Representation by United Kingdom Without Incineration Network (UKWIN) (United Kingdom Without Incineration Network (UKWIN))
- Date submitted
- 24 October 2022
- Submitted by
- Non-statutory organisations
UKWIN objects to the proposed development. We note that the claimed benefits – including with respect to adverse climate change impacts and the claimed need for the proposed capacity - are overstated whilst potential adverse impacts are understated. The planning balance goes against the proposal, with associated adverse impacts outweighing any benefit of the proposed incineration facility. In summary: • The Climate Assessment is inadequate. We dispute a number of the adopted assumptions and methodologies for both the primary analysis and the sensitivity analysis. The information provided is insufficient to demonstrate that the proposal would likely result in a net carbon benefit, and so no weight should be given to such a claim. The approach to climate assessment adopted by the applicant fails to follow industry good practice in line. We note that industry good practice is set out within UKWIN’s July 2021 Good Practice Guidance for Assessing the GHG Impacts of Waste Incineration. • A need for the proposed capacity has not been demonstrated through the Waste Fuel Availability Assessment. While UKWIN is pleased to see the Applicant acknowledging the relevance of draft NPS EN-3 paras 2.10.4 and 2.10.5, our position is that the proposal goes against these emerging policies. The proposed capacity is not in line with Defra’s policy position on the role of energy from waste (EfW) in treating municipal waste and would result in overcapacity of EfW waste treatment. The proposal also goes against other relevant policies, statements, goals and targets that promote the top tiers of the waste hierarchy over EfW incineration and that seek to avoid incineration overcapacity. UKWIN intends to cite concerns about how incineration competes with recycling, including Defra research and comments from the Climate Change Committee.