Warrington Clinical Waste Treatment Centre Appeal Proposed Outline Evidence of Alan Watson

9. Environmental Statement

435. 
     The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 set out at Paragraph 4 in Part 1 of Schedule 4 the issues which are required to be included in an environmental statement as a description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development.
     
436. 
     The Environmental Statement does not adequately address a number of secondary, indirect, cumulative and negative effects of the proposed incinerator including, inter alia:
     

• the indirect impacts associated with treatment and disposal of residues from the proposed incinerator, including bottom ash and air pollution control residues.

• the direct impacts associated with electrical connection from the incinerator to the national electricity grid.

• the secondary effects of long-range air pollution impacts associated with the emissions from the proposed incinerator

• the potential direct and indirect impacts on local groundwater - either from groundwater pumping resulting in the release of historical contaminants as described previously by WS Atkins (as consultants to GCC and the Environment Agency) or from leakage from the waste pit into groundwater.

• the secondary impacts on recycling and waste reduction

• the cumulative effects of the proposed incinerator taken together with the already consented gasifier at Moreton Valence thus giving a combined capacity of up to 220,000 per year

• the applicant's failure to carry out appropriate assessments of the combined impact of the proposed incinerator with the incinerator at Moreton Valence which already has planning permission.

• the potential impacts on groundwater both as identified by WS Atkins as consultants to Gloucestershire County Council acting as Lead Local Flood Authority and in relation to the longer term impacts of leaching from the incinerator waste bunker which will be excavated to 13m below ground level.

• the failure to properly assess the impact of the proposed scheme on the migration and activity of greater horseshoe bats as highlighted, for example, by the ecological experts appointed by GCC.

• Additional impacts which may be associated with aviation warning lights.

437. 
     In each case it is important to satisfy the requirements of the regulations to ensure that before granting “development consent” for projects the environmental impact assessment procedure should be completed.
     
438. 
     Following the Inspector’s comments at the pre-inquiry meeting these issues will be addressed in submission in relation to the facts rather than as substantive evidence.
     

Annexes

36.Annex 1: The WS2007 “One Planet Goal”:

439. 
     The “one planet goal” in WS2007 is a vital one but receives a surprisingly small amount of attention.
     
440. 
     Achieving the “one planet goal” means reducing the ecological footprint of to a ‘fair earthshare’ of approximately 1.8¹⁴⁶ global hectares/capita from the 2004 national average of 5.63 global hectares/capita¹⁴⁷.
     
441. 
     The per capita ‘fair earthshare’ obviously reduces with increasing global population thus if a target date is taken for 2050, as proposed for Wales, then it means that not only is it accepted that we will be living unsustainability and inequitably for the next forty years, but also that much lower target should be set that reflect the likely ‘fair earthshare’ at the target date.
     
442. 
     Whilst it took from our emergence as a species to about 1820 to reach a population of one billion an additional billion is added to our current total of 6.6 billion every 14 years (Johns 2009). The global population is therefore anticipated to increase to between 7.3 and c.10.7 billion in 2050 (Heinberg 2007):
     

443. 
     The consequence is that rather than a target of 1.8 gha/capita a target level for 2050 should be set at 1.03 to 1.48 gha/capita. Obviously the future target date makes a significant difference to the levels of environmental impact and waste reduction required to achieve a ‘fair earthshare’.
     
444. 
     Whilst this Ecological Footprint approach has been criticised¹⁴⁸ it is included in the strategy as a headline indicator and it provides a useful indication of the scale of the problems related to carrying capacity. The indicator is most effective, meaningful and robust at aggregate levels (as used here) rather than sub-regional breakdowns and it can provide a very useful guide as to how effective policy proposals may be at achieving sustainable outcomes.
     
445. 
     The Ecological Footprint approach does not remove the need for consideration of climate change independently and these linkages are addressed in more detail in the Climate change section of this report.
     
