Review of the Vale's "Local Development Plan" FoE's FINAL RESPONSE

https://www.valeofglamorgan.gov.uk/Documents/Living/Planning/Policy/RLDP/Draft-Review-Report-2021.pdf

REVIEW OF THE VALE OF GLAMORGAN LDP STRATEGY

They Say:

1. To promote development opportunities in Barry and the South East Zone

2. The St. Athan area to be a key development opportunity

3. Cardiff Airport a focus for transport and employment investment

4. Other sustainable settlements to accommodate further housing and associated development

They attach “also” to   ## Climate Emergency and ## Nature Emergency

6.4.3 measures to address the climate and nature emergencies will also be key matters for the Replacement LDP

These as fundamental, not 'also' add-ons.                         Climate Change Wales Regs. 2021

Responses submitted 31 January

        “Emergency” means priority for climate and nature: freeze or drop past plans and projects

Instead of above list, we'd substitute

1. Priority to the climate crisis and the nature crisis; cut back development and save natural sites

2. Restrict housing sites to rail/bus linked + small developments within settlements for local need

3. Invest in flood mitigation +SuDS, sewage treatment and sustainable transport for resilient communities.

4. Plan to downgrade the Airport-St Athan enterprise zone (6.3.19) ; cut out the Model farm development

5. Boost local shops and facilities and rejuvenate town centre to reduce the needs for travel.

6. No developments in the coastal strip apart from facilities that need a coastal location

7. Promote tourist opportunities and facilities, restore beaches to Blue Flag standards

The LDP has to integrate responses to the climate and nature emergencies (CC Wales Regs.21

Reconstructing our economy has to cover planting trees and woodland; also re-wilding opportunities rather than “development” opportunities. Reconstruction has to cover our settlements that will flood when hit by rainstorms enhanced by climate change, to implement surface water drainage and to retrofit SuDS schemes. Reconstruction has to put in adequate sewerage and sewage treatment plant for the house-building allowed without foul sewage capacity. Reconstructing our economy includes expanding tourism and informal recreation on the Vale coast, to replace unsustainable holidaying abroad. Development as associated with Rhoose airport that does not integrate responses to climate and nature emergencies is blocked,

The LDP's previous promotion of growth has to be dropped. So much of what is important to our well-being lies outside of the purview of statistics. The misguided policies pursuing growth did not integrate climate and nature emergencies, nor did they assess wellbeing.

Cut back unsustainable Housing expansion

Review these stalled sites at Darren Farm and Cosmeston - two stalled major sites - for compliance with policies in the plan, as well as reviewing sites that have not progressed,as 6.3.15

Cosmeston – car-dependent, far from facilities; in the coastal zone; toxic landfill; access is vulnerable to floods; first planned to be Green Wedge; archaelogical find/listed farmhouse

Darren Farm – cut back as limited market demand; too big for sustainable development and Cowbridge to absorb

Hayes Wood – remote from facilities; not part of a sustainable settlement; poor bus services

Llandough Hill – land vulnerable to flooding from soakways in developments above which discharge rapidly through the permeable rock (limestone). Past permissions of soakaways and discharge into Llandough stream ('drain') have to be corrected. 

 Llandough is not a sustainable settlement – this would be a car-borne extension of Cardiff.

Assess Sewage Treatment capacity for the purposes of new development

Dwr Cymru assurances cannot be accepted as they are unlawfully discharging untreated sewage to rivers and the sea

The assurances with the 2009 UV installation that they'd meet Blue-flag bathing water standards at Barry beaches has proved untrue. This is important for tourism, so must be reviewed.

Review Sewage Treatment capacity

Widely known that many sewage works are discharging untreated sewage frequently, at times when weather conditions are not "exceptional" and therefore unlawfully.  The VoG cannot claim not to know, as effluent from Cog Moors pollutes Barry Island waters

# summertime sampling is showing Whitmore Bay does not comply with Blue Flag standard

# data disclosed by DCWW shows untreated discharge ~80 times a year, more frequently in the winter months

#  the UV disinfection is switched off during the winter months, so Whitmore Bay sea bacteria are likely to be many times worse than summertime. 

The LDP should assess the excess flow over the treatment capacity and conclude there is no leeway for additional sewage in the system as at present.  Accepting assurances from DCWW that they can take the sewage from further connections amounts to collusion with criminals who take payments for dealing with your waste then dis[pose of it unlawfully.  It breaches the duty of care to accept assurances when you have reason to believe their disposal is (in part) unlawful.

As the Vale wants to promote tourism and leisure use of the sea, the LDP should get assurances on 

# use of UV disinfection at all times of the year when immersion activities take place

# specify DCWW has to invest in further treatment capacity to relieve overloading of Cog Moors STW and meet the Blue Flag standard as was intended when the UV plant was installed (2009) and now year-round when immersion sports take place.

In terms of new connections to the public sewer:

# require all new developments in the Cog Moors area (incl. the Kenson-Weycock and Cadoxton catchments in the Vale) to pay towards new treatment works and delay all over a threshold (say 10 dwellings) pending commissioning of the further sewage capacity

# seek that Cardiff Council freezes the Plas Dwr (Cardiff west) development until further sewage capacity is commissioned, or alternatively requires the developers to pay towards new sewage treatment plant.

