Issues of concern to the Council include traffic, construction and impact on visual amenities of adjacent green belt land.

Traffic
It is proposed that the waste burner would be accessed off the A5 by all HGV’s and commercial vehicles accessing the site. Only private cars (i.e. employees / visitors) would be permitted to access the facility via the A449. It is also proposed to carry out improvements to the junction with the A5 and Vicarage Road to improve access to the site. District Councillors are calling for the submission of a routing agreement for vehicles accessing the proposed site that includes alternative routes for vehicles accessing the facility if the A449/A5 is closed/obstructed.

Impact on Visual Amenities of Adjacent Green Belt
Whilst the site itself is not located within the Green Belt, due to the size and scale of the proposed development it would clearly be visible from the surrounding open countryside/Green Belt. The proposed stack would be between 87m and 101m high and the site is bounded to the north, east and south by the Green Belt. Paragraph 3.15 of PPG2 (Green Belts) directs that: The visual amenities of the Green Belt should not be injured by proposals for development within or conspicuous from the Green Belt which, although they would not prejudice the purposes of including land in Green Belts, might be visually detrimental by reason of their siting, materials or design.

According to the District Council’s report:

This guidance therefore clearly states that development proposals, which are not located on Green Belt land but are clearly visible from Green Belt land can prejudice the visual amenities of the Green Belt. The proposed incineration facility due to its extensive scale, bulk, massing and height would clearly introduce a highly prominent and visually intrusive feature which would clearly harm the visual amenities of the adjacent Green Belt. Significant weight therefore needs to be given in the determination of this case with regards to the potential visual harm of the development on the Green Belt and weighed against the potential benefits which the scheme would bring.

The District Council requests that the County Council should consider the full impact of the development on the visual amenities of the Green Belt when determining the application as no reference has been made to Paragraph 3.15 of PPG2 in the Planning Statement submitted with the application.

PLM comments:

The basic fact is, that due to the size and massing of the building (and the height of the stack) and despite what is stated in parts of the Environmental Assessment, it will not be possible to successfully integrate the development into the landscape. The proposed site layout does not sufficiently provide for landscape treatment although this would be largely irrelevant anyway as it would have no mitigation benefits other than to provide a slightly ‘softer’ environment in the immediate area around the building.

Community Opposition

Campaign group Staffordshire Against INcineration (S.A.IN) and West Midlands Friends of the Earth have objected to the proposal (SS.08/10/636W), on the basis that:

• The waste will be hauled in from a large area – undermining the ‘proximity principle’.
• The incinerator will cause avoidable emissions and will not reduce climate emissions as much as alternatives.
• The scale and expected life of the facility is such that it will displace recycling and waste minimisation.
• The energy recovered from the waste is lower than the energy savings from recycling and waste reduction. This relative waste of energy also contributes to climate change.
• The structure is out of scale and character with the surrounding area.
• The over-capacity and inefficiency of the incinerator is not compatible with a region living within its environmental limits.
• The application may not be in accordance with the South Staffordshire District Council Local Plan

Campaigners also note:

In 2006, the latest year that complete data is available from the Environment Protection Agency, Staffordshire County Council’s Hanford incinerator breached it’s emission limits 40 times. In February 2007 the operators received a written warning that they had been in breach of their Pollution Prevention and Control permit as a result of 9 nine days of continually exceeding their NOx emission level. Subsequently, in April 2007 they were served with an enforcement notice for being in contravention of the permit. The enforcement notice stated that “The Management system is inadequately resourced and is not being implemented at this site”.

Also in February 2007, in response to the NOx problems MES Environmental sent a letter to the Environment Agency admitting to problems with the monitoring equipment, and it’s software. In July 2007 another letter was sent to the environment agency about more software problems and drawing attention to an excess of mercury in the test for the first quarter of 2007, and then an excess of metals in the test for the second quarter. Problems like these are not unique to Hanford. In 2006 the incinerator at Dudley had numerous equipment failures, resulting in over 50 emission breaches, and not to be outdone, Wolverhampton’s incinerator had more than 50 breaches as well.

Also, see FoE’s Objection to Four Ashes Incinerator Planning Application

Planning Ref SS.08/10/636 W

Staffordshire County Council has applied for planning permission for a 300 000 tonne waste incinerator at Four Ashes, South Staffordshire. In summary

• The incineration of resources would be a waste of those resources.
• This huge plant, 300 000 tonnes of mixed municipal resources, aka waste, per annum, would undermine local recycling schemes across the county and potentially neighbouring boroughs.
• This huge plant would involve long lorry journeys from across a wide sub region of the West Midlands.
• The burning of resources in this manner would cause avoidable emissions and not reduce climate change emissions as much as more environmentally benign, smaller and more locally based technologies.
• The application may not be in accordance with the South Staffordshire District Council Local Plan.