446. 
     A report by consultants Arup assesses the ecological footprint associated with the waste strategy (Arup for Welsh Assembly Government 2009). This report emphasised that to be able to significantly reduce the size of the ecological footprint “it is fundamental that recycling becomes an option for waste management only after reduction and reuse” (emphasis in the original).
     
447. 
     The Arup report shows that with recycling alone, even at the relatively high rates proposed in Wales, as noted above, the total impact of waste arising will only be reduced by 10% for municipal waste, 6% for commercial and industrial waste and 14% for construction and demolition waste, based on a 2007 baseline. This is best illustrated graphically and the figure below, taken from the Arup report, shows how even 70% recycling by 2025 fails to meet even the trajectory necessary to achieve the current 2050 ecological footprint target unless accompanied by very significant waste reduction:
     

1. 
   Furthermore this report confirms “although the proposed recycling targets will help to reduce the EF [Ecological Footprint] of waste that can be recycled, research suggests that high statutory recycling targets can lead to local authorities focussing on recycling at the expense of waste prevention.”
   
2. 
   The ARUP report concludes with “numerous recommendations” for WAG and highlights “some overarching themes that need to be addressed” including:
   

1. 
   Linking waste policy with policy on design, production and retailing in a coordinated way across particular products.
   
2. 
   Addressing behaviour change and prioritising awareness raising activities that link consumption and purchasing activities to waste
   
3. 
   Making the business case for waste prevention by sharing the limitations on what recycling can achieve. This needs to be coupled with sharing best practice and what can be done in terms of waste prevention.
   
4. 
   Ensuring that recycling is as effective as it can be e.g. by ensuring that waste segregation is carried out and supporting the infrastructure for closed loop recycling.
   
5. 
   The public sector leading by example through procurement policy and action, and supplier development.
   
6. 
   Achieving waste minimisation across all waste streams and materials will not be easy. Monitoring and measuring progress, the report says, will be vital to success and is dependent upon the collection of robust data.
   
7. 
   Current data for C&D and C&I waste is piecemeal and therefore the WAG should consider putting time and effort into developing a consistent methodology for regular and consistent waste data collection.
   

450. 
     Crucially the report also recommended :
     

“WAG set targets to reduce both the total volume of waste arising in the municipal waste stream and the total volume of household waste generated per capita” (bold emphasis in original).

451. 
     The graph in the report clearly shows the scale of mismatch between a 70% recycling target and the “one planet” goals without the recommended waste reduction targets:
     

1. 
   Achieving ‘one planet’ even by 2050 would certainly be challenging – but this would be a completely inadequate response to the global environmental challenges that we currently face. We have seen large changes in the targets set for waste management since 1995 when the Government suggested the aspirational 25% in “Making Waste Work”. There is every reason to believe that the targets will change even more profoundly in the near future as the scale of the challenges we face are increasingly recognised and addressed.
   
2. 
   The consequences of considering the WS20007 “One Planet Target” in relation to this application is that the higher levels of recycling (>70%) envisaged by the Waste Core Strategy but ignored by the appellant will be absolutely necessary.
   
3. 
   Furthermore that recycling target must be complemented by large reductions in the total quantity of waste produced . The Wales waste strategy consultation shows that to reduce the Ecological Footprint to even 1.8 g/ha capita at current population levels will require a further reduction in the footprint, on top of the 70% recycling targets, of:
   

1. 
   Municipal waste - 34% by 2025 and 65% by 2050.
   
2. 
   Commercial and Industrial waste - 39% by 2025 and 69% by 2050
   
3. 
   Construction and Demolition waste - 28% by 2025 and 59% by 2050
   

455. 
     It is obvious that flexibility of future waste management options is the key if there is to be any prospect of achieving the necessary policy goals. The currently proposed incinerator represents an excessively large plant that would provide a substantial impediment to delivering even the higher recycling levels – and is completely incompatible with the levels of waste reduction that are necessary to achieve the WS2007 goals.