Views of the city with and without the new incinerator.
Reasons to object to the new incinerator.
Rabid's objection to the new incinerator.
Link to Greenpeace objection.
Please write to
Head of Planning Division
Department of Planning, Transport and Highways
Howden House
1 Union Street
Sheffield S1 2SH quoting reference 9B/0948
Views of the city with and without the new incinerator.
Reasons to object to the new incinerator.
Here are some of the reasons to oppose the incinerator.
IS SHEFFIELD'S INCINERATOR GOING TO BE SAFE? We have been told all along that incineration is safe. The city council have based this on a report produced for the National Association for Clean Air [May 2001]. The report however does not claim that incineration is a safe process. It claims there are acceptable risks. Risks which RABID do not believe the people of Sheffield should have to bare.
A report from the University of Exeter found this so called "Authoritative" document to contain important factual errors and to show extremely superficial knowledge of the most relevant and up to date scientific literature. It was also found to be poorly and inaccurately referenced and draws in part on out of date literature. The exposure assessment is based upon the emission factor approach, which is known to underestimate releases of toxic chemicals. It also fails to take into account the many poorly understood and unknown toxic chemicals released during incineration. Despite widespread public criticism, the authors have so far declined to defend their work, which is unusual in research.
CANCER AND HEALTH - Emissions from "state of the art incinerators"contain Dioxins, Furans (Toxic chemicals) and Heavy Metals, which can cause cancer. There are no safe level of exposure from Chromium or Nickel and no guidelines recommended for particulates. (National Society for Clean Air Report). Researchers in Britain have found elevated incidents of cancer in the lung, stomach, larynx and bladder within 7.5km of some incinerators. Other health hazards include altered sexual development, male and female reproduction problems, suppression of the immune system, diabetes and a wide range of hormonal effects. These effects can be experienced for up to 30 miles or more.
DIOXINS IN OUR FOOD - Dioxins accumulate in fats - meat, poultry, milk and even a nursing mother's milk. Dioxins get into the food chain from air emissions from the incinerator, they can spread up to 30 miles from the incinerator through wind currents and rain down through precipitation. They land on vegetation, animals eat the vegetation, the dioxins accumulate in the fatty tissue of the animals, we eat the animals or their produce (cheese, milk, ice cream,yoghurts, etc.). You'll recall how Belgian food products were taken off our supermarket shelves in Summer 1999. Their food industry was almost destroyed by just 1g of dioxin contaminating animal feeds. Should we take this risk? Dangerous doses of dioxin are measured in just trillionths of a gramme.For that reason, it is both difficult and expensive to measure, with few laboratories worldwide having the necessary equipment and skills to detect it. An incinerator will operate all day every day. Unfortunately,no monitoring system exists to detect breaches of dioxin limits as they happen Thus, there will be crucial delays between sampling and analysis.
TOXIC ASH - some 25-30% by weight of what goes into the incinerator comes out as hazardous ash. In particular 5% of what goes in, comes out as highly toxic flue ash. Toxic chemicals in this ash include Dioxins, Lead, Cadmium, Arsenic, Mercury and Chromium. In Newcastle Upon Tyne, UK, residents have been warned to avoid eating any vegetables grown in allotments because ash from a nearby incinerator was used to build pathways through them. After local residents had complained, dioxins and heavy metals were measured and found to be up to 800 times above safety levels (The Guardian 26.5.2000).
LANDFILL - The transport of ash to Parkwood. Accidental spills on site or leaks during transport, or the loading and unloading of these vehicles all present the chance of an accidental release of these toxic elements into the environment. Toxic dumps are the natural consequence of incineration. Much more dioxin will leave the incinerator as ash than through emissions. Toxic Lead, Cadmium, Arsenic and Mercury will forever leach out gradually from where they are dumped. To date, there are no facilities for the safe long term storage of toxic ash from incinerators.
OTHER RISKS - There is also the risk of dioxin releases from accidental fires or explosions.
WEALTH - Devaluation in Property Values - In Kilcock, during their recent successful battle against a proposed toxic waste incinerator, people in the locality were unable to sell their properties until after An Bord Pleanala had rejected the application for the incinerator. As well as houses, businesses could also suffer due to their proximity to an incinerator. The incinerator planned for Sheffield will cost £40 million. On top of this, there are running costs, and a profit margin. We are still paying for the £28 million wasted on investing in the old one, which is now to be demolished.The burden of paying for this monster will have to be carried by us.
