CORNWALL SUSTAINABLE WASTE NETWORK
CORNWALL SUSTAINABLE WASTE NETWORK
Proof of Evidence of
CSWN
By Miss Elizabeth Hawken Chairman of CSWN
Rule 6
On behalf of CSWN
Public inquiry Appeal into
APP/D0840/A/09/2113075
Land at Rostowrack Farm, St. Dennis, St Austell,
Cornwall PL26 8DX
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CORNWALL SUSTAINABLE WASTE NETWORK
STATEMENT OF CORNWALL SUSTAINABLE WASTE NETWORK
Contents
1
2
2.4
3
4
5
6
7
8
9
10
11
12
Summary
Introduction of main case from CSWN
E.U. Directive 2008/98/EC
Public enquiry 2002
Planning application 2008
Waste Strategy for England 2007.
PPS 1, 10, 11,
Regional Spatial Strategy for South West England
PPS 22,
PPS 23
Suitability of a waste incinerator in central Cornwall
In regards to the food industry.
Population of Cornwall
Joint waste panel
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CORNWALL SUSTAINABLE WASTE NETWORK
STATEMENT OF CORNWALL SUSTAINABLE WASTE NETWORK
MAIN CASE
2.0
Cornwall Sustainable Waste Network (CSWN) is a county wide organisation whose
membership is open to any individual or organisation that supports the objectives of
Waste minimization and the correct handling and disposal of that waste.
2.1
The members of CSWN have qualifications in a variety of areas. From Engineering,
Farming, law, to myself a member of the Royal Society of Health. I am born and breed
Cornish, like many of my people I left the Duchy, married into the oil industry, so had
many years connected to the oil industry world wide, and fully understand the thinking of
large companies. I studied at college gained qualifications, for the Royal Society of
Health, and food, science and management, divorced, came home again and I came back
home thirty odd years ago, and ran my own food business, farm and delicatessen for quite
few years, and been a manager in the tourist industry. I have been studying the
consequences of dioxin contamination for at least twenty five years or more, with
qualified colleagues around the planet.
CSWN is also connected to GAIA, UKWIN, and other similar organisations world wide.
2.2
CSWN as the name states believes that there is a sustainable way to deal with all products
that the public feel to be waste. CSWN has been working on and investigating the best
way to deal with the disposal of residual Municipal Solid Waste (MSW) and commercial
waste for at least ten years. There are far better modern ways of dealing with our waste
than burning it in a huge incinerator. Anaerobic Digestion, Pyrolysis and Gasification are
good examples. There are also In Vessel Composting, and Autoclaving.
2.3
There are three things which permit the human being to live on this planet: 1, Clean
Oxygen, 2 Clean Water and 3 Clean Protein. If the human animal has these it will
survive, if any of the three are contaminated with bacteria or chemicals, especially
Dioxins, they will not survive.
2.4
Huge incinerators it seems are now against the thinking in the EC directive 2008/98/EC
which supersedes EC Directive 2006/12 and the Waste Strategy for England 2007.
2.5
In both these documents it states that waste must be treated as near as possible to where it
has been produced; Proximity Principle.
2.6
This means that straight incineration of waste will not attract any Renewable Obligations
Certificates, (ROCs). They will only be paid if the installation produces both power and
heat. This is highly unlikely to happen as in this case a Calciner needs more heat than an
Incinerator can produce.
Landfill Allowance Trading Scheme (LATS) are only charged on Putrescible waste which
is land filled. Inert waste is not charged LATS. Anaerobic Digestion, which deals with
most if not all Putrescible waste, attracts double ROCs and also has been proved to be
safe. It has been used extensively around the planet for many years, is economical, and
produces far more power and heat. This also applies to Pyrolysis and Gasification which
also attract ROCs. These technologies are smaller and more convenient and less
demanding on the land mass, so are better suited for small units in urban areas, where
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CORNWALL SUSTAINABLE WASTE NETWORK
most of the waste is produced.
2.7
These are a far better ways of dealing with residual waste and the waste can also be
treated as near as is possible to where it has been produced, in accordance with the
proximity principle.
