Write now to Surrey County Council objecting to the Planning Applications for an incinerator at Capel

Write to:

Ms Hilary Herbert
Planning Manager
Surrey County Council
County Hall
Penrhyn Road
Kingston upon Thames
Surrey

KT1 2DN

There are three planning applications:

(1) Ref 2007/0605/SW/MO07/1949 Energy from Waste Proposal (incinerator)

(2) Ref 2007/0607/SW/MO07/1950 New lagoon

(3) Ref 2007/0608/SW/MO07/1951 Variation to working programme

Please object in writing to all three, quoting the relevant reference no. It is sufficient for the letters on the second and third applications to say that you are objecting to the proposal for an incinerator and without an incinerator the second and third applications are unnecessary.

Grounds to object to the incinerator proposal include:

• Incineration is the wrong technology
  Incineration is an old and outdated technology, posing serious risks to human health. European experience is already turning against incineration as the best form of residual waste disposal. Surrey is achieving increasing levels of recycling which should be able to be improved significantly further and reduce residual waste. Other forms of technology such as Anaerobic Digestion, Mechanical Biological Treatment, Autoclaving and Plasma Gasification are coming forward as better final disposal alternatives. Although some of these technologies may involve some continuing landfill, in the same way as incineration, it is acknowledged in the Inspectors' Report that “there is no dispute that in Surrey there is a substantial supply of mineral void space, offering landfill as an alternative to more favoured processes”.
  
  •  “Preferred Status” no longer exists
  The planning applications rely on the “preferred status” of the Clockhouse Brickworks site in Capel. As the Inspectors have removed the “Preferred” status the Capel site is now just 1 of 5 five sites, on an equal basis. Any planning application must therefore make the case for Capel on a comparative basis. The planning application utterly fails to do this.
  

• Planning Status of the site
  The Waste Plan clearly states that when allocating sites for waste facilities – “priority is to be given to industrial/employment sites, particularly those in urban areas, and to any other suitable urban sites and then to sites close to urban areas and to sites easily accessible by the strategic road network”. Then “ priority is to be given over greenfield land to previously developed land, contaminated, derelict or disturbed land, redundant agricultural buildings and their curtilages, mineral workings and land in waste management use”.
  
  The applicant has wrongly designated the site as previously developed land rather than recognising its correct status as an entirely greenfield site and because of this fundamental error has made no attempt to justify its selection for an incinerator ahead of the four other allocated sites, which all are likely to be more appropriate sites.
  
  •  “Proximity Principle”
  The planning applications fail to apply the “proximity principle”, because the applicant, in cohorts with Surrey County Council, believes that the “proximity principle” no longer exists. Under EU law the “proximity principle” remains as alive and valid now as it did when the previous planning application was quashed in 2002. Incineration amounts to disposal of waste and is expressly defined in the European Directive 2006 as the thermal treatment of waste with or without combustion for recovering energy. Not by any stretch of the imagination can Capel be considered the most proximate site to waste arisings in the County. In fact it is the worst located of the five sites that are now allocated for thermal treatment in the Waste Plan.
  
  •  Traffic and safety
  The site is accessed from the A24 where it is single carriageway and just past a series of notorious double white line bends with a bad accident record. Although proposals to improve this stretch of road have been brought forward since 1960, no proposals have ever reached fruition and there is no likelihood of improvements being made in the foreseeable future. It is difficult to imagine a more hazardous approach to a site being used by massive vehicles. In addition, the most direct routes from major towns producing waste in Surrey will pass along similar single carriageway roads, particularly the A25. It will not be possible to produce enforceable planning conditions relating to the roads to be used in bringing waste to the site.
  
  •  Health Impacts
  At a Capel Village meeting held on 24 May 2006 Councillor David Munro claimed that modern mass-burn incinerators were clean and as such no longer required chimney stacks. It is now common ground amongst all the parties concerned that incinerators produce PM 2.5 particulates. According to The World Health Organisation:
  
  “ there is no safe lower limit below which particulate matter does not have an adverse impact on health”
  
  This truth is widely accepted. The US Environmental Protection Agency, the European Union and Defra all recognise that PM 2.5s adversely affect health. Independent evidence indicates that PM 2.5s produced by an incinerator at Capel will affect all communities within a 16 mile radius of the Capel site.
  
  A mass-burn incinerator should not be permitted at Capel nor indeed anywhere.
  
  •  Impact from aircraft landing at Gatwick Airport
  T he Capel Site area lies, for all practical purposes, beneath the flight path to Gatwick Airport and there is no dispute that the vortices shed by passing aircraft on final approach would descend to the ground. There will be interaction between wingtip vortices and the plume from the proposed incinerator, when landing aircraft pass directly over it on their way to Gatwick airport. Evidence shows that the vortices would suck in pollutants (including PM 2.5 s) from the plume (acting like a whirlpool) during their descent to the ground.
  
  This will pose totally unacceptable health risks to those working and living in and around the site.
  
  •  Impact on Farming
  Pollutants emitted by an incinerator, exacerbated by aircraft vortices, are likely to pollute farmland to such an extent that it may well prove to be unusable for human and/or animal food production. No account appears to have been taken of the implications of this for the surrounding farms, which are at the start of the food chain.

• Visual Impact
  The site is located in a beautiful part of the county and the County Council's own professional advisor stated that the site should be rejected for such a facility on landscape and visual impact grounds. The Inspectors added to this when saying “we therefore consider that waste development on the allocated site would adversely affect landscape character and, notwithstanding the potential for an imaginative design for the building, the stack associated with an EfW facility in particular, would be visible over a wide area.”
  
  There can be no doubt whatsoever that the site should be rejected in terms of landscape and visual impact.