FOR THE ATTENTION OF RESTORMEL BOROUGH COUNCIL PLANNING
DEPARTMENT
AND
Submission
supporting the St Dennis Parish Council Objection to Application:
08/00203/WAS.
is sent to
Restormel Borough Council Planning Department as Consultees.
Submission supporting the St Dennis Parish Council
Objection to Application:
08/00203/WAS.
Is also sent to
Cornwall County Council Council Planning Department as the Determining
Authority.
ST DENNIS PARISH COUNCIL
RESPONSE TO PLANNING APPLICATION:
SITA
(
Proposal
Address
Land at Rostowrack
St Dennis
St Austell
PL26 8DX
Applicant:
Sita Cornwall Ltd.
Waste Management contractor to Cornwall County Council
Proposal:
Construct and Manage a 240,000 tpa. Incinerator.
To burn predominately Municipal Solid Waste (MSW) and Commercial and Industrial (C&I).
The St Dennis Parish
Council request that you consider the following points made in objection to the
Summary of St Dennis
Parish Council submission to Restormel Borough Council Planning Department and
Cornwall County Council Planning Department.
The St Dennis Parish Council Object to this
Application for the following reasons:
(Supported by accompanying text).
1. Overwhelming opposition from the public as evidenced from public
meetings held in the locality.
2. Green field site with only partial permission for plant construction
allied to the China Clay industry.
3. Site is too close to Treviscoe and St Dennis
4. Irreparable visual, noise and smell intrusion into two villages and
numerous hamlets.
5. All Emission figures are modelled and assumed.
6. Waste hierarchy not complied with.
7. Proximity principle not complied with.
8. Minimum road miles policy not complied with.
9. National Policy, W L P and W D F criteria not complied with.
10. Close proximity to SSSI and S A
C sites and the river Fal.
11. No suitable access road to
proposed site without construction of 3.4km. of new
haul road.
12. No back up systems identified
in documentation if major breakdown occurs.
13. More than one Residual Waste
Disposal Plant essential in the County.
14. Duty of care to residents from
the
The St Dennis Parish
Council request that you consider the following points made in objection to the
General Observation
Point 1.5 in the Environmental Statement states that
the
The
Now C C C are being asked to consider a Planning
Application for the Waste Management Incinerator.
The Waste Management Incinerator is part of the
Contract awarded by CCC.
The question arises, how can CCC decide a planning
application on a proposed Incinerator, when C C C were instrumental in awarding
the contract to Sita Cornwall Ltd. in the first instance?
As all Members of the Cornwall County Council had the
opportunity to vote on the Award of Contract, how can the C C C Planning
Committee that is made up of from those same Members be unbiased in their
views?
Question:
Does this constitute a prejudicial interest for
Members of the County Council Planning Committee ?
The St Dennis Parish Council request that you
consider the following points made in objection to the
The St Dennis Parish Council submit the following
documentation to underline their Objection to this Application.
The Parish Council state that they object in
the strongest terms to this application for the construction of a C E R C.
This view has been reached after meetings
with the general public and scrutiny of the application documents.
The following points are made with reference
to the Environmental Statement that is part of this Application.
Quote from Environmental
Statement:
‘‘Transport
1.32 The number of miles each day trucks travel
carrying waste associated with each
scenario was taken as a good proxy for transport
amenity impacts, reflecting the
fact that these impacts are likely to be
proportional to the amount of traffic
involved in each of the scenarios. The results show
that increasing the number
of plants generally decreases the overall transport
mileage, because the average
distance to the nearest facility is reduced.
1.33 The relative differences between the scenarios
are not consistent, in that moving
from one to two plants delivers an 11.3% decrease
in daily mileage…………………’’
Response
Clauses
1.32 and 1.33 indicates that there is a saving in road miles using two
incinerators.
This
11.3% saving is environmentally a very important consideration.
Quote from Environmental
Statement:
‘’Cost
1.35
SITA provided ERM with estimates of capital and operating costs (excluding
depreciation)
and revenues for the three scenarios. With regard to capital costs,
there
are considerable economies of scale associated with the construction of a
single,
large facility (£117M), in comparison with two smaller or, in particular, five
much
smaller facilities (£135M and £223M, respectively). Operating costs per
plant
are markedly higher for a 240,000 tpa facility in comparison to the
120,000
tpa or 48,000 tpa plants. However, when the operating costs for all the
plants
in each scenario are summed, the single plant is the least expensive.’’
