LONGPARISH PARISH COUNCIL

Formal Response to adequacy of Community Consultation

Proposed Wheelabrator Harewood WtE Facility EN010104

 

HEADLINES

  • Longparish is a parish of over 700 people living within 2km of the Site.
  • Longparish Parish Council agreed unanimously at its meeting on 9 December to oppose this project, with overwhelming support from a village-wide consultation.
  • The proposed incinerator would be a huge eyesore and detrimental to the environment, health and well-being of people in our parish.
  • The cumulative impact of this development (including heat and power offtakes) has not been explained to the community.
  • We need a detailed reply to our response to the Stage 1 consultation which has largely been ignored.
  • We consider that the present consultation is inadequate and premature and have already made this clear to Wheelabrator.

RATIONALE FOR DEVELOPMENT

In properly considering this proposed development, two key questions must be answered:

  1. In view of current and future changes in waste management policy, and the Government’s commitment to make the UK carbon neutral by 2050, what guarantee is there that there will be sufficient demand for this additional incineration capacity throughout the planned life of this project?
  2. If there will be such a demand, is this proposal the most environmentally advantageous, and least harmful, solution? Do the perceived wider benefits outweigh the significant actual harm that it would do, particularly to the local community?

The PEIR signally fails to answer either of these questions satisfactorily – confidence is expressed that the demand will continue to exist, but no evidence is produced to support this assertion; and there is no information whatsoever on what alternative sites or solutions were considered or why they were rejected.  This leads to the conclusion that this development is proposed purely for commercial gain rather than as part of an overall waste management system that is genuinely in the national interest. 

ADEQUACY OF COMMUNITY CONSULTATION

It is clear that there are many gaps in the information provided in the PEIR: more detailed comments are provided below.  However, the persistent refusal to take account of local knowledge and usage highlights the inadequacy of the consultation at the local level.  Rather than creating an environment for discussion and understanding, the consultation has left the community wondering what else Wheelabrator has omitted or not understood.

Reiteration of Longparish Parish Council Response to Scoping Report

We provided a detailed, tabulated response to Wheelabrator’s Scoping Report[1]. We reiterate the many questions and objections we raised therein, which continue to trouble the community.

SPECIFIC LOCAL ISSUES

Inadequate Description of the Site

  1. None of documents clearly states that the proposal will have a major impact on two The site technically falls just within the parish boundary of Barton Stacey but is closer to Longparish, on the Longparish side of A303, and on a road frequented by many Longparish ‘receptors’. Wheelabrator’s failure to name Longparish in its descriptions of the site is misleading: the proposal will have a practical and visual impact on both sides of the A303.
  1. Despite us informing Wheelabrator at a very early stage that locally ‘The Street’ is referred to and known as ‘Southside Road’ they have persisted in not using this local name as an alternative. Naturally this creates a barrier to local understanding of the project.
  1. The large aerial map view used at drop-in events did not show important local features such as Southside Road, making it difficult for people to identify the exact location in relation to their property. The misleading aerial view gave the impression that there is no road access to the site except from the A303. In fact Southside Road is the main access to Longparish for many residents and visitors who will have to walk, cycle or drive right by the Site, sharing the unclassified access road with Site traffic.
  1. The cumulative effect of failure to name Longparish or show the main access road to the village (above) is to misrepresent the likely impact of the proposed plant on Longparish.
  1. Forest Edge Kart Club[2] (FEKC) is a thriving kart racing club operating from a track to the east of the Site. FEKC is an immediate neighbour to the IBA processing plant, yet it is barely mentioned in the PEIR. This is a serious omission since users directly access their track along the Site access road. FEKC is busy with kart drivers and supporters on track days, but although these have been identified as receptors in the PEIR, FEKC has not been contacted directly as part of the community consultation. This is clearly a serious omission.
  1. The description of the MOD land to the west of the site as a ‘driver training area’ also indicates desktop rather than local research: local residents know this land is used by units on exercise as an adjunct to Salisbury Plain, and RAF and Army helicopters are frequent visitors.  Later, the PEIR refers to ‘the Harewood Slip Roads[3]’ which again has no local meaning and appears to have been dreamed up by remote desk-workers.
  1. Additional Land: Wheelabrator earlier carried out what they term a ‘Stage 1 consultation’. They should therefore be required to make very clear if there are any changes to information provided at that time, otherwise this constitutes misrepresentation by omission. The proposal now covers a large triangle of additional land to the north (an increase of about 50%) known locally as ‘Pat’s Butterfly Field’ which is easy to miss in the documentation provided. We also understand that they have options on, or interests in, further land adjacent to the site or are in the process of acquiring more. In these circumstances, it should clearly be stated that the proposal now covers a significantly larger area from that shown at Stage 1. More importantly, the entire Environmental Impact Report must of course relate to the entirety of the eventual site: if this has not yet been fixed then any consultation and impact reports are premature.

 

  1. Wheelabrator’s intention is now to use the ‘new’ triangle of land to the north for construction lay down. This will be an unsightly visual intrusion to all those using Southside Road. If permission is granted, conditions should be imposed to ensure it is reinstated and protected as a wildlife area as soon as construction is complete.
  1. Further, Wheelabrator cannot claim that the site context has informed the design and orientation of their proposed structures if they are not even clear about the total land use. Indeed, the PEIR indicates that structures such as noisy air-cooled condensers have been sited to the north of the original plot so as to minimise impact on receptors to the South[4], yet this ignores the impact on residents and receptors in Longparish.

