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FRENCH REPORT November 2004
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| Winbeg Info |
| SECTION 1 THE FAILUTE TO MEET ENVIRONMENTAL JUSTIFICATION CRITERIA We learn from the Economic Impact Assessment pages 5 & 6 that there is a measurement beyond which there is no environmental justification for a BIOMASS Power Plant. "The central 50km (31 miles) ring refers to the theoretical boundary beyond which the benefits of using CO2 neutral fuels are negated due to the extended distances they must be transported." This is not achieved by the WINBEG proposal and therefore the application should be refused since the proposal fails to satisfy the needs of either the Structure Plan or the Local Plan. (Environmental Statement, page8) |
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SECTION 2 |
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| 2a. Significant
Errors or Omissions Contained in the Technical Review with regard to the
Forecast for Lorry Deliveries
each Weekday. (In order to calculate the average cubic volume and also the average weight of a bale, data has been taken from: - "Miscanthus: Practical Aspects of Biofuel Development (The ELY Trial): Heston Bale (rectangular) dimensions; max 1.28x1.33x2.50m - min 1.22x1.27x2.25m; Density 125-145kg/cubic metre. From this data, the volume of each bale varies between 3.486-4.256 cubic metres and therefore weighs between 436-617kgs.) Page 1 of the Technical review refers to 140,000 tonnes required each year. It is forecast that 66,000 tonnes of this will be miscanthus with the remaining 74,000 tonnes being other biomass material. Footnote1 of page 1 of Technical Review suggests 29 deliveries each weekday using lorries of 60 cubic metre capacity and carrying 20 tonnes of material. Using an average volume of 3.87 cu/m per bale, a 60 cubic metre lorry will carry 15.5 bales. Using an average weight of 526.5 kgs per bale, the max weight of material per load is 8.4 tonnes. There is therefore either an error within the calculation of page 1 of the Technical Review which states that a 60 cubic metre lorry will carry 20 tonnes of material, or alternatively the cubic capacity of each lorry is 120 cubic metres ie. a large lorry with a trailer which is not mentioned within the report. If it is intended to use such lorries and trailers, this must be considered a major and somewhat careless omission within this report since the congestion and disruption caused by a 120 cubic metre lorry in these minor roads ("minor roads" EIA page 4) and through the small villages of Beaford or Atherington would be very stressful to local inhabitants. Since it is highly improbable that this was an intended omission, we must assume this was an error. Given the nature of the roads around the plant, it is far more probable that this was a critical error in this report and therefore 60cubic metre lorries will be used as opposed to 120cu metre lorries with trailers. The revised calculations for additional HGV journeys generated by this plant would therefore be as follows: 66,000 tonnes of miscanthus equates to 254 tonnes being required each weekday. This requires 30 deliveries each weekday using 60 cu metre lorries. In addition to the miscanthus deliveries, 285 tonnes of other fuels will be delivered each weekday. Assuming twice the density of miscanthus (20 tonnes per load), this requires an additional 14 lorries each weekday, a combined total of 44 lorries each weekday. This excludes waste collection and other normal deliveries. For the sake of completeness, it is a reasonable assumption that a further 6 lorry journeys each weekday will be required, thereby making the total 50 deliveries or collections, thereby producing in excess of 100 HGV journeys each weekday as a direct result of this plant. This excludes and tractor and trailer journeys from the farms to the various collection centres or any car/van vehicular traffic generated by the staff working at the centres or the plant. Selby Experience An interview with the operators of the Selby plant highlighted that they achieved 9.5 tonnes average weight per delivery - less than 50% being forecast by PPL. Remarkably similar to the calculations above. It is clear from either of the above methodologies, there are significant errors in the Technical Review which has a very significant impact on the local environment and community through the volumes and size of Heavy Goods Vehicles required to supply fuel to the plant. |
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| 2b Significant
Errors Contained in the Environment Impact Statement Regarding Assessment