Response
Clause
1.3 gives the increase in cost for two incinerators over the cost of one plant
rising from £117M to £135M.
This
represents a 15.38% one off rise in capital cost at the outset.
However
the 11.3% decrease in road miles would be accumulative year upon year for the
duration of the contract.
Given
the spiralling cost of DERV it would seem that the argument for a saving in capital
cost is somewhat circumspect.
Clause
1.41 discusses weighting of transport impact criteria and concludes this is not
a logical approach.
Whilst
this may be true in monetary terms we must argue that the Environmental
benefits over the 30 years of the contract will far outweigh any short term
monetary gain.
It
is our opinion that the extra initial capital outlay to build two incinerators
would be the best solution for the County and its inhabitants.
Proximity
Principle and
The
two incinerator site approach will also better fulfil the ‘Proximity Principle’
and also
the
‘Minimum Road Miles’ criteria both of which are part of current Policy
documents that form part of the Planning Guidance for this type of application.
CHAPTER
TWO
Alternative
sites – planning policy background
Quote
from Environmental Statement
National policy
2.5 PPS10
sets outs relevant national policies for waste management facilities,
including location criteria to inform local
planning policy and planning decisions.
In searching for sites suitable for new waste
management facilities, PPS10
recommends that a broad range of locations,
including industrial sites, are
suitable, giving priority to the re-use of
previously developed land.
2.6 In
deciding which sites and areas to identify, PPS10 sets out criteria against
which the suitability of sites should be assessed.
These are as follows:
• The extent to which they support the policies in
the PPS
• The physical and environmental constraints on
development, including
existing and proposed neighbouring land uses.
2.7 The WLP was adopted in December 2002 and the
majority of its policies are
saved to October 2010. On the basis of the BPEO
study that informed the WLP,
the WPA identified an area of search located in the
centre of
which a single EfW plant should be located. The
suitability of sites identified
within this area of search will be assessed against
a range of criteria listed in
Policy L6 of the WLP, although it is acknowledged
that a site need not achieve
them all. The equally weighted criteria are:
• Demonstrate reasonable proximity and
accessibility to the
Network
• The plant is to be served by rail
• Demonstrate reasonable proximity and a good
quality connection to the main
electricity grids
• Will produce both electricity and heat for
off-site consumption
• Will have sufficient on-site capacity to provide
for residue processing facilities
• Can demonstrate that any adjacent ancillary
development will be in
accordance with the spatial strategy
contained in the relevant development plan
• Does not adversely affect the integrity of a
Special Area of Conservation
• The plant has a gross maximum annual capacity of
no more than 200,000
tonnes.
Emerging WDF
2.10
The sites identified in the emerging WDF were derived from a search undertaken
by
the WPA to identify those sites that were considered to be most appropriate ‘in
principle’
for use as waste management facilities, not specifically EfW. Sites with
the
following attributes were identified as being potentially suitable:
•
Vacant and undeveloped sites larger than 0.5 ha
•
Land allocated for employment and industrial uses
in adopted / draft local
plans
•
Unallocated sites with existing industrial uses
•
Existing minerals and waste management sites
•
Areas of contaminated, derelict or previously
developed land.
Response
National
policy, the
Clear
points of conflict are:
National
Policy
·
2.6 The cumulative effects on the well being of
the local community, including any adverse impacts on environmental quality.
·
The capacity of existing and potential transport infrastructure to
support the
sustainable movement of waste and products arising from resource
recovery,
seeking when practicable and beneficial to use modes other than road
transport.
NOT MET
Reasons:
B. P.
1 The well being of local residents will be
adversely affected by the implementation of this Application. Noise, Smell,
Dust, Chimney Stack Emissions and Loss of Green Field Site.
B. P. 2 The existing road infrastructure will not
support the increase in traffic generated to and from the proposed site.
Modes
of transport other than road clearly not considered in this application.
2.7 The WLP was adopted in December 2002 and
the majority of its policies are
saved to October 2010. On the basis of the
BPEO study that informed the WLP,
the WPA identified an area of search located
in the centre of
which a single EfW plant should be located.
The suitability of sites identified
within this area of search will be assessed
against a range of criteria listed in
Policy L6 of the WLP, although it is
acknowledged that a site need not achieve
them all. The equally weighted criteria are:
1. Demonstrate reasonable proximity and
accessibility to the
Network
2. The plant is to be served by rail
3. Demonstrate reasonable proximity and a good
quality connection to the main
electricity grids
4. Will produce both electricity and heat for
off-site consumption
5. Will have sufficient on-site capacity to
provide for residue processing facilities
6. Can demonstrate that any adjacent ancillary
development will be in
accordance with the spatial strategy
contained in the relevant development
plan
7. Does not adversely affect the integrity of a
Special Area of Conservation
8. The plant has a gross maximum annual
capacity of no more than 200,000
tonnes.