Visualisation of the Incinerator/Power Plant

  1. All visualisation of the plant provided in physical displays and documentation is misleading. Wheelabrator has used deliberately-muted colours against the most favourable skies, which is unrealistic for most days. There are no realistic indicative photomontages from pedestrian or vehicle angles such as from the A303, from along Southside Road or from the north (the most likely view from Longparish).
  1. In particular, Wheelabrator completely omits any visualisation of the plume from the two chimneys. This is a crucial aspect of the proposal. Wheelabrator has been informed that the village has experience of an existing stack which was supposed not to emit a visual plume, but does so almost continuously. This is therefore an area of special concern to this village and should have been properly explored, explained and mitigated in consultation.

 

  1. Illumination of high-point at night (for air traffic) means that the plume, too, will be illuminated. The visual impact of illumination of the high points and plume at night should have been properly exposed in consultation.
  1. Further, it is clear from other incinerator projects that light spill has a major impact on local people. The Raymond Brown site already attracts complaints about its excessive use of light on site. The glow can be seen as you approach the village and down in the village at certain times of the year. There are no street lights in most of Longparish and our dark skies are highly valued in this rural area. There has been no satisfactory explanation or indication of how the project will address light pollution.
  1. We have repeatedly asked Wheelabrator to provide indicative barrage balloons to fly at appropriate levels at strategic points on the Site, so that the community can better envisage the impact on the landscape. This should have been a crucial part of a proper consultation process, would have permitted more accurate photomontages and informed proper discussion.

General Comments on the PIER

  1. The Non-Technical Summary is intended to give those with no professional knowledge clear and understandable information on the proposals. In fact this document is difficult to follow: for example, the Main Table 6.1 bears no relation to that document’s contents, making it difficult to find each topic. Such difficulties continue through the PEIR, for example Chapter 10 is inconsistently labelled either ‘Biodiversity’ or ‘Ecology’, typographical errors confuse understanding[5] and the documents have been supplied online but without helpful hyperlinks which would have made them far easier for ordinary people to navigate.
  1. Wheelabrator says that Parish Council comments have ‘helped shape’ the list of chapters presented in the PIER, but it is hard to find evidence that the report takes account of or responds to our comments at all.
  1. It is repeatedly stated that data gathering is ongoing, so there is a dearth of key information to support proper consultation with the community.
  1. The terminology and assessment of impact methodology produce counter-intuitive results throughout the PEIR. For example, the split between Moderate and Major significance[6] in some cases is huge (Moderate being ‘limited effect’ and Major ’considerable effect … for example of more than local scale or in breach of recognised … standards’) forcing what laymen might term considerable effects into moderate.
  1. The consultation documents and events gave the clear impression that the plant output will ALL be renewable baseload electricity. Is this true, is all the electricity treated by law as ‘renewable’? The proposed facility would convert residual household and business waste ‘into renewable energy’ and will incinerate ‘Municipal Solid Waste (MSW), Commercial and Industrial (C&I) waste’. As non-experts, it seems to us this cannot be true - surely the mixed nature of the waste means only a proportion will be ‘renewable’ energy? This is an aspect that has not been adequately clarified to the community.
  1. Studies indicate that at least half of what is currently in the ‘residual’ waste stream is readily recyclable; meaning a significant proportion of what is currently incinerated could have been recycled or composted. We are concerned that contracts for the supply of waste will make suppliers take on the risk of the incinerator not getting enough waste to burn, effectively penalising them for not sending enough waste for incineration.   Contractual mechanisms such as ‘minimum tonnage guarantees’ undermine the economic incentive to reduce, re-use and recycle[7].  Specimen contracts should be provided to reassure the community on this issue.
  1. Similarly there appears to be an overstatement of ‘green’ credentials. The CO2 balance does not appear to take account of the gases emitted as part of the construction materials and process, nor of the decommissioning and destruction. It appears misleading not to have explained this in full to the community. Is the CO2 balance affected if waste is not properly sorted? This seems likely if there is pressure to feed the incinerator at any cost.
  1. Wheelabrator has failed to address clearly the issue of lost energy from heat output. Failing to use this affects the CO2 balance and efficiency of the plant. Other sources suggest that ‘Energy outputs such as heat and transport fuels are expected to decarbonise much more slowly than electricity. In addition delivery of heat from energy from waste can be done at much higher efficiencies than electricity only… Ensuring sites for energy from waste are available that allow potential connection to heat customers is an essential part of maximising the benefits.[8]The community needs to understand why this plant is being built where there is no heat offtake.
  1. If the plant will be ‘heat ready’ then Wheelabrator should show what development is expected to use this, i.e. are we actually looking at a much bigger proposal with industrial offtake (building, traffic, environment etc.). We believe it is highly misleading to the community not to show the whole picture, including cumulative environmental impact.
  1. Wheelabrator have not been clear about the source of waste to be processed at this site. It might be suggested that if all the waste is produced locally, or even produced within Hampshire, this is a more compelling case for local processing. However, Wheelabrator states for example that ‘a significant volume of suitable residual business waste being generated in Hampshire and surrounding counties … continues to be sent to landfill’ and ‘our facility will provide a local solution to manage and recover the energy from residual waste that’s generated in the surrounding areas closer to its point of origination’ (our italics). Wheelabrator should give clear answers to the community about the sources of waste, or confirm that only local Test Valley or Hampshire waste will be used as fuel.
  1. Moreover, at earlier consultation MSW was not included as a potential fuel, yet now it is. This is clearly crucial information for the community, and since Wheelabrator must be planning from where it will source all waste it should be open about the likely constituents.
  1. Nor is it clear what happens to the IBA (the Raymond Brown site processes Hampshire’s IBA and already has periods when it cannot clear all the IBA processed on site) or to the hazardous fly ash. How and where will these be disposed of and, if the IBA is to go to Raymond Brown, how and where will Hampshire's IBA be disposed of?
  1. If the plant will export electricity to the grid then Wheelabrator should show how this is to be achieved, irrespective of whether that forms part of the current application. It is a core part of this development and will have cumulative impacts on the community which should clearly be included in any impact assessment. We believe it is highly misleading to the community not to show the whole picture, including cumulative environmental impact.
  1. The reasons for rejection of potential alternative sites have not been adequately explained to the community. For example, local people are well aware that Didcot Power Station (just up the A34 from Longparish) chimneys were finally demolished in August this year, so reasonably ask why that is not a better site. Parishioners at the Longparish consultation event asked Wheelabrator for more details of the alternative sites explored, yet still have no information to help them understand why this Site has been chosen.
  1. Further, the PEIR dismisses the ‘Do Nothing Scenario’ but does not acknowledge that their argument applies to all undeveloped land. The land could be allocated for tree-planting, the benefits of which are now actively promoted by all political parties. Even if it is established that this type and size of plant is needed (which we dispute) it is clear that doing nothing on this site is entirely compatible with such national need.
  1. Wheelabrator literature claims the plant will have a design life of 50 years, but literature elsewhere on Government sites and incinerator commentaries indicates a realistic 20-30 year lifetime for this type of facility. It would be more informative to the community if Wheelabrator were to calculate the relative cost/benefits on a ‘worst case’ basis of a 20 year lifetime.
  1. Who pays for decommissioning and returning the Site to its original condition? There are no assurances on this, a subject of crucial importance to the local community which should have been part of the community consultation process. If permission is granted it must include a condition that a financial surety is in place to ensure that funds are available to clear and restore the site.
  1. It is not clear what safeguards Wheelabrator intends to put in place to prevent accidents and emergencies. Longparish has already experienced two severe fires at the Hampshire Project Integra waste transfer station at the western edge of the village (which does not even use combustion). Recently there was an enormous industrial fire at the Ocado warehouse facility on the eastern edge of Andover, just 6 miles away, causing local people to be evacuated and discharging a huge quantity of pollution. The community therefore has reasonable fears about the dangers from a huge incinerator and Wheelabrator has an absolute duty to take every step to protect the community from unexpected events.

