Developers bid to make Essex Incinerator one of the biggest in England

11 September 2015

New application for Rivenhall Airfield proposes burning 595,000 tonnes of waste per year

A new planning application has been submitted to Essex County Council (ECC) by Gent Fairhead for their proposed waste site at Rivenhall Airfield. This is the latest application in a planning saga that started in the 1990s.

Once again, Gent Fairhead are trying to vary the planning consent they already have from 2010, which in turn was different to the consent they obtained a few years prior. In particular Gent Fairhead want to make the incinerator capacity larger. The latest bid is for an incinerator with a capacity to burn 595,000 tonnes of waste per year. This is an increase over the 2010 consent for the plant of 65%. But it is 98% more than in the first version of the plant.

The new application is reference ESS/34/15/BTE and is out to a 3 week consultation from 27th August (though ECC has indicated to some objectors that it will accept representations up to 30th September).

The application proposes several things, including:

A Section 73 application to vary the drawings and plans covered by condition 2 of the original consent;

A series of condition “submission of details”;

But most significantly, changing the function of the plant much more towards burning waste.

The outside appearance of the plant is not proposed to be altered much but the application (curiously, considering the developers have only until March 2016 to start construction before their consent runs out), also removes previously agreed internal processing detail and substitutes this with "indicative" drawings.

This latter change adds to the problem of uncertainty surrounding the site which has been the subject of many applications.

 

Cllr. James Abbott, Green Party District and County Councillor, and co-founder of the Stop The Incinerator campaign said

“As the years tick by it appears that Gent Fairhead either cannot, or do not want to, build what they have planning permission for.

They have now had over 5 years to submit details and apply for an Environmental Permit since gaining consent in March 2010. In 2012 they unsuccessfully attempted to “phase” the construction. Then they secured approval from ECC to remove geographic sourcing conditions and so can now bring in incinerator waste and paper wastes from anywhere. Recently they were given an extra year to submit details and start construction by ECC – the new cut-off date being 2nd March 2016; but despite this they are appealing for yet another year to March 2017.

This latest application is not merely the “submission of final details” which Gent Fairhead claims it is. The application fundamentally changes the nature of the plant, significantly reducing the recycling elements and increasing waste incineration. At 595,000 tonnes per annum, the Rivenhall Airfield incinerator would be one of the largest in England. A key question is – would the Inspector and Secretary of State have supported what is now being proposed had it been submitted in 2009 ?

The 2 main impacts on local communities, if this plant is built, will be increased HGV movements on the local road network, and exposure to pollution from the incinerator which would operate 24/7. Although the developers will argue that the pollution plume will be “within limits”, it is an indisputable fact that pollution levels will rise in what is largely a rural area and currently with good air quality.

The history of the planning saga over Rivenhall Airfield is a classic case of “planning creep”. The first planning application about a decade ago proposed a “recycling and composting plant for Essex” – with no waste burning. That application was rightly seen by many as a Trojan Horse application, paving the way for what was to follow.

If this latest application is approved, residents in Braintree District will be subjected to the traffic and pollution from this plant, but the waste will be being trucked in from much further afield. To put that in context, this plant would burn about 10 times as much waste per annum as the total waste produced by all the households in Braintree District. The annual input capacity of the whole plant, at over 800,000 tonnes, is equivalent to more waste than is produced by all the households in Essex put together in a year.

The developers will try to portray the plant as “green” and “producing renewable energy”. It is anything but green and as well as the air pollution of particulates and heavy metals, it will be pumping out about half a million tonnes of carbon dioxide into the atmosphere every year.

Instead of burning waste, investment needs to go into reducing waste at source (such as phasing out non-recyclable packaging) and boosting recycling capacity. This plant would be a major step backwards.

Over a decade ago, Lord Hanningfield, as the then Leader of Essex County Council, stated that we were “political scaremongers” for saying an incinerator was being planned in Essex – and at Rivenhall Airfield. Yet the documents in the public domain and those we have secured under FoI have always pointed to this outcome since this planning saga began in the 1990s.”

 

Proposed changes to Plant Functions

To allow for the increased incinerator capacity, whilst keeping the overall input capacity and HGV movements (404 per day) the same as in the 2010 consent, the recycling elements of the proposed plant are being reduced.

The paper pulping unit capacity is proposed in the new application to be cut by 53%.

The Mechanical Biological Treatment (MBT) unit is proposed to be reduced and the Anaerobic Digestion (AD) plant is down from 85,000 tonnes per annum to just 30,000 tpa.

The 2009 Planning Inquiry heard that the plant was proposed as an integrated plant with a "closed loop" system where the paper pulping plant and incinerator were closely linked. This proposal was used to justify the “Combined Heat and Power” (CHP) designation and was a key part of the reasoning why the Secretary of State gave planning permission in March 2010.

However, now not only is the incinerator proposed to rely far more on imported Refuse Derived Fuel (RDF) from industrial and commercial sources - which could be trucked in from anywhere; but also the previous proposal to use the waste from the paper pulping plant to part fuel the incinerator has been abandoned. It is now proposed to export the paper plant waste by road. The much larger incinerator also leads to the export by road of ash wastes more than doubling compared to the 2010 consent. Some of this material is highly toxic and can only be landfilled.

 

Wind direction – communities at risk of exposure to pollution

The much bigger incinerator will result in greater releases of pollutants into the atmosphere compared to the 2010 version. Weather conditions will determine from day to day which communities/farmland, etc are exposed to it:

North wind – Witham and Rivenhall

East wind – Silver End, Cressing and the Notleys

South east wind – Braintree

South west wind – Coggeshall

West wind – Feering

North west wind – Kelvedon 

 

Chimney height uncertain

Given the proposed increased incinerator capacity, there is more uncertainty over the height of the incinerator stack. Gent Fairhead still states it will only be 35m high as in the 2010 consent, yet a smaller capacity incinerator at Ipswich has recently been built and that was required by the Environment Agency (EA) to have a stack 81.5m high.

It appears from application documents that Gent Fairhead may try to start building the plant before they have obtained a permit from the EA and so the final height of the chimney may not be known even while construction has commenced - the permit process can take up to 9 months. If this happens it could make the stack height a fait accompli despite it being a key consideration at the 2009 planning inquiry due to the impact on the countryside and nearby Conservation Areas – especially Silver End.

The plant permit would operate on the standard basis of “complying with legal limits” on specified pollutants, with allowed exceedances for certain periods. This allows operators to say that emissions will not cause ill health, but the effects of long term exposure to incinerators is controversial. At the 2009 Inquiry objectors tried to secure a condition that pollution monitoring should be set up near communities around the site but this was turned down. So there will be no regular “real world” monitoring in the wider area subject to the plume, only measurements taken at the plant. 

The proposed access remains the same, with all traffic proposed to be from/on to the A120 at Bradwell, though there are questions about what happens if the A120 is blocked for any length of time, with fears of narrow local roads being used to access the site. The combined site traffic from the waste site and existing Bradwell quarry would be up to about 1,000 HGVs per day.

Essex Green Party is urging residents and interested groups to send in representations to Essex County Council at:

mineralsandwasteDM@essex.gov.uk

The full documents on the various plans for the site (which run to many thousands of pages) can be seen on the ECC Planning pages - search under Rivenhall Airfield.

 






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