At the meeting of Shropshire Council's Strategic Planning Committee on 3rd September, 2010, several members of the public plus a number of elected members spoke against the proposed Battlefield incinerator. The acting Chair of the Committee, cllr David Evans, had allowed more than the usual one member of the public to speak as the planning application was considered of more than usual significance to the public.
Despite the meeting being delayed by 6 weeks and held on a weekday at the end of the school holidays, close on 100 members of the public attended to hear the proceedings.
Safe Waste in Shropshire is grateful to all the speakers who kindly provided either the texts of their speeches or their notes.
Despite the meeting being delayed by 6 weeks and held on a weekday at the end of the school holidays, close on 100 members of the public attended to hear the proceedings.
Safe Waste in Shropshire is grateful to all the speakers who kindly provided either the texts of their speeches or their notes.
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For Safe Waste in Shropshire (Speaker: Miriam Walton):
Mr Chairman, ladies and gentlemen,
I trust that you’ve read our detailed response to the Officers’ Report in which we’ve given our reasons for believing it to be an insecure basis for a decision to pass this application.
For the last 3 years we’ve been told that an incinerator is the only affordable answer to Shropshire’s growing waste problem. We’re told we can’t keep ‘throwing it down the hole’ as, if we do, the Council will incur massive fines. We’re told waste figures are rising and will continue to rise as more people come to live here.
Those against are accused of being NIMBYs, scare-mongers and of offering no alternative.
So what is our problem? The incinerator would burn all the waste efficiently and cleanly – no black smoke! – and the Government would help things along with a long-term PFI loan to ease the burden on the council-tax payer.
To gild the lily, this incinerator would also be a power station! How many times have you heard that it would produce ‘enough electricity to power 10,000 homes’?
So – waste made invisible, recycling set to rise to an incredible 55% by the end of the contract and green energy to boot. What’s not to like, as they say?
Well here’s what:
We don’t need it. The council doesn’t need to borrow all those millions of pounds and the council tax payer wouldn’t need to pay it all back with interest. The Council needs to save money, here’s how:
Just don’t build it!
Waste is actually falling, not rising. Yes, even with all those new homes. The figures are in the public domain and provided by Veolia. Please look at the graphs we have produced to demonstrate this.
Shropshire recycling is already nearly 50%; some UK councils are already over 60. San Francisco aims for Zero Waste within the decade. Shropshire needs to take these as models rather than strangle good initiatives like the Ludlow Anaerobic Digester.
We don’t produce enough waste to feed an incinerator and waste would come from outside Shropshire. Not household waste. Commercial and Industrial including ‘garage waste’ – would be burned. Look at Hampshire where Veolia has already changed its permits to import such waste from outside the county.
The council would have to pay for 90,000 tons p.a. whether it provided it or not. And who really benefits from this hugely expensive high-tech bonfire that in about 30 years would need to be dismantled at our own expense?
PFI deals are already proving a problem elsewhere; why hang this millstone round our children’s necks for this unnecessary and dangerous facility?
The smoke plume containing its deadly mixture of small and invisible particulates would ground within 15 miles. We don’t want to breathe the toxic cocktail produced by this ‘great landfill in the sky’.
We fear that burning waste would endanger human health, farmland, crops and animals.
About a quarter of what’s burned would be landfilled anyway, some of it so toxic it would need to be trucked to special dumps well away from Shropshire.
Now that’s NIMBY for you!
I urge you to refuse this application and ‘do the right thing’ for the people of Shropshire.
For Safe Waste in Shropshire (Speaker: Miriam Walton):
Mr Chairman, ladies and gentlemen,
I trust that you’ve read our detailed response to the Officers’ Report in which we’ve given our reasons for believing it to be an insecure basis for a decision to pass this application.
For the last 3 years we’ve been told that an incinerator is the only affordable answer to Shropshire’s growing waste problem. We’re told we can’t keep ‘throwing it down the hole’ as, if we do, the Council will incur massive fines. We’re told waste figures are rising and will continue to rise as more people come to live here.
Those against are accused of being NIMBYs, scare-mongers and of offering no alternative.
So what is our problem? The incinerator would burn all the waste efficiently and cleanly – no black smoke! – and the Government would help things along with a long-term PFI loan to ease the burden on the council-tax payer.
To gild the lily, this incinerator would also be a power station! How many times have you heard that it would produce ‘enough electricity to power 10,000 homes’?
So – waste made invisible, recycling set to rise to an incredible 55% by the end of the contract and green energy to boot. What’s not to like, as they say?
Well here’s what:
We don’t need it. The council doesn’t need to borrow all those millions of pounds and the council tax payer wouldn’t need to pay it all back with interest. The Council needs to save money, here’s how:
Just don’t build it!
Waste is actually falling, not rising. Yes, even with all those new homes. The figures are in the public domain and provided by Veolia. Please look at the graphs we have produced to demonstrate this.
Shropshire recycling is already nearly 50%; some UK councils are already over 60. San Francisco aims for Zero Waste within the decade. Shropshire needs to take these as models rather than strangle good initiatives like the Ludlow Anaerobic Digester.
We don’t produce enough waste to feed an incinerator and waste would come from outside Shropshire. Not household waste. Commercial and Industrial including ‘garage waste’ – would be burned. Look at Hampshire where Veolia has already changed its permits to import such waste from outside the county.
The council would have to pay for 90,000 tons p.a. whether it provided it or not. And who really benefits from this hugely expensive high-tech bonfire that in about 30 years would need to be dismantled at our own expense?
PFI deals are already proving a problem elsewhere; why hang this millstone round our children’s necks for this unnecessary and dangerous facility?
The smoke plume containing its deadly mixture of small and invisible particulates would ground within 15 miles. We don’t want to breathe the toxic cocktail produced by this ‘great landfill in the sky’.