SPECIFIC PEIR CHAPTER RESPONSES

Traffic and Transport (PEIR Chapter 6)

  1. The proposed development will have an impact on traffic flows not just at the A303 junction adjacent to the site, but also on the daily flows on the A303. The PEIR does not provide a comprehensive assessment of the impact of the traffic generated by the construction and operation of the proposed facility, but outlines the proposed methodology and areas where further modelling is being undertaken.
  1. The PEIR states: “Discussions with Highways England has confirmed that there is no need to model the operation of the A34/A303 Bullington Cross set of junctions.” Longparish residents are severely concerned about the impact of the proposed development on these roads, given the high incidence of accidents and closures which cause traffic delays, and the consequent impact on local roads unsuitable for heavy lorries. The impact on the A34/A303 junction and the A303 from Bullington to Andover should be modelled. The model should take into account not only the available PIA data, but also the impact on congestion at this stretch of the A303. The model should take into consideration other developments that will be taking place along the A303 in the given timeframes (2020 – 2025 and beyond), which will contribute to the overall traffic levels on the A303 in the vicinity of the proposed development. The impact of the increased congestion on the journey times, air quality and local amenity should be clearly demonstrated.
  1. It is noted that in generating the Future Baseline traffic projections, Wheelabrator uses data from one year only (2018) and unadjusted growth rates from the area. This approach is unlikely to provide the robust assessment of the traffic impacts, and does not take into consideration specific factors that are and will be contributing to the growth of traffic flows in the local area.
  1. In its methodology for determining Sensitive Receptors, Wheelabrator applies arbitrary parameters which do not recognise the rural nature of the proposed development site. In an area with the low density of population, such as Longparish, the thresholds should be set to reflect the relative increases in traffic, and not the absolute numbers of vehicle movements. In a rural area such as Longparish, an increase from 22 HGV movements at a junction to a 198 HGV movements at the same junction will generate a high impact, even though the relative number of movements is still low compared to the proposed thresholds. The entire assessment presented in Table 6-36 is based on the false premise that as long as the vehicle movements are below 1,000, the effects on the local population will be low or very low.
  1. The PEIR provides an inconsistent picture of the weekday traffic flows, which is misleading. For example, table 6-19 sets out total AADT future baseline traffic at A303 WB Slip Road as 1407, of which 22 are HGV movements. Table 6-30 gives the equivalents with the proposed development as the total of 1757 AADT, with 198 HGV movements. Table 6-31 provides an assessment of net change as an increase of total AADT of 159 and increase in HGV of 130, whereas a simple calculation shows that the difference between the future baseline and the “with development” case is 350 AADT and 172 HGV movements. Comparison with the future baseline shows that at all locations the relative increase in traffic will range between 4% and 800%, with an average increase of 201% across the ten selected locations.
  1. It is noted that in describing the Cumulative Effects assessment methodology, Wheelabrator does not include assessment of the developments specifically highlighted by the local community in the previous response to the consultation. These include the future construction of the A303 tunnel at Stonehenge, developments at Solstice Park and MOD developments at Tidworth.