3.0
In 2002 CSWN gave evidence at the waste public inquiry. We stated at that time that
there were far better ways of disposing of Cornwall’s waste rather than burning valuable
recyclable products in an out of date Incinerator. As they are not tested for dioxins these
will contaminate vast areas of farm land in Cornwall.
3.1
At the public enquiry in January 2002, the inspector, Mr. Howard Rose‘s recommendation
in his letter of July 2002, was not for one centrally situated incinerator but he wrote that
the then Cornwall County Council:(Howard Rose letter of July 2002 states:)- [quote]
5
Council should look at achieving and promoting the provision for minimization of
waste and recycling and composting, and the maintenance of sufficient landfill capacity
for those elements of the controlled waste which needed final disposal by this method.
8
He goes on to state that because the council had not at that time decided on a site,
then it left the way open for alternative technologies such as Gasification/Pyrolysis and
Anaerobic digestion.”
These are acknowledged as acceptable forms of waste treatment, which give back both
heat and power to the populace, together with, Anaerobic Digestion which puts back
nutrients into the soil from whence they came.
The waste plan of 2002 may now no longer be lawful, as it may have been superseded by
the EU Directive 2008/98EC of the European Parliament and of the Council of 19
November 2008 on Waste and Recycling certain Directives.
3.2
The case for a modern way of Reducing, Reusing, Recycling and not burning today is
even more important today, as many more products can now be recycled and need to be,
as a great many products are made from oil, which is rapidly running out. All these
commodities can and should be recycled:- Paper, Wood, Animal and Vegetable food
waste, Cotton, Wool, Glass, Metal, all Plastics, Concrete, Bricks, Road surfaces. The
only things which must be destroyed are hospital wastes, which are bacteria
contaminated, or chemical wastes and Pyrolysis is the best way for this, in close
proximity to where that waste is produced.
4.0
CSWN has also given evidence to the planning authority at Cornwall County Council
Truro in 2008/9 to the effect that incineration is not the best form of waste disposal for
Cornwall
Ref:- Paper:- Comments on response to clarification request to SITA from Cornwall
County Council on CERC December 2008. Document no 477759
4.1
CSWN will give evidence to the fact that the proposed development of an Incinerator in
central Cornwall is considered to be unacceptable because of the harm the development
would cause to the countryside and farming interests in the whole of Cornwall, by way of
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CORNWALL SUSTAINABLE WASTE NETWORK
visual impact, CO2, through unnecessary lorry journeys, noise, and contamination of
agricultural land and would be against the Proximity Principle.
5.0
Sighting a contaminating incinerator in this way is against Waste Strategy for England
2007
5.1
Chapter 4 :- Key Materials and initiatives.
Paragraph 12, to 23, All materials that can be recycled should be.
Para 15 Food and garden waste to anaerobic digesters.
Para 18 Burning plastics not advised.
5.2
Chapter 5 Improving contract design :Para 35 The government now discourages integrated contracts which bundle together
collection and treatment, ---
5.3
Chapter 7 Building the capacity of the third sector in waste:Para 16 Government and -- waste prevention-- [ a huge incinerator does not do that]
5.4
Annex A :- Impact Assessment
Purpose and intended effect, objective
Para 13 Protection of Human Health and the Environment---.
Rationale for policy:Para 20 to reduce risk to health----.
Better collection and management of household hazardous waste [Option J] :Para 90 ---bottom ash. --- Environmental savings from increased separate collection.
5.5
Annex E :- Summery guidance on energy from waste [EfW] technology.
Para 2 encourage anaerobic digestion ---Para. 3 --Government does not have a preference for one technology,---
5.6
Annex K :- Evidence on environmental considerations.
Para 19 --benefits of recycling,---recycling is preferable to incineration---.
Para 23, WS2007 protecting public health.
6.0
Planning Policy Statements:-Incorporating The Regional Spatial Strategy for the
South West:-
6.1
PPS 1, planning and climate change,
Paragraph 10 Decision -making Principles, RSS
Para. 13 integrated climate change, Local Development Documents, Renewable and low carbon energy generation,
Para. 19 - 20, Local requirements for decentralized energy to supply new development,
Para. 26 (i)
Safeguarding environmental performance,
Para 44.