Tighten spec for Attenuation Ponds

Capacity has been planned for average rainfall run-off storage

# settlement/attenuation pond to take run-off; if it discharges to Welsh Water  or to private drain, it had  to be covered in a S.106 Condition at this outline stage

# sizing the attenuation pond to take average annual run-off causes flooding during storms'  It has to have sufficient capacity for the maximum planned storms

Review the Cardiff Airport & Gateway Development Zone of 44.75 hectares of B1, B2 and B8 business park and associated car parking.

 speculative growth, no 'need' demonstrated, contrary to sustainable development

•  related to completely over-optimistic airport projections; put it on hold pending a clearer future for the failing airport

•  now 'need' under climate emergency to cut back air transport and related development

• infrastructure capacity is wanting -   roads, sewage....

• need under nature emergency to save this valuable countryside, farmed sustainably with care for nature.

Plan for expansion of the tourism sector, giving more jobs; valuing our coast (excluding development on it), and regaining our Blue flags (correcting the deficit in sewage treatment).

Enable use of Barry Dock for water sports (incl immersion sports) and cockle-farming by ending the routine sewer discharges into it (150 times a year)

Create a blue-green Country Park with conservation area and history trail on RWE's Aberthaw site (east of the ash-mound, plus south alongside the coastal path)

Proper appraisal of flooding with planning for more severe rainstorms under Climate Change

Flooding is due to housing and roadway run-off discharged to sewer (most of Penarth). In Dinas Powys to the river Cadoxton too. In Llandough to the Eastbrook. Barry has many old CSOs. In Sully, Penarth and Barry, surface water drainage systems need building and enhancing to take rainstorm run-off into the sea.

The Section 19 report on the 23 Dec 2020 floods was inadequate for LDP planning

## wrongly omitted flooding at east Llandough and lower Penarth

## lower Penarth is part of the Cadoxton River catchment, but completely wrongly modelled in NRW flood mapping – this assumes run-off into the Sully Brook, with flooding onto the Glamorganshire golf course. In fact little reaches the Brook, but goes into the sewer – the 23 Dec rainstorm overloaded the sewer and flooded Castle Ave and Lavernock Rd, then Cosmeston car-park and lake.

## found the roadway surface water pipe in Sully (discharge down Swanbridge Rd to sea) was inadequate; probably the housing surface water pipe (over sports field) is also inadequate, but no upgrades were promised.

## accepted that the 23 Dec. rainstorm was well below the 'extreme' but considered capacity only relative to this one, not planning for the 'extreme' rainstorms plus the 30-40% “climate uplift”.

The LDP needs to contain an honest appraisal, relative to the uplifted extreme storms

The S19 report fails to include retrospective SuDS schemes, despite policy for these. The LDP needs to map out the older housing areas which still rely on combined sewer systems, as preliminary to assessing practicality and priority for adding surface water drains.

The LDP needs to include policy for the widest spectrum of SuDS schemes, for individual householders, businesses, and public buildings, as well as highways.

These should include

## holding pond/lake for Llandough Hospital and car-park run-off, with controlled discharge to the Eastbrook

## holding pond/lake for surface drainage waters from Castle Estate etc, (west Penarth) in Cosmeston Park

## retrofit surface water collection systems discharging to sea in lower Penarth, where the existing combined sewer (Brockhill Rise CSO) overflows frequently (over 100x per year) much more than only during the legally acceptable 'extreme' weather.

## expand capacity of Sully surface water discharges to sea.

## incentivise house-owners to install soakaways for drainage from rooves and patios.

## Require planning consent for new hardstanding (over 2 sq m) and that it's permeable and/or drains to soakaway.

# Avoid soakaways in permeable limestone (Llandough), where soakaway rainfall quickly reaches surface water drains and streams; instead retrofit larger holding ponds to reduce flooding of the Llandough stream.

## big programme of SuDS schemes in streets to take run-off into swales and grassed areas

Appraisal of the NRW flood-planning Map

The revision of TAN15 on Flooding has been delayed because of criticisms of the NRW map, which is supposed to be used for LDP purposes.  The VoG needs to examine its inadequacies here. 

# the predictions show limited flooding around Barry's No.2 Dock,though flood levels from the detailed 2008 Arup study for the Waterfront development gave flood levels about a metre higher.  The flood planning level for the East Quays housing development is thus a metre higher than what the Minister assumed for the Barry Biomass incinerator, though the two sites are 100 metres apart.  The rubric for the NRW map says it's not to be used for individual developments, where a specific study is needed.  The VoG needs to choose the Arup study over the NRW flood map and ask NRW to sort out the difference

# the NRW predictions for the east Vale were tested by the 4-hour intense rainstorm of 23 Dec. 2020.  Results in lower Penarth showed the NRW map was completely wrong in showing flooding from the Sully Brook over the Glamorganshire golf course.  In fact the flooding was on the Lavernock Road (Cosmeston) and across the carpark into the lake; the floodmap shows no flooding on the carpark and very little on Lavernock Rd.  

