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

9.Renewable Energy

1. 
   The UBB SoC says: “National energy policy and strategy is unambiguous and unswerving in the need to deploy as much renewable energy as possible, as soon as possible, with statutory minimum targets for renewable electricity as a proportion of overall electricity supply of 10% in 2010 and 15% in 2020”.
   
2. 
   The source of the claim relating to the statutory minimum contribution of 10% in 2010 and 15% in 2020 by renewable energy to the overall electricity supply is unclear.
   
3. 
   There is no doubt, however, that the proportion of renewable energy will exceed 15% of the electricity supply well before 2020.
   
4. 
   The Renewable Energy Strategy⁴⁰ 2009 and the Overarching National Policy Statement for Energy⁴¹ (EN-1) confirm that the UK has committed itself to sourcing 15% of its total energy (across the sectors of transport, electricity and heat) from renewable sources by 2020. Projections suggest that by 2020, about 30% or more of our electricity generation will be from renewables⁴².
   

10.Landscape and visual Impact.

102. 
     XX
     

4. Landscape and Visual Impacts

103. 
     The evidence for GlosVAIN on landscape and visual impacts is included in evidence of Juliet Bailey. I am also aware that other parties including the WPA, Stroud District Council, the CPRE and the Cotswold Conservation Board intend to present evidence on the harm to the landscape and countryside including the visual impacts. The evidence presented by GlosVAIN on this issue has therefore been truncated in an effort to reduce duplication of evidence so far as possible and thus to save inquiry time.
     
104. 
     The appeal site lies within the Vale of Berkeley, part of the valley of the River Severn. The topography is defined by the very flat, low-lying valley bottom landform, a strong rural character with an emphasis on agricultural management and with few obvious landmark features.
     
105. 
     The appellant over-optimistically contends that the design provides a cohesive and functional form with the fragmented roofscape helping to 'contain' it's mass and integrate the design with the surrounding geography and topography and breaks up the mass and line of the building from distant viewpoints. The photomontages presented in the GlosVAIN evidence show the massive bulk of the proposal, combined with the excessive height of the buildings and the stack represent incongruous feature in the landscape which cannot be screened or acceptably integrated. Rather than ‘containing’ the mass of the building the overriding visual impression is of an accident in a box factory with the disjointed rood line and awkward asymmetry of the building along the major axis exacerbating the effect of clutter and disorder.
     
106. 
     The Inspector’s report from the WCS EIP raised particular concerns in relation to the potential impact of an incinerator with a high stack on the site⁴³: “
Although the WDA’s aspirations for this site are now clear (paragraph 14) this is just one of the potential developments that could take place on the allocated site in accordance with policy WCS4. 
121. The site is very open to views from a wide area including parts of the Cotswolds Area of Outstanding Natural Beauty. There seems little doubt that a thermal treatment facility of some size will require a tall emissions stack to satisfy the requirements of the HRA process. ERM stated during the examination hearings that it would generally be possible to design a pollution control system to avoid any adverse effect on the integrity of a European site. The issue at Javelin Park is how that solution would interplay with the landscape and visual impact of the resulting development design. In this context, I note that previous planning permissions at the site have limited by condition the height of any buildings to around 16m.
     
107. 
     And at §125:
     
108. 
     “At both Javelin Park and Moreton Valence the accommodation of any substantial built development that needs to include an emissions stack of any significant height would, in my opinion, present the designers with a challenge in the distinctive landscape context. Whichever of the two sites was developed first would then, in my view, pose an even greater challenge for the development of the other when the cumulative impact came to be assessed against policy WCS7.
     
109. 
     The proposed incinerator is clearly enormous when compared with prominent local landmarks, dwarfing even Gloucester Cathedral and being completely out of scale with the local church – St Peter’s in Haresfield, itself a prominent, though attractive, local feature.
     

110. 
     This impact would be compounded by the impacts of the visible plume which would be visible for up to 3.5 hours during the day⁴⁴ and which the appellant accepts would:
     

• be visible for approximately 20% of daylight hours

• have an average length of around 50 m

• have a maximum length of more than 260m

111. 
     The plume is not included in any of the photomontages forming part of the application and hence the associated full visual impact of the proposal is not properly demonstrated. This is a serious omission as the plume is likely to draw the eye to the stack as well as reminding concerned residents of the potential impacts of emissions from the incinerator. GlosVAIN provided indicative photomontages as part of the earlier representations but this does not excuse the omissions from the Appellants assessment:
     

Scale image of incinerator in situ with representation of chimney plume

112. 
     The presence of such a plume only serves to emphasise the industrial nature of the facility and moreover introduces additional negative connotations in terms of factory emissions of pollution into the atmosphere. These considerations reinforce the point that the facility would be an alien feature and that no mitigation is possible. It would be a vastly disproportionately sized industrial installation, replete with factory chimney emitting a visible plume, further degrading the setting of the AONB.
     
113. 
     The plume will also extend the zone of visibility, so that it will be seen from more places and from further afield.
     
114. 
     Lighting of the stack at night is likely also to increase these visual impacts. Whilst there is currently no proposal to do this I am concerned that such lighting may be necessary due to the sensitive location of the site next to an accident hotspot on the motorway.
     
115. 
     My understanding is that away from aerodromes Article 219 of the UK Air Navigation Order applies. This Article requires that for en-route obstructions (i.e. away from aerodromes) lighting only becomes legally mandated for structures of a height of 150m or more. However, structures of lesser high might need aviation obstruction lighting if, by virtue of their location and nature, they are considered a significant navigational hazard. Routinely, structures less than 150m high and away from the immediate vicinity of an aerodrome are not routinely lit for civil aviation purposes
     
116. 
     The appellants have not included the provision for a warning light in their application but I am aware of other examples of stacks of this height having to be fitted with lights which suggests that it is prudent to assume that lights may be required – due to the M5 accident hot spot and the increasing reliance on helicopter air ambulances for such accidents.
     