GREENHOUSE GASES It is hypocritical to promote smokeless solid fuel, lead free petrol and no smoking public areas, all in the interests of public health, while at the same time promoting incineration, whose emissions will contribute to greenhouse gases.
JOBS- Evidence from recycling in the UK and overseas shows that in Britain 15,000 jobs would be created in collecting and sorting and at least another 25,000 to 40,000 jobs in manufacturing and reprocessing. A city the size of Sheffield would generate about 300 permanent jobs in collection and sorting alone. In Germany, the waste and recycling sector is bigger than either steel or telecommunications. [Creating wealth from waste by Robin Murray pub by Demos and Ecologika 1999.]
VISUAL APPEARANCE- The new building is massive and will be as significant to the panorama of Sheffield as Hyde Park flats and the Hallamshire Hospital. It will completely dwarf surrounding buildings such as the Mega Centre and the prestigious Victoria Quays development. It will be an ugly blot on the landscape.
ENVIRONMENTAL COSTS-The materials our society uses are won at great cost to the environment. The President of the Royal Society warned in November this year that humankind is presiding over and extinction of plant and animal species that matches the catastrophe of the dinosaurs 65million years ago. (The Guardian November 29th 2001). People recycle because they want to do their bit to save the environment. The world is loosing an area of forest larger than the size of Greece each year. A large part of this is caused by our rapidly expanding need for paper and pulp. In 1997 the amount of paper produced could form a pile that could reach the moon and back more than eight times. [State of the World 2000 pub by Earthscan]. Please send a copy of your objection to Graham Wroe Please persuade any organisation you belong to such as a residents association, club, church,branch of a political party or even your local pub to send in an objection too! Some famous people are going to object. Do you know anyone famous or influential who would be willing to back our campaign? Please let us know.
Views of the city with and without the new incinerator.
Reasons to object to the new incinerator.
RABID's OBJECTIONS.
OVERVIEW.
RABID's contention for our objections to be given material consideration, and therefore are wholly applicable in this case.
The Environment Agency.
Land and Contamination.
Air Quality.
Health Impacts.
Land use for Incineration.
An alternative to Incineration.
Residents against Bernard Road Incinerator Dust (RABID) formally object to the use of the Bernard Road site for incineration and contest the application (9B/0984) for a new Municipal Solid Waste (MSW) Incinerator Installation thereon.
RABID was formed to campaign against a policy of incineration at the Bernard Road site. This was out of recognition that incineration is an unsafe, uneconomical and unethical practice. Consensus of opinion has established that the incineration process creates environmental pollution in the form of smoke and gaseous releases of toxins into the environment. The ash from the process goes to landfill, further contributing to the cumulative effects of contamination of the site and the environment generally. The Bernard Road site is seen as uneconomical in the fact that the costs to the environment from MSW Incineration and peoples health are immeasurably higher than any benefits of revenue created from the combined heat and power business. Finally, the use of incineration is unethical in the fact that the easy option for waste management has been taken, thereby discounting the long-term effects on the environment and future generations.
RABID argue that Sheffield City Council should not be considering the application at all, because they have already signed a contract with ONYX, and therefore have an interest in the application — in all fairness the Council should not be judge in its own case. So the application should be called in and decided by a planning inspector acting for the Secretary of State for the Environment. However if this doesn’t happen then the following submission sets out our opposition to incineration.
2. Planning - Renewable Energy - material considerations.
The expressions of Government policy that are most relevant to the consenting process are those expressed in planning guidance. PPG 22 reviews the issues relevant to specific waste to energy proposals, but falls short of clear support. “Renewable Energy Developments” published by the Scottish Executive in November 2000 states:
Planning and pollution control systems are separate, waste combustion developments may not always be, following an assessment of the best practical environmental option, the most acceptable means of managing waste. Their acceptability will, in part, be influenced by their fit with the National Waste Strategy and where appropriate, related area waste plans.
