INTRODUCTION

Listed down the page are lots of facts about why burning rubbish isn't good, however, let's cut right to the chase. We all fundamentally know what is right and what is wrong in terms of stopping pollution, stopping climate change and looking after our world and our health in a much better way than we have. Documentaries such as Blue Planet with Sir David Attenborough, have shown us how we need to start reducing plastic and how climate change is having a disastrous effect on nature.

 

Looking after the planet is no longer seen as a cause followed by hippies and activists, it is something that all of us recognise needs to be done. We are also becoming increasingly aware of the need to improve our air quality to protect our health. It is no longer the time for big business to ignore environmental or health issues in order to make the greatest profit. Just as tobacco companies had their day and eventually had to have their power limited, so too will waste incineration companies.

 

When are we going to recognise that this one beautiful planet, our only home, has limited resources and we can't continue as we are? When are we going to wake up and stop? Burning rubbish is not the answer. We need to get manufacturers to stop producing so much, and we need to stop consuming so much. Burning rubbish destroys resources so they can never be used again. It is not sustainable, and the process produces toxic substances that build up in our environment and reduce the quality of the air we breathe.

 

THERE ARE alternatives to incineration. We can dramatically increase our recycling levels and we can pass laws to get manufacturers to stop using materials that are difficult to recycle. This is ALREADY HAPPENING in other countries. If we build an incinerator with a massive capacity, we will need to feed it with stuff to burn. The incinerator will last for 25-35 years, and will be operating 24 hours a day, so are we seriously going to keep up these backward practices for another quarter of a century?

 

NOW IS THE TIME TO ACT AND ENSURE THAT THE PLANET'S HEALTH

AND OUR HEALTH IS PUT BEFORE PROFIT.

Use your voice, use your vote.

Tell your elected councillors and MPs what you want,

so that the next time you are watching Blue Planet,

you know you have done something to help turn things in a positive direction.

And if you are promoting waste incineration, please reflect on the legacy you are leaving behind you.

AREAS OF CONCERN:

HEALTH

The emissions from waste incinerators include toxic heavy metals and dioxins. Waste companies state that these toxins are either destroyed during incineration or filtered out, with close monitoring. However, they are only referring to particles over a certain size. Any toxins that fall beneath 2.5 microns (known as PM2.5s) are not considered, and worryingly these small particles are perhaps the most hazardous as can be absorbed directly through the skin and inhaled deeply into the lungs. 

 

The government are currently conducting a study into the effects of small particle pollution, the results of which should be published later this year. Click here to read articles from numerous organisations about health concerns surrounding incineration or small particle effects on health.

ENVIRONMENT AND POLLUTION

The term environment covers a wide range of things. It can be the local area or the planet as a whole. It can concern land, water or air. It can refer to wildlife or to plants. Click here to see articles concerning how waste incineration affects the environment, including C02 impact, local ecology and pollution.

EMISSIONS & MONITORING

The incinerator company's own contractor will be doing the emission checking, then submitting their test results to the Environment Agency themselves. This is like you or me writing our own MOT test certificate!

Oxides of Nitrogen are measured continually but other pollutants including Arsenic, Cadmium, Mercury, Chromium, Dioxins are only checked for up to 8 hours twice per year.

The Environment Agency accepts 'Modern Incinerators' can produce Dioxins many times over the permitted limit for months at a time, while deemed to be operating as "Normal".

At present, monitoring only measures toxic particles that are 10 microns in diameter or smaller, known as PM10s. But they don't look for anything smaller than PM2.5s which are a quarter of the size. The PM2.5 particles are much more dangerous as they can slip past the human body's defences and be absorbed through the skin or respiratory system. Billions of these dangerous tiny particles can be released but are not covered by any monitoring.

 

The toxins that come out of the incinerator chimney (stack) include arsenic, mercury, cadmium and dioxins, and they can accumulate in our environment over time.  Click here to read more.

TRAFFIC GENERATION

There will be an increase in HGV lorry movements to and from the plant. The incinerator will be burning rubbish 24/7 and has a capacity to burn 250,000 tonnes of rubbish a year. To meet the demand, rubbish will be imported from 12+ counties including as far away as the Isle of Wight and Yorkshire to keep the burner on track to generate returns for share holders. Furthermore, there will have to be additional lorry movements to take the bottom ash away to a hazardous waste plant for either landfill or processing.