117. 
     The objection made by the Cotswold Conservation Board (CCB) is endorsed in that there would be a: “major significant effect, which would be harmful to a special quality of the Cotswolds AONB – views out from the escarpment”, and also concur that the proposal is contrary to the NPPF, Policy 26 of the Gloucestershire Waste Local Plan and Policy NE8 of the Stroud Local Plan.
     
118. 
     I also note, and support, the submissions made by English Heritage on 24/04/2012 in which they state: “We have closely reviewed the information submitted with the application, focussing especially on the Environmental Statement (ES). Unfortunately, the ES appears to contain a number of factual errors, omissions or areas of doubt to the extent that we do not believe that the ES has fulfilled its primary function of informing interested parties of the scope, nature, impacts and effects of the scheme”.
     
119. 
     English Heritage also objected on the basis that: “No photomontage is included that shows the scheme in relation to the nearest Scheduled Monument or the public rights of way around the SM”
     
120. 
     They concluded: “Consequently, we are at present unable to advise you on the effects of the scheme upon the historic environment. We therefore recommend that this application is not determined until such a time as the applicants have clarified to our satisfaction what these effects might be and what mitigation measures are proposed”.
     
121. 
     Natural England’s objection is also supported: “Natural England objects to this application due to the significant adverse impacts on the special qualities of the Cotswold AONB. The proposed development would also have significant adverse impacts on the setting of the AONB, the Cotswolds National Trail and the landscape and visual amenity of the non-designated areas in the Severn Vale, all of which interact and add to the negative effects on the landscape”.
     
122. 
     As is Stroud District Council’s objection that: “The proposed development is detrimental to the character of the rural landscape by reason of its size, massing and materials. The proposal adversely affects the Severn Vale and the nearby Cotswold AONB both in terms of views from within but also views towards the Cotswold escarpment”.
     
123. 
     The Green Party’s objection is endorsed, particularly in making reference to Cotswold Conservation Board guidelines and the statements made by the Secretary of State to the extant 15.7m height limit development on the site, placed by the Secretary of State in 2007 due to concerns about visual impact. The application is for a building rising to 48m and a stack of 70m far exceeding the 15.7m limit.
     
124. 
     The overall visual impact of the proposed facility would therefore be wholly unacceptable and taken together with the earlier submissions the GlosVAIN evidence demonstrates:
     

• the adverse impact on the landscape and countryside including views from the Cotswold AONB and heritage sites showing that the application offends Development Plan policies including WCS Policy WCS14, Waste Local Plan Policy 37, Structure Plan Policies S6a, E4 and NHE1, paragraph 109 of the NPPF and Stroud District Local Plan Policies NE10 and NE8 and causes harm to interests of acknowledged importance.

• The facility would not be a "positive" "gateway" to Gloucester and the proposed design is totally out of keeping with the setting contrary to WCS Policy WCS17

• the inappropriateness of the proposal for this site as confirmed by the proposed incinerator's excessive height compared with the reasonable conditions set by a previous Secretary of State in the extant planning permission and in relation to planning refusals elsewhere in the Severn Vale.

1. 
   The Overarching National Policy Statement for Energy⁴⁵ (EN-1) states: “In sites with nationally recognised designations (Sites of Special Scientific Interest, National Nature Reserves, National Parks, the Broads, Areas of Outstanding Natural Beauty and Registered Parks and Gardens), consent for renewable energy projects should only be granted where it can be demonstrated that the objectives of designation of the area will not be compromised by the development, and any significant adverse effects on the qualities for which the area has been designated are clearly outweighed by the environmental, social and economic benefits.” I believe that this is relevant here in the light of the heavily adverse visual impacts upon the AONB.
   

11.Future Extension?

126. 
     One issue with similar incinerator proposals has been that the designs have sometimes been arranged with future expansion in mind. The logic of this is presumably that the marginal cost of extending an existing facility is much lower than of building a new incinerator, particularly where the initial cost is supported by a lucrative long-term local authority contract. Expansion and intensification is also much harder to resist in planning terms because the use of the site, and the tolerability of adverse impacts on the landscape etc. has already been established.
     
127. 
     The Javelin Park incinerator has just one line and so is particularly vulnerable to breakdown and has very limited flexibility of operation. It is also likely to require significantly more bypass directly to landfill than indicated in the application - even with the normal seasonal variability in the monthly waste arisings which vary by about 25% through the year as shown in the need section.
     
128. 
     In the case of the Javelin Park plant it is notable that there is a pronounced and visually anomalous asymmetry in the design of the incinerator and that whilst the waste pit extends across the whole of the building the grate takes just half of the width:
     

129. 
     It is unusual for a waste pit to be configured like this and the space at the side of the building looks suspiciously like it might have been left for an easy reconfiguration in the future which would add an additional line and thus double the capacity to c.380,000 tpa. This would require the movement of some ancillary equipment including the condensers but there is sufficient space at the opposite side, or elsewhere on the site, for this to be done whilst maintaining road access around the site.
     
130. 
     This can be seen on the drawing below which demonstrates how a second line might easily be added:
     

131. 
     If this is the intention of UBB – or if there is a possibility that this may be considered as an option in the future then the implications ought to be considered at this stage – not least because the current disjointed visual impact that arises from the asymmetry over this part of the structure.