Interestingly the planning application is to Staffordshire County Council! In our view the planning committee should be commissioning independent analysis to ascertain whether or not this project is in the best interests of the Council Tax Payers of the County and whether its impact on the wider environment is acceptable. This is essential if the planning committee is going to be able to properly determine this application in an open and transparent manner. The work, to date, has been conducted as part of the Staffordshire and Stoke-on-Trent Joint Municipal Waste Management Strategy.

http://www.staffordshire.gov.uk/environment/rubbishwasteandrecycling/wastestrategy

Sub Regional Facility and Waste Miles

As far as we are aware the incinerator would not just burn the waste arisings from the South of Staffordshire. It would be collecting domestic waste arisings from at least North Warwickshire, Sandwell and Walsall Local Authorities. In some cases the arisings would be travelling over 35 miles to be burnt. This is not in accordance with the proximity principle.
Cost

It has a Capital cost of around £158 million. The total public cost after the PFI (Private Finance Initiative) contribution would be around a billion pounds over 32 years. The incinerator would take most of the waste budget and less recycling credits would be passed down to district councils. If it is stopped then the councils would have to commit to funding environmentally beneficial and job creating recycling. With an incinerator the money goes to multinational banks to pay PFI costs and incinerator operators.
Bottom Ash

The wet bottom ash would be trucked off site in sealed trucks after the Incineration process. Hazardous substances would be washed out of the bottom ash as it is weathered for about a month. That polluted water would have to be kept in a special lagoon and could then be sent back to incinerator to be re-circulated.
Fly Ash

The Fly Ash would have to be treated as Hazardous Waste and would have to be sent to a specialist site for storage and eventual specialist land filling. The majority of the dioxins would be collected in this ash.
Need

The Staffordshire Joint Area already has an incinerator within Stoke on Trent that can burn 200,000 tonnes of waste per year. We do not support the use of mass burn for the management of resources but this plant has a contract that lasts until @ 2022 and will continue to be used by the Joint Area as part of its medium term strategy. Once this strategy comes to an end we would urge the Joint Area to investigate more thoroughly the technologies on offer for dealing with residual resources in a much more financially and environmentally advantageous manner for the residents of Staffordshire and Stoke on Trent.

We don’t believe the second incinerator is needed to meet EU and UK targets. The consultant’s report from July 2007 projected a surplus of allowances in Stoke-on-Trent of 22,424 tonnes in 2020 and a shortage of 11,726 tonnes in Staffordshire with a projected overall 50% recycling rate. Large parts of Staffordshire will exceed 50% recycling this year. Friends of the Earth do want biodegradable waste to be diverted from landfill. The solution is not to burn it so that the material is sent into the air instead what is needed are:-
Better Solutions

We have to reduce the amount of waste produced. This is already beginning to take place. This can be done by:

1) reusing as much as possible – (ebay-freecycle, charity shops etc)
2) recycling and composting – (the best community in UK has just reached 75% recycling and composting, while both Wales and Scotland are aiming for 70% in 2025)
3) using mechanical and biological treatment plants to reduce the remainder to inert material which can then be landfilled if not useable.

An example of how this can be achieved is the Alton Recycling Pilot.
Alton recycling pilot Staffordshire Moorlands District Council
A recycling trial in Alton was held for 22 weeks from the 18th July 2006. It led to:

• A combined composting and recycling rate of 74.84% compared with 37.28% in other areas of the district utilising existing collection systems.
• A reduction in the amount of residual waste collected to 105.71Kg/household compared with 237.29Kg/household in other areas of the district.
• An increase in the number of households utilising the recycling and composting services from 54% to 88%

They rolled out the system to the District in September 2007 and obtained 62% recycling in the first month. In 2006/7 the district had only managed 35% recycling. If you gross up the 105 Kg/household that needed landfilling or incinerating you get 248 Kg per year. Multiplying by the 446,460 households in Stoke and Staffordshire gives you 111,000 tonnes of household waste. The household waste from the districts would then only need 2/3rd of the existing incinerator capacity. 63% of the waste from the CA sites is already recycled and over half of the non-household waste is also recyclable or composted. Details can be found at:

http://www.staffsmoorlands.gov.uk/downloads/Waste_Strategy.doc

Energy Balance

Moreover, the energy recovered from the waste would be lower than the energy savings from recycling and other more environmentally benign methods of treatment and waste reduction

Waste Growth is over

The amount of waste in 2006/7 was the same as 2002/3. Waste is falling slightly in Staffordshire but rising in Stoke-on-Trent due to the contract with incinerator operator.

2000/1 2001/2 2002/3 2003/4 2004/5 2005/6 2006/7
Staffordshire MSW (Kt) 453 476 483 480 483 465 478
Stoke-on-Trent MSW (Kt) 133 139 144 145 150 140 148
Staffs + stoke MSW (Kt) 586 615 628 625 633 606 626
Staffs + Stoke households 431,430 434,436 437,442 440,448 443,454 446,460
Occupied households 418,487 421,403 424,319 427,235 430,150 433,066

MSW per household (kg/hh) 1,403 1,461 1,482 1,464 1,473 1,399

Overall waste growth 5.08% 1.47% -0.62% 0.63% -3.73% 2.80%
stoke waste growth 4.51% 3.60% 0.69% 3.45% -6.67% 5.71%
staffs waste growth 4.95% 2.11% -0.48% 1.28% -4.27% 3.30%

It is reported in the 2007/8 Annual outturn report for Staffordshire County Council that the waste budget is under spent by two million pounds, in part due to a fall in waste. The amount of waste generated in Staffordshire has been about the same since 2002.

