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Do you think incineration is a good solution for Devon's waste?
 
The News
Update - September 2011 PDF Print E-mail
Written by Chris Mills   
Saturday, 22 October 2011 09:27

Hi All,

Hope everyone had a good summer. Here is a quick update of where things stand at the moment.
There is a lot coming up in the next few weeks:


Lee Mill Incinerator

We keep hearing from people who think the fight for New England Quarry (NEQ) has been won.
This is not the case at all. We still have to keep up the pressure by responding to possible public
consultations. There may be two coming up:


The Permit from the Environment Agency

EcoIvy is waiting for the recommendation from the Environment Agency regarding a permit to run
the proposed Viridor 275 000 tonne incinerator at NEQ.

Once the recommendation is given there will be a public consultation before the decision is finalised,
so we need you all to respond if the EA recommend giving Viridor a permit. We will let you know in due
course.


Planning Permission from Devon County Council

Devon County planning officers are waiting for Viridor to submit yet further information to the
planning application for the incinerator at NEQ, after it was recommended to be rejected by Council
Officers back in the summer. The company has until sometime in October to reply.

If this new information from Viridor is deemed significant, the public will be given the opportunity
to comment on it before the Council Officers make a revised recommendation to the councillors.
So once again we want people to reply to this consultation if it happens. Again, we will let you
know as soon as possible.


Plymouth Incinerator Protest March tomorrow

Just to let you know Plymouth-based group, Incineration Is Wrong, is holding a Protest March
tomorrow - 10 September - demanding a public inquiry into the proposed incinerator in Plymouth.

The March starts 12 Midday, Plymouth Guildhall, Armada Way. The date ties up with the start of the Americas’ Cup Challenge so people are invited to dress up as Pirates for the march.


Anti-Incineration E-Petition

EcoIvy, among other organisations, is asking as many people as possible to sign an e-petiton directly asking the UK Government to consider implementing a tax on every tonne of waste to be incinerated.

This would be similar to the existing tax on waste to be landfilled. The incineration tax would make incineration of waste far less competitive and would discourage reducing the bulk of waste for landfill by simply burning it.

In turn this will encourage alternatives to both incineration and landfill of waste such as re use, recycling, composting or other more sustainable technologies.

The e-petition is simple and takes seconds to complete, please follow the link below:

http://epetitions.direct.gov.uk/petitions/2642

Once again thanks for your continuing support,

Kind regards,

Charlotte and Murray

ecoivy.org

Last Updated on Sunday, 23 October 2011 09:01
 
Update July 2011 PDF Print E-mail
Written by Chris Mills   
Saturday, 22 October 2011 09:19

Hi All,

Just a short update to let you know that Buckfastleigh Community Forum have a meeting at Buckfastleigh Town Hall this Thursday 7th July. It concerns plans by MVV Umwelt and Gilpin Demolition to dump the vast majority of bottom ash from the proposed Devonport incinerator into Whitecleaves quarry situated in the middle of Buckfastleigh. The Community Forum will have an exhibition starting from 6pm and then presentation at 7.30pm followed by a Q&A session.

New England Quarry Viridor Landfill application

Time is running out! If you haven’t already done so, please write to the Environment Agency to object to Viridor’s application for a 970,000 tonne landfill at New England Quarry. This is in addition to their planning application for an incinerator on the same site. The sooner our letters are received the more closely the EA can scrutinise Viridor’s application on our behalf.

Please send an objection to this permit application to the Environment Agency, quoting the application number EPR/PP3133FC/A001 to:
Email This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Or you can write to The Environment Agency, Permitting Support Centre, EP Team, Quadrant 2, 99 Parkway Avenue, Sheffield, S9 4WF

A full objection letter from EcoIvy has been published on the ecoivy.org website. If you find you are unable to write your own objection letter you can always put a few lines about your main concerns regarding the landfill and then support either the Friends of the Earth South Hams or EcoIvy objection letter.

Waste Core Strategy

Devon County Council have gone out to consultation on their Waste Core Strategy report until 21st July 2011. This is a planning policy document which will eventually replace the core policies of the adopted Waste Local Plan. It will cover Devon excluding the areas of Plymouth, Torbay and the National Parks. However, because waste is transported and treated widely, the Strategy will consider waste produced in these neighbouring areas.