# The S.19 report on Sully and Dinas Powys which also suffered flooding in the 23 Dec. rainstorm did not assess what's needed to cope with the 'extreme' storm.  It reported the 23 Dec. flood was well below the 'extreme' that has to be taken into account for planning purposes.  The LDP therefore needs to make such flood assessments for all these communities and justify the spending on SuDS schemes (as above) against assessed outcomes.

Street Trees: Reverse VoG policy of not replacing street trees; positive schemes to restore tree-lined streets – Broad St in Barry; Plassey St in Penarth

Street trees help absorb some rainstorm run-off and can be combined with SuDS as in Grangetown to add permeable areas where rainwater infiltrates into the ground, relieving the sewer.

Street trees provide much needed shading during extreme heat waves, making shopping areas pleasant and attractive for street life

Street trees have cooling effect in urban areas during heat waves

People like street trees (they increase property values),

The VoG engineers' claim to require costly root-cages is not borne out in other towns; Cardiff has a positive planting policy, Bristol uses root barriers where necessary at a cost of ~£250 and finds many locations don't need them.

Positive strategy re. Nature Emergency

Countryside tree/woodland planting – develop strategy with regard to ecology and species

Policy to join up the Barry Woodlands SSSI - include extra fields and allow them to reforest.

Management plans for the countryside/woodland SINCs – eg. those of Pop Hill and south of Dinas Powys – joining them up and stopping fragmentation

Green and Blue Country Parks – for tourism and nature conservation

Aberthaw Country Park and Historical Site – to create by combining the existing conservation area in the old Thaw valley and Harbour with the coastal strip between the ash-mound and seawall.

Cosmeston Medieval Village: expansion to include the newly listed Farmhouse and archaeological site of Lower Cosmeston Farm..

Five-Mile-Lane archaeological site – save what's remaining with a proper plan for planting and management; exhibit records in a local museum

Value the Coast as a national asset

# planning for maintenance and improvement of the Wales Coastal Path

# exclude development on the coastal strip except for facilities that need a coastal location - this longstanding principle needs safeguarding in the LDP as it was ignored in allocating development land at Cosmeston.  Defining the "coastal strip" needs including in the LDP in consultation with the public, and taking into account the aim to promote tourism and expand the tourism business.

Reclaim Aberthaw Power Station site

With end of power stations from the 1950s, this complex site must be restored to a sustainable state with beneficial uses.  “Re-wilding” of the old Thaw valley and the ash-mound are well underway. Restoring the beach etc. for public recreation.

The LDP should identify the problems and allocate responsibilities to cover

# the artificial river Thaw mouth, which the sea blocks if not maintained

# the seawalls, ongoing maintenance and coping with increasing tidal surges under climate change

#  possible abandonment of the Gileston beach section of seawall with managed retreat plus new river Thaw estuary.

# ash-mound; assessment of managing its drainage and stability.

# New Rights-of-Way E.Aberthaw to St Athan and W. Aberthaw, using the railway bridges, also maintaining the Wales Coastal Path

# after-uses of the area, including for biodiversity, tourism, culture-historical recording, public access leisure-uses and rights-of-way.   Including conservation organisations in ongoing management

# create a Country Park, as above, for leisure and tourism on the coastal strip and eastern part of the site.

Transport Strategy

# town circular buses in Penarth-Llandough and Llantwit Major areas. Reliance on buses passing through on circuitous routes created poor and inflexible services.

# review active travel networks to meet gradient standards. The present networks discriminate against those with physical disability or mobility limitations, so breach the Council's duty to avoid indirect discrimination against the elderly and disabled.

# funding for upgrades to pavements and walking routes to meet good/high standards; the failure to provide reasonable funds (compared with highway maintenance) is indirect discrimination against the elderly and disabled

# make rail stations into activity hubs; the failure to develop retail and other activities at the Vale rail stations has given us very unattractive locations. Being poorly lit and isolated in evenings makes them unsafe particularly for women, so the failure is indirect discrimination against women.

Town Planning towards net-zero in local transport

WGovt wants public facilities to be located in town centres, to rebuild their attractiveness and facilitate access by walking or cycling. This research by RTPI and others show how to achieve it via positive planning rather than the VoG's laisser faire.

https://www.rtpi.org.uk/research/2020/june/net-zero-transport-the-role-of-spatial-planning-and-place-based-solutions/

 Final Comments:

The intention to proceed with old planning allocations that flout the Climate and Nature Emergencies is a dishonest attempt to continue Business-as-Usual.

This is particularly shown in the Model Farm and Cosmeston developments. The Welsh Government is deeply involved in both, so in no position to give disinterested planning advice. The public sees it as an undemocratic fix that discredits the planning system. So the VoG needs to find a way to openly and transparently review both these allocations. 

Severn Radioactivity Survey after Hinkley mud dumping

 

Report of citizen-science Radioactivity Survey

of Somerset and South Wales shoreline sediments      8^th Dec. 2021

Samples of mud taken under scientist guidance were sent for analysis by the French CRIIRAD laboratory. The results show the spread of radioactive nuclides from reactor discharges to the Bristol Channel is far more extensive and widespread throughout the region’s coasts than previously reported.