Waste Management

4.4 The principal reasons for the underspend of £2.033m are threefold. Firstly, the overall quantum of waste tonnages which need to be managed are 4% lower than last year. In addition, of that overall quantum, there is an increase in recycling levels whilst amounts going to landfill have decreased resulting in further savings.

Source:- http://www.staffordshire.gov.uk/NR/rdonlyres/70D7D8C8-EEEF-4600-A925-9F6E38B04F0C/77310/Item5FINAL.pdf

Some Information sources:

1) Friends of the Earth Website http://www.foe.co.uk/campaigns/waste/index.html
2) Nottingham Against Incineration & Landfill http://www.nail.uk.net/
3) Rainsworth Incinerator campaign http://www.p-a-in.co.uk/
4) Slough’s Anti-Incinerator Network http://www.slough.info/sain/sain.html
5) zero waste Alliance UK http://www.zwallianceuk.org/
6) UK without incinerators http://www.ukwin.org.uk/
7) Staffs CC waste plans and zero waste to landfill

http://www.staffordshire.gov.uk/environment/rubbishwasteandrecycling/wastestrategy
Planning Application website http://www.staffswaste2020.info/

Appendix:

The site notice, below, also highlights that this application may not be in accordance with the South Staffordshire District Local Plan

TOWN & COUNTRY PLANNING (GENERAL DEVELOPMENT PROCEDURE) ORDER 1995

NOTICE UNDER ARTICLE 8 OF APPLICATION FOR PLANNING PERMISSION ACCOMPANIED BY AN ENVIRONMENTAL STATEMENT

I give notice that The Cabinet is applying to the Staffordshire County Council for planning permission for The construction of an Energy from Waste Facility (known as an EfW) to manage approximately 300,000 tonnes of residual waste per year including dedicated adminstrative and visitor facilities, gatehouse and weighbridge, vehicle parking and circulation areas, security fencing and other ancillary structures with site drainage and landscape works at The Dell, Enterprise Drive, Four Ashes and that the application is accompanied by an Environmental Statement.

Application Number : SS.08/10/636 W

The proposed development does not accord with the provisions of the development plan in force in the area in which the land to which the application relates, as the land does not fall within the use classes allocated for the land in the South Staffordshire Local Plan.

The proposal affects the setting of land which is situated within the Staffordshire and Worcestershire Canal Conservation Area.

Members of the public may inspect copies of the application, the plans, the Environmental Statement and any other documents submitted with the application at Development Services Directorate, Riverway, Stafford, the offices of South Staffordshire Council, Planning Department, Council Offices, Codsall and Brewood Library, Newport Street, Brewood, during all reasonable hours until 1 July 2008.

Members of the public may purchase copies of the Environmental Statement, in the form of a CD, so long as stocks last, at a charge of £10.00 and paper copies of the full Environmental Statement can be purchased, so long as stocks last, at a charge of £175.00 from Enviros Consulting Ltd, Enviros House, Shrewsbury Business Park, Shrewsbury, SY2 6LG. A Non-Technical Summary can be obtained from the same address, free of charge and can also be found on the Staffordshire County Council web site at: www.staffsprojectw2r.info/

The Case Officer who is dealing with this application is Roger Vearncombe who can be contacted on 01785 277274 or email roger.vearncombe@staffordshire.gov.uk.

Anyone who wishes to make representations about this application should write to the Corporate Director (Development Services), Riverway, Stafford, ST16 3TJ marked for the attention of the Case Officer referred to above by 1 July 2008. Alternatively you can make your representations via the Staffordshire Planning Portal www.staffordshire.gov.uk/planning. Simply go to the Application Register and enter the application number.

Please note: any representations received are open to all to read and to copy (including, but not limited to: the applicant, the applicant’s agent, the public, or the press). Copyright restrictions and photocopying charges may apply. If for any reason you do not want your representations to be made publicly available in this way then you have the right to withdraw them, in which case we will delete your representation from our records and the comments will not be considered by the Corporate Director (Development Services) or the Planning Committee. Also, in the event of an appeal being made any representations would be passed to the Planning Inspectorate for consideration as part of the appeal and they may publish details of your comments, on the internet (on the Appeals area of the Planning Portal www.planningportal.gov.uk/pcs).

Signed: Ron Hilton
Corporate Director (Development Services)
On behalf of Staffordshire County Council

Date : 29 May 2008

Contacts:

West Midlands Friend of the Earth
Keith Kondakor, Waste campaigner 024 76344079 keithk2t@gotadsl.co.uk
Chris Crean, Regional Campaigner 0121 643 9117 chrisc@foe.co.uk
Paul Roughly, Stafford FOE 01889 505771 paul@foestafford.org.uk