FIVE POINTS NOT
MET. (1,2,6, point 7 arguable AND 8)
Emerging
WDF
2.9
Following a second round of public
consultation, these four sites were reduced
to two in the submission stage of the
WDF, which, although not formally submitted
to the Secretary of State, was
agreed by CCC’s Executive in November 2006.
2.10
The sites identified in the emerging WDF were derived from a search
undertaken
by the WPA to identify those sites that were
considered to be most appropriate ‘in
principle’ for use as waste management
facilities, not specifically EfW. Sites with
the following attributes were identified as
being potentially suitable:
·
Vacant
and undeveloped sites larger than 0.5 ha
·
Land
allocated for employment and industrial uses in adopted / draft local
plans
·
Unallocated
sites with existing industrial uses
·
Existing
minerals and waste management sites
·
Areas
of contaminated, derelict or previously developed land.
BULLET POINTS IN 2.10 ARE NOT MET
CHAPTER THREE
The Site
Response
Clause 3.8 states that a 15km radius area was
considered when visual impact was considered.
St Dennis and Treviscoe villages and several
hamlets are well within 1km of the proposed site.
Clause 3.9 states that: The CERC and its access road will be
constructed on an area of previously undeveloped Grade 3 classified
agricultural farmland. A portion of this
land has been identified for china clay industry related development in the
MLP.
This is clearly in conflict with clauses
quoted above ( NP. PPS 10, WLP. 2.7 and
WDF 2.10.
Clause 3.12 deals with the haul road.
The St Dennis Parish Council feel that a
major opportunity has been lost in the design of this road.
If this road is built to adoptable standards
then it would serve as a vehicular link to Nanpean and beyond, if, in the
future the road could be continued through to the existing unclassified road
that connects St Stephen and Roche.
The Parish Council have made representations
to the County Council outlining their proposals but were not successful in
their efforts to make the road a
General Observations The Site
It is our view that the site does not
meet the criteria cited above.
We believe the site selection to be flawed
in the extreme.
It has been freely admitted, in the Planning
Application documentation, that mitigation can not be achieved to alleviate
known problems as described in the Environment Statement.
CHAPTER
FOUR
The
Proposals
Quote
from E S Statement:
4.8 The building housing the plant process
equipment will be approximately 145.5m
long, between 37.7m and 58.2m wide and between 7.5m
to 45.0m in height,
relative to the ground level, at the apex of the
roof (162.5-190.0m AOD).
Elevations of this building are shown in figures
4.4 to 4.7 and a longitudinal
section in figure 4.8.
Response
The building is huge in proportion to even
the largest china clay plant buildings on the adjacent site.
When compared to the domestic scale of St
Dennis and Treviscoe it is totally disproportionate to any building in the
area.
As stated previously no mitigation or
landscaping will overcome such a building mass only a distance of 400 metres
from residents in both St Dennis and Treviscoe.
4.12 A 120.0m (265.0m AOD) chimney stack will be
situated at the northern end of the
site between the
main CERC building and the bottom ash recovery facility. It will
comprise two
flues, one for each line, each having an outside diameter of 3.4m.
The height is
subject to final agreement with the Environment Agency through the
PPC application
process; hence it could be subject to change, possibly resulting
in the need to
amend relevant sections of this ES.
Response
This clause shows clearly the dimensions of the modified chimney stack.
Whilst trying to mitigate the effects on the local immediate environment
there has been no consideration given to the local residents and the blot on
their views across existing green fields, indeed farmland.
4.13 The proposed height has been determined
through extensive computer
dispersion
modelling of emissions and evaluation of the resulting dispersion
plumes. This
height meets the PPC requirement to utilise best available
techniques (BAT)
to minimise pollution and will ensure that ground level
concentrations
of key pollutants are kept within acceptable levels under all
operating
conditions, including emergency shutdowns.
Cornwall Energy
Recovery Centre SITA Cornwall Limited
Planning
Application
ES Chapter 4:
Proposals
Terence O'Rourke
March 2008
4.14 The stacks have been structurally designed
to meet all predicted climatic
conditions. Each
stack has lightning protection, sampling points for manual
measurement and
connections for continuous emissions monitoring equipment.