The survey was undertaken by members of Citizens Groups from both sides of the Bristol Channel/Severn estuary because EdF, who are dredging hundreds of thousands of tonnes of radioactive mud from the site of the proposed Hinkley C reactors, have repeatedly refused to carry out pre-dumping surveys of the Cardiff Grounds and Portishead sea dump sites where they have disposed of the HPC dredge waste. The survey was carried out in the summer of 2021 prior to the proposed dump at Portishead, but three years after the dump at Cardiff Grounds.

The Citizens Groups recognised that the lack of such “baseline” research meant that no one had any information on the pre-dump status of radioactivity, or of the post dump impacts of the disposal of such vast quantities of radioactivity, on the South Wales and North Somerset coastal environments or the people living on the adjacent coasts and coastal zones.

Speaking on behalf of the Somerset based Stop Hinkley and Welsh campaigns against the radioactive mud dump Marine Radioactivity Researcher Tim Deere-Jones said: “The results of this survey clearly demonstrate that there are serious grounds for concern that the Bristol Channel/Severn estuary coasts and communities had already been subjected to radiological contamination from Hinkley since the 1960s and that EdFs current programme of dumping radioactive wastes at Cardiff Grounds and Portishead should not have been permitted by the Welsh and English Agencies in the absence of the baseline data.”

In Summary the Survey:

# found that shoreline concentrations of 2 radio nuclides (Caesium 137 and Americium 241) typical of the effluents from the Hinkley reactors do not decline significantly with distance from the Hinkley site as Government and Industry surveys had previously reported

# noted that the presence of both Cs 137 and Am 241 are indicators of the presence of Plutonium 239/240 and 241. (These are all listed as fission products discharged to sea from the Hinkley reactors)

# found significant concentrations of Hinkley derived radioactivity in samples from all 11 sites (7 along the Somerset coast and 4 in South Wales)

# found unexpectedly high concentrations in sediments from Bristol Docks, the tidal R. Avon, the Portishead shoreline, Burnham-on-Sea and Woodspring Bay

# found that, along the Welsh coast all samples held significant (10Bq/kg or more) concentrations of Caesium 137 and positive (i.e: not <less than) concentrations of Americium 241

# found that the highest concentration of both radio nuclides was detected at the most westerly of the Welsh sample sites (Splott Bay: Cardiff), which is also the most distant from the Hinkley point effluent outfalls

# concluded that the degree of concentration of radioactivity at Splott Bay, implied a possible impact from the 2018 dumping of dredge wastes at the nearby Cardiff Grounds

# demonstrated that the widely used, official method of analysing samples for only 15 hours was far less precise than analysing samples for 84 hours

# proved that some of the sediment to be dredged from Bridgwater Bay and dumped at Portishead and Cardiff Grounds held well over twice as much Caesium 137 as the sediments around the dump sites, thus risking a localised increase in radioactivity concentrations as a result of the dumping of dredge waste

# proved that the, much repeated, EdF PR statement that the material to be dredged and dumped “is typical of sediment found elsewhere in the Bristol Channel” was false and not even aligned with the empirical evidence provided by EdF itself.

Tim Deere-Jones: (Marine Radioactivity Research & Consultancy) Dec 2021

On behalf of the Bristol Channel/Severn Estuary Citizens Science Radioactive Sediment Sampling Campaign

Contact: timdj@talktalk.net    Tel: 01834 871 011

ADDITIONAL NOTES:

Below, we provide Table 1 results from the Citizens Science project analysis of sediment samples taken from sites increasingly distant from Bridgewater Bay which has been receiving radioactive effluents from the 4 reactors of the Hinkley Point site for over 50 years.

For comparison and discussion, we also provide Table 2 details of Government sponsored annual monitoring of Hinkley sediment radioactivity sediment analysis and additional information on EdFs sponsored analysis of the Bridgwater Bay offshore sediments which were dredged and dumped at Portishead in 2020.

TABLE 1: Campaigners Bristol Channel sediment analyses 2021.

English/Somerset coastal samples

Sample site                          nuclide        Cs 137 (Bq/kg)    Am 241 (Bq/kg)

Stolford mud                                                              9.1                          0.53

Steart mud                                                                  5.1                          0.38

Combwich mud                                                        11.0                          0.60

Burnham/Brue mouth mud                                      12.0                          0.50

Woodspring Bay (mouth of R. Banwell) mud         14.7                          0.81

Portishead (Lifeboat st’n) mud                                11.9                          0.86

R.Avon (Pill ferry slip) mud                                    13.1                          1.50

R.Avon/Bristol Central mud                                    11.3                          0.56

Welsh Bristol Channel coastal samples

Sample site                       nuclide           Cs137 (Bq/kg)      Am 241 (Bq/kg)

Sudbrook mud                                                          10.4                          0.49

Goldcliff mud                                                           10.2                          0.72

St Brides lighthouse mud                                         11.8                          0.70

Splott Bay Cardiff mud                                            12.7                          1.10

Comment: It is evident that 83% (10 of 12) samples, including those most distant from the Bridgwater Bay/Hinkley Point effluent discharge, hold in excess of 10 Bq/kg of Cs 137 and in excess of 0.5 Bq/kg of Am 241. These results are in marked contradiction to those produced by the official 15 hour gamma counts, which all imply a steady, and significant decline, with distance from the Hinkley Point discharge points.