We fear that burning waste would endanger human health, farmland, crops and animals.
About a quarter of what’s burned would be landfilled anyway, some of it so toxic it would need to be trucked to special dumps well away from Shropshire.
Now that’s NIMBY for you!
I urge you to refuse this application and ‘do the right thing’ for the people of Shropshire.
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For No Burners in Shropshire (Speaker: Nick Hall)
For No Burners in Shropshire (Speaker: Nick Hall)
Chairman, Members of the Committee
Thank you for allowing me to speak and I wish to make the following points on behalf of NOBIS in objection to this application.
PUBLICITY & REPRESENTATION
The objections of various groups and persons have not been fully represented in the Officer Appraisal Report. In particular, it states, “the main issues raised by NOBIS are discussed in Section 10 of this report”; they are NOT. It also states that “the detailed NOBIS submission is available for inspection in the Members’ Library”; this requires Councillors to visit the library and actively search for it. I ask: How many Members of this Committee have actually done so? Was this the only objection omitted?
The objections of various groups and persons have not been fully represented in the Officer Appraisal Report. In particular, it states, “the main issues raised by NOBIS are discussed in Section 10 of this report”; they are NOT. It also states that “the detailed NOBIS submission is available for inspection in the Members’ Library”; this requires Councillors to visit the library and actively search for it. I ask: How many Members of this Committee have actually done so? Was this the only objection omitted?
LANDSCAPE & VISUAL EFFECTS AND CULTURAL HERITAGE
The Outline Planning Permission for the Battlefield Food Enterprise Park restricted the height of the buildings to 12 metres to the eaves. The reason for this was “To protect the character and appearance of the edge of this rural area” but this is not stated in the report. The Council’s own Landscape Officer’s comments concerning underestimation of visual impact and overstating of the likely mitigation of the proposed on-site planting have largely been ignored in the report.
The development will not preserve the setting and important views of listed buildings (the Grade II* listed Church of St Mary Magdalene and the Grade II listed Albright Hussey), contrary to adopted SABC Local Plan Policy HE7.
The development will adversely affect the topographical authenticity and visual amenity of the site of the Battle of Shrewsbury (1403), contrary to adopted SABC Local Plan Policy HE13. The development will adversely affect the topographical authenticity and visual amenity of the site of the Battle of Shrewsbury (1403), (a nationally important site) and of the Grade II* listed Church of St Mary Magdalene (a scheduled ancient monument), contrary to adopted SABC Local Plan Policy HE13.
SURPLUS INCINERATOR CAPACITY IN THE WEST MIDLANDS
Last December Telford & Wrekin Council refused an application for a 62,000 tonne per annum incinerator citing surplus incinerator capacity in the area; this is currently 139,000 tonnes pa, rising to 288,000 tonnes pa if all the proposed facilities (including Battlefield) were permitted.
COSTS
The Officer Appraisal Report does not deal with those objections raised about costs: Annual costs starting at £10.8 million, rising to well over £20.8 million by contract end, well over the costs of other technologies, including landfill. The Cost of decommissioning the facility at contract end, which will be a huge unspecified additional cost to the taxpayer in the future.
ALL THE ABOVE ARE MATERIAL PLANNING REASONS FOR REFUSAL, and we ask the Committee to refuse the application.
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For Shrewsbury Friends of the Earth (Speaker: Dave Green)
Shrewsbury Friends of the Earth’s detailed objections to this proposal cover a range of concerns including the ridiculously low efficiency of the scheme, the high carbon emissions, the costs of incineration, health effects etc. However today I’ll limit myself to two crucial material planning grounds, both relating to the Waste Local Plan.
I was heavily involved in the whole Waste Local Plan process over a two year period. It was made quite clear by the Waste Planning officers throughout that process that whilst consideration might be given to a gasification or pyrolosis facility there was no point in even discussing mass burn incineration as it wasn’t in the range of options on the table. This was reflected in Schedule 1 pg 48 of the plan which states that the site at Battlefield has a potential use for “small scale energy recovery excluding mass burn incineration”. Whilst much of the plan isn’t technology specific this is a very clear and unambiguous statement.
Veolia have tried to argue that the “application of EFW technology has progressed in the last 5-6 years and facilities with smaller outputs have become more feasible’. However the plant at Chineham which is the same size as this proposal was granted planning permission in 2000 and if you read the 1998 report “Waste Treatment and Disposal” (by P.Williams) you’ll find the statement “mass burn incineration typically involves waste throughputs of 10 to 50 tonnes/hour”. The proposal before you is for 12 t/hour. This proposal may be for a relatively small example but it’s still definitely a mass burn incinerator.
Secondly Policy 17 of the WLP states that any proposals for energy recovery facilities would have to “form an essential part of a sustainable waste management system”. Essential is a very strong word and whilst the proposal may well be convenient and profitable the applicant hasn’t shown that it is essential. Shropshire Council and Veolia, with the public’s support, have done very well in developing recycling facilities in the County so that they’re well ahead of their targets to reduce landfill, particularly for biodegradable waste. With increased national emphasis on waste reduction plus an increasing number and variety of recycling facilities, we are confident in Shropshire Council and Veolia’s ability to continue to keep ahead of the targets without this facility.
The existence of viable alternative strategies can be seen just by looking at what other councils are doing, with incinerator plans being scrapped all across the country,
This application is therefore in breach of two clear statements in the WLP. Richard Benyon MP, Under Sec of State for DEFRA stated in a reply to Daniel Kawczynski on 26th July 2010 that “it’s important that any plans for waste to energy facilities emerge out of local waste strategies”, this proposal clearly fails this test. We urge you therefore to refuse this application, to do otherwise would negate the very considerable effort that went into developing the WLP and call into serious question the whole process.
