Paul Hudson

Lead Member of the Panel of Commissioners,

Rookery South,

Infrastructure Planning Commission,

Temple Quay House,

Temple Quay,

Bristol,

BS1 6PN

14th July 2011

Dear Mr Paul Hudson (Lead Member of the Panel of Commissioners)

Rookery South Pit, near Stewartby, Bedfordshire – IPC Reference Number EN0 100011

Further to your letter of 8th July inviting comment from interested parties upon seven written representations concerning the finalised versions of National Policy Statements EN-1 and EN-3: I write the following: -

1)The first point that I made in my registration was regarding a disregard for‘true sustainability’

EN-1: 3.4.3 would have assisted me in making that point with regard to the waste material to be used for generating electricity.

I’m concerned that rubbish as categorised by the market today should not govern the thinking of what can be burnt in the proposed Covanta Incinerator that may not be built for a further 5 yrs ... the market for re-use and recycling is likely to change significantly over the next decades as the price of raw materials increases and motivation for developing techniques for re-use & recycling grows!

There is now a double filter included within this qualification for incinerator-designated rubbish!

  • The first rubbish to be excluded ... waste that can be reused or recycled.

Of that remaining,

  • Waste that would not be destined to land-fillis then to be excluded.

Of course biomassis renewable and this helps the furnace to be sustainable.

BUT at what cost to the environment is the Covanta proposal ... using diesel fuelled trucks for transport? ... with two railway lines adjacent,at his scale of generation; this just sets the wrong precedent and standard for future energy production from waste! It is a carbon rich solution to power generation imposing itself across an expanding road network, as with time, rubbish is sourced from further afield!And we will be locally locked into it for my children’s generation!What message does this give them regarding ‘The Big Society’?

Concerning EN-3

New paragraph 2.5.62

2)The fifth point I made upon registration included my concern for adverse effects upon the local environment and amenity.I was out running 5 miles from Houghton Conquest past Houghton House and Kings Wood along my regular route one afternoon this week and I saw two orange balloons. Should these have been illustrating the location of the top of the stack and the top of the plant then they are clearly visible at many points upon this route ... even at the lower entrance to Kings Wood from the cowslip meadow. The wind is going to, over time, spread dust and deposit toxic material amongst the surface vegetation, as it is filtered out on the surface of leaves and branches in Kings Wood. The worst of that is likely to occur on low wind-speed days with non-stationary atmospheric conditions when convectional characteristics in the surface atmosphere prevail. This, cancerous pollution will be placed within the very heart of an industrial footprint that has been greening progressively over a decade or more. The views from The English Heritage site at Houghton House will be marred by the view of the Incinerator and associated waste management plant. The sounds from the site are going to be, on occasion, an inescapable noise pollution in the ears of visitors.

It is good to read what should occur at EfW generating stations: -

EN-3: 2.5.62 reception, storage and handling of waste and residues should be carried out within defined areas ... within enclosed buildings ...

My work for 14 years was determining wind loads, at full-scale, on low-rise buildings before working on agricultural spray drift for a further 14 yrs or so. In the real world there will be dust and pollutants escaping from this facility; even where there is a will to manage the local internal and external environments to reduce emissions beyond the site’s perimeter.

3)Finally, ‘The Big Society’ should be seen to be a good steward of limited world resources.

Yours sincerely,

Geoffrey M Richardson

Resident of Houghton Conquest