The following is a copy of a letter sent to Flintshire County Council, which considers Castle Cement's expansion plan on Wednesday.

I am writing to you about the planning application to increase cement production by 50% at Castle Cement and to use alternative fuels at the Padeswood works.

I am sure you will agree this represents a major change to the local environment.

Why is a 50% increase in production required? It is not based on demand and it can only be to transfer production from other areas.

Why alternative fuels? The cement companies are under pressure to increase efficiency and cut emissions. The emissions at Padeswood would increase dramatically to cope with the 50% increase in production.

The company blames the Climate Change Levy, to be imposed by the Labour Government for having to change to the use of waste-derived fuels. It is claimed that this legislation will cost £40m a year.

In 1998 Castle burned 70,000 tonnes of Cemfuel - basically organic solvents unsuitable for recycling - at its Ketton and Ribblesdale works. Cemfuel has probably reached it's peak of availability and it seems likely that some of the 35 million tyres discarded in the UK each year will be the favoured fuel at Padeswood.

Once again, they will be encouraged by the Labour Government which is very keen to burn tyres as an alternative to landfill. The production of cement is becoming secondary to the incineration of waste.

Is incineration the best solution? The emissions are measured in thousands of tonnes but because they are intended to be spread over large areas, it is a case of out of sight out of mind.

With landfill the Environment Agency seeks containment of effluent but with incineration, it conventiantly reverses the principle.

Is Padeswood the best site for a large incinerator? Many of the surrounding villages overlook the site and are set above the level of the tops of the chimneys.

Under certain weather conditions it is likely that the emissions do not escape the perimeter of the bowl produced by the surrounding hills and they will be deposited in greater concentrations in the local area. The site at Padeswood has not been chosen for it's efficient discharge of emissions. It has been chosen because it already exists historically in an area where fuel was once abundant.

The operation of the planning laws leads to sites being chosen for the wrong reasons rather than chosing the most efficient sites for this kind of process.

The Padeswood area is no longer an area of industrial development and it would be clearly contrary to planning principles to develop this site for new processes on such an increased scale.