Representation by United Kingdom Without Incineration Network (UKWIN) (United Kingdom Without Incineration Network (UKWIN))
- Date submitted
- 8 August 2022
- Submitted by
- Members of the public/businesses
UKWIN objects to the proposed development. Claimed benefits are overstated, and 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: 1. The proposed incineration facility could result in local and/or national incineration overcapacity, in contravention of EN-3 (2021) which states: “As the primary function of EfW plants is to treat waste, applicants must demonstrate that proposed EfW plants are in line with Defra’s policy position on the role of energy from waste in treating municipal waste. The proposed plant must not result in over-capacity of EfW waste treatment at a national or local level”. 2. This position was subsequently confirmed as Government policy in July 2022, with the Government stating: “The Government’s view is that Energy from Waste (EfW) should not compete with greater waste prevention, re-use, or recycling. Proposed new plants must not result in an over-capacity of EfW waste treatment provision at a local or national level”. 3. These Government statements add weight to the conclusion highlighted in the Wheelabrator Kemsley North refusal which found that large-scale development can undermine local recycling efforts and divert waste from recycling. 4. UKWIN also intends to cite other concerns about how incineration competes with recycling, including Defra research and comments from the Climate Change Committee. 5. Given the proposed facility would treat RDF, it is notable that it takes more than one tonne of waste to produce a tonne of RDF. 6. We are also concerned about the proposal’s climate change impacts, both in terms of the direct emissions from the stack and indirect emissions compared to waste treatment options further up the Waste Hierarchy. 7. We are concerned about the poor efficiency and questions regarding the deliverability of the proposed carbon capture element of the proposal (including questions about whether or not the Environment Agency would issue an environmental permit for technology that does not meet best available technique requirements), and the potential adverse health impacts of amine degradation associated with the chosen carbon capture technology. 8. The Applicant’s May 2022 Chapter on Waste (6.2.15) and the associated RDF Supply Assessment (5.2) are flimsy and full of errors and outdated information. For example, by focussing the need assessment on the situation in 2019 the Applicant fails to properly account for the capacity that came online during and after 2019 or that is currently under construction. These combine to undermine the Application’s need case for the proposal, raising concerns about the impact this facility would have on recycling and waste reduction. 9. The Applicant’s May 2022 Climate Chapter (6.2.6) contains a number of significant inaccuracies, inadequately-evidenced assumptions, and approaches that are not in line with good practice. These combine to reduce the weight that should be given to claimed environmental benefits of the proposal. 10. UKWIN does not believe that the proposal constitutes ‘essential infrastructure’ that would justify location on a site that is high risk from flooding and functional floodplain.