Air Quality (PEIR Chapter 7)

  1. Air quality has an impact both on human health and the receiving terrain: what goes up must come down. The community needs a clear explanation of what will be released into the air we breathe and into the ground and water below.

 

  1. We have been unable to find a simple explanation of how much of each type of gas will go up the chimneys and what size particles will be released. Even with efficient filters it is accepted that particles under PM2.5 will escape, but it is unclear how many tonnes per annum of such particles will be emitted and what size they will be. This is important both because there is evidence that smaller particles have worse effects on health and can be ingested to all parts of the body, and because there are likely to be large numbers of the smaller particles.
  1. Where do these particles fall? Wheelabrator should provide maps showing what will fall where. Plumeplotter have produced an animation which is helpful[9]:  this information should be provided by Wheelabrator for all pollutants. Only then can the likely effect on the community be gauged.
  1. Research data is incomplete: many of the measurements to give baselines in this and many other areas of the PEIR were not complete when the report was written so the report is not properly informed.
  1. Chimneys: since the Stage 1 consultation we are told the stacks have been reduced in size. Lower stacks are less efficient[10] in dispersing the products of combustion[11]. In the absence of good evidence we resist the reduction in height. The community needs to understand:
  • What is the effect of the lower stacks?
  • Is our health being sacrificed to reduce the visual impact?
  1. Away from the main roads our air quality may be pretty good. If so then the changes resulting from this project may be highly significant in relative terms. What steps has Wheelabrator taken to look at air quality in the village of Longparish?
  1. The PEIR tends to average over long periods (annual) when considering air pollution. This averaging may hide dangerous short-term (hourly or daily) effects. How does Wheelabrator propose to ensure short-term danger is not overlooked?

Health (PEIR Chapter 8)                  

  1. As with several chapters, the studies and evidence provided are very general and not specific to this location. Assumptions are made that the Site is in a low risk area for health so the incinerator, its construction, operating emissions and decommissioning will not have an effect. What evidence is there to deduce this? One could argue the opposite, as the fear of the unknown and long term impacts on air and water quality, and the massive visual impact on a rural area, are likely to produce mental health issues as well as possible physical illness. It is our view that the visual impact of this massive structure will overshadow the villages of Longparish and Barton Stacey and destroy the atmosphere and perception of a unique area of rural England which will deeply affect the psyche of the community and those visiting it. Indirect effects will include damage to tourism, businesses relating to the river, farming, and property prices all of which will have an impact on people’s stress, anxiety and mental health. According to the PEIR this area has very good mental health, but this does not mean that the community’s mental health will not be affected by this massive overbearing structure dominating the landscape.
  1. Human receptors should clearly include all those who use Longparish village facilities (in addition to those included in Barton Stacey) such as Longparish School and Little School, cricket club and scouting groups, as well as residents and workers in both villages.
  1. Human Health Risk Assessment (HHRA) information should have been available at this public consultation stage since emissions are a main concern of residents due to widespread evidence in the public domain which conflicts with Wheelabrator’s assurances.
  1. We do not accept that compliance with the Industrial Emissions Directive is sufficient to avoid detrimental health effects. It is well known that poor air quality correlates with poor health[12] . There is mounting evidence that micro particles emitted into the atmosphere are harmful. The WHO limit is that small particles known as PM2.5 should not exceed an annual mean of 10μg/m3 (10 micrograms per cubic metre), or a 24-hour mean of 25 μg/m3.   Existing UK legal limits for PM2.5 are more than double the WHO limit[13]. Recent work (BMJ 27 November 2019[14]) suggests that there is. "… no safe lower limit for exposure to PM2.5".
  1. The community is naturally concerned about the effects on emissions on health. Experience has taught them the dangers of relying on current knowledge rather than being cautious (e.g., asbestos, diesel and smoking). It is therefore reasonable to insist that Wheelabrator be obliged to comply with the best available technology at the time of installation for cleaning up the gases, to meet the highest contemporary emissions standards throughout its life, and that Wheelabrator be obliged to fund independent research (establishing a baseline and monitoring changes) into the effects of the potentially harmful emissions on the environment and human receptors in this rural area.
  1. We already receive complaints about dust and odour in relation to the existing Fortis and Raymond Brown facilities adjacent to the site, and the Bedmax combustion site at the western end of Longparish. The increase in dust and odour production under various wind conditions and at different phases of this project should not be described as negligible on residential receptors without evidence, particularly now the site acreage has been extended. Smells from delivery vehicles and the transport and processing of IBA will also have a local impact and should be included in the community information.
  1. Piling works are typically one of the noisier construction activities for any site and are considered to indicate the worst-case noise levels to surrounding receptors. Wheelabrator nevertheless suggests these can be carried out between 07:00 and 19:00 hours Monday to Friday inclusive and 07:00 and 16:00 hours Saturday and Sunday. Our villages already put up with noise at weekends from the kart track, the shooting range and army activities. Recent applications for extending the Kart Club activities have been turned down by TVBC in response to noise complaints. Noise assessments have been carried out over the years for these kart and shooting activities and show that the noise carries easily down into the valley and depending on wind direction travels along the river: at times go kart noise is enough to prevent people using their gardens in summer. Noise from the construction of this massive power plant is likely to be at least as intrusive. We therefore object to the description of such noise as insignificant. Mitigation should at the very least restrict noisy activities to ordinary working hours of 9-5 weekdays only.
  1. This chapter concludes that the changes predicted from the construction, operation, and decommissioning of the incinerator will have negligible / minor effects on the health of the local population and will therefore not have a significant effect on their health. The Parish Council cannot agree with this statement. This is a view not evidence. Already the proposal has caused anxiety for those who oppose this development and those trying to sell their property. The prospect of the emissions potentially polluting the river, the land and the air should not be underestimated when assessing the mental and physical health impact of this proposal. What is the cumulative impact on the health of the community?