Planning - Waste Installations
The planning guidance relevant to proposed waste management installations in England and Wales is contained in PPG 10 (September 1999) which includes stringent controls for to all types of waste management facilities. It sets out the principles applicable to planning decisions in respect of all waste streams:
(a) Consideration of BPEO (Best Practicable Environmental Option);
(b) Regional self-sufficiency;
(c) Proximity principle;
(d) Waste hierarchy.
BPEO is a relevant planning consideration specifically when considering proposals in land-use terms. The Government hopes that waste
Development control will be plan-led and promoted at a regional level. The proximity principle is intended to ensure that waste is dealt with near to where it is produced and to deter long distance transportation.
The waste hierarchy is set out in the government’s Waste Strategy (see below).
There is no special treatment advocated for waste to energy installations, but the planning guidance must be read alongside the Waste Strategy.
Waste Strategy
The Government’s Waste Strategy for England and Wales was adopted in May 2000. The strategy is clearly a material consideration in planning decisions.
A waste hierarchy is set out in Chapter 5 of the Strategy and is as follows:
1 Reduction;
2 Re-use;
3 Recovery by way of recycling, composting and energy recovery;
4 disposal - landfill or incineration without energy recovery.
First Priority: Reduction of Waste at Source
In manufacturing, technological and design improvements can reduce raw material waste, improve product lifetime and reduce the use of energy and packaging materials. In commerce, improved office procedures can reduce the use of paper and other consumables.
Second Priority: Re-Use
Some products can be designed to be used several times for the same function (e.g. refillable bottles, wooden pallets, retreaded tyres). In other cases a product might find a second use after it has fulfilled its primary function (e.g. use of old tyres as boat fenders).
Third Priority: Recovery
Recycling, composting and energy recovery are three options which allow value to be recovered from waste.
In London, there is an additional layer of control in that the Mayor will publish a “Municipal Waste Management Strategy”. He has the power to give directions to waste collection or waste disposal authorities requiring them to exercise their functions in a particular way and a power to direct refusal of planning permission for applications of strategic importance, which will include
Waste installations.
3. The Environment Agency
In addition to requiring planning permission, waste to energy processes will require IPPC consent issued by the Environment Agency. Although it is an emanation of the State and a Government agency reporting directly to the Deputy Prime Minister, the Environment Agency has its own agenda as “guardian of the environment”. In deciding whether to authorize waste processes, and what conditions to impose, the Environment Agency will consider what is, overall, the best practicable environmental option, and will now insist upon the adoption of BAT (Best Available Techniques), rather than BATNEEC (Best Available Techniques Not Entailing Excessive Costs), as was previously the case under IPC.
The Environment Agency is unlikely to have regard to the overall environmental benefits of waste to energy in terms of the reduction in fossil fuel use which occurs when waste derived fuel is used as a substitute, and will allow no relaxation of emission limits to enable those benefits to come forward.
The Environment Agency's responsibility established under the Environment Act 1995, is the protection of the environment by the limitation of emissions, and they are unlikely to be distracted into looking at the bigger picture”.
4. Human Rights
When making planning decisions, local planning authorities will take into account all material considerations, not just government policy, whilst planning remains a political process in this country. The voices of local objectors (council taxpayers and voters) are likely to stand out. The coming into force, in October 2000, of the Human Rights Act, which incorporates the European Convention on Human Rights into domestic law, will enable residents and environmental groups to stop developments. The first round of cases examining the Human Rights Act have looked at the planning system, and in particular, whether the Secretary of State, when deciding cases which he has called-in for his own determination, can sit as both judge and jury of his own policies, especially where the State has an interest in the outcome. The planning system has been given the all clear, but
on the basis that individual decisions may be challenged in the Court.
Provisions likely to benefit objections are Article 6 (right to a fair trial) and Article 8 (right to respect for private and family life). These Articles of the European Convention on Human Rights are now incorporated into domestic law, and decisions of the European Court of Human Rights must be taken into account by English judges.
Relevant case law.
