Representation by Wisbech Town Council
- Date submitted
- 11 November 2022
- Submitted by
- Parish councils
This representation is submitted on behalf of Wisbech Town Council in response to the Development Consent Order (DCO) application for the construction, operation and maintenance of an Energy from Waste (EfW) Combined Heat and Power (CHP) Facility. Wisbech Town Council object to the application on the basis that there is no need for the facility to meet residual waste requirements and to include such an over-provision in recovery capacity will jeopardise the achievement of recycling targets. NPS (EN-3) make it clear that an assessment should be undertaken that examines the conformity of the scheme with the waste hierarchy and the effect of the scheme on the relevant waste plans including the contribution it would make to recovery targets taking into account existing capacity. The emerging NPS (EN-3) makes it clear that the proposed plant must not result in over-capacity of EfW waste treatment at a national or local level (paragraph 2.10.5). The Applicants wish to retain the flexibility to accept waste from anywhere. There are no safeguards to ensure that the development will not prejudice the achievement of waste management targets if there has been no assessment of the implications for those targets. The study area in the WFAA is based on a two-hour travel time as it is not commercially viable to transport waste beyond that. The Applicant has relied on waste arisings from areas in Essex and Hertfordshire that are outside this catchment. Reliance on such data significantly distorts the results of the assessment of available waste. The WFAA does not consider the impact of the opening of the Rookery South ERF on the amount of residual waste available. If waste is excluded from those areas beyond the two-hour catchment and the contracts with Rookery South are taken into account, HIC arisings would fall from 17.9 mtpa to only 6.5 mtpa. This does not allow for improvements to recycling rates and is likely to be an over estimate. The application of the methodology underpinning the catchment area has been manipulated to such an extent that the outputs are seriously distorted and cannot be relied upon. The WFAA does not consider the impact of capacity at other EfW facilities in the catchment on the availability of waste that have recently come on stream or will do shortly e.g. Rivenhall Waste Management Facility and Newhurst Energy Recovery Facility. The impact of these facilities will not be reflected in historic data relied upon by the Applicant on the availability of residual waste or the amount of waste landfilled. The assessment of residual waste forecasts in Waste Local Plans is inaccurate in that the data it relies upon is out of date. Additionally, the summary of WPA forecasted future residual waste requirements only records shortfalls significantly distorting the figure. NPS (EN-3) makes it clear that the assessment should include the production and disposal of residues as part of the ES. No detail is provided on the likely location of the facility for dealing with either IBA or APCr or the extent of available capacity. No consideration has been given to alternative sites. If proximity to waste arisings was not taken into account in the site selection process at the PEIR stage, it cannot have been taken into account at submission stage as the location of the facility was already fixed. The failure to consider alternative sites is a serious omission (contrary to NPS (EN1) and the NPPF) given that the application site is within Flood Zone 3. It is not possible to verify whether the data relied upon to inform the assessment of construction traffic is robust. As it is not clear what proportion (if any) of this excavated material will be used on site, clarification is required as what assumptions have been used in the transport assessment. The noise assessment fails to consider the rise in electric vehicles and therefore a potential reduction in the future noise baseline even with traffic growth. The predicted traffic noise increase of the proposed EfW CHP facility would therefore be proportionately greater. It is questionable as to whether the failure to take into account anticipated improvements in air quality represents the worst case as if the baseline is improving, the impact of emissions from the EfW plant will be proportionally greater. Whilst the landscape assessment states that the deposition of excavated waste materials has been assessed in the LVIA, this cannot be the case if it is unclear what proportion (if any) of this excavated material will be used on site. The justification for the conclusion that the EfW CHP buildings and chimneys would result in an effect of Very Low magnitude on the Wisbech Conservation Area on the basis that it would be seen in the context of existing large scale industrial buildings is not accepted. Even if a magnitude of Low is ascribed to the effect on the Conservation Area, based on the classification of effects set out at Table 10.16, this would lead to a moderate (probably significant) effect. The ES makes no assessment of the operation of the EfW CHP on the water environment despite the hydrology chapter stating that potential effects on specific species and aquatic and riparian biodiversity are assessed within the biodiversity chapter. The entirety of the EfW CHP site lies within Flood Zone 3. NPS (EN-1) makes it clear that the decision maker should be satisfied that where relevant the Sequential Test has been applied as part of site selection. As the site selection process did not include an assessment of alternative sites at a lower risk of flooding, as a matter of fact, the Sequential Test cannot have been met. The assumption that the current proportion of residual waste that is currently landfilled will continue to be so until 2066 is not credible and would be contrary to policy trends. If the Applicant is assuming a declining proportion of waste is landfilled to 2066, these assumptions need to be clearly set out and justified. The amount of waste available as fuel for the proposed EfW CHP facility is grossly exaggerated in the Waste Fuel Availability Assessment and therefore reliance on this document as an input to the climate change assessment will significantly over estimate the carbon savings of the proposed facility in comparison to the landfill baseline. No information is included on the transport assumptions associated with the management of IBA and APCr. It is not clear where this material will be processed. Similarly, no information is included on the transport assumptions associated with the import of consumables necessary to operate the facility. Without this information, the assessment is incomplete. The information contained in the WFAA has been distorted and misrepresented to such an extent that it should not be relied upon. Implementation of the proposed facility would result in significant over-capacity of EfW waste treatment contrary to the draft NPS (EN-3) and would prejudice the achievement of recycling targets for many years to come. The Environmental Statement requires clarification on a number of matters to ensure that an assessment of the effects of the scheme is accurately assessed. A detailed submission has been emailed to medworth@planninginspectorate.gov.uk