Open Letter to the Planning Inspectorate in Wales, to Pembrokeshire Council and the Welsh Assembly Government, by Pembrokeshire Friends of the Earth, The Environment Network Pembrokeshire and Biofuelwatch
Dear Sir/Madam,
Re: Further consultation on Egnedol’s planning application for a waste and biomass gasification plant with ancillary business activities at Blackbridge, Ref APP/N6845/A/16/3146073
The Planning Inspectorate has re-opened the public consultation about the planning application for a large waste and biomass gasification plant with ancillary developments, but has restricted consideration of comments to ones about local ecology impacts.
Pembrokeshire Friends of the Earth, The Environmental Network for Pembrokeshire (TENP) and Biofuelwatch wish to express their grave concerns about this decision, i.e. about the Planning Inspectorate’s refusal to examine other material planning issues as part of a further public consultation. Detailed joint letters setting out those concerns and calling for them to be fully considered had previously been sent by our organisations to the Planning Inspector and the Welsh Assembly Government during May 2017. We have never received any substantial response.
It is right that the potential impacts of Egnedol’s proposal on protected species and habitats should be very carefully considered, based on appropriate evidence.
However, we are deeply concerned that the potential impacts on local residents and workers and on the economy in Pembrokeshire are being effectively ignored by the Planning Inspectorate, as are questions around compatibility with waste policy. Those issues were not explored during the previous hearings either. Despite clear shortcomings of the planning documents submitted by Egnedol in relation to the development’s impacts on residents and workers, on waste policy, and on the regional economy (which our groups previously highlighted), no further information about those has so far been requested from Egnedol.
Our detailed concerns are set out in our groups’ previous planning objections. They can be summarised as follows:
1) Health and safety risks:
Egnedol’s site falls within two Control of Major Accident Hazard (COMAH) zones. It is widely acknowledged in the literature about gasification that such technologies are associated with fire and explosion risks which are different from and additional to those posed by conventional biomass combustion plants. Syngas produced from gasification is a mix of carbon monoxide and hydrogen, the latter being highly explosive. It is vital to prevent either a build-up of pressure or sudden depressurisation inside the gasification chamber so as to prevent an explosion.
In view of those serious risks, the European Commission has published guidelines for safely operating biomass gasification plants, i.e. for minimising health and safety risks[1]. We would question whether the residual risks for a biomass gasifier operating according to the guidelines could ever be justified inside COMAH zones. However, this is a purely theoretical question because Egnedol’s planning proposal does not accord with the safety guidelines.
For example, the European Commission Guidelines include a detailed discussion of the necessary gas flaring system, stating, amongst other things:” Typical emergency shutdown measures include: + stop feeding to the gasifier; + stop air supply to the gasifier; + direct the gas to the flare; + note: inerting the gasifier with nitrogen is not effective as the gasifier normally contains a lot of fuel and charcoal.”
Egnedol, however, proposes to build a large gasifier with no emergency flare, which means it will have no credible means of preventing an explosion in the event of an emergency shutdown, e.g. if a turbine or engine unexpectedly malfunctions. We note that Policy GN1 of the Pembrokeshire Local Development Plan requires public health and safety impacts of developments to be considered. We are deeply alarmed by the fact that fire and explosion risks continue to be ignored entirely, despite the fact that Egnedol proposes to build a plant that contravenes safety guidelines, thus posing a significant explosion risk inside two COMAH zones.
2) Lack of evidence of compliance with sustainable development principles:
Egnedol’s site is one of two strategic employment sites identified in the Local Development Plant. It is therefore vital for the region that any development should create long-term local employment. As we have shown in detail in our planning objections, there are strong reasons to doubt the technical viability of the proposed development. There is thus a high risk that planning approval would result in planning blight for this site, and possibly in lengthy unsuccessful construction and development attempts – thus preventing any credible employment generating activities from being developed.
3) Lack of evidence about compliance with EU, Welsh and local waste policies and legislation:
Egnedol states that it intends to gasify around 50% waste derived fuel, yet the company has not even been required to disclose what type of waste it would source, where the waste would come from, or how efficient its energy conversion would be. Without information about the type of waste which Egnedol intends to use, its calorific value, and a comparison of greenhouse gas emissions from gasifying such waste compared to recycling it, compliance with the waste hierarchy and waste proximity principles cannot be credibly assessed.
4) Pollution and Human Health:
In its previous Local Impacts Assessment Report, Pembrokeshire Council warned of inadequacies in the pollution assessments. We are particularly concerned about air quality impacts given that the stack height is on a level with nearby residential properties. Yet the Planning Inspectorate is limiting consideration of air pollution impacts to those on biodiversity, not on human health.
We are deeply concerned that the way in which the Planning Inspectorate has so far handled this case does not allow those material planning issues to be properly assessed – including those related to waste policy and to the Wellbeing of Future Generations Act – and that the health and safety of residents and workers is being put at serious risk as a result.
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Yours faithfully,
Bettina Becker, Pembrokeshire Friends of the Earth
Charles Mason, The Environment Network Pembrokeshire
Almuth Ernsting, Biofuelwatch