Noise and Vibration (PEIR Chapter 9)

  1. This section of the PEIR is limited in factual or local information. It is impossible to make any considered judgment given our limited knowledge of the technical detail, but in particular because no specific analysis related to this actual project has been conducted. It is vital that the greatest effort should be made at the earliest stage and all baseline surveys concluded so that the local detail can be properly evaluated and later re-consulted. Impacts of any significance will only be realised once the construction phase is under way, which is too late.

 

  1. In particular we note that background noise levels at receptors are yet to be defined as baseline monitoring is ongoing. It has not been clearly explained why noise levels near the A303 are not considered as an issue due to the ‘already high volume of traffic.’ It must be true that an additional 400 lorry movements per day and associated added traffic required to service the site (non-waste delivery, personnel etc.), in addition to cumulative impact from ‘each of the developments’ will generate significant additional noise[15].
  1. Noise emissions from the top of the two stacks have been modelled as point sources with a sound power level of 97dB LwA – or the equivalent of a helicopter at 100ft or a jack hammer. The closest residential receptors are listed at 9.105 as 280m away (and, confusingly, at 9.76 as over 300m away) but these are unlikely to be the only receptors to such noise.
  1. We note that Longparish receptors have been omitted and will be disadvantaged by the orientation of the plant so that the cooling systems in the stacks are directly facing the village[16] - ‘locating the air-cooled condensers on the northern side of the Site to allow the main building to assist in acoustically shielding them from sensitive receptors to the south’ [17]. Why should Longparish residents bear the brunt of acoustic impact, and has modelling shown the likely noise and vibration for village receptors, as well as walkers, cyclists and others enjoying the rural peace? The impact on receptors to the north of the site must be acknowledged and mitigated.
  1. There is no Construction Management Plan, therefore all information is again based on best practice and modelled information. Full consultation demands such a plan be shared with the local community.

Biodiversity / Ecology (PEIR Chapter 10)

  1. The PEIR broadly reflects a desk-top exercise, though a number of areas have not been explored - for instance the potential for longer term environmental impacts on the Ancient Woodland of Harewood Forest, the second largest area of woodland within Hampshire. It provides an excellent woodland habitat for wildlife, including roe deer and buzzards yet desk-study data source omits this Ancient Woodland since it wrongly limits the scope to within 1km of the Site.
  1. The on-the ground survey data seems cursory. Despite the lack of detail in the Report the survey identified a series of important habitats and pinpointed some areas of local biodiversity, which should have set alarm bells ringing. Further investigation is evidently required at the correct time and in the correct fashion, to provide evidence on which to base a planning decision of this size and importance.
  1. More generally, there are significant oversights with regard to what is now deemed the ‘laydown works area’, the new triangle of land to the north of the original site locally known as Pat’s Butterfly Field, which call into question the quality and depth of the report with regard to its findings for the construction site. In addition, the disturbance to wildlife of increased noise and light does not appear to have been considered.
  1. Pat’s Butterfly Field has been managed since October 2010 along conservation lines. There has been a mowing regime to encourage chalk grassland perennials. The species-rich hedgerow along Southside Road has been laid on two occasions and insect food plants have been planted and encouraged to grow. An interim Natural History Report is being written and is constantly being updated. A wildlife diary has also been kept this year (2019) with records and pictures dating back to October 2010 on which these comments are based.
  1. A local ecology expert has supplied greater detail on how a proper on-ground survey should have been conducted and what it would have found. This report notes that many indicator species were missed, together with some more uncommon species found in the hedgerow. The Butterfly Field has a rich diversity of plants with over 120 species recorded, many species of which are the food plants of rare insect species. Only a fraction of the nesting bird species were recorded, whilst four species of Schedule 1 birds (afforded the highest level of legal protection) have been recorded on this site. There are some important gaps in the Taxa covered; there appear to be no invertebrate surveys, specifically an entomological survey ,and no overwintering bird survey, nor a mammal study: all areas for which this site is important. Other gaps include no records of Fungi, Bryophytes and Lichens. There are large numbers of butterflies on the site especially the Marbled White, where an estimated 400 can be seen on one day. The site is home to one of our more iconic beetles and a vulnerable species of snail, associated with wood piles, occurs at two locations on the site. Five animal species have been recorded on the site, which are listed under Appendix A of the Wildlife and Countryside Act 1981, again affording the highest level of protection to these species. Badgers are intermittent visitors to the site and occur in the surrounding area, evidence of which does not seem to have been picked up.
  1. Our expert’s conclusion is that further, better designed Ecological Survey work is required before an informed decision can be made on the Natural History value of Pat’s Butterfly Field. Realistically this would require the minimum of a further eight months of field-work followed by the subsequent write-up.

