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October 2008

For the attention of: Kate Stephens, Principal Planning Officer - Major Projects, Telford & Wrekin

Dear Miss Stephens

I write as a local resident, and member of CPRE Telford & Wrekin District Group, to object to the above planning application.

Saved policy NR1, of Wrekin Local Plan 2000 states that the Council will support proposals for generation of power from renewable sources providing they do not have negative impacts on the local environment. Also the proposals should accord with other policies, particularly those regarding Countryside and Open Land.

The proposed site for the incinerator is in the Telford green network and close to the local nature reserve of Granville Country Park.

Therefore saved policies OL2,OL3 and OL4 of Wrekin Local Plan 2000 are applicable to this proposal.

Policy OL2 states that development will not be permitted which is likely to affect, either directly or indirectly, local nature reserves, unless there are no alternative sites, and the benefits of the proposal significantly outweigh the importance of the Nature Reserve.

Wrekin local plan paragraph 8.3.9 clearly states that "the Council will not hesitate to refuse planning permission for development that has an adverse effect on the green network and makes no contribution to its overall function or value".

Saved policy OL4, only permits development in green network if;-

a) there are exceptional circumstances.

• There appear to be no exceptional circumstances present.
• The applicant has identified in the application a number of other sites in the borough which could equally be suitable.

b) it contributes or is complementary to the aims of the Green Network.

• The application does not contribute or is complementary to the 6 aims as stated in paragraph 8.2.12. In fact the opposite is true.
• Because of its overall size and location on the side of a hill, the incinerator will have a visual impact on people visiting the country park.
• The scrutiny commission for environment and regeneration issued a report in 2005 on Granville Park. One of the recommendations was that the park be extended. I understand that this is now in the process of being implemented.
• This will bring the park boundary even closer to the proposed incinerator site.
• Due to the height of the stack this visual impact, particularly from the gas emission plume, will be seen over a wider area, particularly to the north, including the golf and horse riding recreational centres.
• The applicant claim that the emission plume will be visible 10% of the time. This will be weather dependant, so on certain days this percentage will increase.
• The applicant have based their environmental impact report on the use of a dry gas scrubbing system. If in order to get an operating permit they have to change to a wet scrubbing system, they should clarify what effect this will have on the time the plume is visible.
• I could not find any reference in the EIA of the visual impact from any hot air pluming from the air condensers. Due to the height of the condenser discharge, and low efflux velocity, this could become a nuisance to the local properties, and have a visual impact on people using the country park.
• The extent of pluming could increase during times when the steam turbine is bypassed for maintenance, and if no user is found for the waste heat from the boiler.
• I note from the application supporting statement, paragraph 3.91, that the likely recipients for the surplus heat energy from the incinerator are industrial processes in the nearby business parks.
• However I cannot find any mention in the application how the heat is to be transferred from the incinerator site to the end user. This needs to be clarified as it could have adverse effects on the green network.
• During the two year construction period, visitors to Granville Park will be subjected to noise from the building of the incinerator, and disruption when the incinerator electric supply cable is being installed, as the cable route passes along one of the main access roads.

c) environmental and community benefits are an integral part of the proposal.

• The application does not provide any of the benefits as stated in paragraph 8.3.15.
• My understanding from the Parish Council is that there are also no other benefits to Donnington and Lilleshall Parish.
• Even though the regulations concerning gas emissions from incinerators have recently been tightened, there is still a debate amongst experts on the long term effect of exposure to the emission chemicals and particulates.
• This coupled with the fact that the incinerator and stack are highly visible, could reduce the number of people prepared to visit the Country Park, and the local area.
• Following the closure of the Granville Colliery, the Councils policies have ensured that the landscape of the surrounding area has changed from industrial to one which has a collective value for nature conservation, recreation, access, and visual quality.
• Given the requirement by central government to reduce waste to landfill the remaining industrial activity connected with the operation of the landfill site will gradually reduce.
• The approval of this planning application will reverse this and result in increased noise, environmental and visual impacts on the surrounding area for the foreseeable future.

Yours faithfully

Mr J.W.COX
CPRE Telford & Wrekin