Last week, South Marston Parsih Council responded to the Borough following consultation on revised application documents for the Energy Centre.
The Parish Council submitted a report on the application. This report can be seen below:
South Marston Parish Council (SMPC) Energy Centre Report March 2017
This SMPC Report is in response to the Keypoint Swindon Waste Gasification Plant (WGP) Environmental Statement Updated Non-Technical Summary by Rolron Kilbride (RK) October 2016. We have already in December 2016 made comment on the Traffic and Transport report in July 2016 but there have been developments in the issues since then as there have in the predicted Air Quality. These will be addressed below.
2. Technical Expertise
RK has stated that: “Energos will be the technical partner for the project and Energos will, as a minimum, operate the plant for the first two years following commissioning including recruitment and training of the personnel.” Unfortunately, Energos is now in administration and it is not clear who will fulfil this role and have the experience to operate the plant and be available for questions about the technical data in support of the air quality assessment. Furthermore, Energos holds the patent for the gasification process and it is also unclear how this will affect the new development if the new patent holder is not involved.
3. Page 3 Introduction
The plant does not produce renewable energy and the term ‘Renewable Energy Centre’ is misleading as it suggests the plant is carbon neutral and produces no emissions. This is patently not the case – the term ‘Renewable Energy Centre’ implies that the plant is more environmentally friendly than it actually is. We request that the more accurate title of ‘Waste Gasification Plant’ is used.
4. Page 16 Proposed Development
What protocols are proposed to prevent the acceptance of hazardous or clinical waste?
5. Page 18 Fire Water Tank
With respect to the Fire Water Tank, the use of the word “would” is not understood as it implies an associated condition. Please confirm that a Fire Water Tank is to be installed and change “would” to “will”.
6. Page 20 Operating Hours
It is stated that HGV movements will be spread evenly throughout the day. We had requested that movements be minimised during peak traffic flows in the early morning, mid day and evening rush hours for existing HGV traffic, particularly that delivering to Honda. This request has not been addressed. We therefore request restrictions on HGV movements during peak times.
7. Page 23 Air Quality
Paragraph 5.2.8 of the RK Air Quality Report July 2016 states:
“The proposed plant is not operating and as such its performance with regard to pollutant releases is unknown. However, there is some guidance from a similar plant operating elsewhere. A similar sized system to that proposed for this development, with two lines, has been operating in Sarpsborg in Norway for some time.” The Air Quality data recorded at the Norwegian plant is then read across to the proposed plant as Paragraph 5.2.152 states:
“When the air quality assessment has indicated the requirements for a more detailed investigation of a release, reference is made to the measured releases from the Sarpsborg plant.”
However, the proposed plant has three lines, not two, and there is no comparison made of the feedstock planned here compared with Norway. The pre-processing at both plants appears to be the same but the website of the Energos plant in Norway states that the plant uses “residual, non-recyclable waste” whereas the proposed plant
will use “Refuse Derived Fuel (RDF) together with other pretreated wastes”. There is no definition of any differences in these feedstocks which casts doubt on the validity of the readacross of the data.
Page 30 Traffic and Transportation
We had made comments in our previous response about the inconsistencies in the predicted traffic flows resulting from comparing the impact of the WGP contribution with the movements that were predicted to occur if the Warehouse that was approved in 2011 on the same site had actually been built, thereby hiding the actual WGP increase on existing HGV movements of 99 HGVs arriving and departing. These have not been addressed in this updated report. Please could our concerns be properly addressed and revised figures provided?
Furthermore, since the RK traffic flow analysis in July 2016, we have experienced queues of HGVs, at the peak times quoted above, blocking the narrow railway bridge on Thornhill Road, between the Gablecross roundabout and Keypoint roundabout, in both directions effectively closing the Thornhill Road access and exit from South Marston Village. We had this email extract from Honda on 7 October 2016:
“As you are aware, the volume of deliveries to our Key Point facility has increased due to the changes to our daily production volumes. We appreciate that this has an impact on the local road network and would like to assure you that we are continually monitoring the situation and taking action to limit congestion.” This increase post dates the data collected for the RK Report.
If an additional 99 HGV movements were to be added to the existing level of traffic, which does not include the HGV traffic to the Thornhill Industrial Estate, or the increase in Honda “Just-in-Time” deliveries, or the threefold increase from the expansion of South Marston village, the short length of road between the Gablecross roundabout and Keypoint would not have the capacity to allow such an increase without causing unacceptable blockages and dangerous deterioration in road safety. The blockages would probably cause grid lock back to the A420 at the roundabout. Also, it is also very unlikely against this background traffic that the new plant will be able to receive up to 50 arrivals and send up to 50 departures in a 12 hour period, every quarter of an hour, because of the traffic jams that will not allow it, even if the Honda peak times are avoided. Surprisingly, the RK report makes no attempt to model this problem which we believe to be essential.
We conclude that the supply route for the proposed plant between the Gablecross roundabout and the Keypoint roundabout does not have the capacity for the increase in HGV traffic delivering to the proposed plant. Furthermore, the validity of the readacross from the air quality data from the Energos plant in Norway is doubtful at best until it can be demonstrated that any differences in the feedstock and number of lines has no effect on the air quality of the exhaust from the stack. Finally, the recent administration of Energos, which held the patent for the gasification process, leaves a gap in our confidence that the operators will have the right experience and there will still be technical experts to support the data on which this development proposal is based.
7 Mar 2017