Campaign Update 3 January 2009
Some of the main points:- The current consultation is on revised information about the planning application. This followed a Regulation 19 request to the developers from Essex County Council. Some of the previous information supplied to the authority raised a number of significant questions, and in places issues of accuracy. The responses from the developer reveal that even more woodland will be removed or cut back. There are also what appear to be serious misrepresentations about the screening effect of the residual woodland. The new tree survey undertaken in November that the developer has published states that the woodland around the site is about 15m high, whereas the developer had previously claimed various heights - including in places to over 20m. The Stop the Incinerator campaign will be issuing a more detailed report about this issue soon. If the residual woodland belt has less screening effect, both in terms of height and depth, the massive buildings proposed in the scheme that are hundreds of metres in length could be much more intrusive in the countryside - a key planning consideration. The most recent ecological and tree surveys show the site is a more important wildlife area than the developer had previously stated but that the developer is now not agreeing to try and transplant any of the threatened trees. There are many protected and listed species on the site, particularly bats and birds.
- The developer has not demonstrated that there is “an overriding need” for the development in the countryside that justifies the loss of woodland and habitats, harm to protected and listed species, loss of “best and most versatile” agricultural land, damage to a Protected Lane, harm to the setting of listed buildings and the impacts on local residents living in nearby villages. Having submitted inaccurate drawings in the original application claiming the proposed 35 m high incinerator stack would not be seen from the listed buildings at Woodhouse Farm, the developer has now published new drawings revealing the stack would clearly be visible, thereby affecting the setting of the historic site. Despite doubts, the developer is sticking to his claim that a 35m incinerator stack would be high enough to meet emissions standards but is now saying that the gas flare stack may need to be raised.
- Braintree District Council has recently added its strong objections, with the District Planning Committee unanimously agreeing to object to the planning application.
- There remains strong local support for a public inquiry, should Essex County County fail to refuse the application. The developer in his latest information repeats his justification for the scheme in terms of the Essex Waste Strategy and the Essex PFI bid that the County Council is making to fund it. As far as the Stop the Incinerator Campaign is aware, Rivenhall Airfield remains the only site over which the Council has agreed with the owner about the principle of siting a waste incinerator - as detailed in the PFI Outline Business Case. Yet Essex County Council has written to many local residents (in letters including from Lord Hanningfield and the Chief Executive) stating that it is planning policy, not the Waste Strategy or PFI bid, that will be used to determine the application. Lord Hanningfield has even stated that the application is "a private matter", despite the correspondance that has emerged between his authority and the site owner revealed under Freedom of Information Act requests. The Stop The Incinerator Campaign agrees it would be the correct procedure to determine the application against planning policy, but there is little faith that the County Council will actually do that. The Council resolved to grant consent for the previous RCF scheme because the Council thought the development was in line with their own Waste Strategy. The Council chose to override it's own Waste Planning document which limited the size of the site and the buildings on it that could be allowed at Rivenhall Airfield. The current application is for a site 4 times as large, and for buildings over 20 times as large as in the Waste Plan. The County Council is the waste planning authority, the waste strategy authority, is bidding for finance under a waste PFI scheme, would have a commercial interest in the final sites, not to metnion awarding the contracts. Many local residents and councillors believe this is a conflict of interest and that therefore there must be a public inquiry if the Council fails to refuse the application. The decision on this would rest with the Government Office for the Eastern Region (Go-East).
- The incinerator plant would burn over 1,000 tonnes of waste PER DAY. It would be the third largest incinerator in the UK outside London and would be the incinerator that Lord Hanningfield pledged to the voters of Essex would never be built without a referendum. There has been no referendum. Silver End is the nearest community. The developer had previously claimed that the wind blowing towards Silver End was a "worst case scenario". But the Stop the Incinerator Campaign conducted its own investigations using met station data that showed that on average, the wind would blow from the incinerator chimney stack and gas engine flare stack towards Silver End on 73 days per year. All other local communities would be exposed according to the wind direction and weather conditions. The highest average exposure would be to Coggeshall, downwind about 106 days a year. The developer claims there are no “unacceptable” health risks. The Stop the Incinerator Campaign has consistently called for a public inquiry (unless ECC refuse the application outright) so that the full impacts of the emissions on residents, crops and wildlife - which would be continuous for over 20 years - can be carefully assessed and not left to the claims of a commercial developer.
- The developer has still not produced an assessment of the greenhouse gas emissions for the total operations of the plant. The incinerator would be expected to emit several hundred thousand tonnes of carbon dioxide per year, and Government planning guidance points to the need for a proper assessment on schemes that have significant impacts on emissions.
- The most recent information from the developer confirms that OVER 1.2 MILLION TONNES of waste per year would be trucked in and out of the site. The wasted delivered to the site would be more than from all the households in Essex put together and the developer claims this can be done with 404 HGV movements per day. There is widespread doubt that this is possible, as the previous, smaller scheme (the "RCF") showed exactly the same number of lorry movements. There is also concern that the access remains as previously proposed - the A120 at Bradwell, a notorious bottleneck and where residents already suffer high levels of air pollution and vibration from heavy lorries and high volumes of traffic. A private haul road would then cross the River Blackwater Special Landscape Area and then over a Protected Lane, a country lane into a village and then farmland. Essex County Council and the Highways Agency have not, to date, appeared to consider this access a problem. Household, commercial and industrial waste could come from all over Essex. In addition, a third of a million tonnes would come from the six counties of Eastern Region. And in the latest plans, (as the Stop the Incinerator Campaign had predicted), the developer now admits some of the waste could come from London. The developer also now says that if he does not get the contract from Essex County Council to take household waste, he will devote the entire operation to commercial and industrial waste, yet has not supplied details of how this would change the site operations, waste sources, emissions and vehicle movements. This appears to be a comprehensive moving of the goalposts as the entire scheme has to date been sold as a "composting and recycling centre" mainly for household waste. In either case over 95% of the waste would come from outside Braintree District. The Stop the Incinerator campaign is asking - What sort of reward is that for local residents who have helped deliver one of the best recycling performances in Essex - set to better 50% soon ? There is a need for facilties, but these should be district scale facilities, devoted to recycling, composting and anaerobic digestion, avoiding the need for any waste burning.
- The construction period remains as previously stated and would last up to 2 years, 7 days a week. The plant would then operate 24/7. As local people know, the area is very quiet at night. Yet this would be one of the largest waste sites in Europe with engines running continuously - in the open countryside on a site not allocated for industrial use in the Braintree District Local Plan.
- The developers now admit that most of the power the plant would produce will not be sent to the national grid - but used within the plant itself. This shatters the claim that it is a “combined heat and power plant”. No heat will be used to benefit any local homes and the peak amount of electricity to be exported is now nearly 40% less than previously claimed. It is not known what the actual average amount produced would be, but it is likely to be much less than the peak. Yet Lord Hanningfield, in what could be regarded as a prejudicial comment, has written to local residents claiming that the Rivenhall proposal is for "an energy plant".
The Stop the Incinerator Campaign is encouraging people to send representations to Essex County Council during this second consultation period. The Campaign team will be active in the next few weeks contacting local residents in all the communities around the airfield and conducting original research which will be published soon.
People wishing to write to the County Council will need to quote reference number ESS/37/08/BTE (Reg 19 information).
They can write to: Philip Thomson Essex Legal Services, New Bridge House, 60-68 New London Road, Chelmsford CM2 0PD. Click here to email Essex CC Minerals and Waste.
The campaign is also encouraging people to write to GO-East to call for a public inquiry to Click here to email Janna Tweed at GO-East.
