Marston Moreteyne Action Group www.mmetag.com

Covanta Resource Recovery Facility Proposal at Rookery South Pit

Notes re IPC Registration

Completing the Registration Form

During this registration stage you will be asked for brief comments - at a later stage you will be given the opportunity to provide a more detailed written account of your views

• Please note the application form should be completed by each individual - not 1 per household. • The form states a guideline of 500 words. The IPC have clarified this in the following statement - “A representation will not be excluded if it exceeds the 500 word limit but it would assist the examining authority in ensuring that all issues are made known as this will inform a judgement on how the examination will proceed. I would therefore encourage you to state your outline case concisely at this stage.” • The form states – and the IPC has confirmed - that if you do not make reference to a particular point or issue YOU are concerned about at this stage you will not be able to make further representations on that topic at any later stage – including the detailed written account – and/or any hearings. • Please avoid using emotional or colourful language in your submission, The IPC have stated your registration may be rejected or portions redacted if your comments are vexatious or frivolous. How exactly they will judge that is open to question! • The IPC have stated that if your submission is rejected in part or as a whole – you will not be advised until after the registration period has closed and therefore will not be able to re-submit. • If you are completing the form on behalf of a Company - which is a different legal entity than you – the IPC has stated that you are entitled to complete a 2nd form as an individual interested party.

IPC Source (for details other than those stated on the Form):- Janet Wilson Head of Case Management

Please visit http://infrastructure.independent.gov.uk to register. A paper version of the registration form is also available at The Forest Centre, Marston Moreteyne , Town Council and Town Council Offices and by download from the MMAG website at www.mmetag.om - alternatively you can request a registration form direct from the IPC at 0303 444 5000.

The full Covanta submission document is available to view on the IPC website http://infrastructure.independent.gov.uk and hard copies can be viewed at the following locations:-

• Central Library (Harpur Street in Bedford) • Ampthill Town Council Offices (66 Street in Ampthill) • Ampthill Library (1 Dunstable Street in Ampthill) • Wootton Library (Lorraine Road in Wootton) • Bedford Borough Council’s office at the Town Hall (St Paul's Square in Bedford) • Central Council’s offices at Priory House (Monks Walk, , near Shefford) • Forest Centre (Marston Vale Millennium Country Park, Marston Moretaine) • Covanta Energy Bedfordshire office (Water End Barns, ) – by appointment only

It is vital that as many people as possible register. To help inform responses MMAG have prepared a selection of points that people may want to use. We feel they are broadly representative of those issues of local concern to most people. However it is not an exhaustive list – there will be issues that are of equal concern e.g. climate change, hydrology, effect on recycling etc. [email protected] 1of 4

Marston Moreteyne Action Group www.mmetag.com

Initial Headline Issues of Concern

Headings have been taken from the Generic Impacts listed in the Draft Overarching National Policy Statement (NPS) for Energy (EN-1) and the Draft National Policy Statement for Renewable Energy Infrastructure

Air Emissions

• There is serious concern about emissions from the EfW stack and long term health implications.

• Residents are concerned about reports that Covanta been served legal improvement notices on its plants in the USA.

• In the sky above the Marston Vale there is the meteorological phenomenon of temperature inversion – on still days emissions linger in the atmosphere immediately above the Vale and eventually drop into the Vale. When inversion is not occurring the prevailing wind is south westerly.

• There is serious concern that the proposal will cause a cumulative impact over the 30 year + life cycle of the plant either within the Marston Vale and/or Bedford and Kempston

Biodiversity and Geological Conservation

• The proposed site is adjacent to the Marston Vale Millennium Country Park – a primary purpose of which is to re-forest the Marston Vale. An oversize Energy from Waste plant will fundamentally undermine that purpose.

• Since clay extractions ceased in Rookery Pit – the adjacent Millennium Country Park and the Pit are now an ecologically integrated and co-joined wild life site.

• The surrounding villages are all within a rural landscape populated by residents who wish to preserve their rural way of life.

• The Covanta proposal will be a retrograde step ecologically and would ultimately lead to the industrialisation of Rookery Pit South.

• The site is host to large numbers of wildlife and the proposal will lead to direct and indirect habitat loss.

Dust, Odour, Artificial Light, Smoke, Steam and Insect Infestation

• There will also be permanent loss of night sky with severe light pollution from a site operating 24/7.

Landscape and Visual Impact

• The sheer size of the building will dominate the skyline - most of which will be visible above the existing edge of Rookery Pit.

• The buildings within the site will abut the footpaths of the Country Park.

