Representation by Ruth Fenella Hopgood
- Date submitted
- 12 November 2022
- Submitted by
- Members of the public/businesses
Having been a contaminated land consultant / geoenvironmental engineer with over 15 years experience in the sector, and with an MSc in Contaminated Land and a BSc in Soil Science, I have been in a position to assess the MVV documentation and the associated responses. Given the size of the proposed incinerator I consider that MVV have failed to provide adequate information and assessments despite numerous requests from consultees. This is notably in agreement with the thorough high level review carried out by Lucent Energy and the responses from Fenland District Council and the local MP, Stephen Barclay, as shown within the project document pages. There was no explanation as to why the site in Wisbech was chosen as a potential location for the mega incinerator, with possible alternative sites not even mentioned despite being a requirement. There was also no explanation as to why such as huge incinerator was required. Even MVVs chosen consultants, Wood Group, concluded in Ch 15 (Economic) that there would be no significant effects locally, on a county level, to local suppliers, employment opportunities (direct / indirect) or the housing market, and that this would apply even if there were to be an annual community benefit package. In addition the Wood Group Ch 16 (Health) highlighted the problems of noise from the project in the proposed location, requiring addition mitigation measures to reduce the significant effects, and that even the perceived risks from such a facility can adversely affect health and quality of life. The road infrastructure in the area consists of only minor A and B roads, the largest being the A47, and even this being limited to single carriageway across much of the area that would be used. Despite the recent improvement of the A47 Guyhirm roundabout with the A141 the local roads are already overused by heavy lorries. The addition of vast numbers of heavy vehicles carrying untreated waste to the proposed site, together with others leaving with hazardous waste for further treatment or for landfilling elsewhere is untenable, and unacceptable for the inhabitants of Wisbech, the surrounding villages and a nationally important agricultural area. Clarity is required as to whether it is actually feasible to provide sufficient suitable, non-recyclable material from the surrounding area to actually run an incinerator at the quoted level of input, as detailed in Stephen Barclay’s submission. If not this would be deemed a non-DCO development and would have to go through the ‘normal’ planning process with far more input from local, regional and statutory consultees. It was also noted that the waste types quoted as being available included significant quantities of currently readily recycled or reusable materials. This is ridiculous when Reduce, Reuse and Recycle is accepted as a far preferable process, with residual waste treated using lower carbon options. In addition, the presence of incinerators has been shown to notably reduce recycling rates in those areas tied into incineration contracts. The nature of domestic waste currently being produced is extremely variable, and by its nature could not be assessed for potential contaminants adequately before being incinerated. It will contain significant levels of persistent organic pollutants (POPs), including perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) that are part of a large group of lab-made chemicals known as perfluoroalkyl and polyfluoroalkyl substances (PFAS), many in seemingly innocuous items such as clothing and cooking utensils. Incineration does not necessarily destroy some of these compounds, at whether at ‘normal’ operating temperatures of 850 degrees or the higher 1200 degrees indicated as being possible, and / or can lead to breakdown to other potentially dangerous compounds. There is insufficient information relating to the potential risks from such chemicals if they escape from the chimneys, with MVV stating that 90m would be high enough for anything that might escape to disperse across the surrounding area being totally inadequate, especially in this proposed location, with schools, a hospital and housing amongst the many buildings lying to the northeast, this being predominately downwind. This is an important agricultural area, notably including production of fruit and vegetables. The short and long term effects on crops and soils, and the subsequent risks to human health, have not been adequately assessed. In a widespread area of shallow groundwater with many waterways, including field ditches, this water would also be at risk, both during construction and operation. Inadequate information was supplied regarding the fate of the huge quantities of bottom ash and fly ash which would produce a further 165,000 tonne of waste material (this being 26.5% of the initial waste, and at least partly hazardous waste) and with a further 5% as fly ash (hazardous waste). This means that 31.5% of the material that entered the site would then have to be transported off site again to suitable landfill sites, using even more heavy lorries, and due to the nature of the material to be disposed of probably having to be taken long distances by road. This has further implications regarding the viability of the whole project, and was not given proper consideration by MVV in their submissions, with no chapter having been produced on waste despite this being a fundamental aspect. No details have been supplied regarding the potential recipient(s) of the waste heat from the process or how it would be transferred. Concerns have been expressed by consultees that MVV have assumed that the currently disused railway could be at least partially taken over. This does not take into account the ownership, and in particular the continuing hopes of many in the area that the line to March will be reopened for domestic use in the foreseeable future. In the light of the now largely accepted climate crisis facing us it is totally unacceptable to be proposing building an incinerator that would pump out huge quantities of carbon dioxide (and probably other damaging gases). There has been no suggestion by MVV that carbon capture would even be considered unless it was forced to by the government, and even then the limited successful processes running to date have generally recovered about 50% of the carbon at the most (as quoted by the Institute for Energy Economics and Financial Analysis, with the highest reported example being 68%; New Scientist, 10 September 2022). Given that the UK is committed to decarbonising its electricity network to meet 2050 Net Zero targets, and as already determined by the Secretary of State on a national scale, this project must not be allowed to go ahead.