BCC Waste Development Plan Document

Failures to meet Soundness Tests

(Figures relate to Tests in the Representation Form )

 

VOLUME OF WASTE for incineration is unsoundly calculated as it includes a high proportion which is recyclable or compostable.  -9

 

GREEN BELT:   the argument for protection of green belt in this case have been disregarded, whereas it should be taken into account unless there are no viable alternatives.  -3

 

SITES:    the concentration on a smaller number of large sites for treatment facilities offends the Proximity Principle, which means treating waste as close as possible to its source, and it is not reasonably flexible.   Reasons for rejection of the site “adjacent to the current High Heavens site” is unclear.  Many of the Criteria for Waste Management Facilities are not met by Wapseys Wood  -7

 

TRAFFIC:    opportunities from greater use of rail are not pursued and road traffic levels not fully taken into account.  -3 -4B

 

AIRCRAFT:  there should be a full investigation of sites which were on the preferred list until excluded because of possible high chimneys near to airports:    identifying opportunities or plans for changes to flying practices and use of technologies not requiring high chimneys.  -9

 

FINANCE:    the method, apparently being favoured, could involve long term commitments and is not reasonably flexible.   It does not fully take into account the high financial risks to the community from inevitable changes of circumstances, technology, regulation, waste handling and public opinion in the next 24 years.  -7  -9

 

COMPETITIVENESS:      a “robust competitive process” is rightly stated as  “needed”    This looks unlikely to be achieved in the Procurement Process as the Strategy could limit the sites to 2 and the bidders to 3 ,one of which is out of County leaving two owned by bidders.    The element of competitiveness with the inclusion of a neutral site has been lost with the exclusion of Aston Clinton, which could have been of interest to further bidders.  -7

 

THE BUSINESS CASE needs to be reviewed in the light of changes already in place or anticipated, nationally and internationally, since the case was initially developed several years ago . -4B -9

 

TIMING:   the rush into conclusions without very carefully looking again at the financial impacts and at opportunities to reduce the amount of waste needing incineration, by increasing recycling and composting and using modern technologies and hence avoiding heavy penalties until later than anticipated, is unsound.   -9

 

INCINERATOR EMISSIONS are unacceptable as one tonne of waste incinerated can produce about one tonne of CO2.  -3

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NEIGHBOURING WASTE FACILITIES, existing or being considered, are not taken into account.

-6

 

HEALTH:  there is no satisfactory answer to the health concerns about incinerators – no certainty that there are or are not risks.    As medical science increases its knowledge of health factors there will be increasing possibilities of risks being found and public pressure which could lead to banning of large scale incineration.  -3

 

Yours sincerely

Mrs Diana Hepburn-Park

Clerk to the Council