 

Amey Cespa have so far been unable to clarify accurate traffic movements, but working with their capacity needs, CCC expects an extra 100 lorry journeys will be made each week. The additional traffic movements will add to the air pollution, noise and congestion in the area.  Amey have not reproduced their traffic impact report since recently requesting an increase of 9 counties to the preferred catchment area, and reducing the quota of waste from Cambs from 93% to 70% (meaning original traffic impact, health impact and environmental impact reports are now null and void).

BURNING THE WASTE OF 11 COUNTIES IS NOT A LOCAL SOLUTION TO LOCAL WASTE

Currently according to the developer, 94% waste treated at the Waterbeach Waste Management Park comes from Cambridgeshire's residents, 4% from Northamptonshire, and 1% from the Isle of White and Yorkshire.

 

Amey Cespa intend to continue current landfill rates of 200,000 tons per year (110,000 household waste and 90,000 other) and feeding the incinerator from day one with 250,000 tons per year.

Buried in a single paragraph on one page within the many thousands of pages of Amey Cespa's plans it states that the incinerator will have a 'local catchment area' that consists of 11 counties (Cambridgeshire and Peterborough, Milton Keynes, Hertfordshire, Suffolk, Essex, Norfolk, Luton, Bedford, Northamptonshire, Rutland and Lincolnshire.

They also state that any waste imported into those counties and then transferred here will still be considered part of the 'local catchment' - not such a local solution to local waste.

 

Furthermore, they have offered just 70% incinerator capacity (140,000 tons per year) to this ‘local catchment‘, and want to retain 30% (60,000 tons per year) for unrestricted importing which means any geography (rest of the world) and any type of non hazardous waste including burning of construction and demolition waste. 

Amey's plans show a missing 50,000 tons of incinerator capacity which it is unclear to us whether will be assigned to the not so local 'local catchment area' or 'rest of the world'.

IMPACT ON LOCAL AREA

The proposed waste incinerator is a giant industrial structure with an 80 meter tall chimney, (twice the height of Ely Cathedral and taller than Nelson's Column) which will dominate the surrounding countryside. The volume of the building will be 2-3 times the volume of Ely Cathedral. It was concluded by the developers own Landscape and Visual Impact Assessment (LVIA) and that of the county council that the incinerator creates a significant and serious impact on Ely Cathedral and Denny Abbey and the fen edge landscape. Additional important information on this was provided in the community funded independent landscape review by a nationally renowned expert in this field.  It provided even more evidence on the seriousness of the landscape impact on the Fen Edge from a number of locations and including the cathedral. It’s conclusions were largely agreed with ("Overwhelming serious and significant harm to landscape, visual and heritage") and it formed part of the solid basis as to why the county council committee by majority (7/8) objected to the incinerator.

The Fens are unique and have an intrinsic value. They are flat and rural with uninterrupted views of the wide open skies and striking landscape. If walking along the Cam / Ouse, do we want to see this massive chimney with its possible visible plume towering over the land and looming over one of the main routes into the historic town of Cambridge, where before just the majesty of Ely Cathedral stood quietly on the horizon.

The concern of the impact is very real of this huge building on the neighbouring historic setting of Denny Abbey and nearby deserted medieval village (DMV), as listed on the Sites and Monuments Record. Denny Abbey is minute compared to Ely cathedral which will itself be dwarfed, and Denny Abbey will neighbour the incinerator.  Does a promise of money and trees and new driveway from Amey Cespa mitigate an industrial power station next door to an ancient monument linked to the knights Templar? To what point do you erode this historic asset and setting and surrounding landscape so that it becomes worthless?

English Heritage states, "Denny Abbey has a unique and fascinating history, having been occupied at various times by three different monastic orders. Founded in 1159 as a Benedictine monastery, in 1170 it was taken over by the Knights Templars and used as a home for aged and infirm members of the order. After the Templars’ suppression for alleged heresy in 1308, it became a convent of Franciscan nuns known as the Poor Clares. Following the dissolution of the nunnery in 1539 by Henry VIII, it became a farm and was in use until the late 1960s." Click here to read more.

TRACK RECORD OF AMEY CESPA

Amey Cespa have already been fined £50,000 for polluting the local area and making people sick.

 

This is key to mention because all the assurances given about the safety of the proposed incinerator site and protecting the surrounding area are based on the plant being run in an exemplary manner.

