SLYFIELD INCINERATOR
- PLANNING APPLICATION BY THAMES WASTE MANAGEMENT
RESPONSE FROM
GUILDFORD ANTI-INCINERATOR NETWORK
The
Guildford Anti-Incinerator Network (GAIN) comprises residents and community
associations which believe this incinerator is the wrong solution and the
location is too sensitive. We want to
reduce waste and recycle instead. We
want kerbside collections of waste sorted for recycling. We want a moratorium on incineration in
Surrey. Over 20,000 letters of
objection to the Environment Agency and Surrey County Council’s Planning
Department and Waste Local Plan Review Team.
IMPACT
OBJECTIONS:
Harm to Visual Amenity and Character of
Guildford:
It would be out of scale and character with all other
developments in Guildford and detract from the Cathedral. It would unacceptably
harm views of the town from strategic road and rail networks and public rights
of way and from nationally and regionally important areas, including the North
Surrey Hills AONB and the River Wey Navigation.
Cause
of Pollution and Not Proven Safe:
a)
Atmospheric Emissions:
It would cause deterioration of the air quality in
Guildford. Nitrogen dioxide and
particulates, including very fine particulates, are of particular concern. Some of the emissions, such as heavy metals,
dioxins and furans would be highly toxic and bio-accumulate. Guildford’s topography and microclimate and
the potential for induction looping and inversion episodes are a concern. The Environment Agency has admitted to
Parliament that it does not know how dangerous modern incinerators are to human
health. The following assessments have
not been undertaken: background levels of dioxin in the local population, risk
and consequences of accidents, emission levels achieved in practice by
incinerators, full extent of the impact zone or fugitive emissions. The Agency cannot find an incinerator in
England and Wales that hasn’t breached its pollution limits. Safety must be proven before an
incinerator is acceptable in the heart of a borough of 129,000 people. The Waste Framework Directive is clear that
waste should be “recovered or disposed of without endangering human health and
without using processes or methods which could harm the environment and in
particular without risk to water, air, soil and plant and animals..” . Circular 11/94 requires that planning
functions are exercised “in line with” the Directive. Unless the Council is satisfied that there are no risks, or only
de minimus risks, to environmental objectives, it would be justified in
refusing planning consent.
b) Other Pollution
Issues:
The
noise impacts of the air cooling condensers; odours including ammonia from the
flue treatment; the waste and the ash residues; long operating hours; light
pollution; highly toxic dust; disturbance of the adjacent landfill; need to
remove substantial quantities of toxic sewage sludge; potential instability of
the structure on this material.
Unacceptable Impact of Traffic:
The applicants have failed to assess the traffic
impact against the proximity principle or beyond the immediate vicinity of the
gateway junction, including connections with the strategic road network. They have not considered transportation by
rail. There are incorrect assumptions about traffic increases, existing
congestion and the capacity at the gateway junction, which fundamentally
undermine the applicant’s case as to the levels of traffic to be generated by
the proposed development and its impact on the locality. The Traffic Impact Assessment is flawed as it is based on the
erroneous assumption that the Slyfield incinerator would treat only Surrey’s
waste. There will be a dramatic increase in articulated vehicles leading to
much greater congestion, road damage, accidents and site development
constraints.
Detrimental to the Functioning of the
Flood Plain:
The excavation of a massive waste storage bunker below
ground level would reduce the water storage capacity of the land. Bunds around the incinerator would impede
the flow of water. A pinch point would be
created which would increase the risk of flooding upstream in Guildford. The incinerator would be built on land that
attenuates flows into the river and is used as an overspill when the sewage
treatment works get overloaded. That
water has to go somewhere. If it is
diverted, it will increase the flood risk elsewhere. In view of the recent floods and concerns about climate change,
the wisdom of designing an incinerator for a 1 in 100 year flood event in this
vulnerable location is questioned.
There is a risk of flooding of the incinerator itself in an extreme
flood event making the site unsuitable for such a potentially dangerous and
toxic installation.
Contrary to
Economic Strategy:
It
would pose a threat to the economy of Guildford because the type of business
and employee that Guildford attracts, and relies upon, as the “administrative
centre of the South East Region” would be deterred by a large polluting
industrial installation.
Contrary to the Slyfield Development
Brief:
The
proposal is at odds with the Brief which seeks to “improve and enhance” the
existing estate and “ensure that the environmental and visual impact of any
development is acceptable”.
"Recycling facilities" will only be considered suitable if
they do not require large-scale buildings (the proposed incinerator measures
139m by 101m) or create significant levels of pollution or noise or other
environmental disbenefits.
"Excessively large-scale buildings will be resisted, particularly those
which may have an over-bearing and visually dominant impact on the adjoining
environment". Building height is
limited to no more than 10 metres to ridge or 8 metres to a flat roof. The
proposed incinerator building is 40 metres at its highest point and the stack
extends to 70 metres high - both clearly in breach of the Brief's guidelines. It
will push the capacity of this part of Guildford to accommodate undesirable
development beyond acceptable limits and set a precedent for breaches.
Harm to Recreational Amenity:
It
would undermine the recreational and amenity value of the Wey Navigation and
the Riverside Park Local Nature Reserve.
Risk of Harm to a Site of National
Nature Conservation Importance:
It
would acidify Whitmoor Common Site of Special Scientific Interest, which has
also been designated as a “potential Special Protection Area” under European
law. It should therefore be protected
as if an SPA.
