The proposed Capel Incinerator

Fact Sheet on

Transport Issues beyond the direct vicinity of the site

Points Drawn from the applicant's Environmental Statement

Heavy Goods Vehicle movements are expected to average 50 trips a day from 2012. 32 of the trips will be on 22 tonne heavy good vehicles and 18 trips will be on 9 tonne refuse collection vehicles. In 2012 78% of the waste is expected to be sourced from the Slyfield Waste Transfer Station near Guildford . Heavy goods vehicles will therefore make a significant number of trips from the Slyfield WTS. The longest distance to Capel would be via the A3, M25 and A24, and this now is the proposed route although in the Environmental Assessment earlier this year the proposed route was to be the shortest available route which is eastbound on the A25 ultimately picking up the A24, close to Dorking.

From 2013 the bulk of the waste is now expected to emanate from the Epsom WTS.

Points drawn from expert evidence provided to CAG on Transport

The two most sustainable sites (out of eight that were considered) for a waste disposal facility are those located at the existing Waste Transfer sites at Charlton Lane, Shepperton and at Slyfield, owing to the majority of the required waste already being at the sites, and not needing to be transported elsewhere.

By far the least sustainable site is the Clockhouse site at Capel. This is not surprising owing to the site being located remote from the bulk of Surrey 's waste arisings.

The Proximity Principle – points drawn from Counsel's closing remarks at the Examination in Public on behalf of the Capel Action Group

A fundamental element of the unsoundness of the allocation of Clockhouse in policy terms is the assessment of its locational sustainability. The position can now be summarised as follows:

• Surrey County Council (SCC) has conceded that it did not carry out any assessment of the allocation of Clockhouse by reference to the proximity principle as expressed in PPS10 “that waste should be disposed of in the nearest appropriate installation.”
• SCC accepts that the Clockhouse site is remote and far away from the main urban locations.
• SCC has not carried out any comparative assessment of the sites it considered in terms of transport suitability.

The “proximity principle” remains a fundamental principle of European, and hence domestic law. It is a central objective and is obligatory. The failure to consider the Clockhouse site, or assess its allocation, by reference to this principle is fatal to the soundness of the plan.

If one applies the proximity principle, and treats it as an objective, it is clear that the Clockhouse allocation conflicts with it.

Additional points that can be made in letters

• If any of the trips from Slyfield Waste Transfer station were to be via the A25 22 tonne heavy goods vehicles would go through the villages of Gomshall, Abinger Hammer, Wotton and Westcott before reaching the vicinity of Dorking. The A25 is narrow and winding, with steep gradients, for much of this stretch of road and is accordingly wholly unsuitable for vehicles of this size and weight.
• Clay extraction is permitted and can be expected to continue at the Clockhouse site for many years to come. If an incinerator were to be built there is every prospect that landfilling would have to resume once again at some future date. This would serve to compound the traffic problems around the County even further.
• Given that the Clockhouse site is the least sustainable site in terms of transport (and associated pollution) its allocation for an incinerator clearly contravenes the Proximity Principle, which requires waste to be disposed of in the nearest appropriate installation.