of Traffic Impact Notwithstanding the errors highlighted within the Technical Review, there are significant concerns over the quality of information and scale of transport being suggested in the EIS document. Using page 12 of this report there are various surveys which highlight the current traffic volumes on arterial routes and on the Winkleigh bypass. There are also forecasts of a 1% increase in HGV traffic. "HGV movements from fuel deliveries during the Monday to Friday 7am to 7pm delivery period are estimated to increase HGV flows during this period by approximately 1%" In order to understand the specific volumes being forecast, the following table has been compiled from the data supplied:
Total Additional HGV journeys created by WINBEG 5 Please note, these are one way journeys and therefore this report calculates that there will 2-3 lorries per day only serving the plant if we accept their estimate of a 1% increase in HGV traffic - each carrying in excess of 100 tonnes!! As calculated in the above section, on the basis of using 60 cu metre lorries, 100 HGV journeys each weekday will be generated by this plant and not the 5 used by Scott Wilson when assessing the environmental impact of the increased traffic. The EIA is therefore fundamentally flawed with regard to the key consideration of the impact of traffic on the community and therefore the application should be refused. Indeed the scale of this oversight in such a key subject as transport impact, calls into question the integrity and relevance of the EIA report. |
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| 2c Sensitivity
Analysis of Vehicular Traffic In order to truly assess the potential scope of impact on the environment, it would be normal to apply sensitivities to these forecasts of HGV traffic generated. The application of various sensitivity analysis identifies that the potential transport impact could be significantly increased thereby having a greater impact on the environment. i) Estimates of Total Tonnage required It is significant that these forecasts assume that the tonnage of dry fuel required by the plant will be in the order of 263 tonnes per day. (Page 20 of the Technical Review) in order to produce 12.9MW of electricity from this stage of the process. On page 16 of the Technical Review, there is reference to the Vermont plant producing under trials 8MWe using up to 200 tonnes per day of fuel. If we apply a simple extrapolation of the power outputs being forecast and apply a similar increase to the tonnage used during the Vermont experiment, then this would require in excess of 320 tonnes per day, an increase of 20% over the forecasts. This could increase the additional daily HGV to 52 deliveries per day. It is recognised that this assumes no efficiency gains over the Vermont experiment, however it must be stressed that the proposed plant at Winkleigh is almost 50% greater capacity and has never been tested. ii) Crop Volumes within 50 mile Radius It should be further considered that if the yields forecast for the miscanthus crop or the percentage of farmers entering into the production of this crop were less than forecast, then this would require another extension of the catchment radius which would in turn have a significant detrimental effect on the traffic impact. iii) The Impact of Increased Transport Impact arising from the need to use Alternative Fuels as the major fuel source for over six years Whilst variations of the type of fuels used will determine the size of lorry and the numbers of vehicles passing through the parish of Winkleigh, the distance the fuels have been transported is of little consequence. However the distances for the collection of the alternative fuel is very significant to the surrounding parishes, to all of the districts within Devon and even different Counties. This is particularly relevant given the fact that these alternative fuels will supply the majority of the plant's needs for over six years. The Fuel Assessment report offers various alternative fuel sources which could be used. Page 13 suggests "There is significant forestry product availability both within the SW and nationally that could be diverted to WINBEG". There is no reference to the likely transport distance required for this fuel. However, since it refers to the SW catchments and also to national catchments it is unlikely that this is within a 25 or even a 50 mile radius from Winkleigh Page 16 refers to the use of Wood Waste as an alternative fuel. Again they refer to the quantities of fuel available on both a national and SW basis. Again no estimates of travel distance are offered. On the basis of the assumption that the majority of sources of this fuel as highlighted (page 16) will come from major conurbations and since all of these are located beyond 25 miles, then it is a fair assumption that the transport distances exceed 25 and in most cases 50 miles. |
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| 2d Scale
