Why are so many people angry about the proposal?
Tamar Valley looking towards the Tamar Bridge and Saltash from Higher St Budeaux
Proximity to housing and armaments depot - the nearest homes will be less than 200 metres away
These houses are already very close to the neighbouring Royal Naval Armaments Depot which is subject to the Major Accident Control Regulations. The World Bank guidelines indicate that this distance is too close to housing to be suitable for an incinerator.
Adjacent to an Area of Outstanding Natural Beauty and county wildlife site
The setting at Ernesettle in Plymouth is in one of the most beautiful locations in the country - the Tamar Valley affords a wealth of wildlife and beautiful views when crossing the Tamar Bridge, while also lying very close to the Tamar Valley Area of Outstanding Natural Beauty and a number of Sites of Special Scientific Interest, a scheduled Ancient Monument and untouched ancient woodland.
The same view showing one of the regular river fogs in the valley
The Council's analysis amazingly suggests that the land is of little environmental significance, but it is part of the existing green space network and a previous analysis of the site indicates a biodiversity at least comparable with other significant areas of the city.
Location in a fog-prone river valley which will inhibit dispersal of the pollution
The location in a river valley will increase the incidence of fog - we have a comment from meteorologists who state that the incinerator should not be in operation on calm nights when stable air will trap and inhibit pollution dispersal. In reality, these incinerators run twenty-four hours a day, seven days a week, regardless of the weather.
The location at the most westerly point of the county means very long journeys for waste; a more central location would be less-environmentally damaging
Plymouth City Council has been quoting the proximity principle to justify the use of a site within the City boundaries. However, the PCC Transport Assessment in the evidence base includes a doubling in size of the EfW plant to a capacity of 240,000 tonnes pa to accommodate waste from Devon and Torbay. Why should this waste be driven right across the south of the county, to the westernmost part of Plymouth? Surely the proximity principle fails completely on this point?
Normal rush hour traffic on Ernesettle Lane
The road network is unsuitable for the heavy goods vehicles
The only two routes into the site go through residential areas. The route through the principal Ernesettle community is not viable for HGV traffic, leaving only one possible route which becomes quickly clogged during the rush hour and whenever there is an accident on the A38 Parkway or Crownhill Road. In the event of an incident at the incinerator it could be very difficult for emergency vehicles to get through. The route via Ernesettle Lane is also very steep and will cause significant pollution from HGVs. The city council's transport assessment states that 80 HGVs per hour are expected to use the route into and out of the facility.
High proportion of cardiac and respiratory illness in the local population
DEFRA's Review of Environmental and Health Effects of Waste Management: Municipal Solid Waste and Similar Wastes (May 2004) raises concerns about composting and emissions from incinerators, and concludes:
"During the course of the project, we found several areas where potentially useful information was lacking, or was less than ideal as a basis for waste management policy. Some of the waste management operations involve heating or burning municipal solid waste (for example, incineration, gasification/pyrolysis, anaerobic digestion and the burning of collected landfill gas). These could have an effect on local air quality. For example, mercury emissions from municipal solid waste incinerators were found to contribute 20% of the overall background mercury concentration at locations surrounding the incinerator. Emissions of dioxins from municipal solid waste incinerators can increase levels of dioxins in soil, although the present generation of incinerators release much smaller amounts of dioxins than was the case five or ten years ago. Dioxins from an incinerator in an industrial environment will only slightly increase the total deposition of dioxins. We found that an incinerator located in a relatively clean rural environment could significantly increase the dioxin deposition above the much lower background level. Even then, the increase would only affect the immediate vicinity of the plant."
Exchanges of correspondence with senior staff at DEFRA have failed to find a definition of "the immediate vicinity" and yet the Government Inspector has accepted this same DEFRA report as indicating that the site in Ernesettle Lane is suitable. This is particularly relevant here as a high proportion of the population of Ernesettle has long-term illness, specifically a high rate of cardiac and respiratory problems (PCC Sustainable Neighbourhood Study January 2008).
The site was originally earmarked for a community sports facility in an area of deprivation
This land was allocated originally for recreation in an area of low car ownership and poor health. The Plymouth 2020 Sports Plan envisaged the development of a joint University/community recreation centre. The site also offers the possibility of waterfront sports and recreation facilities. PCC have suggested that the use of facilities at Derriford would be an acceptable alternative.
However, according to "Planning Policy Guidance 17" any loss of open space or recreation land should be "to exchange the use of one site for another to substitute for any loss of open space, or sports or recreational facility. The new land and facility should be at least as accessible to current and potential new users and at least equivalent in terms of size, usefulness, attractiveness and quality".
It is inconceivable that a site at Derriford could be considered accessible to people in Ernesettle.