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For Shrewsbury Transition Towns (Speaker: Steve Boulding)
The Climate Change Committee, an independent scientific and economic adviser to the UK government, has just issued a report warning of the economic consequences of the failure to bring forward large scale early investment in green technology, citing especially such things as the potential for widespread installation of new generation solar photovoltaic panels on the millions of available roofs, domestic and commercial/public.
This adds to the joint report published two months ago by Chatham House (Royal Institute of International Affairs) and the research dept. of Lloyd’s of London (the global insurance market), which looked at the likely economic consequences of UK business failing to make adequate preparation for the effects of climate change, and the coming massive increase in the price of oil as production becomes more difficult and expensive (as shown by the BP fiasco in the Gulf of Mexico, and the environmental disaster of tar sands extraction in Canada), and demand increases in India, China, Brazil and Russia, who all have the economic clout to outbid Europe and North America for supplies.
The Pentagon’s strategic geo-political analysis published in March makes a compelling argument for “Peak Oil” happening between 2013 and 2015. Peak Oil is the point at which global demand exceeds the capacity of the industry to extract, process and distribute enough to meet requirements, as reserves dwindle and extraction becomes more difficult.
Fuel prices will double within the next five years, and a hundred years of an economy and a way of life based on cheap oil will rapidly have to change.
There will have to be a move towards much more local and regional production and consumption of food, especially, and this is not lost on the growers, manufacturers and retailers, who are already planning for major supply chain and logistics efficiencies, and especially the quickest and easiest “win”, reduction and elimination of packaging, most of which is oil-based or derived. Considerable effort is going into planning for everything that cannot be eliminated to be made easily recyclable or re-usable.
There is also considerable pressure for investment in large-scale composting and anaerobic digestion, both as an environmental solution and an additional source of income for hard-pressed farmers.
All sectors – manufacturing, retail, construction and civil engineering – are rapidly improving the energy efficiency of their premises and processes, and dramatically reducing the amount of physical waste that they produce.
The concept of “zero waste” is being embraced as a practicable and achievable goal, and a key component of modern best practice in management.
Waste streams from office, retail and factory-floor activity will dwindle rapidly as the only relevant waste hierarchy – reduce, re-use and recycle, becomes ingrained in the business world’s philosophy.
Local authorities which educate and motivate their householders, for example Rochford in Essex, are already achieving a recycling rate of two-thirds of all waste, and are on course for 75% plus in the next few years.
Incinerator feedstock can at best only produce a calorific value of 20-25% of the total amount of energy embedded in its raw material, manufacture, transport, etc., and therefore represents a doubly negative impact on CO2 emissions.
I therefore submit that the above shows that there are material planning grounds for refusal of the application, on the following grounds:
1. Absence of demonstrable need for the facility
2. Non-compliance with binding EU and UK Government CO2 emission
and waste reduction targets, as specified in relevant planning
guidance to local authorities
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Balfours, acting for Sundorne Estates (Speaker: Karine Swanson)
Chairman, Members of the Committee, I wish to make the following points in objection to this application:
DEPARTURE
The Committee Report itself accepts that this proposal does not accord 'with theDevelopment Plan because
(i) Policy 6 of the Waste Local Plan expressly excludes mass bumincineration at this site;
(ii) Para 6.87 ofthe WLP states that"In Shropshire preference will be given to these alternative energyrecovery technologies" - referring to pyrolysis and gasification processes.
A proposal which does not accord with the Development Plan should be rejected unless material considerations indicate otherwise. In this case the relevantmaterial considerations which I set out below also demonstrate the proposal Should be rejected.
BATTLEFIELD SITE
The plans attached to the Committee Report at page l72 are scaled anddemonstrate how close the new building is to the historic battlefield site. Itschimney at 65m high (plus plume) will be readily apparent and detract from thesite's setting which is an integral part of Shrewsbury's heritage.
ALTERNATIVE METHODS OF TREATMENT
The Applicant has chosen the easiest option for dealing with waste and not themost sustainable. Gasification and Pyrolysis would not require such a largechimney.
HEAT RECOVERY
The heat from EFW plants should be used (see para 11.58 of the CommitteeReport) but the Applicant has not shown how this will be done and will onlycommit to schemes which use the heat subject to "economic criteria being met"(Report para 11.60). This conflicts with PPS 22 and the Waste FrameworkDirective 2008/98/EC.
LANDSCAPE EFFECT
The Report tells us the EFWF plant is smaller than others operated by theApplicant (para l1.77), So what! The proper question is whether the building"fits" in this location. It does not. This will be the largest building in Shropshiredwariing the surrounding buildings and incongruous in the historic townssetting.
RAMSAR / SSI/ PROTECTED SPECIES
The Committee Report has not asked two questions it should have, namely(i) Where is the overriding objective to justify destruction of GCN habitatand(ii) do alternative sites exist whereby this could be avoided?
ADJACENT LAND USE
It is not enough to say there will be tight controls to protect the Food EnterpriseCentre - which lies immediately to the north and west of the site (Report paral1.160). The question is whether these two uses of land should be adjacent toeach other. Which food producer / processor wants an address next to anincinerator? Which supermarket will buy its products?
TRAFFIC, DUST, AIR QUALITY
These issues are dealt with by others and we support these objections.
Finally, the Committee should treat as a material consideration the contractual obligations entered into by another arm of the Council to deal with Shropshiies Waste. One bad decision should not be relied upon to justifyanother. This application should be referred to Government Office as the Report recommends if the Committee do not propose to reject it.
I ask that you refuse permission for the reasons that I have given.
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For the Albrighton Estate and Battlefield 1403 (Speaker: David Haston) *
The incinerator application should be refused for many reasons. I will concentrate
on just one:
The proposed incinerator is located within just 300 metres of the Registered site
of the Battle of Shrewsbury.