of HGV Traffic being Generated from the Winkleigh Plant It is very difficult to assess the total annual mileage of HGV traffic which this plant will produce given the uncertainties of the distances which the alternative fuels will have to be transported and also of the total fuel required to generate the proposed levels of electricity. Any mileage calculation must also consider that HGV vehicles will have to travel from their depot to the farm, (or waste disposal yard or wherever for the alternative fuels) and then to the plant and then return to the depot after delivery. The minimal radii referred to must be increased to round trip journeys plus deviations as described. Furthermore the HGV vehicles will be directed to use designated roads (EIA page 12). Given the "minor roads" which prevail around Winkleigh this will have a significant impact on the total travel distance. For example, the HGV route to Exeter and beyond from Winkleigh is via North Tawton and Whiddon Down, a significant increase over the direct non-HGV mileage. Tiverton, Taunton, Launceston and Plymouth all require HGV detours. These have a significant impact on the total mileage traveled when compared to the theoretical minimal radii used in the Fuel Supply Review (page 12). During the first 6 years when the various forecasts demonstrate that the majority of the fuel will be sourced from non energy crops from the general SW region and beyond, it is quite feasible to use an average round trip of 65 miles per lorry allowing for deviations and returning to depot etc. On the basis of 56 lorries deliveries required each weekday, this would produce an additional 946,400 miles of HGV traffic each year. |
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| 2e) Summary
of Environmental Assessment Report with regard to Traffic Impact Page 12 of the Environment Impact Assessment states: "It is suggested that the very modest traffic increases due to WINBEG do not give need to carry out significant mitigation measures to overcome environmental or safety concerns." This statement was made on the basis of their calculations which has proved to totally underestimate the traffic volumes generated. The magnitude of the error in forecasting additional HGV traffic is such that the report calculates 5 HGV journeys per day whereas approximately 112 HGV journeys each weekday will be generated. The scale of the impact of traffic is a major consideration of the Planning Review and since this report is fundamentally flawed and consequently lacks credibility, it cannot therefore be used by TDC in order to asses the environmental impact of the project. It should be noted with extreme concern that during the "consultation meeting" with the Winkleigh Community on 23rd November 2004, a presentation was given by the authors of the EIS. At no time was any mention of an error offered. It was only when challenged over the error detailed below was any error in the report confessed to. The meeting was then advised that a revised and amended report had been forwarded to the Planning Authority. The report should have read a total increase of 1%. Taking the information supplied above, the average daily HGV traffic movements around the airfield area is 228 which will increase by an additional 112 movements per day. This represents an increase of almost 50%. This was a disgraceful misrepresentation of the facts and a deliberate attempt to mislead the public. The authors of this reports are very aware that the impact on the local community of HGV traffic is far greater than normal cars etc. By failing to advise the meeting of the impact of HGV traffic as opposed to the increase of overall traffic, they were clearly intending to mislead the local community. This was a flagrant abuse and once again demonstrated the biased nature of this report. Consequently, this report should be dismissed. |
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SECTION 3 Impact on Tourism There is a fundamental flaw on this section of the Economic Impact Assessment page 20, section 7.2 . The introduction of the Key Implications for the 10 Year Tourism Plan as displayed on the South West Tourism website states in the opening argument that "Tourism generates £8.3 Billion to the economy the South West and employs 307,000 people." The Economic Impact Assessment page 20, states this as £4.4b. It underestimates the total value of tourism in the South West by almost 50% because it has considered staying visitors only! It has failed to recognise the contribution from day visitors which is almost 50% of the revenues. This is totally unacceptable and once again calls into question the value of these reports to the Planning process. From the SWT website, the following analysis is obtained:
Devon has the largest proportion (26%) and 59,438 FTE jobs employed. 16% of employment in Devon is related to Tourism. Winkleigh is unique in that if falls close to the boundary of four
councils and therefore any impact on tourism will be spread across all
four areas. A significant proportion of the revenues and those employed
within these areas come from "countryside" tourism as opposed
to "Coastal" tourism - critical to this planning application.
