This is why Calderdale Green Party objects to the proposed waste to energy incinerator on the Belmont site.
1. It is in the Green Belt.
2. It is not compatible with the 2014 National Planning Policy for Waste, which says that Waste Planning Authorities should prepare local plans which…drive waste management up the hierarchy. (In other words: waste management should aim first to reduce waste, then to re-use it, then to recycle it.)
When Calderdale Council develops a local plan which drives waste management up the hierarchy, this could radically reduce the amount of residual waste in the borough. But this application assumes that a continuing supply of residual waste will be available (although it is incredibly vague about future sources.) If Calderdale Council does its job of preparing a local plan which drives waste management up the hierarchy, there will be no need for this incinerator in a few years.
Norfolk County Council’s waste policies (September 2015) aim to move towards zero waste; they specify that any proposed treatment facility will not only reduce dependency on landfill but it must be higher up the waste hierarchy than incineration. Calderdale Council should similarly be moving towards zero waste and the creation of a local circular economy.
3. It will stifle innovation.
The 2014 National Planning Policy for Waste also specifies that Waste Planning Authorities should take care not to stifle innovation when they identify sites and areas for new or enhanced waste management facilities. But a waste incinerator will stifle innovation because it provides a way of disposing of residual waste and so removes the need to innovate to find ways of driving waste management up the hierarchy.
There are many ways in which the Council could and should reduce the amount of residual waste – both its own municipal residual waste which is currently the bulk of the incinerator feedstock, and the industrial and commercial waste that makes up the rest. But none of them are likely to be pursued if there’s an incinerator.
4. Significant adverse impacts on the wellbeing of the community.
The 2014 National Planning Policy for Waste says that Waste Planning Authorities should assess the suitability of sites for new or enhanced waste management facilities against the cumulative impact … on the wellbeing of the local community, and this includes assessing how air emissions are “in proximity to sensitive ecological and human receptors.” There are many people (“sensitive human receptors”) living near the incinerator and there are good grounds for thinking that emissions from the incinerator will harm their health in a cumulative fashion.
The incinerator emissions include carbon monoxide, volatile organic compounds and nitrogen oxide (NOx) as well as particulate and acid gas emissions. The application says that emissions will be within legal limits – but it only gives the mass of particulate emissions – not the size of the particles, which is what is crucial for health.
Airborne particles are classified according to their size. Particles with a diameter of ≤ 10 microns (1 micron (1 µm) = 10-6 metre) are potentially dangerous because they are small enough to be drawn into the lung; such particles are designated PM10s.(‘PM’ = ‘particulate matter’)
Particles with a diameter of ≤ 2.5 microns are more dangerous because they can be drawn deeper into the lung; they are designated PM2.5s.
Even smaller particles are considered by many to be even more dangerous. The Environmental Protection Agency cites health studies indicating that particles smaller than 2.5 micrometers (PM2.5) are
“the major contributor to serious health problems like respiratory illness and premature mortality” .
Filter bags trap some waste incinerator emissions – but not the smallest particles. Information from a multi-national waste management company (Veolia) showa that
“…baghouse filter collection efficiency was 95-99% for PM10s, 65-70% for PM2.5s, and only 5-30% for particles smaller than 2.5 microns, even before the filters become coated with lime and activated carbon”
[Howard C.V. The health impacts of incineration, with particular reference to the toxicological effects of ultrafine particulate aerosols, organo-chlorines and other emissions. Proof of Evidence submitted to East Sussex and Brighton and Hove Local Plan Public Inquiry, 2003].
And sometimes these filter bags tear. There was a major incident on 19 June 2001 at Dundee Energy Recycling Limited which the Scottish Environment Protection Agency (SEPA) described as
“ a lot of black dust had poured from the incinerator for an hour after filter bags suddenly burst. The pollution emission dials went off-scale, so there were no readings for the amounts that were discharged. The incinerator was shut down and the operators are trying to find out why the filter bags, which were new, had failed”
The 2006 Paris Appeal Memorandum, supported by the European Standing Committee of Doctors (representing 2 million doctors), urged a moratorium on building any new incinerators.
“ Long-term exposure to even low concentrations of fine particles may be associated with reduced life expectancy”
[Brown L.M., Collings N., Harrison R.M., Maynard A.D. and Maynard R.L. Ultrafine particles in the atmosphere: introduction. Philosophical Transactions of the Royal Society of London A 358 (2000) 2563-2565].
A study (Aboh, et al. 2007) that looked into a medium sized city in southwestern Sweden, clearly identified their new modern incinerator as the single most significant source of PM2.5’s.
Another study (Mao, et al. 2007) found that the concentrations of PM2.5 and PM10 in the study area located downwind of the incinerator were significantly higher (between 220% and 700% higher) than the study area upwind of the incinerator. The study indicated that the air had “significant contamination by air pollutants emitted” from a waste incinerator, representing a public health problem for nearby residents, despite the facility being equipped with a modern air pollution control system.