It is clear that the 84 hour counting time gamma spectrometry commissioned by the Bristol Channel Campaign has generated more precise Cs 137 and Am 241 outcomes than have other gamma spectrometry analyses carried out by Government agencies on behalf of EdF.

It is also clear that the 84 hour count has reduced the lower limits of detection for Am 241 and generated “positive” results for Am 241 in all Campaign samples as opposed to the <less than results reported for all RIFE samples in Table 2

TABLE 2: Government/Industry sponsored RIFE sediment sampling (RIFE-26: 2020 latest available data)

Sample site                  nuclide    Cs137 (Bq/kg)        Am 241 (Bq/kg)

Pipeline sediment                                      50                              <1.30

Stolford sediment                                      9.3                              <1.30

Steart Flats sediment                                 7.2                              <0.78

River Parrett (estuary) sediment                14                               <0.84

R. Parrett (B'water town) sediment           7.9                              <0.90

Burnham-on-Sea sediment                        0.75                             <0.49

Weston-Super-Mare sediment                   2.4                               <1.20

Commentary

N.B. We note that the RIFE sediment sample taken from the site named “pipeline” is remarkably high compared to recent years data: not since 1997 has Cs 137 concentration in sediments from the near Hinkley samples exceeded 50 Bq/kg. RIFE -26 has failed to discuss this analytical outcome and makes no attempt to offer an explanation for the very large year on year increase from around the upper “teens” which has been the norm for the last decade. However RIFE-26 does report that HPB suspended power generation in June 2020 to undertake “extensive inspections and maintenance operations”. It would be interesting to know when this sample was taken (before or after the suspension of power generation).

However, The RIFE sediment analysis results for 2020 are mostly representative of RIFE work over recent years. Only 2 of the 7 samples (43%) analysed by RIFE in 2020 had Cs 137 concentrations of 10 Bq/kg or above. All of the samples were recorded as having < less-than concentrations of Am 241.

Compared to the results of the Citizens Science sample analyses (Table 1) the RIFE results are anomalously low. We propose that this is a function of 2 flawed aspects of the official sampling and analytical methodology:

1: The short “counting time” (15 hours) of the RIFE agreed gamma-spectrometry methodology which, according, to a number of peer-reviewed academic reports, does not produce the most precise or accurate radiological data.

It is clear that the Table 1 longer “count times” provide notably lower Am 241 <less-thans than the Table 2 outcomes. When the shorter count-time methodology has been used, there are no “positive” results for Am 241, and the overall outcome has provided no usable or representative data for that nuclide. We note that many observers treat such outcomes as implying negative/nil Am 241 concentrations in the samples thus described.

Similarly, the RIFE Report’s low (and declining with distance from the HPC site) reported concentration of Cs 137 may also be attributed to the short count time. In that context, it is possible that the RIFE maximum Cs 137 results would be higher, had a longer “count time” been used.

We conclude that it is evident that the analytical methodology used by Government Agencies to produce RIFE radiological data over many decades has provided the public with incomplete and inaccurate data.

2: The RIFE reports provide only the descriptor “sediment” of the samples. In marine science terminology “sediment” is a broad term used to define “natural unconsolidated granular material with sediment density greater than water”. This term thus includes anything from very fine silt/mud material through to pebbles and cobbles. There is a very broad scientific consensus that higher concentrations of these radio nuclides are closely associated with the increased presence of fine particles, while lower concentrations are found in association with coarser particles.

Our review of technical data on the sedimentology of the Inner Bristol Channel and Outer Severn estuary confirm that the vast majority of the regional inter-tidal zone is composed of fine sediments and that these are therefore most representative of the sediments likely to hold highest concentrations of man-made radioactivity. We propose that the low (and declining with distance from HP) concentrations of Cs137 and Am 241 recorded by RIFE may be a function of poor choice of sediment sampling sites and that sites chosen for RIFE sampling produce mixed grain size sediments (added sand shingle etc) rather that high % of fine sediment “mud” or “silt”

In this context it is postulated that the lower Cs 137 concentrations reported by the RIFE (Table 2) report are a function of the presence of coarser sediments in the samples which are poorly described and do not consist of only the finer sediments. We conclude that RIFE reporting is indicative of poor methodology and does not provide either an accurate, or a conservative description/quantification of the radiological status of regional and dump-site adjacent sediments.

Note that the RIFE Report’s sample analytical outcome for Cs 137 at Burnham (0.75 Bq/kg) in a sample, described imprecisely as “sediment, is also clearly anomalous in comparison to our Citizens Science Cs 137 outcome for its Burnham sample (12 Bq/kg), precisely described as mud. This represents a percentage increase of 1,500%. We conclude that the official RIFE methodology is a further example of a combination of poor site (larger sediments) and short count times.

We conclude that it is evident that the analytical methodology used by Government Agencies to produce RIFE radiological data over many decades has provided the public with incomplete and inaccurate data and left coastal zone communities in ignorance of the long term radiological exposures from contact, diet and inhalation doses they have been receiving from marine radioactivity.