"Composting site operator fined £50,000 after breaching its permit", published 21 September 2016, by the Environment Agency,

"Mr Richard Banwell, prosecuting for the Environment Agency, told District Judge Ken Sheraton: “AmeyCespa failed to implement appropriate measures until after the incident in July and the serving of three enforcement notices... The company had also failed to submit an adequate odour management plan to the Environment Agency before the July offence."

He said: “There was a history of non-compliance at the site and there was a serious effect on human senses and it was persistent enough that it led to a widespread change in behaviour of those exposed to it.”

 

“At a nearby business, staff complained of feeling sick, gagging and sore eyes and throats. Staff could not take regular outdoor breaks and sickness rates went up.”

 

In sentencing the company on 8 September 2016, District Judge Sheraton said: “There had been a great deal of adverse effects on human health, quality of life and air quality. I therefore impose a fine at the maximum of my sentencing powers.”

Click here to see the article in full.

UK waste sustainability authority (Waste and Resources Action Programme) recommends ‘against siting incinerators near residential properties and schools to minimise health and environmental risk’.

CONSULTATION AND DEMOCRACY

Many local residents and businesses have only just found out about this plan.

There has been a public meeting, 29 January, with just a week's notice of it's set-up, and no independent speakers in attendance to verify Amey Cespa's statements. A second public meeting organised by residents and CBWin took place 20th March and was boycotted by county council, Amey and regulators despite early indication they would attend to provide information.  See home page for quick links to audio recordings (in 'breaking news')

The public consultation period fell mainly over Christmas, which feels like consultation by stealth.

 

The UK is a signatory and has obligations under article 6 of the AARHUS Convention to ensure the public have the right to meaningful influence on decision making at a time when it can still make a difference to the outcome.

 

Given these proposals are literally thousands of pages long, are of a technical nature and of the utmost importance to the future of Waterbeach and Cambridge, it is completely unacceptable and, frankly, undemocratic for those of us who are not experts in this field to have so short a time to review and comment upon this information. The inadequacy of this period constitutes in itself a valid reason for approval to be withheld. 

ALTERNATIVES TO INCINERATION / RECYCLING / SUSTAINABILITY / RENEWABLE ENERGY

There ARE alternatives to burning our rubbish and good reason why we shouldn't!

The Chief Scientific Advisor to the Department for Environment, Food and Rural Affairs (Defra) warned against further investment in incinerators in the UK while speaking at a hearing of Parliament’s Environment, Food and Rural Affairs (EFRA) Committee on 31 January 2018.

 

Professor Ian Boyd co-authored the recent report ‘From Waste to Resource Productivity’, which emphasised the importance of moving away from incineration and landfill, towards a more sustainable resource use. Professor Boyd told the committee, “If there is one way of extinguishing the value in materials fast, it’s to stick it in an incinerator and burn it."

 

Prof Boyd explained how investment in incinerators can actually harm future innovation, as these facilities need to have waste streams to keep them supplied, and will continue to encourage people to throwing away what could be potentially valuable materials. 

He advised that instead, we should be investing in innovative recycling processes and ‘designing out’ waste as part of a holistic approach to resource management. His comments echo those made by the European Commission at the start of 2017, on how incineration could harm the circular economy, a stance that led the European Parliament’s Environment (ENVI) Committee to vote to phase out subsidies for EfW/incinerators.  Click here to see full article: https://resource.co/article/chief-defra-scientific-adviser-warns-incineration-investment-mayharm-innovation-12382
 

"... William Neale, a member of the European Commission's (EC) environment cabinet, says one of the problems for incinerators has been that they bind countries into burning waste rather than developing new ways to recycle. “Once you build incinerators, they are there for 50 years or so and you have to feed the monster.” Click here to see full article: https://www.theguardian.com/lifeandstyle/2014/jun/12/rubbish-futures-can-technology-help-us-reach-zero-waste

Incineration Isn't The Only Way To Generate Energy From Waste

There are many technologies available to recover energy from waste. Incineration is recognised by the EU waste management hierarchy, DEFRA, EUNOMIA and Wrap.org.uk (global expert waste think tanks) as the most polluting and least efficient method of energy recovery from waste. They recommend anaerobic digestion, composting, pyrolysis, gasification as preferred. Which is why they classify incineration at the very bottom of the EfW hierarchy, just one step above landfill. Cambridgeshire is a city renowned  for pioneering innovation and the County Council has made a commitment to the current climate emergency via the UK100 pledge-  incineration of waste is not a solution that fits this ambition at all.

