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Development Management
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Ref No 12/01631/DC Erection of integrated waste management facility, Polmadie Disposal
Complex 425 Polmadie Road Glasgow G42 0PJ
Dear Sirs
I wish to object to the planning application 12/01631/DC made by Viridor Waste
Management Ltd for the construction of a waste management facility (the Glasgow
Recycling and Renewable Energy Centre) at the Polmadie Disposal Complex 425
Polmadie Road Glasgow G42 0PJ on the following grounds:
1. Health and pollution
Although modern incinerators are designed to minimise the release of harmful emissions
and operate under license, overseen by SEPA I believe that this plant is potentially a risk
to public health as such plants in other places have had to be closed because they have
breached their operating conditions 1. There is a further risk from the hazardous wastes
which result from the cleaning of the flue gases.
Although gasifier fumes pass through expensive filter systems they still emit significant
levels of NOx and of ultrafine particles. The latter includes nano-particles which are of
great concern because they can pass through the lung lining, causing internal
inflammation and penetrate organs. Although dioxin emissions are restricted by filters,
studies show that high levels are emitted during start up and close down, when dioxins are
not monitored.
2. Lack of consultation
The statutory requirements of the Planning (Scotland) Act 2006 state that “Since August
2009 all developers submitting major planning applications are now required to undertake
a comprehensive consultation before submitting an application.”
1
Dumfries emissions breaches http://www.robedwards.com/2012/07/toxic-pollution-upsets-plans-for-wasteincinerators.html
In our view this has not been undertaken and communities in the G42 postcode area have
not been adequately consulted about this development. Furthermore several of the claims
about the consultation undertaken have clearly not happened, in particular the circulation
of “circa 16,000 newsletters to residents in the G42 postcode area.” Our group comprises
people from Battlefield, Govanhill, Mount Florida and Toryglen, only one of whom received
such a newsletter.
We are sure that Glasgow City Council is aware of the Aarhus Convention, adopted by the
United Kingdom and the European Union in 1998. As well as the Convention recognising
every person’s right to a healthy environment, the Aarhus Convention also clearly states
that national and local government must allow access to information, permit public
participation on decision making and provide access to justice on environmental matters.
The dearth of information for residents in the G42 postcode area has, as we are sure you
will agree, an adverse effect upon the public’s ability to fully participate in the decision
making process, and acts as a barrier on the public’s ability to gain access to justice on
environmental matters.
We would also like to bring to the attention of the City Council a principle which is now a
part of customary international law. That is to say, it is universally binding and nonderogable. This principle is referred to as the ‘precautionary principle’. At its simplest, the
precautionary principle states that the threat of an action should be known before it occurs.
Given the pollutants caused by similar plants the length and breadth of the United
Kingdom, the city council will obviously be aware of the consequences of this action
should it transpire.
3. Traffic and transport
Transport in and out of the plant will involve moving loads by road which will contribute to
increased noise and emissions. Heavy vehicles will have to move through residential
areas on roads not designed for such movements and already subject to congestion. The
developer claims that all site traffic will go directly onto the M74 but this significant
increase in traffic will still impact air quality in the area.
4. Evidence of need
The developer has not proved the need for a waste facility of this scale in this location.
Furthermore the developer claims that the site will operate for up to 30 years with an
annual consumption of 200,000 tonnes. Given the significant progress on recycling that
has been made in the last 10 years, this will clearly act as a barrier to further increasing
waste minimisation, reuse, recycling and composting, achieving Scotland’s aspirations for
a Zero Waste future and Safeguarding Scotland’s Resources, which the Government is
currently consulting on2.
We suggest small local schemes are more environmentally friendly and more effective in
promoting waste-awareness. In addition gasification requires a particular amount of
2
Safeguarding Scotland’s Resources consultation http://www.scotland.gov.uk/Publications/2012/06/4215
materials to function, for example plastic, paper and food waste. However this conflicts
with the proposed desire to increase recycling rates.
5. Energy production
Any fuel produced from gasification will not make up for the energy spent in manufacturing
new products – re-use and recycling are still more efficient. These technologies have been
mainly used on more defined waste streams, so their reliability and effectiveness on mixed
municipal waste is often questioned.
Further, rubbish is not a renewable resource. It is highly dependent on consumption of oil
based resources. Scotland’s Zero Waste strategy is first and foremost to reduce waste and
consumption – using rubbish for energy provides no incentive to do so.
6. Location
This development is unsuitably proposed in a highly populated area, with Europe’s largest
high school Holyrood Secondary a short distance away.
Many of the areas surrounding and downwind from the proposed gasification plant are
classed in the 15% most deprived areas of Scotland, with associated higher rates of
incidence of cancer and heart disease and significantly shortened life expectancy. The
cumulative negative health impact of operating a gasification plant in such an area, which
is already surrounded by motorways, is sufficient grounds to refuse this application.
7. Employment
The promotional materials for the development give high prominence to the number of jobs
that will be created from this development however a recent report from Friends of the
Earth3 shows that recycling 70% of municipal waste will create significantly more jobs than
this type of development.
8. Length of contract
The Council has already signed a 25 year contract with Viridor4 to handle the City’s
residual waste. Again given the significant progress that has been made in increasing
recycling in recent years this shows a clear lack of strategy to work towards waste
reduction in the city. The long term financial burden of this contract, in the face of
significantly falling levels of waste and increases in recycling, will also have a long term
negative social impact on the city.
9. Lack of strategy
The Council appears to quite happy to sign a 25 year contract for the management of its
residual waste without having a 25 year strategy in place for waste reduction reuse and
recycling. In particular there is a clear lack of strategy for dealing with food waste and biodegradable materials as well as tackling tenements and high density housing. The City
Plan 2 and associated Waste Management Strategy pre-date the Scottish Government
3
4
Friends of the Earth, ‘More Jobs, Less Waste’ http://www.foe.co.uk/news/waste_jobs_25198.html
25 year contract signed http://www.pennon-group.co.uk/pennon/en/mediacentre/pressreleases?ref=65
Zero Waste policy and GCC will be unable to align with government policy whilst locked
into this 25 year contract.
I look forward to hearing from you in due course. I would appreciate it if you could send all
correspondence relating to this matter to me by email rather than post.
Yours sincerely
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YOUR NAME