1. The Infrastructure Planning Commission Temple Quay House Temple Quay
Bristol BS16PN
22 March 2011
Dear Sir/ Madam,
With the IPC due to consider proposals for an Energy to Waste Incinerator at Brig y Cwm in the coming months, we
write to express our views, as locally elected representatives, but more importantly, as residents of Merthyr Tydfil &
Rhymney who care deeply about the future of our communities.
We believe that this response also reflects the views of the hundreds of constituents who've approached us to express
their concerns over the plans since they first emerged in 2008. We feel it is worth reiterating our main concerns about
the proposed development:
Above all, we are deeply anxious over the size and scale of the proposed incinerator. As has been pointed out
previously, at over 115m in height, the stack would be taller than the Meridian Tower in Swansea, which is currently
the tallest building in Wales.
While we note that in your most recent 'newsletter' for local residents, dated February 2011, the application talks about
the revised design for the incinerator which is supposed to mirror "the rolling shape of the surrounding landscape" and
"blend in well with its surroundings", it is obvious that the plant would totally and utterly dominate the landscape of the
surrounding area.
We do not feel that adding a curved roof to the plant is going to make it blend in -it would be the largest structure for
miles and would be dominant on the horizon in a landscape which we are increasingly seeking to promote for leisure
and tourism activities. Neither do we believe that the addition of "green and yellow shades" to the exterior of the plant
will make any real aesthetic difference.
Another key concern, which has been repeatedly raised but never adequately addressed, is the source of the waste to
be processed at this plant. 750,000 tonnes is a significant proportion of the non-recyclable waste currently produced in
Wales annually, and the Welsh Government's "Towards Zero Waste" strategy will reduce this figure still further in the
coming years.

2. In 2008-9 just over 1.7 million tonnes of municipal waste was produced in Wales, and data for the industrial and
commercial sectors shows that, combined, they produce about 3.6 million tonnes of waste annually. Of that, 37% of
municipal waste was recycled and rates for the commercial and industrial sectors are over 50% and rising.
As the years go by there will be less non-recyclable waste locally to meet the needs of the plant, and it seems very
likely that waste would have to be bought in from further afield to meet the needs of the plant -certainly from England
and perhaps even from abroad. This runs directly counter to the 'proximity principle' that is at the heart of the Welsh
Government's strategy -the idea that waste should be handled as near as possible to where it was produced. In the
event of insufficient recyclable waste being available the need for mixed fuel co-firing may become necessary but is as
yet not described.
We note that in Covanta's Feb 2011 "Brig y Cwm newsletter" 'independent' research is highlighted which argues that a
single 'large-scale' facility would have less impact on climate change than several smaller waste treatment facilities.
While it is not for us to question the validity or otherwise of that research, policy in this regard should be driven by the
Welsh Government's own research and strategies, rather than research commissioned by those with vested interests.
Again, such an approach is inconsistent with the 'proximity principle' so central to the Welsh Government's "towards
Zero Waste".
We are not scientists, so we will leave the detailed arguments over the impact on the environment and local people's
health to others. But we are also seriously concerned at reports from America that Covanta has been fined for
exceeding carcinogenic emission levels. Whether you look at lower life expectancy, poor public health or
unemployment caused by illness and disability, in many ways, communities in Merthyr Tydfil & Rhymney are still
recovering from the legacy of heavy industry and its impact on the health and wellbeing of local residents. We would
be deeply concerned about anything which would threaten that recovery.
As elected representatives with strong links to the trade union movement, we are incredibly worried about reports from
the states on Covanta's record of industrial relations. It's a concern that is shared by the main representative body for
Welsh trade unions, the Wales TUC, as well as many of their individual member organisations.
None of us underestimate the importance of economic development and regeneration in Merthyr Tydfil & Rhymney.
While the 81 jobs this facility could bring to the area would be a welcome boost to the local economy -we do not want
jobs at any cost, and it frankly seems a scant return considering the amount of disruption the construction and long-
term operation of this site would cause local residents and the environment.

3. Covanta, we can't help but feel, would be getting far more out of this site than they would be putting back into the local
community, and we passionately believe that this is the wrong development, in the wrong place and at the wrong time.
Our communities have seen many remarkable improvements in the last fifteen years: New health facilities constructed
throughout the constituency which are beginning to improve the wellbeing of the local population, a massive
investment in education which has seen six new schools built and Merthyr Tydfil becoming a university town, a first-
class arts centre to be constructed in Merthyr Town Centre which will add to the areas tourism potential, and the
Welsh Government relocating over 400 jobs to the local area.
That is the image of Merthyr Tydfil & Rhymney we all want to promote: proceeding with this development would send
out totally the wrong message.
To put it simply, we are firmly against the proposals, and are now more convinced than ever that this
development would be bad for Merthyr Tydfll & Rhymney and its people and we will work tirelessly to show
that Covanta Energy's plans are inappropriate and unacceptable.
Copies of this letter will be made available to our constituents.
Yours Sincerely,
HUW LEWIS AM DAI HAVARD MP
Merthyr Tydfil & Rhymney Merthyr Tydfil & Rhymney
CLLR. BRENDAN TOOMEY CLLR. GERALD JONES
Park Ward New Tredegar Ward
Opposition Leader, Merthyr Tydfil Council Deputy Opposition Leader, Caerphilly Council

4. CLLR. PHIL WILLIAMS Moriah Ward
Dowlais Ward
CLLR. DAVID HARDACRE
CLLR. RAY THOMAS MBE Darren Valley Ward
Dowlais Ward
1%f:,----) CLLR. CHRIS BARRY
Park Ward
CLLR. DAVID JONES
CLLR. BRENT CARTER
Town Ward
Plymouth Ward
CLLR. BILL SMITH
Gurnos Ward
CLLR. DAVE PHILLIPS
Gurnos Ward
CLLR. CLIVE JONES
Park Ward
CLLR. JOHN BEVAN
Moriah Ward
CLLR. GAYNOR OLIVER
Pontlottyn Ward
CLLR. LES REES MBE
New Tredegar Ward
CLLR. RICHARD PUGH