R (on the application of Holding and Barnes plc) v Secretary of State for the Environment, Transport and the Regions
R (on the application of Alconbury Developments Ltd) v Secretary of State for the Environment, Transport and the Regions
R (on the application of Legal and General Assurance Society Ltd) v Secretary of State for the Environment, Transport and the Regions, Judgment - House of Lords, 9 May 2001
LAND & CONTAMINATION
In the environmental statement for the Bernard road site it was described as "potentially contaminated." Under Part IIA of the Environmental Protection Act 1990, the statutory definition of contaminated land is:
"Land which appears to the local authority in whose area it is situated to be in such a condition, by reason of substances in, on or under the land, that -
"(a) Significant harm is being caused or there is a significant possibility of such harm being caused; or
"(b) pollution of controlled waters is being, or is likely to be, caused." (DETR Circular 02/2000)
RABID argues that tier 1 assessment wasn’t sufficient to establish whether the site was contaminated, to what level and therefore the need for suitable remediation to ensure the site is made suitable for acquisition and redevelopment. Source-pathway-receptor issues were only given superficial consideration and potential risks to residents; people employed near the site and anyone in its vicinity are not assessed adequately.
For example:
Section 6.23 of the Environmental Statement (ES) shows that lead in borehole tests was above United States Environmental Protection Agency (USEPA) screening guidelines. Figures recorded were 400mg/kg (micrograms per kilogramme) at ground level (?) and 899.5 mg/kg at a depth of 0.6 metres (m.)
Bunding issues are relevant here as the site at Bernard Rd doesn’t have adequate precautions in place, migration of these chemicals into controlled waters are of particular concern.
6.25 shows Mercury at 0.05mg/l (milligrams per litre?) which is 50 times environmental quality standards.
The size of the new incinerator building is of major concern. Its height is 44metres, which makes it not an insignificant blot on the landscape. The drawings available in the planning application do not give a true representation of its immensity.
6. Air Quality.
It is not necessary to go into very much detail on the process involved in MSW incineration, safe to say that apart from heat and power, both bottom and fly ashes are produced. Along with these, gaseous releases are made into the local environment from the chimney. Our concerns are that the health effects of the release of toxic pollutants are not fully understood.
The main pollutants of concern are dioxins, acid gases (So2 etc), nitrogen dioxides, heavy metals (including cadmium, lead and mercury) and particulates. These are present in the bottom ash, fly ash and combustion gases.
Air quality monitoring in the area around Bernard road is not sufficient to give a relevant baseline on which to base the assessments used by Onyx in their proposal. Baseline Environmental Assessment is an evaluation of environmental conditions which exist at a facility at the time of purchase, occupancy, or foreclosure that reasonably defines the existing conditions and circumstance at the facility so that in the event of a subsequent release, there is a means of distinguishing the new release from existing contamination.
The environmental baseline around the proximity of Bernard road is constantly changing. Onyx bases their assessment on arguably out of date statistics from the Leeds (1993-96) and Finningley (1991-94) meteorological stations. This fails to provide sufficient up-to-date modelling of conditions in the area. RABID argues that this doesn’t meet the essence of section 78A(2) of the Environmental Protection Act 1990, which states “Significant harm is being caused or there is significant possibility of such harm being caused”.
7. Health Impacts
It is the presence of these pollutants in the gases emitted from the MSWI chimney that are our primary concern. Dioxin is suspected of causing cancers and birth defects. Acid gases and particulates can harm people with respiratory illness and those more susceptible to these such as the elderly, asthmatic and very young.
A report from the Department of Health’s committee on the Medical Effects of Air Pollution (COMEAP) concluded that PM10 pollution of urban areas (ultrafine particles of less than 10 millionths of a metre, 10 microns) hastens 8,100 deaths/yr and increases hospital admissions by 10,500/yr.
CANCER AND HEALTH - Emissions from "state of the art incinerators" contain Dioxins, Furans (Toxic chemicals) and Heavy Metals, which can cause cancer. Researchers in Britain have found elevated incidents of cancer in the lung, stomach, larynx and bladder within 7.5km of some incinerators. Other health hazards include altered sexual development, male and female reproduction problems, suppression of the immune system, diabetes and a wide range of hormonal effects. Airborne particulates: Total suspended particulate matter found in the atmosphere as solid particles or liquid droplets, including windblown dust, emissions from industrial processes. These effects can be experienced for up to 30 miles or more.