• The Covanta Rookery Pit stack will be higher than the long disused brickworks chimneys.

• The plume will accentuate the stack visibility

• The sheer size of the Covanta plant will have a major impact on the visual amenity of the area. The site was always considered to lie within an area of great landscape value and will materially impair the views from the Vale to the surrounding Greensand Ridge and the panoramic views from the ridge across the entire Vale, especially those seen from Ampthill Park and . [email protected] 2of 4

Marston Moreteyne Action Group www.mmetag.com

Noise

• Noise has only been considered in terms of ‘average’ levels so no adequate account been taken of intermittent noise such as that from rattling of empty HGV’s which lead to huge disturbance.

• There will also be noise from the plant itself.

Local and Regional Waste Management

• We promote local responsibility in the collection and disposal of waste – the proximity principle – except in cases where we voluntarily - and freely combine with other Local Authorities to form Joint Waste Authorities. The Covanta proposal will override attempts to deal with waste locally. A fundamental question is whether there should be permission for one Local Authority to discharge its responsibility for waste management by entering into an agreement with a private contractor to build a plant for the sole management of that Authority’s waste in another Local Authority’s area.

• We have our own local waste management project - The BEaR Project - which is currently evaluating the first stage of the tender process so they can short-list the bidders to come forward with solutions that will best meet local needs

Socio-Economic

• The project proposes to export electricity serving the energy needs of 82,500 homes, broadly equivalent to the housing energy needs of Bedford and the Marston Vale. It has never been explained how residents will directly benefit from this green electricity and how this figure of 82,500 is arrived at. Covanta exaggerate their electricity generating capacity in terms of meeting average domestic consumption.

• We believe that the construction of the site utilizing 300+ jobs will be undertaken by labour imported temporarily into the area which will leave when construction is finished.

• Of the remaining 60-70 jobs this will have a negligible effect on overall employment patterns.

• There can be no guarantee that the jobs, ongoing or in consideration, will be offered to local people.

• There will be a detrimental effect on existing property prices - which in turn will depress economic activity.

• The Covanta proposal is at odds with the stated desire of local people to be a leisure destination and not somewhere others send their rubbish.

• We cannot envisage an incinerator becoming a popular tourist destination.

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Marston Moreteyne Action Group www.mmetag.com

Traffic and Transport Impacts

• Significant vehicle movements to and from the site – arriving and departing between 5am and 11pm 6 days a week and 7 days a week on Bank Holiday weekends will lead to immense and ongoing disturbance to the local community

• The new A421 was designed to cope with existing traffic problems and some elements of growth in Bedford Borough.

• The volume of lorry and associated traffic for a large scale industrial area will be beyond the predicted capacity of the road.

• The Covanta proposal is that all rubbish will be delivered by road - despite the fact that Rookery Pit lies between two rail systems.

• The transportation of upwards of 585,000 tonnes of rubbish per year will take place along the de-trunked old A421.

• The waste to be is to be transported using HGV’s and many of which will use the new M1 Junction 13. Evidence submitted by the Highways Agency during the Public Inquiry into the duelling of the A421 from Bedford to J13 indicated that the new junction layout would at peak times have just sufficient capacity to handle the anticipated peak traffic flows, excluding the projected traffic from the Covanta site. Further the adequate functioning of the new J13 is dependent on the further duelling of the A421 from J13 to and funding for this future project must now be in doubt given needed cutbacks in public spending.

• The impact of increased traffic from the proposed project through J13 could significantly increase congestion at the junction at peak times which would in turn give rise to increased traffic flows through neighbouring villages and congestion further afield at key junctions in Milton Keynes.

• Thus far there has been no consultation by Covanta on the impact of the proposed project on communities beyond the Marston Vale but within Bedfordshire.

In conclusion, it is our considered view the following points render the Covanta proposal to be the wrong solution in the wrong location for dealing with Bedfordshire’s waste: • the visual impact • the loss of wildlife habitat in an area that has naturally regenerated over many years, • the predicted traffic levels with associated noise and dust pollution • the proposal to draw huge proportions of the waste processed by the plant from surrounding counties (at odds with the minerals and waste local plans), • the fact that incineration discourages recycling and contributes significantly to atmospheric CO2

For additional items you might want to consider on your IPC submission – please visit the MMAG website at www.mmetag.com . To view MMAGs submission to the Local Impact Report and view other peoples comments on the comments page and at the on-line petition at http://www.gopetition.co.uk/petitions/stop-covanta-building- an-efw-incinerator-plant.html .

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