Objection to EA/EPR/TP3036KB/A001

Site Address: Ashby Road East, Nr.Loughborough LE12 9BU

“Application for an energy recovery facility and ancillary facilities”.

Applicant Name:  Biffa Waste Services Limited

 

From Cllr Max Hunt and Garendon Ward residents,

Introduction

This is an objection to the proposal based firstly on it’s non-compliance with the County Council’s Waste Development Framework (WDF), and also Charnwood’s extant planning policies, including WDF Policy 10 which states that:

Planning permission will be granted for waste incineration facilities, provided that:

(i)     pre-sorting of waste is carried out

(ii)   energy recovery is maximised,

(iii) value recovery from bottom ash is maximised, and

(iv) the proposal accords with the requirements of other policies contained in the waste development framework.

We refer to the emissions and associated risks to health.  We also refer to the damage to the economic and educational reputation that such a development would do to Loughborough.

We feel this is particularly relevant to residents, students and those working to the north and east of the development in the path of prevailing winds.

As this is the first application for a major incineration waste treatment plant in Leicestershire, we feel it is essential that the strictest consideration is applied to policies.  Whatever is agreed here will form precedent for future and competing applications.

Relying on the professionalism and impartiality of officers and members in this regard we also propose conditions, which if adopted would set a standard for other applications.

Such, therefore is the importance of this application and in an area of necessarily limited expertise of the authority, that prior to acceptance we request:

      the council commissioned an independent Environmental Impact Assessment study.

Local environment

The site at Newhurst was given a permit by LCC to land fill and re-landscape the site.  The opportunities of the promised re-landscaping will disappeared if the proposal for an incinerator and associated plant are accepted.

That application would have been, at least in the long term, compatible with the local Charnwood Forest and National Forest policies.  The county has only 3.8% woodland cover, making it one of the least wooded areas of England.  Regardless of the environmental merits or otherwise of landfill waste disposal, using a disused quarry for this purpose at least avoided the need to excavate an alternative site, would be out of sight from surrounding areas and eventually restore the area to an aesthetically acceptable standard.

The site lies within the National Forest and the Charnwood Forest Policy Area and the Garendon Park lies immediately down wind. The area of the Garendon estate, alongside the A512 and to the south of Butthole Lane, is designated green wedge and subject to an application to become the Garendon Country Park, open to the general public to enjoy.  The park has Grade II listed buildings, notably the Temple of Venus c. 1730. If the incinerator goes ahead, visitors will be able to view the Temple of Venus and Biffa's incinerator stack simultaneously, hardly the rural idyll anticipated.  Also to the east of the proposed incinerator is farmland, Longcliffe Golf Course and the Outwoods. Charnwood Policy EV/1 requires us to safeguard important viewpoints, landmarks and skylines.

To the west of the proposed incinerator is farmland again, together with Mount St Bernard’s Abbey, founded on land donated to the Cistercian Order by the Garendon Estate in 1835. Blackbrook Reservoir is also to the west. All of the structures mentioned above lie within, at most, a two mile radius of the proposed incinerator

Much will be said about the traffic problems in and out of Shepshed and around Junction 23, which is not now due to be widened.  We also remind the authority that air quality problems related to road transport have been identified as a problem, including along the M1 corridor.

The site acquires a significant flow of water, principally along the Shortcliffe Brook.  We question whether adequate measures are in place to minimise the risk of pollution from leachates from the plant.

The site is inappropriate due to:

      Policies and richness of Charnwood Forest, National Forest and Garendon Park.

      Watercourses running the site and associated risks

      Current and prospective air quality and congestion associated with the heavy traffic occasioned by the plant.

There is insufficient household waste in the county to make an incinerator viable.  If the recommendation is to approve Conditions should include:.

      We need full disclosure prior to permission as to what the road transfer, and a waste transfer station plans are required to feed the proposal. 

      No municipal household waste should be brought in from outside of Leicestershire.

Design of the plant

One of the major concerns we have is about the design of the plant which is well behind leading industrial standards.  We understand this is the first incinerator that Biffa have designed and as such it is not designed to extract the most energy from the waste, it discourages recycling and does nothing for re-use.

In short, this plant lies at the lowest end of the waste hierarchy, neither maximising reuse and recycling, nor energy recovery.

The design is one of ‘burn’ with as many filters as the law requires, all of which have a related risk.  The use of ammonia to combine with emissions is particularly unfortunate.  Benchmarked against other systems being developed in other counties and cities, this is retrograde.  Should the permit be granted, it will stand for twenty years and more as a monument to history, not the future.

The Charnwood LDF Core Strategy Document states:  “The Council would like to create a prosperous, enterprising and dynamic low carbon economy that makes the most of locations that minimise the need for people to travel and which benefit from renewable energy opportunities.  The Charnwood Sustainable Community Strategy says in policy SO7: “to promote energy conservation, the wider use of alternative and renewable energy resources and to facilitate more recycling of waste materials.“  The WDF says we should “facilitate other methods of waste management, treatment and disposal which pushes waste up the waste hierarchy.”

We do not believe this plant to be within the aspirations for extant development policies of Charnwood County or Local Strategic Partnership which would favour a holistic approach, based on several appropriate re-use, recycling, anaerobic and other technologies.

      We therefore ask the planning authorities to contrast the design and function of this proposal with the aspirations on both the retained Local and Structure Plans s well as the Waste Development Framework.

      It is essential that all incoming household waste is pre-sorted to remove all recyclable materials, including a dry paper and cardboard, plastics and metals.

Prior to any permit, the authority will need to know:

      What do the applicants plan to do with it the solid residues?  These can be particularly nasty.

Atmospheric emissions and risk

This is perhaps the most common concern of the public, and of those living in the wake of the stack.