The South West Tourism Intelligence Project, page 109 states; "The whole relationship between the landscape, public access, agriculture and tourism is important across the region, within and outside of the protected areas. This was strongly demonstrated by Foot and Mouth Disease. Since the middle of the last century some of the rural attractiveness of the region has been lost,….,and could be further threatened by changes in agriculture. Villages and small towns are extremely important to the rural economy and the visitor experience of these inland areas. A characteristic of inland rural areas, which has an important influence on tourism performance, is their relationship to transit routes which cross them." Winkleigh falls between the two moors and also the Taw and Torridge river valleys which each have their specific tourist attractions. There is therefore considerable "transit tourism" arising from its unique location which could be vulnerable were this plant to go ahead. It is a fragile economy with farmers topping up their incomes through the tourism sector. Summary on Impact on Tourism The Economic Assessment page 20, offers a summary on the impact on tourism which beggars belief. "It is difficult to say exactly what effect WinBEG might have on the tourism sector since there has never been a plant of this size and type before………. While the views of consultees (drawn from local businesses, local authorities and regional and national government bodies) tended to be negative (though not exclusively) it is thought that WinBEG could contribute to the tourism offer of the area." There can be little doubt by anyone that the introduction of one of Europe's Largest Biomasss plants; located on one of the highest visual point in central Devon; consuming 140,000 tonnes of biomass fuel per year which requires transportation to the plant from across the region and beyond; generating over 950,000 HGV miles per year on the West Country roads, will have a negative impact on tourism. This comment highlights more than any other, the fact that this report has been written with no serious consideration of the negative impact of this plant and has been crafted to consider the additive aspect only. It is not an objective and independent study and consequently should be dismissed.
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| SECTION 4
Scale of The Proposal and the Risks Involved The risks can be categorized in several areas: a) Technical The scale of this plant is very significant in that it will be 50% larger than previous short term demonstrations. None of these experiments ran on a long term basis whereas the normal period of demonstration is for a 1 or 2 year period. (Technical Review, page 14) It is remarkable that none of the experiments ran for a significant period of time yet the Technical Review spends but a few paragraphs explaining these failures as non technical. It is staggering, given the technical risks involved and the completely theoretical scaling-up of these demonstrations, that the authors of this report FAILED to consult with any of the companies involved in these experiments in order to verify the reasons for failure. (Technical Review, page 30) They appear to have concentrated their research on FERCO, the manufacturer of the technology to be used. This can hardly be considered as an objective review. b) Fuel Source There are relatively small amounts of miscanthus crop currently grown within the 25-50 radii from Winkleigh and therefore there is considerable risk over whether the crop potential will ever materialise in the volumes required as confirmed in the Fuel Supply Report. (This has a significant influence on the transport impact due to the greater distances required to source the alternative fuels.) It is entirely feasible that Energy crops will never provide the majority of the fuel source in this area. c) Ongoing Financial Capability The Royal Commission on Envirnomental Pollution - Biomass as a Renewable Energy Source page 57, states that "Bauen has calculated mean economic road transport distances………………………………20km for miscanthus." As stated previously, the Fuel Assessment clearly states that this
will not be feasible with this proposal. There must therefore be serious
concerns on the ongoing financial viability of the plant, irrespective
of the grant aid - were this to be applicable which it is not under
current guidlines. |
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| SECTION 5
The Failure to meet both the DTI Funding and DEFRA grant support Criteria and the Impact on the Financial Viability of the Project.