The battlefield is of national importance and contains a Scheduled Ancient
Monument and a Grade II* listed Church. It is also the first English battlefield to
benefit from a privately developed, operated and critically acclaimed heritage
centre.
The site of the Battle of Shrewsbury is consequently one of Shropshire’s most
important heritage, educational and tourism assets.
The importance and sensitivity of the battlefield has, to date, been recognised
through the restrictions placed on the height of nearby buildings. For example, the
adjacent Food Enterprise Park was capped at about 12 metres.
For some reason, the setting of the battlefield no longer appears to be important to
the Council’s officers, as a 28 metre high building, with a 65 metre high chimney
emitting a plume up to another 100 metres above has been recommended for
approval.
The applicant has prepared a Conservation Management Plan for the battlefield in
consultation with English Heritage and Shropshire Council under the pretext that
this will in some way mitigate the harm that they acknowledge will be caused to
the setting of the battlefield.
Part of the Conservation Management Plan involves the planting of a small area
of trees in the roadside verge, but even in 60 years it will be physically impossible
to properly screen a building of this scale.
The Conservation Management Plan also refers to other works that might be
secured by way of a Section 106 agreement. These include:
1. Maintenance of the mounds car park, the footpaths and fences within the
Battlefield;
2. A separate heritage exhibition within the incinerator site and enhanced public
access and interpretation on the battlefield itself.
Given that Mrs Jagger effectively owns about 85% of the registered battlefield
and her family already operates a dedicated heritage centre, one has to ask:
Firstly, how will additional access to the battlefield be achieved?
Secondly, what will be gained from another battlefield exhibition competing with
the existing heritage centre? and
Thirdly, why was Mrs Jagger not consulted about the part of the Conservation
Management Plan which affects her land and would need her agreement for it to
be implemented? As it stands, it cannot be fully delivered and it is not an
enforceable obligation on Veolia.
However, more importantly, one has to ask why officers have failed to report to
you that under an Agreement dated 17 December 2002, the Council is already
contractually obliged to maintain the majority of footpaths and fences across the
Battlefield in perpetuity.
One assumes that English Heritage was also unaware of that agreement, and as a
consequence, may have prematurely withdrawn its objection and unintentionally
secured virtually no gain or effective mitigation by doing so.
This planning application fundamentally conflicts with numerous Development
Plan policies.
In order to counter these policies, exceptional material considerations would have
to be demonstrated. However, in this case the significant material harm to an
irreplaceable heritage asset of national importance simply weighs against the
application further.
I would therefore urge Members to refuse planning permission.
Shrewsbury Friends of the Earth’s detailed objections to this proposal cover a range of concerns including the ridiculously low efficiency of the scheme, the high carbon emissions, the costs of incineration, health effects etc. However today I’ll limit myself to two crucial material planning grounds, both relating to the Waste Local Plan.
I was heavily involved in the whole Waste Local Plan process over a two year period. It was made quite clear by the Waste Planning officers throughout that process that whilst consideration might be given to a gasification or pyrolosis facility there was no point in even discussing mass burn incineration as it wasn’t in the range of options on the table. This was reflected in Schedule 1 pg 48 of the plan which states that the site at Battlefield has a potential use for “small scale energy recovery excluding mass burn incineration”. Whilst much of the plan isn’t technology specific this is a very clear and unambiguous statement.
Veolia have tried to argue that the “application of EFW technology has progressed in the last 5-6 years and facilities with smaller outputs have become more feasible’. However the plant at Chineham which is the same size as this proposal was granted planning permission in 2000 and if you read the 1998 report “Waste Treatment and Disposal” (by P.Williams) you’ll find the statement “mass burn incineration typically involves waste throughputs of 10 to 50 tonnes/hour”. The proposal before you is for 12 t/hour. This proposal may be for a relatively small example but it’s still definitely a mass burn incinerator.
Secondly Policy 17 of the WLP states that any proposals for energy recovery facilities would have to “form an essential part of a sustainable waste management system”. Essential is a very strong word and whilst the proposal may well be convenient and profitable the applicant hasn’t shown that it is essential. Shropshire Council and Veolia, with the public’s support, have done very well in developing recycling facilities in the County so that they’re well ahead of their targets to reduce landfill, particularly for biodegradable waste. With increased national emphasis on waste reduction plus an increasing number and variety of recycling facilities, we are confident in Shropshire Council and Veolia’s ability to continue to keep ahead of the targets without this facility.
The existence of viable alternative strategies can be seen just by looking at what other councils are doing, with incinerator plans being scrapped all across the country,
This application is therefore in breach of two clear statements in the WLP. Richard Benyon MP, Under Sec of State for DEFRA stated in a reply to Daniel Kawczynski on 26th July 2010 that “it’s important that any plans for waste to energy facilities emerge out of local waste strategies”, this proposal clearly fails this test. We urge you therefore to refuse this application, to do otherwise would negate the very considerable effort that went into developing the WLP and call into serious question the whole process.
----------------------------------------------------------
For Shrewsbury Transition Towns (Speaker: Steve Boulding)
The Climate Change Committee, an independent scientific and economic adviser to the UK government, has just issued a report warning of the economic consequences of the failure to bring forward large scale early investment in green technology, citing especially such things as the potential for widespread installation of new generation solar photovoltaic panels on the millions of available roofs, domestic and commercial/public.
This adds to the joint report published two months ago by Chatham House (Royal Institute of International Affairs) and the research dept. of Lloyd’s of London (the global insurance market), which looked at the likely economic consequences of UK business failing to make adequate preparation for the effects of climate change, and the coming massive increase in the price of oil as production becomes more difficult and expensive (as shown by the BP fiasco in the Gulf of Mexico, and the environmental disaster of tar sands extraction in Canada), and demand increases in India, China, Brazil and Russia, who all have the economic clout to outbid Europe and North America for supplies.