DIOXINS IN OUR FOOD - Dioxins accumulate in fats - meat, poultry, milk and even a nursing mother's milk. Dioxins get into the food chain from air emissions from the incinerator; they can spread up to 30 miles from the incinerator through wind currents and rain down through precipitation. They land on vegetation, animals eat the vegetation, the dioxins accumulate in the fatty tissue of the animals, we eat the animals or their produce (cheese, milk, ice cream, yoghurts, etc.).
You'll recall how Belgian food products were taken off our supermarket shelves in summer 1999. Their food industry was almost destroyed by just 1g of dioxin contaminating animal feeds. Should we take this risk? Dangerous doses of dioxin are measured in just trillionths of a gramme. For that reason, it is both difficult and expensive to measure, with few laboratories worldwide having the necessary equipment and skills to detect it. An incinerator will operate all day every day. Unfortunately, no monitoring system exists to detect breaches of dioxin limits as they happen Thus; there will be crucial delays between sampling and analysis.
TOXIC ASH - some 25-30% by weight of what goes into the incinerator comes out as hazardous ash. In particular 5% of what goes in comes out as highly toxic flue ash. Toxic chemicals in this ash include Dioxins, Lead, Cadmium, Arsenic, Mercury and Chromium.
In Newcastle upon Tyne, UK, residents have been warned to avoid eating any vegetables grown in allotments because ash from a nearby incinerator was used to build pathways through them. After local residents had complained, dioxins and heavy metals were measured and found to be up to 800 times above safety levels (The Guardian 26.5.2000).
LANDFILL - The transport of ash to Parkwood. Accidental spills on site or leaks during transport, or the loading and unloading of these vehicles all present the chance of an accidental release of these toxic elements into the environment. Toxic dumps are the natural consequence of incineration. Much more dioxin will leave the incinerator as ash than through emissions. Toxic Lead, Cadmium, Arsenic and Mercury will forever leach out gradually from where they are dumped. To date, there are no facilities for the safe long-term storage of toxic ash from incinerators.
OTHER RISKS - There is also the risk of dioxin releases from accidental fires or explosions.
WEALTH - Devaluation in Property Values, as well as houses, businesses could also suffer due to their proximity to an incinerator. The incinerator planned for Sheffield will cost £40 million. On top of this, there are running costs, and a profit margin. The burden of paying for this monster will have to be carried by us.
GREENHOUSE GASES - It is hypocritical to promote smokeless solid fuel, lead free petrol and no smoking public areas, all in the interests of public health, while at the same time promoting incineration, whose emissions will contribute to greenhouse gases.
8. Land Use for Incineration.
Certain general employment uses (within Class B2 General Industry) may have a substantial environmental impact or be potentially hazardous to health or life and, therefore, need to be located away from sensitive areas, for example, housing or areas that attract large numbers of people. Such use should not inhibit development of nearby land. The degree of potential impact on nearby areas depends on the nature of the proposed use.
There are schools and housing nearby, and an incinerator is likely to inhibit future development of nearby land.
9. AN ALTERNATIVE TO INCINERATION.
Whether rubbish is buried in its primary state, compacted or concentrated in its toxicity by incineration (when the process is working properly) it is not the answer to responsible waste management. Ultimately the local planning authority carries the responsibility for ethical disposal of the city’s waste. RABID will try (very hard and determinedly) to persuade them to adopt a zero waste strategy through our Citizens Resource Recovery Strategy (CRRS).
In the initial tender process the opportunity for waste management in Sheffield there was very little incentive for alternatives to incineration. The structure of the tender gave very high weighting for the inclusion of incineration in any waste management option.
When Onyx gave consideration to alternatives to use of the Bernard road site the main criteria was for the combination of combined heat and power operation to be intrinsically linked with access to the district heating network, this is biased and reduces the opportunity for a different site. Air quality issues were last on the list for alternative sites. The site at Bernard road to all intents and purposes is in an air quality management zone and will have a significant affect on this.
The Yorkshire and Humber regional energy forum makes to reference to the potential contribution of electricity generation from Sheffield. The energy generation characteristics of the plant, when assessed against its potential to harm the environment are insignificant in a regional context and concerns over the plants potential harm to the environment and the people of Sheffield locally make it an unnecessary burden.
RABID request that the planning authority gives the maximum regard to the high level of opposition from the people of Sheffield to the proposal to build the new incinerator at Bernard road.
RABID Residents Against Bernard Road Incinerator Dust