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The
following points of concern have been raised with PCC
(Plymouth City Council) and the government inspector
with regard to the proposed siting of an
incinerator on Ernesettle Lane
1. Location –
very close to residential area (less then 250 metres) – also impossible to
screen
2. A high
proportion of the population has long-term illness (PCC Sustainable
Neighbourhood Study January 2008)
3. The location
in a river valley will increase the incidence of fog – we have a comment
from meteorologists at the University who state that the incinerator should
not be in operation on calm nights when stable air will trap and inhibit
pollution dispersal.
4. The quoted
height of the chimney stack would indicate that the top would release
emissions on a level with properties in Higher St Budeaux, including schools
and a nursing home.
5.
DEFRA’s Review of Environmental and Health Effects of Waste Management:
Municipal Solid Waste and Similar Wastes (May 2004) raises concerns about
composting and emissions from incinerators, and concludes:
During the course of the project, we found several areas
where potentially useful information was lacking, or was less than ideal as
a basis for waste management policy.
Also:
“Some of
the waste management operations involve heating or burning municipal solid
waste (for example, incineration, gasification/pyrolysis, anaerobic
digestion and the burning of collected landfill gas). These could have an
effect on local air quality. For example, Mercury emissions from municipal
solid waste incinerators were found to contribute 20% of the overall
background mercury concentration at locations surrounding the incinerator.
Emissions of dioxins from municipal solid waste incinerators can increase
levels of dioxins in soil, although the present generation of incinerators
release much smaller amounts of dioxins than
was the case
five or ten years ago. Dioxins from an incinerator in an industrial
environment will only slightly increase the total deposition of dioxins. We
found that an incinerator located in a relatively clean rural environment
could significantly increase the dioxin deposition above the much lower
background level. Even then, the increase would only affect the immediate
vicinity of the plant.”
Exchanges of
correspondence with senior staff at DEFRA have failed to find a definition
of “the immediate vicinity” and yet the Government Inspector has accepted
this same DEFRA report as indicating that the site in Ernesettle Lane is
suitable.
6. Residents will not
be reassured by the Council’s statement that appropriate mitigation will be
employed on a site as sensitive as Ernesettle, in the light of a report in
the Herald recently in which the Local Government Ombudsman ordered the
council to pay compensation to a resident. The council had failed to ensure
that an industrial company complied with planning permission issued in
2001. The judgement stated that “the council should have acted much sooner
to secure implementation of an adequate environmental protection scheme.”
7. Land was
allocated originally for recreation in an area of low car ownership and poor
health. The Plymouth 2020 Sports Plan envisaged the development of a joint
University/community recreation centre. Entec Report Technical Note 004
highlights the loss of sports pitches, but the loss is of a complete sports
facility – hall, 9 hole golf course, tennis/basketball court as well as
sports pitches, which offers a much more wide-ranging choice of facilities
to a much larger section of the community. PCC have suggested that the use
of facilities at Derriford would be an acceptable alternative. However,
according to "Planning Policy Guidance 17" any loss of open space or
recreation land should be quote "to exchange the use of one site for another
to substitute for any loss of open space, or sports or recreational
facility. The new land and facility should be at least as accessible to
current and potential new users and at least equivalent in terms of size,
usefulness, attractiveness and quality". It is inconceivable that a site at
Derriford could be considered accessible to people in Ernesettle.
8. The only two
routes into the site go through residential areas. The route through the
principal Ernesettle community is not viable for HGV traffic, leaving only
one possible route which becomes quickly clogged during the rush hour and
whenever there is an accident on the A38 Parkway or Crownhill Road. In the
event of an incident at the incinerator it could be very difficult for
emergency vehicles to get through. The route via Ernesettle Lane is also
very steep and will cause significant pollution from HGVs. The transport
assessment states that 80 HGVs per hour are expected to use the route into
and out of the facility.
9. PCC has been
quoting the proximity principle to justify the use of a site within the City
boundaries. However, the PCC Transport Assessment in the evidence base
states “Assumption 4: doubling in size of the EfW plant to a capacity of
240,000 to accommodate waste from Devon and Torbay”. Why should this waste
be driven right across the south of the county and right across Plymouth –
surely the proximity principle fails completely on this point?
10. The setting
is in one of the most beautiful locations in the country – the Tamar Valley
with its wealth of wildlife and the beautiful views afforded when crossing
the Tamar Bridge also lying very close to the Tamar Valley Area of
Outstanding Natural Beauty and a number of Sites of Special Scientific
Interest.
11. The Entec
report “Waste Management Site Feasibility Study” December 2006 clearly
indicates a number of difficulties with the site and states “Subject to the
above comments, Ernesettle has potential to accommodate strategic waste
management facilities subject to there being no suitable accommodation on
those sites cited within the Core Strategy.”
Despite point 11,
in the documentation submitted to DEFRA in application for funding,
Ernesettle is the indicated site for the Outline Business Case. There are
strong feelings that the most appropriate site for an energy from waste
facility would be Langage with the power station development and the new
community being built at Sherford. This has been dismissed as South Hams
wish to reserve the land at this site for employment. With a downturn in
the economy and, according to PCC, an oversupply of employment land along
the A38 corridor, we feel that this solution should be re-visited.
A number of
residents in the Ernesettle and Higher St Budeaux areas will continue to
press for the plan to site an incinerator to be abandoned. If you wish to
be involved or kept informed about any developments, please feel free to
pass your details to one of the following people:
Geraldine Lane,
geraldine.lane@talk21.com
Jan
Jackson
Neil Mawdsley
neil@mawdsley.co.uk
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