Objection Letter

20th June 2007

Dear Sir/Madam

Objection to planning application

I am writing to object to the proposed incinerator on Marsh Barton on the following grounds:

  1. community consultation has been inadequate. There have been two public consultation events – both were poorly advertised and subsequently poorly attended. When I raised this with Devon County Council (DCC) the response was that ‘ if local people want to know more about the proposals, the information is readily available for those who ask for it’ (letter from Mr B Jennings 24 April 2007) – however people first need to know about it in order to request information. There was no information distributed in the community directly to residents, for example I haven’t seen anything in ‘Exeter Citizen’ magazine nor received a notice through the door. The lack of community consultation and feedback is reflected in the non-technical summary of the environmental statement section on ‘Community and social effects’ which only looks at employment issues. Since the proposal has regional significance (as set out in the Draft Regional Spatial Strategy) then this approach and level of consultation is wholly inadequate.
  2. I welcome the fact that it has been estimated that the new plant will not cause additional traffic to the proposed site than that currently generated by the current waste transfer site. However the environmental statement points out that a new waste transfer site will be required and subject to a separate planning application (p2 para 1.12), and that a proposed new site could be near to the proposed incinerator (P10 para 3.12). Therefore the two sites combined will generate a significant increase in traffic i.e. lorry movements. The two issues need to be considered as a whole. You will also note that Alphington Road and Church Road – only a short distance away is already subject to an AQMA.
  3. In correspondence with DCC on the matter the plant is cited as being built on the ‘proximity principle’ – which I would agree with on a principle of environmental justice. However the planning application does not bear this out, because a proximity principle would imply disposal of Exeter’s waste however the plant is proposed to take all or some of Teignbridge, Mid Devon and East Devon’s waste as well as residuals from recycling centres and commercial and industrial waste. This is justified on the basis of economies of scale and the role of Exeter as a ’regional centre’ and has been happening for the past decade. This is not sustainable. The draft Regional Spatial strategy highlights that: “The South West’s ecological footprint is unsustainable as it stands. If everyone on the planet consumed such a quantity of natural resources and energy as an average South West resident, three planets would be needed to support life on Earth.  Consequently, a shift is needed towards ‘one planet’, lower consumption, with lifestyles which are more resource efficient. This should include a move towards locally produced, replaceable natural resources, more efficient usage of energy, better waste re-use/recycling, and more efficient use of scarce natural resources such as minerals.” The planned proposal is inconsistent with this based on proximity and reduction of waste.

Correspondence with DCC (see above) states that the plant is only designed to deal with the waste stream already being handled in Exeter. If at this stage the current suppliers of waste are locked into a contract how will it be able to cope with the proposed growth of Exeter and its population (increased density and Cranbrooke) as outlined in the Draft RSS? The Regional Waste Strategy, has a target that by 2020 less than 20% of waste produced in the region will be landfilled”.  Can that plant demonstrate that it will help Exeter achieve its fair portion of this target in light of the proposed growth if the district?  A figure of 75% mass of the incoming waste will be destroyed is quoted in the report (if the bottom ash is not re-used) (p 19 para 3.72).