6.2
PPS1 Delivering Sustainable Development,
National Planning Policies, Key
principles
Para. 12 (ii) (v) Planning for Sustainable Development, - Protection and Enhancement of
the Environment,
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CORNWALL SUSTAINABLE WASTE NETWORK
Para. 20
6.3
PPS 10, Planning for Sustainable Waste Management:- sustainable waste
management,
Para. 1, 2, key planning objectives,
Para. 3 Local development documents ,
Para. 16, Determining planning foliations,
Para. 22, 31. Document 4 Partial Regulatory Impact Assessment, Background
Para. 7, Benefits,
Para. 21, equity and Fairness, Rural impacts,
Para. 41, 42,
Document 5:-Non-Technical Summery of the Environmental Report,
6.4
PPS 10 Objectives and waste policy,
Para. 5, 7,
6.5
PPS 11, The Sustainability Appraisal Paragraph
Para. 2.37 Annex A Policy and guidance on topics to be covered in a Regional Spatial
Strategy
7.0
RSS
8.0
PPS 22, Locational Considerations
Paragraph 10, National Designations
Para. 11 Other Considerations, Small scale Renewable Energy Developments
Para. 18 Policy RE4 meeting the targets through development of new resources:- [no
negative impact.]
Para. 3 Planning Policy Issues : Regional Level. Community involvement at regional
level
Para. 3.39 There has been none what so ever with the majority of the employers in
Cornwall the food producers and processors.
Para 4 Planning Policy Issues Local Level.
Para. 4.14 [ must be flexible.] Landscape Issues
Para. 4 15 [it is not appropriate for the local council to identify specific locations]
8.1
Second no 3 document energy from Waste [Thermal processes] Implications of
Renewables Obligations,
Paragraph 9, 10, 11. Planning Issues
Para. 26 [located close to source]
9.0
PPS 23, Introduction second paragraph first sentence [impacts on health, material
planning consideration]
Air Quality document
The Precautionary Principle:Para. 6 Government policies on Planning and pollution Control:Para.
8, 9 Proximity Principle.
Government Policies on Land Affected by
Contamination:Para. 17, Appendix, A : Matters for Consideration in Preparing Local Development
Documents and Taking Decisions on Individual Planning Applications.
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CORNWALL SUSTAINABLE WASTE NETWORK
9,1
All these documents state that waste has to be treated as near as is possible to the
production of that waste; Proximity Principle, and to use the Precautionary Principle over
human and animal health at all times.
9.2
Placing a huge incinerator in the centre of this Duchy which is 105 miles long and 14
miles wide, goes against this principle, we will not meet the government CO2 targets in
PPS 1. The large amount of lorry journeys, will contribute to these CO2 emissions which
we must reduce. Incineration does not reduce waste arising but it increases them, by
giving the public a false idea of how to deal with their unwanted products, these are not
waste, but just goods which are unwanted by that person, but can be reused by another
person, in one form or another.
10.0
St Dennis and the central area of Cornwall is a completely unsuitable area, situated beside
a SSSI and within kilometre’s of some of the best farm land, a large amount of which is
organic, in Cornwall. This land is producing millions of gallons of milk per day, which is
feeding the population of the whole UK. Paper from the Cornwall Economic Forum
AGRI-FOOD
10.1
To place one huge 240,000 ton incinerator with a chimney of 120 meters, which will
contaminate upward of ten miles with the dioxins which can not be stopped from
emanating from this chimney, as there is no known way to stop nanoparticals from
escaping from such a high chimney and entering into any cell vegetable or animal.
Countries in the EU are learning this to their cost.
Ref:-Paper from Denmark attached.
Many millions of animals have had to be destroyed in the EU over the last few years
because of dioxin contamination which has been found in the meat, or milk.
10.2
The village of Grignon near Albertville, in the French Alps. The incinerator at Gilly-surisere. Was closed down in 2002 and all farming ceased in a five mile radius of the
incinerator, all animals and produce was destroyed. Millions of pigs have had to be
slaughtered in Belgium, France and Germany because of Dioxin contamination in their
food supply. Cheese production was curtailed in Italy because of Dioxin contamination
of the milk supply.
10.3
The population of Cornwall is 550 000, 220,000 are of working age, and 100,000 of these
people work directly or indirectly, or are attached in some way to the food producing or
processing industries in Cornwall.
