Object Now to the Incinerator Plans

TOO.

1. I do not trust Gloucestershire County Council to make an objective and legal decision on this planning application. Gloucestershire County Council has generated a serious level of mistrust through its handling of this project throughout its life. The lead councillor is abrupt and aggressive in his dealings with all who oppose his views. The recent removal from the case of the lead planning officer who has worked on it for 9 months since it was submitted, plus the re-allocation of the case to an officer recently recruited and soon to leave again, has added significantly to that mistrust. This replacement has happened right at the stage when the planning application is almost due to be determined. I am very concerned that these actions indicate an attempt by the administration to unduly influence the professional staff, who are required to make objective recommendations. Hence I no longer trust them to make an objective decision and Gloucestershire County Council is bringing local government into disrepute.
2. I object to this proposal because of the impact it will have on the setting and special qualities of the nationally important Cotswolds Area of Outstanding Natural Beauty. Natural England has opposed the application for this reason, and I understand that their opinion must hold significant weight.
3. The application overrides the 15.7m height limit for this site set previously by the Secretary of State. Incinerators are very large, tall buildings. This building rises to 48.5m with a stack of 70m, and a plume extending to 262m. The size of the roof alone will be 2.2acres. The existing height limit protects the views to and from the Cotswolds AONB, and, by disregarding it, the applicant is disregarding the powers of the Secretary of State. Alternative residual waste technology can be accommodated in smaller buildings that would not flout the height limit.
4. There are already too many incinerators being built in the region to meet need. There are at least 10 incinerators, either with planning permission or already being built on Gloucestershire’s borders, which between them will have the capacity to deal with over 10 times the total of Gloucestershire’s household and industrial waste. Waste consultants Eunomia[1] predict that there will be 370 tonnes per annum overcapacity in the South West region by 2015/16 and between 440,000 and 1.9m tonnes per annum overcapacity by 2020/21. There is more than sufficient capacity within the region without this incinerator.
5. This incinerator is too expensive for the taxpayer – there are cheaper options. At a time when the Government is trying to reduce local government spending, it is incomprehensible that the county council should be pursuing a £500m option when there are cheaper, better and more sustainable alternatives. An alternative high-recycling plant at Avonmouth used by South Gloucestershire, North Somerset, Bath & NE Somerset and Bristol Councils was built for around a tenth of the capital costs, is £20 per tonne cheaper to run than incineration, the contract is for 9 years only and the building is less than 15m tall.
6. I am worried about the possible affect on my/my family’s health. The air quality in the Severn Vale is already poor because of the M5 motorway. I am concerned that additional emissions from this incinerator might add to the already high levels of toxins in some people, causing illness. I am particularly concerned about the negative health impact on infants and young children.

[1] Eunomia ‘Residual Waste Infrastructure Review’ May 2012 section 4.0 p19

2. Planning Permission Objection Letter

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PLANNING OBJECTION REASONS

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1. The Landscape and Visual Impact is unacceptable, particularly from the AONB. The incinerator would be a very large industrial building, covering 13,040 square metres - nearly twice the land area of Gloucester Cathedral – and rising to a height of 70 metres – taller than Gloucester Cathedral. The proposed design, including the size and layout of the building and the materials proposed, are totally out of keeping with the character of this rural area. It will be highly visible from the adjoining Area of Outstanding Natural Beauty (1 mile away) and the Cotswold Escarpment and Cotswold Way, damaging the beautiful views. Appendix 10.13 of the Planning Application states that ‘Vale landscapes prominent in views from upland areas with wide vantage points such as the Escarpment and Escarpment Outliers landscape types are particularly sensitive to the effects of large scale built development’. Gloucestershire County Council’s draft Waste Core Strategy states that ‘the site is located in an area that is relatively low and flat, therefore any facility would be clearly visible from the Cotswold AONB, the M5 and the surrounding low-lying areas’. Stroud District Council, in recognition of the sensitivity of this site, has imposed a planning height restriction of 15.7m. This application would flout that restriction, and the democratic process by which it was set. The proposed development is over-bearing, out-of-scale and out of character in terms of its appearance compared with the existing rural nature of the area and would cause demonstrable harm.
2. Adverse effect on the residential amenity of neighbours. The loss of existing views from properties close-by (there are 40 residential properties within 1km), and the increased traffic, noise and occasional smells (for instance when the incinerator is shut down for maintenance and the waste builds up) would adversely affect the residential amenity of near-by owners. The factory plant for waste burning, bottom-ash processing and electricity-generating will operate 24/7. Deliveries of 190,000 tonnes per annum (tpa) of waste, and the export of around 45,000 tpa of bottom ash and nearly 9,000 tpa of polluted Air Pollution Control residues will take place 7-days a week between 7am-7pm – nearly one HGV per minute at peak times.
3. I am worried about the health impact. Incinerators emit a variety of toxic substances, such as dioxins, heavy metals and fine particulates, which will increase the levels of toxic substances present in the environment and have well documented negative health impacts. For example, dioxins are known carcinogens, and can also give rise to a range of other health impacts. Although promoters of incineration point to studies that claim incinerators do not pose a health hazard, it remains the case that the UK Health Protection Agency has commissioned a new study into “birth outcomes” around incinerators in the wake of research showing increased child deaths near incinerators, and in response to demands to reassess its current advice that incinerators are “not a significant risk to public health”. The Human Health Risk Assessment in Appendix 14.1 of the Planning Application shows that the cadmium exposure predictions for local children is above the health threshold. The fear of negative health impact will itself have an impact on the health and well-being of residents in the area. There are 20,447 children attending educational settings within 5 miles of the proposed incinerator, whose health may be at risk.
4. There will be a negative environmental impact on nearby protected sites. This site is about 7km from the Cotswold Beechwoods Special Area of Conservation. As Natural England states: ‘The Cotswolds are nationally important for their rare limestone grassland habitat and for ancient beechwoods with rich flora.’ Polluting emissions from an incinerator can contribute to acid rain and cause damage to trees and plants. The Habitat Regulations Assessment commissioned by Gloucestershire County Council (GCC) in 2010 from ERM shows that ‘potential significant effects on European sites cannot be ruled out’ for Javelin Park for thermal waste facilities over 100,000 tonnes per annum (see table 6.1, page 39). This proposed facility will deal with 190,000 tpa. The effect needs to be considered together with the 32k tpa thermal facility, already granted planning permission, at the Moreton Valence site (only 600 metres from Javelin Park) making a combined throughput of 222,000 tpa. This is well above the level already considered as potentially significant. The Planning Application does not assess the combined impact of the two sites.
5. The need for this facility is not proven. At the Examination in Public of the Waste Core Strategy, the independent Inspector, waste industry representatives and other experts all agreed that the County Council’s waste projections were far too high. Their estimate for residual household waste was around 90,000-100,000, rather than the 150,000 predicted by GCC, and on which this application is based. GCC assume waste will rise steadily, whereas even DEFRA is now planning for a continuation of the downward trend of the past 7 years. This facility is far too big and inflexible to meet the county’s requirements, and will depend on Commercial and Industrial waste being brought in. It is impossible to monitor and control import of Commercial and Industrial waste into the county, as admitted by GCC officers at the Examination in Public of the Waste Core Strategy. This facility is not being built to meet need in Gloucestershire as stated, but will use market mechanisms to attract waste from further afield.
6. This project does not meet the requirements of the Waste Hierarchy. The incinerator will act as a disincentive to prevent, reuse and recycle.