest that while approving a route the department points out that the individual drivers will likely decide which way to go on an ad hoc basis, thereby rendering the proposed traffic management plan futile.

There has been no detail given by the developer to indicate the amount of material to be burnt by the incinerator, the likely number of vehicles to be used, (and how much of an increase this will be, compared to previous, intermittent, operations), where they will be coming from and where they are returning to after leaving the plant. No information has been given regarding the removal of char and how many HGVs will be required for this. Considering that hazardous waste is proposed as a fuel-stock, it would be expected that a traffic management plan would provide detail regarding its safe removal. The Highways department report does not address these important issues. Again, the developer needs to be pressed on his estimates of this since there is no evidence to base this on to date. The issue of waste removal is not addressed at all in the report. b) Non-validated Emissions Report

The developer has produced an Air Quality Assessment using weather data from Hereford (34 miles distant) without taking into account local topography or undertaking any ‘sensitivity’ testing. Monmouthshire County Council should assure themselves of the veracity of this report and – as they have done with previous applications at other sites – commission air quality consultants to critically examine it. NRW assessed this application on the assumption that the plant had been running commercially since 2013:

“As previously indicated in our letter dated 22 March 2019 (our ref: CAS-81147- F8D3), the application form and supporting information suggest the proposals are for physical works at the site, rather than changes to the combustion/gasification process.”

This assumption is likely to be invalid again based upon Ms Bingham’s assertion of continuous commercial energy generation. See Operational history above. Also, MCC, after taking action to reduce traffic originating emissions of late will be undermining any benefits from this if this plant is allowed to proceed (see MVV 2018 Air Quality Progress Report in fulfilment of the Environment Act 1995 Local Air Quality Management). c) No Landscape and Visual Impact Survey

If approved, this plant will considerably alter the rural quality of the currently unspoiled Usk Valley. We can see no evidence of such a survey either by the developers or by MCC to

5 date. This must, based on the criteria used to assess other projects, be a requirement before this application can be assessed. d) No Environmental Health Assessment

The Environmental health report (20/2/2019) addresses only noise levels. The report states:

“The nearest dwellings are approximately 190 meters away from the proposed site boundary and this section has not received any complaints in recent years from the premises relating to noise.”

This is hardly surprising if the plant has not been working continuously at a commercial level. Given the nature of the proposed plant and the use of specified fuels with known hazards proposed for use, it would seem irresponsible for MCC planners not to risk assess the significant other areas and yet we can see no such evidence in the application. Has consideration been given to involving Public Health Wales? It is clear that a comprehensive health impact assessment is required in relation to this proposal, yet we can see no evidence of this.

3. Concerns over Future Developments and Regulation

If approved, this application will require the plant to obtain an NRW permit, based on the fuel-stock information supplied by the developer’s agent in June 2019; we are concerned about the future oversight of this area. Indications are that the owner of the site may require a commercial partner to develop the project and to operate it. What impact would such a relationship have on local control of the plant? How can future expansion be regulated? This application is out of all proportion to the size of the original project approved in 2007, hence residents are clearly concerned by the prospect of yet more expansion in the future. Have planners taken this into consideration? We can find nothing to reassure us on this point on the planning portal in respect of this application.

Furthermore, allowing this project to proceed may well set a precedent for further industrial projects in open countryside to the detriment of residents. Other such projects will impair Monmouthshire County Council’s capacity for future regulation of open country development which leaves Gwehelog Fawr Community Council approaching the future with a degree of pessimism.

We consider that this project could well undermine numerous Strategic and development policies included in MCC LDP:

 S13 LDP Landscape, Green Infrastructure and the Natural Environment;  SD1 LDP Renewable Energy;  EP1 LDP Amenity and environmental protection;  MV1 LDP Proposed Developments and Highway Considerations;  LC1 LDP New Built Development in the Open Countryside;  LC5 LDP Protection and Enhancement of Landscape Character.

For the reasons detailed throughout this report, Gwehelog Fawr Community Council objects to planning application DM/2018/01641.

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