CBWIN are as much about promoting recycling and investing sustainable truly renewable energy alternatives  as they are about campaigning against incineration

Landfill is certainly not the answer.  As much as landfill sites in Cambridgeshire are being utilised fast, Cambridgeshire County Council are in advanced stages of an emerging blue print Local Plan for minerals and waste that is expected to complete end 2019 (similar timing to the incinerator public inquiry.  It has been through two rounds of public consultation already. That blue print does not mention anywhere 'energy from waste' and concludes very clearly that existing waste sites, services and facilities for waste management across the county are adequate out to 2036 and foresee at this stage no difference thereafter. They have performed robust analyses looking at populations and expected developments across the county and decided there is NO NEED FOR A WASTE INCINERATOR. 

Is Incineration Really Renewable?

Officially (and oddly) the UK government classes incineration as ‘renewable’ but there is a difference between this government terminology, and the terminology accepted by leading environmental organisations and global authorities on waste.  The UK terminology and government classification benefits incinerator developers who hide behind it to green wash the very non-renewable reality of burning rubbish for energy . Renewable energy is officially a form of clean energy that is provided by natural sources present in nature. Incineration of rubbish is not renewable in this sense, it is a linear produce incinerator fuel from burning fossil fuels to making things and then burning those things process.  Incinerators require constant feed stock to achieve the profits promised to incinerator company shareholders, this requires a constant draw on fossil fuels in the form of feed stock and results in the loss of their value forever. Incinerators do not in any way contribute to the zero waste and circular economy initiatives which are so critical to protecting the climate .  More here on what renewable energy really means 

https://www.terrapass.com/10-facts-renewable-energy

But Incinerators Create Power So Climate Impact Doesn't Matter

Incinerator companies sell incinerators on the ability to power ‘local homes and businesses’ in a slightly less carbon producing way than traditional fossil fuel power sources.  It is important not to forget that fossil fuel is the constant feed stock.  Amey Cespa's plans provide for heat off take ONLY to the houses expected on the new town (which achieved outline planning in May 2019). Existing Cambridgeshire residents will not benefit from the heat produced.  Heat will be produced constantly as the developer intends to burn 24/7 for 35+ years, but the heat produced and not required in warmer months will not be captured according to the plans. 

 

The electricity produced will be connected to the main grid, it will not be ring fenced for local homes or businesses. The electricity/heat subsidies that incineration attracts from government are poor in comparison to truly renewable forms of energy generation, because it is classified as a non-recommended form of EfW,  because it uses out dated technology (a grate, fuel and a flame) .Any small subsidy that is provided is often bolted onto household energy bills, meaning the likelihood of ‘cheap energy’ for local people is slim. If the developer was to invest in a state of the art recycling centre, or truly renewable  technologies to make energy or even more preferred EfW methods (such as more anaerobic digestors) then existing residents, businesses and the new town would really benefit from tangible energy bill savings. 

IT IS possible to recycle a lot more of our rubbish

In Cambridgeshire, our recycling rates are currently getting worse not better. East Cambs managed to recycle 52.4% in 2016/17, a drop of 4% since 2015/16. South Cambs managed 46.1% 2016/17, dropping a massive 11.4% since 2015/16. Compare this to Powys in Wales who achieved 65.2% 2016/17 and is aiming for 70%.

 

The incinerator proposed for Cambridge has a giant capacity of 250,000 tonnes per year and so will need rubbish to be fuelled. There will be no incentive to improve recycling. Once burnt, that resource is gone forever, whereas recycling is limitless.

Despite what incinerator companies claim, incinerators physically can’t improve recycling rates. An incinerator can only do this if it also includes a mechanical recovery facility on site (which removes recyclables).  Where an MRF exists already the building of an incinerator does not provide additional recycling ability, it just provides a burning vessel.  Amey Cespa already have a state of the art MRF at Waterbeach Waste Management Park, and if it is working efficiently (we have no information to say it isn’t) then ALL the things that can be recycled are already being removed for recycling . This means the incinerator proposal is unable to improve Cambridgeshire's recycling rates. Improving recycling from the current 46% for Cambridgeshire, which the county council has clear aims to do, requires state of the art recycling plants and suite of projects and facilities that support households to recycle more and fill black bins less. A great opportunity for the developer and council to champion more.  Something a giant incinerator cannot make happen. 