The Pentagon’s strategic geo-political analysis published in March makes a compelling argument for “Peak Oil” happening between 2013 and 2015. Peak Oil is the point at which global demand exceeds the capacity of the industry to extract, process and distribute enough to meet requirements, as reserves dwindle and extraction becomes more difficult.
Fuel prices will double within the next five years, and a hundred years of an economy and a way of life based on cheap oil will rapidly have to change.
There will have to be a move towards much more local and regional production and consumption of food, especially, and this is not lost on the growers, manufacturers and retailers, who are already planning for major supply chain and logistics efficiencies, and especially the quickest and easiest “win”, reduction and elimination of packaging, most of which is oil-based or derived. Considerable effort is going into planning for everything that cannot be eliminated to be made easily recyclable or re-usable.
There is also considerable pressure for investment in large-scale composting and anaerobic digestion, both as an environmental solution and an additional source of income for hard-pressed farmers.
All sectors – manufacturing, retail, construction and civil engineering – are rapidly improving the energy efficiency of their premises and processes, and dramatically reducing the amount of physical waste that they produce.
The concept of “zero waste” is being embraced as a practicable and achievable goal, and a key component of modern best practice in management.
Waste streams from office, retail and factory-floor activity will dwindle rapidly as the only relevant waste hierarchy – reduce, re-use and recycle, becomes ingrained in the business world’s philosophy.
Local authorities which educate and motivate their householders, for example Rochford in Essex, are already achieving a recycling rate of two-thirds of all waste, and are on course for 75% plus in the next few years.
Incinerator feedstock can at best only produce a calorific value of 20-25% of the total amount of energy embedded in its raw material, manufacture, transport, etc., and therefore represents a doubly negative impact on CO2 emissions.
I therefore submit that the above shows that there are material planning grounds for refusal of the application, on the following grounds:
1. Absence of demonstrable need for the facility
2. Non-compliance with binding EU and UK Government CO2 emission
and waste reduction targets, as specified in relevant planning
guidance to local authorities
----------------------------------------------------------------------------
Balfours, acting for Sundorne Estates (Speaker: Karine Swanson)
Chairman, Members of the Committee, I wish to make the following points in objection to this application:
DEPARTURE
The Committee Report itself accepts that this proposal does not accord 'with theDevelopment Plan because
(i) Policy 6 of the Waste Local Plan expressly excludes mass bumincineration at this site;
(ii) Para 6.87 ofthe WLP states that"In Shropshire preference will be given to these alternative energyrecovery technologies" - referring to pyrolysis and gasification processes.
A proposal which does not accord with the Development Plan should be rejected unless material considerations indicate otherwise. In this case the relevantmaterial considerations which I set out below also demonstrate the proposal Should be rejected.
BATTLEFIELD SITE
The plans attached to the Committee Report at page l72 are scaled anddemonstrate how close the new building is to the historic battlefield site. Itschimney at 65m high (plus plume) will be readily apparent and detract from thesite's setting which is an integral part of Shrewsbury's heritage.
ALTERNATIVE METHODS OF TREATMENT
The Applicant has chosen the easiest option for dealing with waste and not themost sustainable. Gasification and Pyrolysis would not require such a largechimney.
HEAT RECOVERY
The heat from EFW plants should be used (see para 11.58 of the CommitteeReport) but the Applicant has not shown how this will be done and will onlycommit to schemes which use the heat subject to "economic criteria being met"(Report para 11.60). This conflicts with PPS 22 and the Waste FrameworkDirective 2008/98/EC.
LANDSCAPE EFFECT
The Report tells us the EFWF plant is smaller than others operated by theApplicant (para l1.77), So what! The proper question is whether the building"fits" in this location. It does not. This will be the largest building in Shropshiredwariing the surrounding buildings and incongruous in the historic townssetting.
RAMSAR / SSI/ PROTECTED SPECIES
The Committee Report has not asked two questions it should have, namely(i) Where is the overriding objective to justify destruction of GCN habitatand(ii) do alternative sites exist whereby this could be avoided?
ADJACENT LAND USE
It is not enough to say there will be tight controls to protect the Food EnterpriseCentre - which lies immediately to the north and west of the site (Report paral1.160). The question is whether these two uses of land should be adjacent toeach other. Which food producer / processor wants an address next to anincinerator? Which supermarket will buy its products?
TRAFFIC, DUST, AIR QUALITY
These issues are dealt with by others and we support these objections.
Finally, the Committee should treat as a material consideration the contractual obligations entered into by another arm of the Council to deal with Shropshiies Waste. One bad decision should not be relied upon to justifyanother. This application should be referred to Government Office as the Report recommends if the Committee do not propose to reject it.
I ask that you refuse permission for the reasons that I have given.
--------------------------------------------------------------------------------
For the Albrighton Estate and Battlefield 1403 (Speaker: David Haston) *
The incinerator application should be refused for many reasons. I will concentrate
on just one:
The proposed incinerator is located within just 300 metres of the Registered site
of the Battle of Shrewsbury.
The battlefield is of national importance and contains a Scheduled Ancient
Monument and a Grade II* listed Church. It is also the first English battlefield to
benefit from a privately developed, operated and critically acclaimed heritage
centre.
The site of the Battle of Shrewsbury is consequently one of Shropshire’s most
important heritage, educational and tourism assets.
The importance and sensitivity of the battlefield has, to date, been recognised
through the restrictions placed on the height of nearby buildings. For example, the
adjacent Food Enterprise Park was capped at about 12 metres.