3: We further note that the shoreline “surface” (0 to 5cm deep) sediment sample outcomes of the RIFE and the Campaign surveys are both dis-similar from the outcome of EdFs 2020 radiological analysis of Bridgwater Bay sediment cores from the Cooling water intake and Effluent outfall areas where dredging is necessary. In summary, EdFs 2020 data on the gamma analysis of 23 deep core (0 to 5.6 metre) samples of Bridgwater Bay sediment from the dredge area, presented by CEFAS on behalf of EdF, shows the following:

Cs 137 concentrations in the surface to 0-5 metre subsamples of 15 sediment cores (65% of 23) exceeded 10 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 12 sediment cores (52%) exceeded 15 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 10 sediment cores (43%) exceeded 20 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 8 sediment cores (35%) exceeded 25 Bq/kg, Cs 137 concentrations in the surface to 0-5 metre subsamples of 4 sediment cores (17 %) exceeded 30 Bq/kg,

These sample sets were from both the “outfall” and “intake” dredge sites. The maximum Cs 137 conc’ recorded was 34.8 Bq/kg. REF: “TR533 and TR534 Radiological Assessment of Dredging Application for HINKLEY POINT C (2020).” CEFAS: Part 1 and Part 2.

It is clear from the above that the samples referenced hold two to three times more Caesium 137 than the shorelines samples tabulated in Table 1 and Table 2.

It is also clear from the above that the, much repeated, EdF claim (made in respect of dredge sediment disposal at Portishead) that “The sediment is typical of sediment found elsewhere in the Bristol Channel” is deeply inaccurate, based on an un-evidenced EdF assumption and not even aligned with the empirical evidence provided by EdF itself.

We conclude that the EdF commentary is inaccurate and based on a total lack of Bristol Channel wide data. We conclude that the EdF statement should NOT have been made as it is clearly yet another major mis-representation of the true radiological status of Bristol Channel/ Severn estuary environments distant from Hinkley Point

………………………………………………………………………………………………………

Tim Deere-Jones (Marine Radioactivity Research & Consultancy) for Bristol Channel/Severn Estuary Citizens Science Radioactive Sediment Project: 02/11/2021

Future of Aberthaw power-station site: request to WGovt for EIA Screening Direction

our FoE group see the EIA Screening by the Vale Council last April as completely wrong.  They failed to require information on the future of the whole of the site, including the seawalls, ash mound and nature reserve.  

The power stations have completely changed the whole of the site, including the historic Aberthaw port and river Thaw estuary.  On pulling out, they have to put this artificial environment into sustainable condition, if not some approximation of the original green fields.  Quarries have to come up with an afteruse plan - why don't the Vale Council require one here? 

Request for an EIA Screening Direction by the Welsh Minister      FoE letter of 23 Nov.2021

WG Planning Directorate, Decisions Branch

Demolition of Aberthaw Power Station and withdrawal from the site

Aberthaw Power Station, West Aberthaw, Barry

Town and Country Planning (Environmental Impact Assessment) (Wales) Regulations 2017

Dear Mr Litherland,

The Vale Council gave a screening decision  (28 April 2021) on demolition 2021/00162/SC1  without considering all parts of the site and the planned withdrawal from the site. They have subsequently approved demolition of the Ash plant 2021/00608/PND and the Carbon-capture plant 2021/00288/PND.  

This the demolition and withdrawal from the site is being considered piecemeal despite being part of a single development.   RWE did put the site up for sale, but withdrew as, it seems, the liabilities far exceed the site value. The way-out proposal to use the site for a Fusion Reactor came to nought. The company apparently now intends to withdraw from the site without assessing the longer term liabilities, which could fall on the community.

Faulty Screening decision by VoG Council

The Council's Screening report (see the file 2021/00162/SC1) said the project is

EIA Schedule 2, Part 10 ‘Infrastructure projects’, (b) ‘Urban development projects’

This was wrong.

It is an amendment to an EIA Schedule 1 part 2 (a) Thermal Power Stations.

and thus a project under Sch 2: 13 (Any change to... a Sch 1 development)

It follows that in your new screening, you have to consider whether

The development as changed or extended may have significant adverse effects on the environment.

RWE presented no information on the future management of the site, except for saying they intend to leave the seawater intake and discharge structures in place. Likewise the seawalls , artificial river channel and bridge, site railway bridges, lagoon created by cutting off the old harbour, and ash mound with its drainage would be left in place, but unmentioned in RWE's application.

We consider that in the absence of information, your screening will have to conclude that the changes may have significant adverse effects on the environment.

Let us point out

The environmental sensitivity of the location

The coast is vulnerable to erosion from the sea; the stones on the beach on the west section of the seawall need to be regularly pulled up the beach by JCB. The seawall was overtopped by the sea last winter.

Rising sea levels and storm surges will increasingly overtop the seawall under the Welsh Climate Change predictions.

The river mouth is tidal, causing flooding upstream. If the channel is not cleared, storm surges will block it with stones and cause flooding upstream a km or two.

The Council's screening report failed to see any environmental sensitivity of the location.