Deposit Schemes for Plastic Bottles - "A Scandinavian deposit-based system for recycling bottles is thought likely to be adopted in the UK. Advisers to government say the schemes have massively reduced plastic litter in the environment and seas. And a ministerial delegation has been to Norway to see if the UK should copy an industry-led scheme that recycles 97% of bottles. In the UK, figures show that only around half of all plastic bottles get recycled. Norway claims to offer the most cost-efficient way of tackling plastic litter. Click here to see full article: http://www.bbc.co.uk/news/science-environment-42953038

Landfill Mining and Recycling – "Historic landfill is full of useful rubbish, buried before we had the ability or inclination to recycle it. At the Remo landfill site in Flanders, trials have been successfully conducted to show the potential for digging up old waste and separating out material we can use. Around 45% of the buried material is estimated to be reusable. Click here to see full article: https://www.theguardian.com/lifeandstyle/2014/jun/12/rubbish-futures-can-technology-help-us-reach-zero-waste

Separation and Storage – "Also being trialled at the Remo site is the separation and temporary storage of rubbish. Tom Jones from the ELMC says, “this is basically a way to store certain fractions [of waste] which are not yet recoverable today, but we do not wasn't to incinerate them today, so we want to keep them in such a way that we can recover them in the near future.”" Click here to see full article: https://www.theguardian.com/lifeandstyle/2014/jun/12/rubbish-futures-can-technology-help-us-reach-zero-waste

IT IS possible to design out waste through reducing or changing the materials we use.

"A “world first” plastic-free supermarket aisle is being unveiled in Amsterdam, prompting calls from campaigners for retailers to roll them out in the UK. More than 700 products will be available without plastic packaging in the aisle which is being set up in a new metro-sized pilot store..." Click here to see full article: http://www.independent.co.uk/news/world/europe/plastic-planet-packaging-free-supermarket-ekoplaza-amsterdam-netherlands-recycling-pollution-a8232101.html

 

 

BREXIT IMPACT ON EU DIRECTIVES ON WASTE MANAGEMENT

Incineration is considered the second worst way to manage waste (EU Waste management directive).   Eunomia (Global authority on waste management) agree and also predict saturation of UK incinerators within the next 2 years, which may explain why Amey need to import waste here from across the country and outside the UK to achieve financial returns (see below).  Both authorities recommend alternative EfW solutions ahead of incineration (more sustainable, economical, efficient, less environmental and health impact).  CCC have not fully appraised alternative EfW solutions in respect of what county actually needs.

Incineration discourages recycling and therefore moves waste management away from the highest priorities recommended at National and European level  (waste reduction, recycling, re-use) and towards the lowest priorities (landfill, incineration). This is a retrograde step.

Cambridgeshire recycling rate is 46%, EU directive aim is 50%, many other counties and countries achieve 70%+. 

CCC in danger of signing up to 30yr+ contract at a time when landfill and incineration taxes and waste management directives are likely to change with Brexit.

EMERGING JOINT LOCAL PLAN FOR MINERALS AND WASTE

The EfW SSPD of the local plan has identify potential issues and options with EfW, and issue direction for these solutions for the county if demand and rationale for them suggests a strategic need for the supply of them.

 

Cambridgeshire County Council are in advanced stages of an emerging blue print Local Plan for minerals and waste that is expected to complete end 2019 (similar timing to the incinerator public inquiry.  It has been through two rounds of public consultation already. That blue print does not mention anywhere 'energy from waste' and concludes very clearly that existing waste sites, services and facilities for waste management across the county are adequate out to 2036 and foresee at this stage no difference thereafter. They have performed robust analyses looking at populations and expected developments across the county and decided there is NO NEED FOR A WASTE INCINERATOR. 

The emerging local plan for minerals and waste should be afforded the due time and fair process to complete.  Ruling on a major waste proposal now without  giving full weight of consideration of the new emerging local plan that is very close to being rubber stamped, and which has completed extensive waste needs assessments would be inappropriate.

The local plan and the appeal may also be influenced by ongoing investigations (as of 2016) into the need to introduce tax on waste incineration and to undertake a review of the charge on nitrogen oxide emissions.  CCC should take a precautionary approach in looking at incineration as a landfill tax bill solution. 

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