Chippenham Devizes & North Wiltshire and South West Wiltshire Green Parties
Development Management Wiltshire Council, County Hall Bythesea Road Trowbridge, BA14 8JN
By Email To: [email protected]
17th September 2020
Dear Sirs,
Objection to Planning Application 20/06775/WCM We write on behalf of our Wiltshire memberships to register our strong objection to the above planning application.
Approval of this application, if granted, would clearly contravene the Core Strategy adopted by you in January 2015 and as a significant potential source of carbon dioxide (and other greenhouse gases), runs contrary to the Climate Emergency which you acknowledged as recently as last year.
Furthermore, the Carbon Assessment which forms part of the application contains some fundamentally flawed assumptions and errors, resulting in a gross underestimation of the total CO2 the plant will emit over its lifetime.
Miscalculation of Carbon Dioxide Emissions
Incorrect Calculation of CO2 Offset via Electricity
The Assessment does not cover any district heating aspects of the incinerator. If existing homes (with gas or oil boilers) were to be heated the effective carbon output from the incinerator would be greatly reduced. But district heating of new homes would make little or no difference to its carbon output. The reason for this is that shortly new homes will be required to be heated using low-carbon heat pumps, and heating them instead by incinerating waste containing some fossil carbon, would be worse.
The Carbon Assessment assumes that the proposed development will replace some electricity from gas- fired power stations. The report itself says that the UK Government 2050 net-zero CO2 target must mean that those power stations will hardly be being used in 30 years but proceeds to compare the incinerator’s output with gas generation today. A much more logical comparison (in the absence of exact knowledge about the future) would be to assume a linear reduction in nationwide gas-generated electricity to near- zero over the next thirty years, and therefore to compare incineration to half the current gas output – the fifteen-year point. Clearly, after thirty years when almost no electricity is being produced from gas, the incinerator cannot be saving anything over the non-existent gas power-station emissions.
This means that the Assessment’s figure of carbon offset through electricity export of 70,439 tonnes of CO2 per year is grossly exaggerated. A much more accurate estimate of the savings would be 35,000 tonnes per year.
Incorrect Calculation of Landfill Baseline
A similar argument applies to the assumption made by the Carbon Assessment that the alternative destination for the waste would be landfill, with its consequent generation of the potent greenhouse gas methane (some of which could be burned). However, the disposal of such waste in landfill is again unlikely to remain static over the next 30 years, so comparing the plant with landfill today is once more unreasonable.
For example, in Scotland the Landfill Tax1 has reduced landfill per year from 15 million tonnes in 1995 to 4 million tonnes twenty years later. Clearly such reduction cannot continue linearly since the tonnage can never be negative. However it is naive to assume that the current landfill tonnage will remain static. The more it reduces, the less methane from landfill will be saved by the incinerator. It seems reasonable to assume that landfill will be reduced by one third over the next fifteen years. Under that assumption the landfill emission in the Assessment reduce from 95,914 tonnes of CO2 equivalent to 64,000 tonnes.
These two effects make a dramatic change to the table in section 4.1 of the Assessment: Parameter Units Northacre Facility – Base case
Releases from landfill gas t CO2e 108,187
Transport of waste and outputs to t CO2e 2,267 landfill
Offset of grid electricity from t CO2e -14,540 landfill gas engines
Total landfill emissions t CO2e 95,914
Emissions from the Facility t CO2e 104,550
Transport of waste to and outputs t CO2e 3,118 from the Facility
Offset of grid electricity with t CO2e -70,439 Facility generation
Total Facility Emissions t CO2e 37,229
Net Benefit of the Facility t CO2e 58,684
With more realistic assumptions about gas-generated electricity and waste going to landfill the following figures apply:
1https://www.sepa.org.uk/regulations/waste/scottish-landfill-tax/
Parameter Units Northacre Facility – Base case
Releases from landfill gas t CO2e 76,273
Transport of waste and outputs to t CO2e 2,267 landfill
Offset of grid electricity from t CO2e -14,540 landfill gas engines
Total landfill emissions t CO2e 64,000
Emissions from the Facility t CO2e 104,550
Transport of waste to and outputs t CO2e 3,118 from the Facility
Offset of grid electricity with t CO2e -35,000 Facility generation
Total Facility Emissions t CO2e 72,229
Net Benefit of the Facility t CO2e −8229
Therefore, the proposed development would have no Net Benefit at all – worse, it would create 8,000 more tonnes of CO2 in the atmosphere than if it were not to exist.
The proposed development would not operate in isolation. Were this the case, it would have a full supply of waste that would be otherwise going to landfill, regardless of how much landfill nationwide was reduced. Similarly, it would always be replacing some gas generation of electricity almost no matter how little gas generated electricity was produced. in this case, solely from a C02 perspective, the proposed incinerator operating in isolation would be worthwhile, and the Carbon Assessment would be valid. However, as there are currently 90 incinerators across the UK, the lower the Net Benefit becomes and benefits from each additional incinerator are reduced.
Contravention of Core Strategy
At paragraph 6.3.3 of your Core Strategy you make a commitment to: ‘Ensure that development contributes to sustainable construction and low-carbon energy production’.
As we have detailed above, ‘energy from waste’ energy production has a significantly higher environmental impact than traditional fossil fuel energy sources and is therefore NOT a low-carbon energy source.
Much of what is currently used as incinerator feedstock could be recycled or composted, and this would result in carbon savings and other environmental benefits. 2
We trust that in reaching your decision, this clear and significant departure from Wiltshire Council’s own strategic approach to energy production will be given requisite weighting. Furthermore that the serious
2 Evaluation of the climate change impacts of waste incineration in the United Kingdom October 2018 (Rev 1.01: April 2019) https://ukwin.org.uk/files/pdf/UKWIN-2018-Incineration-Climate-Change-Report.pdf errors contained with the Carbon Assessment will be acknowledged and any purported CO2 benefits of the proposed development disregarded when making your decision.
Yours
Margaret Green For and on behalf of CDNW and South West Wiltshire Green Parties