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Letter to Michael Gove regarding the Westbury Incinerator

March 15, 2022 8:53 PM
By Ellen Nicholson

The very disappointing Environment Agency briefing on the Northacre Renewable Energy Ltd (NREL) this week stating that they may consider allowing NREL a permit to operate the Waste incinerator in Westbury crossed with our letter to the Secretary of State, Michael Gove MP

The text from our letter is laid out below:

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To the Rt Hon Michael Gove MP
Secretary of State for Levelling Up, Housing and Communities

Saturday 12th March 2022

Dear Rt Hon Michael Gove MP

We are writing to you on behalf of residents in Westbury and the surrounding areas of the South West Wiltshire constituency regarding planning number: 20/06775/WCM submitted to Wiltshire Council by Northacre Renewable Energy Ltd (NREL) for a proposed incinerator in Westbury, Wiltshire.

The application was opposed by Westbury Town Council and 17 other local councils, and wide spread objections across the political parties and residents from towns and villages across the region.

It has been a year since we wrote to your predecessor requesting, they 'call in the application for further scrutiny' and over eight months since Wiltshire Council's strategic planning committee approved the application.

Our reasons for objection were multiple and listed below for reference:

  • Town Infrastructure: the estimated traffic disruption caused by the planning application is underestimated. Westbury does not have a by-pass and the increased traffic from the haulage lorries along the A350 would cause considerable congestion to the town centre, through traffic and residents. This is a small market town not an industrial site and the extra traffic will push the town's infrastructure to breaking point.

  • Westbury is one of 8 Council designated 'Air Quality Management Areas for nitrogen dioxide. Wiltshire Council have a duty of care to protect its residents from adverse effects of air pollution, in particular particulate matter of PM10 and less. Little is known yet about the adverse effects of minute particulate matter but considering the government announced record investment in ensuring the UK is reducing carbon emissions and pollution by 2050, the incinerator is a step in the wrong direction.

  • The incinerator would be built close to the Arla Foods UK dairy factory on the Northacre Industrial Estate in Westbury. Arla Foods UK objected to the application and have stressed there is a risk that when the NREL facility is built it will contaminate the clean air that Arla needs for its production processes. Arla have said that if the air and products are contaminated, they will need to shut down production at a cost of thousands of pounds per hour.
  • The Design and visual impact. The incinerator is bigger in size than Arla. The proposed stack is 20m higher than Wells Cathedral and will visually impact on the landscape and overall character of the historical town.

  • The proposed operating times take little account of the proximity of the town, or current and proposed residential developments. Continuous lorries between 7am -10pm on working days and on a Saturday from 7am - 5pm is completely unacceptable levels of vehicle activity, noise pollution and emissions when considering the sites proximity to residential houses and the town.

  • An 'environmental justice' issue may apply, populations most vulnerable find themselves with an incinerator located in their area. This may correlate that Westbury is highest in the county for cancer and second for cardiovascular disease regarding mortality in those aged under 75 years.

  • Whilst Hills have stated a benefit to the local economy, this is likely to be overstated and the proposed site will be a low-density employer - few people employed per hectare, with fewer people employed than in the local supermarkets of Lidl and Aldi.
  • It was asserted in the planning application that greenhouse gas emissions from moving grate incineration are lower than landfill because it takes much longer for waste to breakdown. However, that claim disguises the fact that moving grate incinerators consume far greater levels of energy and therefore release far greater volumes of emissions in the short term than landfill; and conveniently omits the fact that most incinerators are often given extended lives and that non biogenic waste material in landfill does not break down or cause emission.
  • A study by zero waste Scotland into the "Climate change impacts of burning municipal waste in Scotland", published in October 2020, concluded that in terms of carbon intensity, EfW incinerators can no longer be considered a low carbon This is because their carbon intensities [as electricity generators or CHP or both], are above the marginal average at 509 gCO2e/kWh. It is however acknowledged that results as ever depend on the exact composition of residual municipal waste. Nevertheless, we contend that these conclusions are in line with current trends.

Zero Waste Scotland - The climate change impacts of burning municipal waste in Scotland - a summary report October 2020.

  • Moving grate incineration discourages and disincentives innovations in recycling industrial technologies or the emergence of sustainable recycle, reuse, repurpose markets as they consume significant waste volumes a practice hardly consistent with recent COP26 outcomes.
  • Controversially, moving grate incineration was considered most suitable for developing countries because of its capacity to consumed vast quantities of waste that would otherwise go to landfill. No such claim is made regarding developed countries where economies are much more diverse with multiple contributions to emissions and where air quality regulations are much tighter. A highly discriminatory practice that should not be replicated in Westbury.

As the Environment Secretary in 2019 you launched a strategy to "clean up our air and save lives". At the launch you stated that "air pollution is one of the biggest threats to public health in the UK - behind only cancer, obesity and heart disease" and promised that the Government would set an ambitious, long-term target to reduce people's exposure to particulate matter, which the World Health Organisation has identified as the most damaging pollutant.

With the findings from the latest Intergovernmental panel of climate change (IPCC) report on the 28th of February 2022, which noted that human-induced climate change is already causing dangerous and wide spread disruption in nature and already affecting the lives of billions of people around the world, despite efforts to reduce the risks. The chair of the IPCC, Hoesung Lee said that our actions today will shape how people adapt and nature responds to increasing climate risks, we would ask that you call in this application for scrutiny and provide us with an indication of when a decision might be made.

To conclude, we request that in your role as Secretary of State for Levelling Up, Housing and Communities, call in the application for further scrutiny and reversal of the Wiltshire Council strategic planning committee decision. Should you wish to visit the site prior to your decision, we would be pleased to meet with you alongside other stakeholders.

Yours Sincerely

Cllr Gordon King, Wiltshire Councillor for Westbury East

Ellen Nicholson, Liberal Democrat Spokesperson for South West Wiltshire

Cllr Carole King, Wiltshire Councillor for Westbury North