For some reason, the setting of the battlefield no longer appears to be important to
the Council’s officers, as a 28 metre high building, with a 65 metre high chimney
emitting a plume up to another 100 metres above has been recommended for
approval.
The applicant has prepared a Conservation Management Plan for the battlefield in
consultation with English Heritage and Shropshire Council under the pretext that
this will in some way mitigate the harm that they acknowledge will be caused to
the setting of the battlefield.
Part of the Conservation Management Plan involves the planting of a small area
of trees in the roadside verge, but even in 60 years it will be physically impossible
to properly screen a building of this scale.
The Conservation Management Plan also refers to other works that might be
secured by way of a Section 106 agreement. These include:
1. Maintenance of the mounds car park, the footpaths and fences within the
Battlefield;
2. A separate heritage exhibition within the incinerator site and enhanced public
access and interpretation on the battlefield itself.
Given that Mrs Jagger effectively owns about 85% of the registered battlefield
and her family already operates a dedicated heritage centre, one has to ask:
Firstly, how will additional access to the battlefield be achieved?
Secondly, what will be gained from another battlefield exhibition competing with
the existing heritage centre? and
Thirdly, why was Mrs Jagger not consulted about the part of the Conservation
Management Plan which affects her land and would need her agreement for it to
be implemented? As it stands, it cannot be fully delivered and it is not an
enforceable obligation on Veolia.
However, more importantly, one has to ask why officers have failed to report to
you that under an Agreement dated 17 December 2002, the Council is already
contractually obliged to maintain the majority of footpaths and fences across the
Battlefield in perpetuity.
One assumes that English Heritage was also unaware of that agreement, and as a
consequence, may have prematurely withdrawn its objection and unintentionally
secured virtually no gain or effective mitigation by doing so.
This planning application fundamentally conflicts with numerous Development
Plan policies.
In order to counter these policies, exceptional material considerations would have
to be demonstrated. However, in this case the significant material harm to an
irreplaceable heritage asset of national importance simply weighs against the
application further.
I would therefore urge Members to refuse planning permission.
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Mr James Ellerby, local resident
Mr James Ellerby, local resident
Health Impact of an Incinerator.
You (The Council and Veolia) say that there will be no adverse effects on health and Veolia also claim that health information is not publicly available. If that is the case how can you or they possibly say that there will be no adverse effects? You cannot claim this if there is no information!
Regardless of Violia’s claim I believe that there are a number of studies that conclude that there are health problems associated with incineration.
You (The Council and Veolia) say that there will be no adverse effects on health and Veolia also claim that health information is not publicly available. If that is the case how can you or they possibly say that there will be no adverse effects? You cannot claim this if there is no information!
Regardless of Violia’s claim I believe that there are a number of studies that conclude that there are health problems associated with incineration.
From what I have researched it would appear that as with any study it depends how the information is gathered. Whether you take information in concentric circles around an incinerator or compare results in different areas around the incinerator. Eg: Upwind and downwind of the incinerator (prevailing wind directions).
Even if you accept that there is no absolute proof one way or the other over the health question there is considerable weight of evidence that incineration poses some risk to health, yet no official health studies around EfW plants have taken place, contrary to the Precautionary Principle which states that “Decision Makers faced with an unacceptable risk, scientific uncertainty and public concerns have a duty to find answers.”
You are going to build an incinerator which will be working 24 hours a day 7 days a week at full capacity for 25 years, can you as councilors say, hand on heart that this will have no adverse health effects on any one living in Shropshire, man woman or child? And that’s when it’s working within its safety limits what about when there are problems? The incinerator at Dudley for example has exceeded safe limits on a number of occasions.
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Councillor Maxwell Winchester (STC, Quarry and Coton Hill)
I ask that the Government office of the West Midlands call in this decision and refuse planning approval for a number of reasons.
Firstly, the fact that Shropshire County Council is has a clear interest in approving the applicant and being the organisation making the decision is clearly a conflict of interest. SCC in no way will be capable of making the balanced and informed decision it needs to make for something that has the potential to have such a dramatic effect on the landscape and air quality surrounding it.
Secondly, the planning application has the potential to be in breach of national legislation on construction near to conservation areas. The planned incinerator is very near to the historical Battle of Shrewsbury site and as you are no doubt aware, it is illegal to build anything that interferes with the views to or from an area of historical significance. Building the large chimney stack planned will undoubtedly change what are currently views of the historical centre of Shrewbsury that can be seen from the Battlefield site.
Finally, and most importantly, I am concerned with the mis-information that has been distributed by Veolia ES Shropshire regarding previous research on the effects of incinerators and public health. In a letter to me, Donald McPhail insinuates that there is no peer reviewed research available linking such incinerators with public health risks.
Ironically, in Veolia ES Shropshire’s own leaflets promoting the “proven safety” of the incinerator, they are unable to cite any peer reviewed studies that confirm such a facility is, in fact, safe at all. As a scientist myself, it did not take much of an effort to find peer reviewed sources that suggest a relationship between incinerator locations and infant mortality rates[i], birth defects[ii] and a range of other health problems. Contrary to Veolia ES Shropshire’s point of view promoting the incinerator’s “proven safety”, many authors of other studies note caution of such facilities due to the lack of empirical research and difficulty in determining causality[iii].
I have also discussed this issue with a colleague of mine at Harper Adams University College who is an environmental scientist, Dr Andrea Humphries. She completely agrees with my concerns with the building such facilities and the potential effects on public health.
In light of this I ask that Government office of the West Midlands call in this decision and refuse planning approval until a thorough review of current infant mortality and birth defect rates around existing incinerators has been conducted by independent scientists.