Cornwall earns her living from food production and processing. The tourist industry
employs around another 12,000 people, but that industry does not produce food for the
masses as the farmers do, but they now sell themselves on the perception that their
industry is in fact feeding the tourist on locally grown clean uncontaminated food.
10.4
Placing a huge incinerator in the centre of this very large industry may seem very good if
the people working in the incinerator industry live, and come from a large city, and
neither know or understand where their daily food has come from. If that food is
contaminated they will very soon learn the hard way that this is the cause.
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10.5
Cornwall produces more food for human consumption than any other county in the UK.
This incinerator is putting both that industry and the lives of the unborn child at risk.
11.0
Figures showing where the population of Cornwall is mostly situated, is from Truro to
Penzance. There are fewer people living in the area from Newquay, St. Austell area up to
the Devon border.
11.1
All waste would have to travel up to a hundred miles per trip to get to this site. This is
going to cause a very large amount of CO2 being released daily by the 150 lorries
estimated to have to travel to the site on a daily basis.
12.0
The Waste Local Plan that is being used for this planning application was started on the
15 June 1995. At that time the proximity principle and reusing, recycling and composting
was at the top of the agenda. The production of the new plan was to be ready by April
1996, and there was no waste management plan in operation at that time.
That Cornwall Waste Local Plan was written 10 to 15 years ago, and is now well out
of date with current thinking on the waste issues. In 1998/9 AEA technology
Consultant Dr Patel, was appointed to do a study of energy from waste, after it had been
decided they should build this then 300,000 ton incinerator. In February 2000 Dr Patel
recommended that they should build an incinerator in the middle of this Duchy beside a
SSSI and at the end of a large airport run way.
12.1
Regarding commercial waste; more and more companies are realizing that it is cheaper,
and more cost effective to recycle, and reduce their waste than to send it either to be
buried or burned. So there is not going to be a huge amount of commercial waste in
Cornwall to be burned. Far from the residual waste going up in Cornwall it is actually
going down. In 1998 Dr Patel stated that a 300,000 ton incinerator would be needed in
the centre of Cornwall, Inspector, Rose put this back to 200,000 tons. We are now down
to 180,000 tons of Municipal Solid Waste MSW, solid waste that originates from
residential sources, with the commercial part of the waste stream getting smaller by the
week.
12.2
If this contaminating incinerator were to be built, the county would still have to find
landfill space for 60,000 to 80,000 tons of fly and bottom ash to be buried each and every
year. SITA insists that they can turn contaminated bottom ash into aggregate for roads,
and building blocks for housing. This is not possible as Cornwall can not rid herself of
the millions of tons of clean aggregate that she already has. No one is going to buy
contaminated ash from an incinerator, particularly as the Highways agency has now
banned the use of bottom ash in foamed concrete because of the risk of explosion.
When all putrescible waste is anaerobicly digested the end product goes back into the land, there
is no waste to go to landfill.
For all these reasons set out above CSWN request that this planning appeal be refused.
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DOCUMENTS
2.4
E U Directive 2008/98/EC of the European Parliament and of the Council.
3
Inspector Howard Rose letter to Cornwall County Council July 2002
Cornwall Waste Local Plan. A Brief Review, by Alan Watson BSc (Hons) Public Interest
Consultants 2002
4
4
CSWN Paper comments on response to clarification request to SITA from Cornwall
County Council on CERC December 2008. Doc 477759
6
8
Planning Policy Statements 1, 10, 11,
Planning Policy Statements 22, 23,
10
British Society of Ecological Medicine, The Health Effects of Waste Incineration
4th Report of the British Society for Ecological Medicine Second Edition June 2008
Paper from Paul Connett on nanoparticals
10
10
10.1
10.2
10.4
Cornwall County Council Economic Forum AGRI-FOOD
Paper from Denmark:- Country-specific chemical signatures of persistent
environmental compounds in breast milk
Papers from Gilly-sur-Isere Albertville France.
Soil Association of Organic farms in five mile area of St. Dennis
11
Cornwall County Council population figures.
12
Papers from 1998 1999 2000 Joint Waste panel, Cornwall Waste Local Plan
12.2
Paper on the danger of bottom ash
9