Hexton,
Ashburton Road,
Totnes
Devon
TQ9 5JU
Re: Construction and operation of a MRF and IBA plant at Whitecleave Quarry, Buckfastleigh Application number: DCC/3242/2011
Response from South Hams Friends of the Earth
1. Whitecleave Quarry is not identified in the Devon Waste Local Plan (DWLP) as being suitable for any waste disposal use. If the site was suitable for waste management it should have been identified as being so in the Waste Local Plan.
1.1. A Waste Local Plan undergoes rigorous preparation and examination and includes community consultation. To allocate a site which has not undergone this process when there is relevant plan goes against Government Policy, the Localism Act and raises questions about the validity of the plan preparation and examination process. PPS12 describes the importance of spatial planning in creating strong and prosperous communities. It goes on to say that “spatial planning ensures that strategies can be based on the community’s views and obtain community buy in”. The participation of stakeholders, and this includes the community, is to be considered in plan making.
1.2. The South West Devon Waste Partnership (SWDWP) has already proposed a major waste management facility on a site not allocated in a waste local plan, namely the MVV Incinerator proposed for Devonport, Plymouth. Whitecleave Quarry is therefore the second proposal on behalf of the SWDWP which contravenes local planning policy in seeking to advocate a site which has not been allocated for the purpose of waste management. This will be the second time that community consultation is being ignored and the local community is being denied a voice.
1.3. Policy WPP4 of the DWLP allows for non-allocated sites to come forward provided they contribute to a sustainable waste management strategy. The identification of Whitecleaves Quarry cannot be justified under policy WPP4 because it includes a Materials Recovery Facility (MRF) for which the need has not been demonstrated, and because transporting IBA from Plymouth to Buckfastleigh is not sustainable. It fails the proximity principle which says that waste should be treated as near to the source as possible.
2. The environmental impacts are unacceptable.
2.1 The proposed activities will have unacceptable impact on the Dartmoor SAC, the South Hams SAC and several SSSIs. The Habitats Directive applies the precautionary principle to relevant designated areas in that plans and projects can only be permitted if it has been ascertained that there will be no adverse effect on the integrity of a SAC. This is not the case with this application.
2.2 Pollution effects on the Dartmoor SAC, especially from particulate matter pm2.5 and pm10 resulting from transporting the IBA from Plymouth to Buckfastleigh by HGVs, have not been modelled in this planning application nor were they considered in the MVV Plymouth, Devonport Incinerator application. This is a serious omission.
2.3 During construction the risk of surface water pollution is serious given the proximity of the Dean Burn to the site. There is also not enough information provided on the groundwater and whether this is in hydraulic continuity with the Dean Burn. If it is then any contamination of the groundwater on the site, caused by leaching of chemicals from IBA, or leaching of copper contained in the dolerite which is to be used as a infill of the quarry void or by spills or other contamination incidents during construction or operation, could impact on the Dean Burn and ultimately on the River Dart. Not enough mitigation has been proposed to protect this watercourse during construction or during the plant’s operation.
2.4 The operation of the plant will use energy unnecessarily. If the plant were sited nearer the point of waste production it could possibly benefit from heat or power generated by the plant. Its siting is not unsustainable or environmentally acceptable in respect of energy use.
3. Problems with IBA and IBAA (Incinerator Bottom Ash Aggregate)
3.1 It is asserted that the IBA will be recycled, but how is not clear. A major problem is that bottom ash will be quenched in water in Plymouth before further processing at Buckfastleigh. This step makes separation of the IBA into particle size fractions, a step that is necessary prior to materials separation, more complicated. It means that it is possible to miss some of the metals that may be present which means that they will not be removed from the final product. This in turn means that the IBA will contain some waste which renders it unsuitable for combining, with dolerite for example, as an aggregate. It also means that the IBAA is unlikely to be inert as is claimed.
3.2 No market has been identified for the resulting IBAA. It is possible that it will have to be stored at Whitecleave Quarry, but this application does not provide the necessary information that would be required if the IBAA were to be stored long term. The capacity of the Quarry for long term storage has not been ascertained, and there is no application to landfill IBA or IBAA at this site.
3.3 It is said in this application that the IBA will be heterogeneous. To determine how heterogeneous the IBA is, testing will have to be frequent and rigorous. The characteristics of incinerator bottom ash, from a municipal waste incinerator, may vary on a daily basis due to waste collections from different areas and testing needs to recognise this. There must be traceable records and documents kept in relation to IBA testing. It is not clear from this application exactly what the testing procedures will be.
Kate Wilson,
South Hams FoE 3/4/12