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[i] Dummer, T.J.B., Dickinson, H.O., Parker, L. (2003). Adverse pregnancy outcomes around incinerators and crematoriums in Cumbria, north west England, 1956-93. Journal of Epidaemiology and Community Health, Vol 57, 456-461.
Tango, T., Fujita,T., Tanihata,T., Minowa, M., Doi, Y., Kato, N., Kunikane, S., Uchiyama, I., Tanaka, M. and Uehata, T (2004). Risk of Adverse Reproductive Outcomes Associated with Proximity to Municipal Solid Waste Incinerators with High Dioxin Emission Levels in Japan, Journal of Epidaemiology, Vol 14(3), 83-93.
[ii] Dummer, T.J.B., Dickinson, H.O., Parker, L. (2003). Adverse pregnancy outcomes around incinerators and crematoriums in Cumbria, north west England, 1956-93. Journal of Epidaemiology and Community Health, Vol 57, 456-461.
Tango, T., Fujita,T., Tanihata,T., Minowa, M., Doi, Y., Kato, N., Kunikane, S., Uchiyama, I., Tanaka, M. and Uehata, T (2004). Risk of Adverse Reproductive Outcomes Associated with Proximity to Municipal Solid Waste Incinerators with High Dioxin Emission Levels in Japan, Journal of Epidaemiology, Vol 14(3), 83-93.
[iii] For example:
Harding A.K., Greer M.L. (1993). The Health Impact of Hazardous Waste Sites on Minority Communities: Implications for Public Health and Environmental Health Professionals. Journal of Environmental Health, Vol. 55.
Martuzzi, M, Grundy C., & Elliott, P. (2002). Perinatal mortality in an English health region: geographical distribution and association with socio-economic factors. Paediatric and Perinatal Epidemiology, Vol 12(3), 263-276.
Dolk, H. & Vrijheid, M. (2003). The impact of of environmental pollution on congenital anomalies. British Medical Bulletin, Vol 68: 25–45
Roberts, R.J. & Chen, M. (2006) Waste incineration—how big is the health risk? A quantitative method to allow comparison with other health risks. Journal of Public Health, Vol 28(3), 261-266
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Councillor Malcolm Price (SC, Battlefield)
Chairman there are a number of important items and issues to be covered in such a short period of time so I will stick to the most salient;
Firstly I would like to cover the issue of predetermination by Shropshire Council and its Councillors. Proven evidence shows beyond doubt that Shropshire County Council/Shropshire Council have agreed to support the Energy from Waste Facility planning application for Battlefield within its agreement with Veolia. Clearly this must, and has got to be predetermination?
Residents of Shropshire and particularly Battlefield are well aware of the Shropshire Waste Local Plan and like most people understand the need to reduce waste, recycle more and not to continue sending thousands of tonnes each year in to landfill.
And for their part they have endorsed and supported the recycling process which sees us recycling around 50% of our waste, with the figures continuing to rise.
They trusted this strategy which categorically excluded Mass Burn Incineration as a method of dealing with waste.
Undeniably a departure from the local plan, and material planning policies of Shropshire Council and a justifiable reason for refusal.
SITE LOCATION – (Refusal)
Close proximity to the historic Battlefield site. Visual impact, scale, height (65m high chimney clearly visible from many parts of Shrewsbury and the surrounding rural area). Totally out of keeping with anything in this area even on the existing industrial estate.
Does it make any sense to spend millions pounds on building and promoting a Food Enterprise Centre and then to enhance it with a massive waste incinerator next door?
Firstly I would like to cover the issue of predetermination by Shropshire Council and its Councillors. Proven evidence shows beyond doubt that Shropshire County Council/Shropshire Council have agreed to support the Energy from Waste Facility planning application for Battlefield within its agreement with Veolia. Clearly this must, and has got to be predetermination?
Residents of Shropshire and particularly Battlefield are well aware of the Shropshire Waste Local Plan and like most people understand the need to reduce waste, recycle more and not to continue sending thousands of tonnes each year in to landfill.
And for their part they have endorsed and supported the recycling process which sees us recycling around 50% of our waste, with the figures continuing to rise.
They trusted this strategy which categorically excluded Mass Burn Incineration as a method of dealing with waste.
Undeniably a departure from the local plan, and material planning policies of Shropshire Council and a justifiable reason for refusal.
SITE LOCATION – (Refusal)
Close proximity to the historic Battlefield site. Visual impact, scale, height (65m high chimney clearly visible from many parts of Shrewsbury and the surrounding rural area). Totally out of keeping with anything in this area even on the existing industrial estate.
Does it make any sense to spend millions pounds on building and promoting a Food Enterprise Centre and then to enhance it with a massive waste incinerator next door?
THE PUBLICS BIGGEST FEAR (ONE OF THE MAIN REFUSAL REASONS)
This is of course about incinerator emissions, pollutants and the lack of conclusive evidence to show that they are safe.
The Case Law on Public Concern. Kidderminster – this is what the inspector said
“I am satisfied that the concerns of the public are
genuine and are not simply the outcome of an orchestrated campaign: very
many people in this area have a very real fear of what they see as the unknown health effects of the incinerator. The public perception of risk is a negative factor of some significance to place in the scales of the decision making process”. He added “Moreover, in this case where a development about which there are concerns is also very much in the public view, this would be likely to serve as a constant reminder and focus those concerns”.
Planning Authorities do not need to prove that an incinerator is harmful in order to reject permission, only that it is perceived to be harmful by the public
Committee you can’t win here today, but then again you don’t have to, you can refuse the application on the many genuine reasons that have been given to you and to allow the planning inspector to make the final judgement through a full public enquiry.
512. DEFRA acknowledges (DEFRA 2009) that the existing Waste ramework Directive (2006/12/EC) (European Parliament and Council 006) classifies “incineration on land” (at Point D10 of Annex IIA) as a disposal operation.