As detailed in the Economic Impact Assessment page 4, "Government guidelines state that, in order to qualify for a DEFRA grant, energy crops must be sourced from within a 25 mile radius of the plant." b) DTI Funding is based meeting the timescales for achieving sufficient energy crops from the locality. As detailed in the Biomass Fuel Supply (BFS) report page 9, "A requirement to achieve 25% feedstock supply from energy crops by the end of the third year of power station operation and 50% by the end of the sixth year." and "Energy crops must comprise 50% of the fuel mix of WINBEG by year 6 of power station operation ion order to comply with the terms of the DTI grant (with 25% energy crop fuel supply by year 3)." In order to consider whether Planning Permission should be approved for the siting of this plant at Winkleigh, the first consideration must be to test whether these overriding Government criteria are met. The WINBEG Fuel Supply Review (FSR), Summary and Conclusions, page 101 states "Overall, there is sufficient agricultural capacity to produce 55% of WINBEG's fuel requirements within the region, BUT NOT WITHIN THE 25 MILE RADIUS…" This fundamental test of suitability of the location therefore fails to meet DEFRA criteria. Page 101 of the FSR goes onto state that "Even with an active grower group in the region, scale up will be a challenge in the time frame required." The reports therefore confirm that the timescales as required by the DTI are also not met by the proposal It is clear from the failure to meet these two basic criteria, the proposed site at Winkleigh should be refused planning permission. Consideration for Alleviation of these Fundamental Criteria In order to promote the acceptance of this proposal, the FSR (page 101) highlights that "Increasing the supply radius to 50 miles provides sufficient land resource.." In addition, they recommend that "PPL formally request an extension to the current 25 mile energy crop fuel supply radius……and that they engage in further discussions with DTI about extending the deadline for reaching maximum energy crop fuel supply…" The FSR (page 33) refers to a 50 mile radius and states that "There have been many precedents of increased radii being accepted" and suggests a further qualification for this consideration being "…the proximity to good trunk road links…" There are no good trunk road links near Winkleigh. The FSR fails to consider assessment of the suitability of Winkleigh as detailed in the EIA (page 4) which provides a matrix of considerations which indicates that of all the sites listed, the traffic assessment for the Winkleigh site is the lowest and describes these as "Minor roads leading to the site…." The Planning Authority should not be tempted to approve the planning application on the basis that this alleviation might be granted since the reports themselves highlight that the location fails to meet even the criteria for alleviations.
The various reports commissioned by PPL and the RDA identify that neither of these criteria are forecast to be achieved by some significant margin. As a consequence, unless alleviations are granted to the criteria of the maximum radius, it is unlikely that farmers will be financially induced to grow the crops and therefore the crop potential will be significantly reduced. However the alleviations should not be granted in an area where there are only minor roads. Similarly unless an alleviation is applied to the 6 year target, the
DTI funding will not be achieved with the consequential financial impact
on the project. |
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| SECTION 6
Project Management "The most common arrangement in conventional power sector projects is for the developer to employ a prime engineering, procurement and construction (EPC) contractor who takes care of the project risks and provides a guaranteed turnkey service for the developer. This approach, while providing comfort for the developer, is high cost. PPL has decided to appoint a Project Management Team (PMT) to oversee the project rather than employ an EPC contractor……" One of the benefits of appointing an EPC is to delegate the responsibility and accountability for the project to one company. Penalties normally apply for failure to deliver the project on time, on budget and full operational. This minimizes the risk of delay or failure of the project. Given the complexity of this project and the technical risks involved
and also the amount of Government funding being offered, surely this
high risk strategy merely adds to an already high risk project? |
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| SECTION 7
Visual Impact Winkleigh Airfield is located on high area of ground between Dartmoor and Exmoor. It enjoys a panoramic and unbroken view from the airfield to Dartmoor and vice versa. It is unique in that it is located on a large plateau which was the very reason that the site was chosen as an airfield. This location is on the horizon for a significant part of Central Devon. Any large structure will therefore be a scar on the landscape. The plume of smoke or steam which will emanate from this plant will also be on the horizon and therefore the sight line. It will destroy the visual aspect of this core part of central Devon. To make matters worse there is the suggestion that this plant be called Winbeg1 and therefore there is already an argument being prepared by the applicant that this area be turned into an industrial area. This cannot be allowed to be developed since it would have a significant
detrimental impact on the visual aspect of the area where there is a
major push on developing tourism. |
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