Water Resources and Flood Risk (PEIR Chapter 11)     

  1. The consultation meetings and PEIR again lacked detail. One significant question asked was how water will be supplied to the Site during both construction and operation. All water within this area is supplied from the local aquifer; in South Hampshire a significant percentage of the drinking water supply is from the River Test which is within 600m of this proposed Site. The PEIR recognises that this is ‘an area of serious water stress’[18]. In 2019, drought orders were sought from Southern Water to protect both the Rivers Test and Itchen, Southern Water acknowledging that  “Using a drought permit means that we must do everything in our power to reduce water use and so minimise the impact on the river’s precious and unique habitat[19]. It is understood that high volumes of water must to be supplied from neighbouring companies under ‘bulk import of water’[20]. Further annual abstraction at this Site (calculated at 131,400m3 or 165,000,000 litres[21]) this can only exacerbate the situation.
  1. After reviewing the documentation and asking questions at the consultations, it was confirmed by the representatives of Wheelabrator that Southern Water have not yet been approached formally and no modelling has been conducted to show how such a volume of water being abstracted will affect the flow rates. This is a critical factor and this detail should have been part of the consultation process. No mitigation is proposed, yet others will suffer.
  1. Reference is made to ground water levels recorded at 8.6 to 9.4m below the surface between September and October but also as shallow as 6.3m. Ground water levels are generally low at this time of year - further measurements should be taken from March onwards when ground water will reach peaks. Local experience of construction within the valley shows that ground water can be less than 0.6m below surface. As the main boiler room is now proposed to sink 4m below ground level there is significant risk of contamination within the construction phase.
  1. We note that the construction area is a Source Protection Zone, a receptor of High importance[22]. Groundwater flood risk is considered to be high[23] and Wheelabrator have been made aware of local residents’ concerns about a winterbourne close to both the north and south of the Site[24]. This is a key instance of where local knowledge should be given great weight by Wheelabrator and where they should seek to assuage the community’s concerns. If the area is subject to ground water flooding this will impact millions of Hampshire residents whose only source of drinking water is contaminated, whilst several SSSI sites and AONB locations (not to mention farmland and the delicate ecosystem of the rivers) would be devastated.
  1. Significant numbers of local families and businesses rely on private boreholes to legally access water supplies. No modelling has been done to assess the potential impact of flow or pollution issues on these water users.
  1. There is further serious concern that the world-renowned clear chalk waters which meander through our village may forever be damaged by this commercial operation. Our community finds no reassurance in the PEIR.

Ground Conditions (PEIR Chapter 12)

  1. There is no design statement or construction management plans so we conclude that Wheelabrator have not considered any necessary measures to be implemented to reflect ground conditions. The PEIR refers only to industry best practice. Therefore at this stage it is impossible to reflect upon how the multiple risks will be mitigated or controlled.

Archaeology and Heritage (PEIR Chapter 13)

  1. There are some 130 listed buildings within a 5km radius of the proposed development, including St Nicholas’ Church Longparish (Grade 1) and Longparish House (Grade II*), all of which would, to a greater or lesser extent, be affected by this proposal. However, the PEIR only identifies two (in Barton Stacey) on which the impact would be significant, even though Middleton House (Grade II), for example, is in an elevated position looking directly towards the site.  It is therefore not clear how this conclusion has been arrived at or why the impact on the whole of the Longparish Conservation Area, which is long and linear in nature, is never ranked above ‘Low’, when the impact must vary considerably at various different points and the visual impact will not just be restricted to glimpses of the stacks, exacerbated, of course, by the plumes and the red warning lights at night.  The suggestion is that trees by the river will provide screening, but these trees are deciduous so the views will be much more open in winter.  We conclude that the PEIR seeks unjustifiably to play down the impact of the proposed development on heritage assets.

Landscape and Visual Impact Assessment (PEIR Chapter 14)