  1. Correspondence with DCC letter highlights that the costs of waste management is expected to increase over time – surely we need to be planning for amount of waste to be collected to be kept to a minimum and not to significantly increase over time. Nowhere have I seen how much energy will be produced by the incinerator and the amount of income it’ll generate and how that income will be applied (will it be profit to Viridor, offset against the contract (i.e. reimbursed to taxpayers who are having to pay for this) and what will be the payback period and to whom for the investment in the infrastructure required to sell it to the trading estate?
  2. With regard to bottom ash – the report talks of preferentially securing a re-use option avoiding the requirement to landfill it (P19 para 3.72); but it is not apparent that efforts have been made to secure this – and should planning permission be granted for the site – I doubt efforts will be made to undertake such an option. Should planning permission be granted then it should be a requirement that bottom ash be safely re-used rather than landfilled.
  3. In relating to the flue ash – I understand a site in Gloucestershire was originally proposed that was able to deal with this toxic waster. Transporting this waste out of the area undermines the ‘proximity’ principle advocated by DCC and will generate increased CO2 emissions as a result of transportation. The draft Regional Spatial Strategy highlights the need to be more locally self-sufficient so if there isn’t a local facility to deal with this toxic waste –are their proposals to  develop a local site to safely handle this material or will you ignore the draft RSS and transport it even further a field?
  4. On the face of it one should be reassured that the emissions from the incinerator will be within ‘legal limits’ – however we need to be clear that incinerator chimneys emit organic substances such as dioxins, heavy metals such as cadmium and mercury, dust particles and acid gases such as sulphur dioxide and hydrochloric acid. These can have the following health effects:
  • Dioxins – dioxins may be associated with cancer, hormonal effects such as endometriosis in women and reduced sperm counts in men, and reduced immune system capacity. They may also affect foetal development.  
  • Heavy metals – cadmium may cause lung and kidney disease, and mercury can affect the nervous system.
  • Dust particles – these exacerbate lung diseases such as asthma or chronic bronchitis, and heart disease.
  • Acid gases – these also exacerbate lung disease.

 

The permissible limits for emission of these substances (apart from dioxins) have been tightened by the European Waste Incineration Directive which came into force in the UK on 28 December 2002. The Directive aims to prevent and limit negative environmental effects by emissions into air, soil, surface and ground-water, and the resulting risks to human health, from the incineration and co-incineration of waste. Monitoring requirements include the reporting of dioxins and dioxin-like PCBs. However this does not meant that the proposed 2,000 tonnes of APC residues per annum are safe and will have no adverse affect on local communities and their health – it just means they will be within legal limits. Indeed the report states that the risk to human health from exposure to pollutants from the site are ‘not considered to pose unacceptable risks to the proposed receptors’. Please can you confirm exactly what this ‘acceptable risk’ will therefore be and if this risk remains acceptable within the context of other emissions from the other polluters estate identified by the Environment Agency?

The Environment Agency published a report in May 2002, on the safety of incinerator ash which followed well publicised problems about the use of ash from incinerators at Edmonton in North London and Byker on Tyneside. The report concluded that handling of fly ash is enough to keep risks within permitted limits. It also reported that bottom ash can be safely used in construction materials as suggested in the Officer’s letter, although bottom ash and fly ash should no longer be mixed, as occurred at Edmonton. However a number of concerns have been identified with the report including the fact that it did not consider heavy metals, organic carbon and other toxic materials apart from dioxins. It did not consider the variability of ash, nor did it acknowledge our already high intake of dioxins. A Tolerable Daily Intake (TDI) standard, which includes dioxins ingested with food, has been proposed. One third of the population is already exposed to levels which exceed this daily intake. Alphington Road/Church Road is already an Air Quality Management Area because of the high nitrogen oxides emitted by excessive levels of traffic and the impact on vulnerable groups including local e.g. schools and the hospital also needs to be considered. Given the extreme toxicity of dioxins, any extra burden on human health would be unacceptable, so the ‘precautionary principle’ should be applied and no more avoidable dioxin should be added to the environment i.e. through incineration.

  1. The report highlights that about 17 jobs will be created by the site and the use of sustainable transport i.e. buses and cycling is proposed in environmental statement report. However the plans (drawings) set out space for 30 cars, even allowing for visitors to the site the proposed level of car parking I can only assume this is because it is expected that each employee will drive to and from work. This is excessive and inconsistent with the stated objectives to promote sustainable transport as set out in the in the report.
  2. One of the main thrusts behind the type of plant suggested is that of prolonging the life of landfill capacity – however the report states that this has not been quantified; nor has the reduction of fossil fuels as a result of the energy generated. On which basis how do we know DCC is securing best value from the proposed project if these fundamental points are not addressed?
  3. Last, but not least, the proposed site is expected to generate some 45,000 tonnes of CO2 every year, locking Exeter and area into generating this quantity of dangerous greenhouse gases for the next 30 years at a time when we need to be urgently reducing emissions.

Yours faithfully

 

Diana Moore (Ms)

 

CC: Cllr Vanessa Newcombe, Cllr Peter Wadham

 

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