From  Neil Pitcairn, Bindura, The Avenue, Sth Nutfield, Surrey  RH1 5RY
neilpitcairn@hotmail.co.uk

To: West Sussex County Council Planning Dept.

Date: 16 May 2021

re: Planning Application ref. WSCC/011/21 (Ford Circular Technology Park)

I write to object to the above planning application, on the following grounds:

I note in the applicant’s Non Technical Summary (para NTS2) that waste will be drawn not only from West Sussex but also from the neighbouring counties of East Sussex, Hampshire and Surrey. There is evidence from the UK and mainland Europe indicating that the presence of incineration facilities depresses recycling and progress to a more circular economy. The proposed incinerator is likely therefore to have a negative impact across the whole region of SE England, including Surrey where I live. I and others will be considering asking the Secretary of State to call in this application as one of regional importance.

Evidence showing a clear correlation between low recycling rates and high incineration rates in the UK is presented on pages 3 and 4 of UKWIN’s August 2020 Submission to the National Infrastructure Commission, which I will submit with this objection for ease of reference. Further evidence from around the world of how waste incineration undermines recycling and jobs growth is available at  https://www.no-burn.org/wp-content/uploads/Bad-News-for-Recycling-Final.pdf. 

That same document also illustrates how much of what is burnt is actually recyclable if properly pre-sorted – a situation paralleled in the UK. Pages 4 and 5 of UKWIN’s Submission of March 2020 on the Environment Bill to the House of Commons Public Bill Committee (which I will also submit here) summarises some of WRAP’s findings on this matter. It is unlikely that the truly recyclable fraction which could be retrieved from so-called residual waste in West Sussex differs significantly from the research examples identified by WRAP. In other words, over well over 50% of what Viridor would propose to incinerate at Ford would be readily recyclable if properly presorted. 

I consider that a waste incinerator at Ford, as an example of linear economy waste management, would undermine progress towards a more circular economy, not only in West Sussex but also in my own county of Surrey.

West Sussex’s nominal household recycling rate in 2020 was 53%, better than some councils but below the best. It should improve with the introduction of food waste collections (long overdue); however it is clear that to achieve the targets now set by national government and by the Climate Change Commission, priority should be given to the top end of the waste hierarchy, and not to expanding residual waste disposal infrastructure such as this incinerator.

I note that the West Sussex Waste Local Plan, agreed in 2014 and set to run until 2031, has allocated Ford as a strategic site for waste treatment and recovery, and that planning permission was previously given for a gasification incinerator on this site. I appreciate it may be difficult for the Council to contemplate refusing permission for a revised design of incinerator on the site in these circumstances. I suggest however that there have been material changes in the overall situation which would allow the Council to justify a refusal decision, or an approval with strict conditions attached.

The objection dated April 2021 by UK Without Incineration Network (UKWIN), which I support and with which I wish to be associated, focuses on the climate change impacts of the proposed incinerator. It indicates how there are legal grounds for climate change impacts alone to be considered sufficient for a planning refusal, how the applicant has failed to comply with standard guidance in assessing the climate impacts, and how in fact the incinerator would function as a high carbon energy source if it was ever connected to the grid. UKWIN’s objection also draws attention to the latest Climate Change Commission advice on waste incinerators – advice which it is stated government policy to accept. Seven years have passed since the Waste Local Plan came into force; the Climate Emergency is a material change which the Council is duty bound to take into account in its interpretation of the Waste Local Plan.

Strategic Objective 14 of the Waste Local Plan reads: “To minimise carbon emissions and to adapt to, and to mitigate the potential adverse impacts of, climate change.” Approving the proposed incinerator at Ford would increase carbon emissions and be in direct breach of this Objective, unless the Council insists that Carbon Capture and Use or Storage (CCUS) is installed and made operational at the same time as the incinerator is commissioned. Promises to install CCUS at some indeterminate future time would not be compliant with Climate Change Commission recommendations.

Admirably and wisely, West Sussex chose not to join the rush to build incinerators when the Landfill Directive was introduced, and avoided being locked in to long term expensive incineration contracts. Given the over-ample supply of incinerator capacity now in the UK, given the recently enhanced UK government and Climate Change Commission recycling targets, and given the large amount of recyclable material waiting in “residual” waste to be properly sorted, there is still no urgent need to build an incinerator at Ford. The urgent need is for more and better facilities to reuse and recycle what is put out for collection, by both businesses and households, and for more and better education to encourage waste reduction at source. The site at Ford may be much better suited for a reuse centre.

It is customary for incinerator operators to talk up the prospects of using waste heat as a means to improve the apparent energy recovery credentials. Near the Ford site there is a strategic housing development site. I recommend any suggestions that waste heat from an incinerator could be used for district heating should be treated with caution. The Council should have regard to Viridor’s unhappy experience at Ardley in Oxfordshire where a component failure led to no electricity or heat being exported from the incinerator for one year; also to Viridor’s Beddington incinerator which failed to supply heat to local residents this past winter. Customers of such systems cannot get by without emergency backup for when the incinerator is offline; they may also find themselves unable to source cheaper and greener sources of heat, being locked in to a district heating system which itself is complex and expensive to install and maintain. Therefore, should the Council be minded to give planning approval for the incinerator, the Council should avoid being manoeuvred into a position where it picks up any part of the cost or liabilities for a district heating system; these should remain entirely with the incinerator operator.

I should like to add a cautionary comment on public health and emissions to air, even though I know it is unlikely to qualify as a reason to reject the application. I note that emissions will be monitored and soil samples taken if the incinerator is built. Recently researchers in Holland have discovered dioxin accumulations in free range hens eggs and in the wool of free roaming sheep in the vicinity of a modern incinerator which meets all EU and Dutch emission controls. The eggs would not be safe to eat. These accumulations would not be detectable in soil samples where the same bio-accumulation does not occur. I cannot put forward these findings as part of a formal objection since they have not yet been replicated elsewhere and peer reviewed. However studies are now planned in Latvia and Spain to see if the results are replicated. The comment I wish to offer is that, possibly, the last words have not yet been written on the safety of modern well run incinerators, and that those planning to build houses – or rear hens – nearby should be cautious.

Neil Pitcairn