  1. In spite of the changes that have been made to the design of the proposed development, and the reduction in its height, such a massive structure would continue to represent a significant intrusion into the local landscape that would stand out well above the treed horizon. It would not be ‘visually attractive’ or ‘sympathetic to local character’ as required by the NPPF, nor would it be of any benefit to the local landscape.  The PEIR suggests that any significant impact and consequent loss of amenity would be limited to a 5km radius, but this is a highly subjective judgement that ignores, for example, the fact that both the main structure and the stacks would be clearly visible, and therefore interrupt the view, from Beacon Hill, which is some 15km away.  Added to this is the fact that the site is located some 3 km south of the North Wessex Downs Area of Outstanding Natural Beauty and some 11.5kms north west of the South Downs National Park, so there is a particular sensitivity to such a development that would intrude into the rolling chalk downland linking these two areas of national importance to the landscape.
  1. The PEIR presents no superimposed images of the proposed development from representative viewpoints, so the photographs do not provide any basis on which to make a judgement about its potential impact, particularly as they were taken when all the trees and bushes were in leaf. Such theoretical representations are in any case inadequate.  What is essential is a physical simulation on the ground when there are no leaves on the trees, perhaps by means of tethered balloons at the height of the main structure and the stacks, so that their effect can be seen from all angles and from anywhere within the affected area.
  1. The PEIR consistently underestimates the visual impact of the plumes from the stacks, as well as that of the stacks themselves, and does not acknowledge the starkness of the effect of aircraft warning lights on them at night. It is also unclear why the effect of the plume has not been considered in Year 15 of the plant’s operation, as it would still be visible in winter. 
  1. It is difficult for non-experts to judge the validity of the methodology for assessing the visual impact of the proposed development, but some of the conclusions appear very questionable, and the suspicion is that this was primarily a desk-based exercise with an element of subjectivity. This emphasises even more the need for a physical representation of the proposal on the ground to enable valid judgements to be made.
  1. The PEIR fails to include any mention of how the plant would be connected to the electricity grid and what impact this might have on the landscape. It also omits any assessment of the visual impact of the 50,000 m3 of spoil that would presumably be dumped on the newly added laydown area to the north of the site that would bring the development even closer to the village of Longparish.   

Climate Change (PEIR Chapter 15)

  1. Climate change is increasingly forcing local and national bodies to think clearly about how best they can preserve the planet. Changes in waste management policy and the Government’s commitment to make the UK carbon neutral by 2050 make it instinctively unattractive to plan large-scale incinerators, especially when in this case there will be such a devastating impact upon the environment. Longparish and local villages have brought in new initiatives to encourage residents to reduce, recycle and reuse, and this local commitment to prevent waste along with the declaration of a Climate Emergency at Council level demonstrate the clear resolution to stop excessive waste. Our ambition is to severely limit the amount of waste reaching the bottom of the waste hierarchy, so that in future incinerators of this kind are defunct. It is therefore wrong to build and assume a 50-year lifetime for this type of facility. In fact, the ecological cost of construction and operation over a shorter life mean the facility will always be a net climate destroyer.
  1. It is ironic that the proposed location of this Site means that an existing ‘green’ solar farm will be overshadowed. If we are to combat climate change we should treat as sacrosanct existing measures to produce power from truly green, renewable sources.

Socio-Economic and Land Use (PEIR Chapter 16)

  1. It is notable that ‘key stakeholders’ approached by email is not a sufficiently broad list. This is partly because Wheelabrator have chosen to limit the study area to just 2km. Clearly the socio-economic impact of this project is likely to affect a far wider area, given that the reputation of the region for specific leisure or tourism uses, for example, may be affected for an indefinable time. For example there are many bed and breakfast, public house, fishing, game, cycling, walking, holistic therapy, food and drink producers, historical and cultural enterprises within, say, 15 minutes’ drive of the site, all of which are likely to suffer an impact from the visual size of the incinerator alone. Clearly a wider area and broader range of leisure and tourism receptors should be assessed within the PEIR. Data has not been collected from a sufficiently broad range of receptors to allow proper assessment.
  1. It seems that the longevity of emotional responses to factors like potential pollution has not been adequately quantified. It is correct to say that the effect on tourism and leisure, for example, are more qualitative than quantitative. People’s opinions and emotions are what count in whether they choose to take a walk near an incinerator, or fish in a nearby river. Qualitative data should be collected by survey, interviews, focus groups or other methods rather than simply ignored. In sensitive areas like leisure and tourism an impact lasting a year (‘short term’) can have a catastrophic effect on viability. Even ‘short term’ impacts should therefore be weighted heavily. Reliance on the ‘expert judgment and experience of the author[25]’ is not justified and it should be acknowledged that this author is far from independent.
  1. Magnitude criteria seem ill thought-out. For example, the definitions at Table 16-6 are not clear, and Table 16-7 (and 16.52) excludes some impacts in magnitude assessments, so that for example an impact on heritage or biodiversity is deemed unable to have an impact on fly fishing, which is clearly wrong. Any ‘major significance’ residual effect could be of high magnitude in qualitative terms.
  1. The assessment methodology for this section assumes that these two small rural villages can be usefully treated as part of Andover for many purposes. This would be appropriate within the town but seems to us likely to give statistically-skewed results.
  1. Employment and GVA statistics appear misleading. Publicity from other Wheelabrator sites indicates that many employees are likely to come from outside the area and be low paid[26]. Given the proximity of other towns, such as Basingstoke, can it really be said that the Test Valley area will reap any benefits in terms of employment or GVA? The estimate 800 FTE workers accessing the site for 42 months will themselves be exposed to environmental impacts, whilst impacting on the local environment.
  1. We completely disagree, for the reasons stated above, that there are no recreation or tourism receptors that would experience a significant effect on their amenity during construction, operation or decommissioning.