This is of course about incinerator emissions, pollutants and the lack of conclusive evidence to show that they are safe.
The Case Law on Public Concern. Kidderminster – this is what the inspector said
“I am satisfied that the concerns of the public are
genuine and are not simply the outcome of an orchestrated campaign: very
many people in this area have a very real fear of what they see as the unknown health effects of the incinerator. The public perception of risk is a negative factor of some significance to place in the scales of the decision making process”. He added “Moreover, in this case where a development about which there are concerns is also very much in the public view, this would be likely to serve as a constant reminder and focus those concerns”.
Planning Authorities do not need to prove that an incinerator is harmful in order to reject permission, only that it is perceived to be harmful by the public
Committee you can’t win here today, but then again you don’t have to, you can refuse the application on the many genuine reasons that have been given to you and to allow the planning inspector to make the final judgement through a full public enquiry.
512. DEFRA acknowledges (DEFRA 2009) that the existing Waste ramework Directive (2006/12/EC) (European Parliament and Council 006) classifies “incineration on land” (at Point D10 of Annex IIA) as a disposal operation.
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Councillor Margaret Locke (for Astley Parish Council)
Since the beginning of this planning process, my council has expressed serious reservations and I speak to reiterate the objections stated in previous correspondence.
In 2003 when the plans for a Recycling Centre at Battlefield were first drawn to their attention, my council was led to believe that there were no plans to build an incinerator on the site. Indeed, the ShropshireWaste Local Plan 2002-2014 specifically excluded ‘Mass Burn Incineration’ for the Batttlefield site.
Then, in 2007, in contravention of this Local Plan, the contract with Veolia for the development of an incinerator was drawn up ‘in camera’.
Astley Parish is 2/3 miles downward of the proposed incinerator with a large proportion of organically farmed land. The majority of residents are not convinced by the assurances that “Metals and dioxins would not pose a significant risk to human health”. This admits that there is some risk of long-term air and land pollution from toxic emissions.
The visual impact of the proposed facility will be enormous: its scale will dwarf all existing buildings in the area and will be an intrusive eyesore from the historic site of Battlefield and the Church of St Mary Magdalene.
There are concerns about the increase in commercial traffic both to and from the site via the A 49 and A53, which would have a detrimental impact on the parish and on the environment, especially if, as recycling increases, it became necessary to import waste from a wider area to sustain the efficient working of the facility.
My council is also concerned that the site could be further developed in the future as a waste technology park on an even greater scale.
In short the proposal that incineration is the only viable solution for waste disposal in Shropshire remains unproven.
Since the beginning of this planning process, my council has expressed serious reservations and I speak to reiterate the objections stated in previous correspondence.
In 2003 when the plans for a Recycling Centre at Battlefield were first drawn to their attention, my council was led to believe that there were no plans to build an incinerator on the site. Indeed, the ShropshireWaste Local Plan 2002-2014 specifically excluded ‘Mass Burn Incineration’ for the Batttlefield site.
Then, in 2007, in contravention of this Local Plan, the contract with Veolia for the development of an incinerator was drawn up ‘in camera’.
Astley Parish is 2/3 miles downward of the proposed incinerator with a large proportion of organically farmed land. The majority of residents are not convinced by the assurances that “Metals and dioxins would not pose a significant risk to human health”. This admits that there is some risk of long-term air and land pollution from toxic emissions.
The visual impact of the proposed facility will be enormous: its scale will dwarf all existing buildings in the area and will be an intrusive eyesore from the historic site of Battlefield and the Church of St Mary Magdalene.
There are concerns about the increase in commercial traffic both to and from the site via the A 49 and A53, which would have a detrimental impact on the parish and on the environment, especially if, as recycling increases, it became necessary to import waste from a wider area to sustain the efficient working of the facility.
My council is also concerned that the site could be further developed in the future as a waste technology park on an even greater scale.
In short the proposal that incineration is the only viable solution for waste disposal in Shropshire remains unproven.
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Councillor Alan Mosley (SC, Castlefields and Ditherington)
Unfortunately, I did not prepare a full statement in advance but made a few notes during other presentations. It was clear, given the wealth of detail and range of objections that I should take a line which I hoped might convince the members that they should follow their commitment to representing people.
Unfortunately, I did not prepare a full statement in advance but made a few notes during other presentations. It was clear, given the wealth of detail and range of objections that I should take a line which I hoped might convince the members that they should follow their commitment to representing people.
In summary I tried to explain that: Although the people I represent were divided on the merits of the incinerator it is clear that the overwhelming majority are opposed and I drew comparison with the comprehensive consultation programme the Council had quite rightly undertaken on the North west Relief Road.
I indicated three critical lines of personal and public objection. The planning ones relating to scale, obtrusion, etc and that it was contrary to the Councils waste plan That the incinerator was unnecessary given the increasing rates of recycling and indeed was contrary to the Council’s intent to reduce waste and to recycle more. Coupled to this was the increasing awareness of safer alternative technologies for dealing with the reducing levels of residual waste. I drew attention to great concern about potential health hazards notwithstanding official pronouncements.
I referred to mounting scholarly evidence to the contrary and the significant widespread fear among many residents.
I urged them to re-consider their position, aware that many would have supported the contract 2 years ago and referred to my experience as one who voted for the contract but had become increasingly alarmed at having done so. The documentation had been discussed in private and hence, had not been open to public scrutiny and advice other than that from the protagonists.
It is sometimes difficult to admit to serious error but vital in such critical circumstances. Hence, I finally urged the Committee to be independent minded and aware of the public will. They should be strong and brave in rejecting the application.”
*The full and comprehensive notes for Mr. Haston's speech are available on request. See panel on right for contacting us.
Safe Waste in Shropshire.