The first question we pose is: ‘Is a stack necessary’?  Cannot all emissions be treated on site.  With a large conurbation to the north and east of the site prevailing winds will carry any emissions over a large area of human habitation.

Further, we are concerned that whilst assurances of the applicant may aim to minimise risk, a finite risk of unacceptable release from the plant will exist.  This means that unplanned emissions will be released at some point.

Several European doctors' associations (including cross discipline experts such as physicians, environmental chemists and toxicologists) representing 33,000 doctors, in June 2008, wrote a keynote statement to the European Parliament citing “widespread concerns on incinerator particle emissions and the absence of specific fine and ultra-fine particle monitoring or in-depth industry/government studies of these minute/ invisible particle size emissions”.

Concerns regarding the health effects from incinerator plant emissions forced the UK Health Protection Agency to give a position statement in a report in September 2009. The report concluded that, whilst modern, well managed incinerators make only a small contribution to local concentrations of air pollutants "it is possible that such small additions could have an impact on health".  All emissions are additive to the existing levels of pollutants, rather than substituting for the ambient level.  Many toxicologists criticise and dispute this report as not being comprehensive epidemiologically, thin on peer review and the effects of fine particles on health.  The Scottish Protection Agency's (SEPA) comprehensive health effects research concluded "inconclusively" on health effects in October 2009.  These authors stress "small but important effects might be impossible to detect". 

History offers many examples of supposedly safe, exhaustively tested substances later proved to be anything but, DDT and Thalidomide being two obvious examples.  In short, in respect of incinerators, the jury is still out and, therefore, alternative waste disposal methods should be preferred.

The authority is referred to: ‘The Health Effects of Waste Incinerators: 4th Report of the British Society for Ecological Medicine’. Recent data has been published strengthening evidence that fine particulate pollution plays an important role in both cardiovascular and cerebrovascular mortality (eg strokes).  This shows that the danger is greater than previously realised.  Data has also been released on the dangers to health of ultra-fine particulates and about the risks of other pollutants released from incinerators. With each publication the hazards of incineration are becoming more obvious and more difficult to ignore.

In the light of this data and the discussion provoked by our report, we have extended several sections. In particular, the section on alternative waste technologies has been extensively revised and enlarged, as has that on the costs of incineration, the problems of ash, radioactivity, and the sections on monitoring, and risk assessment.

Recent research has also demonstrated the very high releases of dioxin that arise during start-up and shutdown of incinerators. This is especially worrying as most assumptions about the safety of modern incinerators are based only on emissions which occur during standard operating conditions.

Of particular concern, therefore is the likelihood that these dangerously high emissions will not be detected, rapidly enough, nor by present monitoring systems for dioxins and very fine particulates.

The WDF says:

6)     To limit emissions to air to levels that will not damage natural systems and affect human health (cumulative effect).

7)     To minimise the contribution of waste development to adverse climate change (cumulative effect).

8)     To minimise public nuisance from waste treatment and disposal (cumulative effect).

9)     To maximise the benefits to human health and well-being.

Recognising the importance and powers vested in the planning process, we therefore request that:

      The Environment Agency be asked to address how fine particulates and dioxins can be monitored and the plant must include filters to remove all airborne particulate pollutants.  The exhaust gases must be scrubbed to remove all the dioxins, nitrous oxides, sulphur dioxide and other gaseous pollutants

      The data from 24/7 monitoring is published daily on the Internet, together with mitigating and corrective actions applied with financial penalties for breaches of minimally environmental standards

Risk to reputation

As a prime motorway junction site there is a major opportunity cost at stake.  There are many more economically advantageous use of this site.

The LCC Sustainability Appraisal refers to “general perception of incinerators as ‘bad neighbours’ which may limit number of sites where such facilities could be located”

Loughborough University offers exceptional facilities for sport and fitness.  Many of our national sporting stars train here.  The University and its associated enterprises regularly hold national and international athletics meetings on campus. It will be the host facility for the Japanese in their preparations for participating in the 2012 London Olympics.  The consideration given to environmental conditions by athletes, coaches and sporting organisations was demonstrated by the concerns expressed at the choice of Beijing for the last Olympics.

When originally suggested as a site for an incinerator the University asked critics to downplay their response in order not to imperil their then application for the national UK Olympic ‘holding camp’.  Although that application was lost, the critics were advised that competitors would take advantage of a proposal for an incinerator to discredit Loughborough’s application.

 

      Based on the risks outlined above, damage to reputation appears as a material consideration.

 

References

1. Biffa: http://www.biffa.co.uk/content/other_areas/newhurst
2. Energy Technology Institute:  www.energytechnologies.co.uk/
3. Health Effects of Waste Incinerators: 4th Report of the British Society for Ecological Medicine:  http://www.ecomed.org.uk/content/IncineratorReport_v3.pdf
4. Leics CC Waste Development Framework:  http://www.leics.gov.uk/index/environment/planning/community_services_planning/planning_policies/local_development_plan/minerals_and_waste_development_framework.htm
5. Leics Waste Partnership (LCC and Districts):  http://www.lesswaste.org.uk/
6. National Forest Sustainability Report:  http://www.nationalforest.org/document/research/sustainability_report.pdf
7. Newhurst Application on LCC:  http://www.leics.gov.uk/index/environment/planning/community_services_planning/planning_applications/index/environment/planning/community_services_planning/planning_applications/eplanning_searchform/eplanning_resultpage/eplanning_detailpage.htm?appno=2009/2497/02&map=f
8. Surrey County Council Waste policies:  http://www.surreycc.gov.uk/sccwebsite/sccwspages.nsf/LookupWebPagesByTITLE_RTF/The+Surrey+Waste+Plan?opendocument