POLICY
OBJECTIONS:
Against Recycling and Contrary to
National Waste Policy:
It
would prejudice recycling by burning material that is capable of being
recycled. A Colchester initiative has
achieved 57% recycling in three months demonstrating that if an authority makes
a major commitment to recycling large increases in recycling rates can be made
in a short time. Government policy is
that recycling must be given priority over incineration. Surrey and Guildford need to set up
comprehensive recycling first.
Not Proven to be the BPEO:
This
incinerator has not been proven to be the “Best Practicable Environment
Option”. Waste minimisation, recycling,
composting, digestion and other techniques need to be assessed. Lifecycle analyses, locational factors and
the proximity principle need to be considered.
Even if incineration were to become the BPEO for part of Surrey’s waste
stream, which is not accepted, the application for this incinerator in this
location has fundamental problems that call into doubt whether it can be the
BPEO. It would waste energy by
attempting to burn large volumes of materials that are non-combustible. Reliance on air-cooling, in the absence of
an adequate water supply, would make the plant noisy and inefficient. The plant would lack combined heat and
power, which is an absolute requirement and its absence places this application
low down the waste hierarchy. The site is
too constrained for adequate pre-sorting of waste, ash processing and
landscaping, the latter being a requirement of the Slyfield Development
Brief. Ash would need to be transported
significant distances to landfill and processing. No market has been identified for the ash produced from the
incineration process. The location
poses unacceptable risks (e.g. flood, pollution risk near people, traffic,
microclimate). There is no rail link.
Premature
and Undemocratic:
It
would be premature because the Surrey Waste Plan is discredited and the
replacement is not ready. The last one
was condemned as “undemocratic” by an inquiry inspector and only adopted as an
interim measure. Residents have not yet
had a chance to decide how they would like to achieve Government targets for
recovering value from waste and where they believe any necessary waste
installations should be. Whether to
incinerate or go for ambitious recycling and digestion is a matter for local
decision. Government is clear that we
should be given that choice. The number
of letters of objection to this and the other incinerator proposals indicates
residents need to be consulted on waste policy in Surrey generally before any
decision is taken on the need for, let alone the location of, an
incinerator. Waste Strategy 2000 is
clear that social preference needs to be taken into account.
Speculative and Need Unproven:
The applicant
claims to need an incinerator to process Surrey’s municipal waste. But the £1
billion contract to handle this waste for the next 25 years has been awarded to
another company, which has its own contractual obligations with Surrey County
Council to build installations and handle our waste. This incinerator could
burn waste imported from London and elsewhere. There is no control over where
commercial and industrial waste is attracted from and without a contract there
is no certainty about the origin of any municipal waste. Traffic movements cannot be assessed because
the waste catchment cannot be determined. The best technology cannot be
determined because the nature of the waste input is not known. A prime determinant behind this application
is not that Guildford is the best location but that the applicant owns the site
for historical business reasons. The
need for incineration capacity is not proven by TWM or SCC, and is refuted by
realistic scenarios described. No
actual requirement in terms of tonnage has been formally identified for
incineration capacity in Surrey to date.
Contrary to Objectives of Sustainable Development:
Maximising
waste reduction, waste re-use and recycling is required of us by sustainable
development. This proposal would work against this objective. It would push the environmental capacity of
this part of Guildford beyond acceptable limits, especially in view of the
number of nearby residents. For any
large waste installation to be the BPEO, sustainable development requires that
it should be served by rail. We have
inherited Guildford as a town of special qualities, which we wish to hand on,
undiminished, to the next generation.
An incinerator would harm those special qualities. We wish to see this application refused and
to explore more environmentally acceptable and sustainable waste solutions.
GAIN wishes to put on record its great concern that
it is being asked to participate in an unsatisfactory and flawed planning
process. This is because:
* Our Human
Rights are compromised by the fact that it is unjust that the applicant has an automatic
right of appeal against refusal of consent but that we, as residents who would
be affected by the development, have no right of appeal against granting of
consent.
* The
applicant has applied for an IPC licence, which may be given prior to planning
consent. European Law requires that, as
from October 1999, any application such as this should be considered from the
outset under stricter IPPC requirements.
If an IPC licence were to be awarded, this may influence the Planning
Authorities. This application would not
be considered on the same basis as the other two incinerator proposals before
Surrey County Council which have both applied for IPPC. Use of IPC procedures prior to an “upgrade”
to IPPC could also prejudice consideration of whether the site is appropriate
for IPPC requirements.
* A contract
has been awarded by Surrey County Council for 335,000 tonnes of waste to be
processed by energy from waste incinerators.
This risks prejudicing establishment of the Best Practicable
Environmental Option as required by the Government’s Waste Strategy 2000.
* The Surrey
Waste Plan, against which this application should be judged, is discredited and
was only adopted as an interim measure, having been severely criticised and
described as “undemocratic” by a Government Inspector. We are being denied a democratic, plan-led
assessment.
We also wish to raise the following procedural
points:
* We submit
that this application raises important issues of development control, gives
rise to significant public controversy and is of more than local
importance. We are particularly
concerned to know how the three incinerator applications will be considered
together and consider that this raises questions of natural law.
* At the
time of making these comments, we have only seen an Environmental Statement by
the applicant, which is simply the raw data upon which an Environmental
Assessment can be based, rather than a detailed assessment as required in
accordance with EU and UK law. We understand
that the Council is required to make its own assessment of this document with
independent specialists brought in as required. Please advise us of the
mechanism for informing the public of the findings of the Council’s Assessment
and how the opportunity will be provided for the public to comment on this
assessment and any changes made to the applicant’s Environmental Statement as a
result.
* We ask you
to advise us what procedure Surrey County Council will follow to determine
whether this application is the BPEO and how the public will be able to
participate democratically in this process.
GAIN 22 12 00