Let's point out relevant criteria in EIA Schedule 3

(e) pollution and nuisances; covers the natural storm processes blocking the river channel and worsening flooding upstream

(f) the risk of accidents and/or disasters including those caused by climate change ;

covers the sea overtopping the seawall and destroying it in time. It also covers the ash-mound slipping due to long-term erosion and water penetration (long-term issues akin to a coal tip)

(b) the cumulation with other development; covers the issues unmentioned by RWE consequent on neglect of

# aftercare of the 65metre ash mound

# maintenance of the seawall or managed retreat of the western section

# ongoing management of the artificial river Aberthaw channel

# management of the biodiversity area and SSSI of the old Harbour (blocked by the power station diversion of the pre-1960 river and construction of the seawall)

# the seawater intake tower and discharge structure.

# the site railway bridges.

Let us point out the complexity criterion in Schedule 3 

  3 (d) the intensity and complexity of the impact;

It's clear the issues in this case involving potential coastal retreat, climate change and restoration of a quasi-natural sustainable environment after 65 years of power stations are unusually complex.  They also require the Welsh Minister's planning section to consult on and reach a properly broard view of the issue, which the single VoG case officer could not be expected to do.

We look forward to your Screening Direction, based on the information in the VoG Planning file 2021/00162/SC1.

Memorial Bench to Keith in Cosmeston Park

 Keith loved to pass through Cosmeston park on his cycle tours around the Vale, stop off and watch the many and varied birds, changing with the seasons and migration times.

A fitting place to remember him, including his managing teams and numerous projects with Conservation Volunteers.

https://www.gofundme.com/f/keith-stockdale-memorial

Sad death of Barry&Vale Coordinator, Keith Stockdale RIP 24 April 2021

Obituary   (amended with additions 31 October 2021)

    Keith was politically active as Labour Councillor from 1979-1983, then the miners' strike of 1984-5 when a strong Barry group held rallies and collected money and stuff on King Square. He was also active with the Anti-Apartheid movement as it grew from a pressure group to a mass movement with a consumer boycott and demand Nelson Mandela: Freedom at 70. At the end of the 80’s, he was prominent against PM Thatcher's 'Poll Tax', standing as Communist candidate in the 1989 County elections. Keith became active on local environmental issues in the 90s, campaigning against the one-way system proposed to replace lower Holton Rd (via Merthyr St and a continuation of Wyndham St). He joined Barry FoE and assisted FoE's coordinator (from 1995) Byron Lewis in holding up Council plans to fill one of Barry’s two Graving Docks with toxic materials from the derelict western dockland. Byron found him a breath of fresh air, being like-minded and confident on eco-matters. Sponsoring legal action, they forced the Council to put in a lining to stop the pollution leaching into the main dock (at a cost of ~£1million the Council wanted to avoid).  They delayed the Council's intention to give away Central Park for a supermarket (developers Centros Miller) - the Council paid to move the Bowling Green, but a FoE-supported judicial review fronted by local mums whose kids depended on the Park held up the land transfer – long enough for Kwiksave to build Barry's first town centre supermarket down Thompson St, causing Centros to pull out in 2001.  Then the Vale Council proposed to pull down the Town Hall, all but the facade, and build shop units on one side of King Square.  Keith was in the public campaign which won keeping the historic building, with a new Library building added at the rear. 

Barry's Chemical Complex 

   Campaigning to clean up Barry's chemical companies was another of Keith's interests - with noises which each company denied, blaming the others. Dow Corning did admit to spots on car paintwork, but not to harming people’s health. FoE loaned a "Grimm" particulate monitor, in the early days of these pollution monitors. With the Cadoxton activist Joan Holt, Keith set it up to record pollution near the Cardiff road.  This found sharp early-morning peaks, with traffic particulates peaking later, showing the plant being cleaned out via the chimneys - prior to restart for each morning’s shift.  This led to requirements for continuous monitors at Dow Corning and other plants.  Byron Lewis took the “Grimm” monitor to some other FoE groups in south and north Wales

Regulations were also brought in on major accident hazards (CIMAH / COMAH) and planning, which led to the primary school being closed.  The derailing of chemical tankers in October 2011, with evacuation of many families, led to the realisation of how dangerous were the movements of VCM from Merseyside (vinyl chloride monomer - highly carcinogenic and potentially explosive).  Ships were brought in instead and soon afterwards BP Chemicals sold the plant, ending the shameful deaths from VCM liver cancer (angiosarcoma) of staff working there. Thus Keith, living then in Cadoxton, played a part in taming Barry's chemical works at a time when the authorities treated them as untouchable, because of the high-paid jobs. 

Move from Cadoxton to Castleland 

   Keith moved up to Castleland and became Plaid Cymru councillor for the ward in 2004-2008. He then took on the role of FoE Coordinator from Byron Lewis, his campaigning "twin".  He extended FoE support to campaigns beyond Barry - over the ash mound at Aberthaw power station (stopping it rising further, so they switched to infilling Aberthaw quarry); over housing land at Llanmaes offered for the privatised ‘Metrix’ training facility (abandoned, but the Vale retained the greenfield housing); over Tesco’s attempt to buy golf course land at Bryn Hill and over the Vale’s proposed road from Caerau to Pencoedtre across the Wenvoe valley. Won some, lost some.  Keith introduced new members to the group, inspiring them to challenge and resist where possible, and was always ready to stand in at short notice to chair public meetings etc.