THE PROJECT AS A WHOLE

  1. Information ‘About Wheelabrator’ on their event stands and documents states their current UK involvement, but does not acknowledge that out of existing and proposed sites, only this one is proposed in rural area; and only this one will be unable to use heat . Full disclosure would represent proper engagement with the community.
  1. Further, we understand that Wheelabrator UK is currently up for sale by Macquarie Infrastructure Partners. How will this affect the project, and how can we be protected against any adverse consequences?
  1. Wheelabrator mentions in their SoCC (2.2) that their only current facility is ‘a joint venture with SSE’. The consultation process does not make clear that the proposed development is NOT instigated by our Local Authority or their identified needs. In fact Hampshire has already identified[27]suitable industrial areas for waste management facilities and states ‘It is expected that the needs of rural areas will generally be met by smaller, more community-based facilities’. This is a commercial proposition (Wheelabrator acknowledge that a deciding factor in location was ‘The availability of the land in terms of being able to agree commercial terms’). This lack of background local need should have been made clear to local consultees.
  1. Wheelabrator’s own feedback form asks leading questions, requiring that respondents select which of two variations in building colour they prefer. Given that the visualisations do not accurately reflect the design of the plant and show ‘best case’ background only, and that respondents are encouraged to comment on a binary choice, Wheelabrator should not seek to rely on responses to this question as any kind of endorsement.
  1. Wheelabrator misleads the community in claiming ‘We will be an economic partner in the region…benefit the local community’. The electricity is not for the local community, nor is the waste source local. Any economic benefits to local economy are likely to be outweighed by visual and economic impact, including impact on the broader leisure market. Wheelabrator have failed to give sufficient weight to this inevitable balance in their consultation.

 

Community Support and Engagement

  1. If there is deemed to be a demand for this facility and the perceived wider benefits outweigh the significant actual harm that it would do, particularly to the local community, those making commercial profit from the venture must contribute to help that community.

 

  1. The Landfill Tax provides benefits to the local community. This project is only viable because there is, at present, no equivalent tax on waste which goes for incineration.  In the absence of such a tax we consider that Wheelabrator must provide benefits to the local community of the same order of magnitude, say £50 per tonne incinerated or £25M per annum.

 

  1. Wheelabrator must commit to educating the local and broader community on the ways in which it is mitigating damage to the environment, and how they can help. Viridor’s Ardley ERF, for example, engages with the local community about the need for energy recovery technology, and works in partnership with the waste hierarchy to reduce, reuse and recycle waste. They have built a visitor centre to run educational visits and encourage people to learn more about the process.
  1. Wheelabrator should also mitigate the impact of lorry traffic through village roads which are totally unsuited to heavy vehicles and have no traffic separation for vehicles and pedestrians, cyclists or riders. Schemes such as that in place at the local Co-Op Distribution Centre in Andover restrict vehicle routes and include technological solutions which can identify and fine traffic which should not be using village roads.

 

CONCLUSION

Longparish Parish Council is against the Wheelabrator Harewood proposal due to the size, location, and environmental impact of the proposed facility.

The Parish Council has held two parish meetings on the proposal and is clear that the community’s concerns around the likely environmental and community impacts of the proposed development have not been satisfactorily addressed by Wheelabrator.

Longparish Parish Council feels that the public consultation and Preliminary Environmental Impact Report are incomplete and premature.

 

 

[1] See Appendix 2 to Scoping Opinion

[2] http://fekc.co.uk/

[3] PEIR 16.60

[4] PEIR 5.25

[5] E.g. mathematical errors in car data at Table 6-22 and sensitivity criteria definitions at Table 16-6

[6] PEIR Non-Technical summary 6.3

[7] http://ukwin.org.uk/oppose-incineration/

[8]https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/284612/pb14130-energy-waste-201402.pdf

[9] https://www.youtube.com/watch?v=j56RqqjjHLc

[10] 4.18 Typically increasing stack height has beneficial effects on ambient air quality by benefit of increased atmospheric dispersion

[11] The graph at figure 5-1 on page 38 of Appendix 7 shows that chimney height of 85M gives about half the pollution per unit area of 70M.

[12] https://www.gov.uk/government/publications/comeap-long-term-exposure-to-air-pollution-effect-on-mortality  "We are left with little doubt that long-term exposure to air pollutants has an effect on mortality and thus decreases life expectancy."

[13] https://www.theguardian.com/environment/2019/nov/25/living-near-busy-road-stunts-childrens-lung-growth-study-says

[14] https://www.bmj.com/content/367/bmj.l6609

[15] PEIR 9.112

[16] PEIR 5.31 ‘Located the ACC centrally within the Site away from southern noise and visual receptors and best shielded these with the massing of the main building’

[17] PEIR 5.25

[18] PEIR 11.54

[19] https://www.southernwater.co.uk/water-for-life/water-for-life

[20] PEIR 11.56

[21] PEIR 11.74

[22] PEIR 11.42

[23] PEIR 11.51

[24] PEIR 11.34 and Figure 11-2

[25] PEIR 16.43

[26] https://www.bbc.co.uk/news/uk-wales-north-west-wales-42878571

Unions also want the project to adopt the National Agreement for the Engineering Construction Industry (NAECI) which would mean higher wages and improved terms and conditions.

[27] https://documents.hants.gov.uk/planning-strategic/TheSuitabilityofIndustrialAreasforWasteManagementinHampshiretheHampshireAuthorities2012.pdf This Report fed into Hampshire’s subsequent Minerals and Waste Plan