Many studies, old and new, show that communities all around the world, living close to incinerators, even modern facilities, suffer higher rates of cancer and respiratory problems (e.g. http://tinyurl.com/y7dteo).
It is now established beyond reasonable doubt that particulate air pollution causes death by various means. Research shows these include:
- Cardiovascular morbidity and mortality [Miller K.A., Siscovick D.S., Sheppard L., Shepherd K., Sullivan J.H., Anderson G.L. and Kaufman J.D. Long-term exposure to air pollution and incidence of cardiovascular events in women. New England Journal of Medicine 356 (2007) 447-458]
- Cardiopulmonary mortality [Pope C.A. Mortality effects of longer term exposures to fine particulate air pollution: review of recent epidemiological evidence. Inhalation Toxicology 19 (2007) 33-38]
- Respiratory, immunological, haematological, neurological and reproductive / developmental problems, sometimes with long time-lags between exposure and health effects [Curtis L., Rea W., Smith-Willis P., Fenyves E. and Pan Y. Adverse health effects of outdoor air pollutants. Environment International 32 (2006) 815-830]
Every 10 µg/m3 increase in fine particulate levels was associated with a 4% increase in deaths from all causes, a 6% increase in deaths from cardiopulmonary illness and an 8% increase in lung cancer mortality [Pope C.A., Burnett R.T., Thun M.J., Calle E.E., Krewski D., Ito K. and Thurston G.D. Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution. Journal of the American Medical Association 287 (2002) 1132-1141]
There is particular concern about the effects of particulate pollution on infants. Increases in infant deaths from respiratory causes with a 10 µg/m3 increase in PM2.5s have been identified [Woodruff T.J., Darrow L.A. and Parker J.D. Air pollution and postneonatal infant mortality in the United States, 1999-2002. Environmental Health Perspectives 116 (2008) 110-115]
A 10 µg/m3 increase in PM2.5s was related to a 5% increase in the risk for wheezing bronchitis [Pino P., Walter T., Oyarzun M., Villegas R. and Romieu I. Fine particulate matter and wheezing illness in the first year of life. Epidemiology 15 (2004) 702-708]
No matter which way the wind blows Sowerby Bridge will be showered in these gases and particulates every day. If there was ever a more unsuitable location for an incinerator then either of these locations are it.
5. Past management of the existing waste facility strongly indicates that the operator’s management system and/or their technical competence is inadequate – at the Belmont site, there was a fire in the building which filled the Ryburn Valley with a dense cloud that lasted for over a day and spread up the valley all the way to Rishworth.
J Air Waste Manag Assoc. 2012 Jan;62(1):103-11. Ultrafine particle emission from incinerators: the role of the fabric filter. Buonanno G1, Scungio M, Stabile L, Tirler W.
There is a vast literature concerning the health effects of airborne particulate matter [Pope C.A. and Dockery D.W. Health effects of fine particulate air pollution: lines that connect. Journal of the Air and Waste Management Association 56 (2006) 709-742].
This is why Calderdale Green Party objects to the SWIP application for a licence to operate a small waste incineration plant at Mearclough Road, Sowerby Bridge (17/00114VAR)
The EPR SWIP PERMIT APPLICATION SUPPORT DOCUMENT claims that there would no health risks from the proposed incinerator because the levels of pollutants are within legal limits.
Quite apart from the fact that the meteorological data used in the air emissions modelling is totally inappropriate since it comes from Leeds/Bradford airport which is flat, not at the bottom of a narrow valley, the official data about health risks is not very reliable.
See the health risk points above in the objection to the Belmont waste to energy incinerator.
The British Society for Ecological Medicine’s Reply to the Health Protection Agency points out:
“Science is continually evolving and research studies are revealing toxicity at progressively lower exposures for many toxic substances. This trend is certain to continue. Secondly there is the historical fact that regulators have consistently and repeatedly underestimated the risk of pollutants and toxic chemicals. This has been true for asbestos, lead, DDT, PCBs,dioxins and CFCs. Often it has taken decades for regulators to acknowledge these risks and ban these substances.
Recent evidence has shown alarming evidence of body burdens of chemical contamination in the general population and more worryingly shows that newborns are being born with their bodies already polluted. This again shows how present regulations are failing to protect the public from toxic exposure. The BSEMreport also highlights important new evidence that pollutants can cause genetic changes that can be passed on through subsequent generations – the implications of this research are as yet unknown but demo nstrate how little we understand about the dangers of toxic chemicals and just how serious they can be.”
The proposed incinerator is close to homes and schools and well-used roads. It is 100 metres away from an Air Quality Management Area where NOx levels exceed legal limits. We know many people suffer ill health and even die from this; extra air pollution from the incinerator is going to make matters worse.
The risks associated with the proposed incinerator include fire/explosion. failure of abatement plant, spillages and uncontrolled releasses.
The is literally playing with fire. The precautionary principle should apply and this proposed incinerator should not receive an environmental permit.
Sowerby Bridge doesn’t need this or any other incinerators.