2009: two incinerators hit Barry

    The Vale had an enthusiastic recycling officer, Brian Mayne, whose efforts FoE very much supported.  But he was replaced by a guy who insisted 30% was the maximum recyclable.  This meant Barry was to have a ‘Biogen’ waste incinerator by Rank’s Flour Mill and a ‘Sunrise’ waste wood incinerator on the Castleland side.  The Vale approved the former and refused the latter (against officer recommendation), which the Welsh Government then approved after a public Inquiry.  Keith and FoE led sustained public resistance and neither proceeded.   But in 2015, the Vale officers pushed through renewal of the ‘Sunrise’ permit, despite the public campaign.  Big money came in from Aviva, FoE set up the separate DIAG campaign in which Keith was a leading light.  And as we see today, the plant has been built but is not able to operate.  Officers bending the law to avoid environmental impact assessment (EIA) has proved under FoE pressure to be the project’s Achilles heel.  The announcement in March of a Welsh moratorium on new incinerators reflects the public distrust and opposition from Barry and other parts of the country. 

Severn Estuary 

   Barry and Penarth FoE groups living by the Severn Estuary have always engaged with issues around a tidal barrage. The Bondi barrage from Lavernock Point would have been destructive to our local environment but give national benefits as a major renewable energy source. Local FoE tended to argue for a smaller tidal barrage upstream, near the Severn Bridge. FoE’s leader, Jonathan Porritt came down for a TV confrontation at Aberthaw’s Blue Anchor pub, where Keith stood his ground. That was about 1990 – two decades later the two FoE groups had merged and we saw off the second attempt to get the Lavernock tidal barrage, but by that time the Estuary was designated a European conservation site and major wildlife organisations were on-side. The Cardiff Lagoon idea for tidal generation was more interesting; Keith brought in the Swansea Lagoon company to explain it. In the end, he was opposed to it, for enclosing a large section of the wild natural estuary and for power generation with gaps – gaps that had to be filled with fossil-fuelled power. Despite central FoE and Welsh political parties lining up in support, the Swansea lagoon was vetoed by Westminster; with it the Cardiff lagoon idea disappeared. The group remained founder-members of the Marinet network of coastal groups (a FoE spin-off) who are like-minded on coastal environmental issues. 

Hinkley nuclear plant 

   Keith was staunchly anti-nuclear, opposing the Hinkley-C nuclear station throughout, and regretting the environmental movement’s failure to stop it – as in the last years he viewed it building across the Severn from his home. In 2017-18, the Hinkley project’s intention to dump excavated mud off Penarth Head hit us. Central FoE shunned us, but Keith continued to argue the mud would surely contain historic nuclear discharges and supported the ‘Geiger Bay’ campaign led by Neil McEvoy to require full testing of the sediments. When interviewed for BBC TV on Penarth Head, he prepared to say a few sentences in Welsh - seeing that we needed to engage the Welsh-speaking community on the nationalist point of English mud dumped on Wales. The first stage dumping was lost in 2018, with the legal decision on EIA came too late. But Keith had the satisfaction of the campaign’s success on the EIA requirement in 2020, then of the second stage dumping application running into sand early this year.

Sincere environmentalist 

   As people have said, Keith was one of life’s sincere people and true environmentalists, who put that above any political interest. After finishing his teaching career (primary schools in Wenvoe and Llangynwyd), he worked with the Forest Farm conservation scheme, leading teams of youngsters on conservation projects around Cardiff and the Vale. When its funding ended, he joined Cardiff and Vale College to assist special-needs students. He was an inspiration to many on environmental issues. Keith was frequently seen out cycling, from his early days when he cycled to his primary school teaching job at Wenvoe to cycling part way to his conservation job at Forest Farm (he drove by car till he met Cardiff traffic, then parked and pulled out his bike for riding up the Taff trail). He regularly participated in the “Barnardo” cycle-rides, 40 miles around the Vale.  In recent years, Keith was often out on his bike to keep fit and enjoy the Vale countryside.  He played the flute for enjoyment, with a small group who played at a few clubs and ‘open mic’ evenings.  He was able to enjoy last ‘lockdown’ summer, out many times on local beaches with grandchildren.

Changing orientation of FoE, England & Wales 

   Keith has lived through many changes in Friends of the Earth, from when FoE Cymru was independent, supporting campaigns on local issues (and the Welsh “acid rain” issue), then absorbed into the England & Wales FoE in 1994 when centralised campaign goals got priority (from GM-crops to ‘cuddly’ bees), to recent years when local issues have been given greater prominence. He did not allow his criticisms on some issues to detract from overall loyalty to FoE, carrying their banner to many public events. Throughout, Keith held to his strong belief in local activism, and gave FoE’s support to local campaigns in Barry and around the Vale. 

Environmental activism 

   Keith contributed much to Barry over the years. Though politically engaged – a Plaid Cymru member for two decades, his main achievements were with Friends of the Earth, where he showed that community environmental activism achieves. Enthusiastic to the end, despite his COPD, Keith was looking forward to meeting the Barry&Vale group and resuming public activity post-lockdown, when death struck on 24th April.  He lived to see the Biomass incinerator deadlocked if not yet dismantled.