The Waste Core Strategy will come into force from its adoption in 2013 and remain in place until 2031. The Strategy will provide waste planning visions, objectives and policies, and will also specify where the major waste planning sites will need to be located. The Waste Core Strategy will address all of the major waste streams.

Devon County Council state that engagement with members of the public, the waste industry and stakeholders will play a major role throughout the development of the Waste Core Strategy and there will be a number of opportunities throughout the process to influence and comment on the content or principles outlined within the Waste Core Strategy.

To take part in the surveys follow the link below. This will take you to an external website.

devoncc.limehouse.co.uk/portal/

EcoIvy would be very grateful if you could pass on this information to friends and neighbours who would be interested in these community issues or who do not have access to email.

Kind regards,

Charlotte and Murray

 
EcoIvy Environment Agency Response to NEQ Landfill PDF Print E-mail
Written by Chris Mills   
Wednesday, 29 June 2011 21:58

The Environment Agency,
Permitting Support Centre,
EP Team,
Quadrant 2,
99 Parkway Avenue,
Sheffield,
S9 4WF.

23 June 2011

 

Dear Sir/Madam,

 

This is a letter from EcoIvy, which campaigns on behalf of the residents of Ivybridge who object to the proposed Viridor landfill at New England Quarry. Application number EPR/PP3133FC/A001.

 

I have laid out the response in the same order as the Environment Agency permit application has been submitted.

 

Section 6 Operation Techniques

 

OT2 Odour

 

There are three main areas of concern regarding unpleasant odours from this proposed landfill. Landfill gases, leachate and incoming waste.

 

2.1.2 Leachate

Leachate produced by the landfilled waste will be extracted from collection wells within the waste and then be transported elsewhere. The application does not give an indication of how the leachate will be extracted and what the expected volumes will be. Nor does it specify where the leachate will be transported to and the method of disposal. The leachate will be produced by waste classed as directive waste and will have hazardous properties (H15). This will require specialist transportation and disposal.

 

2.1.3 Received Waste

Viridor states the landfill site will receive low volumes of waste. However predictions are based on an average fill rate of 33,000 tonnes per annum (tpa) but could increase to 60,000 tpa, with a breakdown as follows:

 

• Un-burnable MSW – 20,000 tpa;

• Incinerator Bottom Ash – 4,500 tpa;

• Commercial and Industrial Waste – 8,500 tpa.

 

Over the life of the landfill the total of waste that will be dumped in NEQ void will be 970,000 tonnes that cannot be quantified as a “low volume”. At least 500,000 tonnes will be un-burnable MSW straight to landfill.

 

Viridor suggests none of these waste streams are considered likely to be an odour risk. This is misleading when you consider the waste stream that will be brought to the site. Some of that will include waste from human and animal healthcare, processing meat, fish and other foods of other animal origin, wastes from anaerobic treatments including digestate and waste from sewage cleaning. The company has suffered from odour problems at its Heathfield site near Newton Abbott.

 

If the EFW process line becomes inoperable, Viridor then proposes that all of the waste will then go straight to landfill.

 

3.2 Temporary Odorous Activity

Concerning the delivery of particularly odorous wastes, Viridor suggests pre-booking of this waste as a solution. I, and waste experts I have consulted, fail to see how pre-booking this waste stream will make it smell any less offensive for the residents living 220 meters away from this site.

 

3.3 Viridor states that for the disposal of high odour waste streams they will minimise the storage and transport of odorous waste but then go on to say in Section 3.5 that high odour waste deposition shall, where possible, occur during periods of favourable weather conditions. EcoIvy would like the Environment Agency to seek clarification of this point and forward the response on to us.

 

3.10 Minimising Disturbance to Previously Impacted Waste

Disturbance of previously impacted waste creates offensive odours and should be avoided but due to the New England site being a quarry, waste will have to be dumped on top of previously filled waste. In some cases Viridor states that this will be after a significant period of dormancy, this is far from ideal and indicates this is a poor choice of site for landfill.

 

3.11 Landfill gas infrastructure

A gas abstraction network will be installed in order to maintain gas control to help prevent fire explosions and landfill membrane rupture. This will be connected to an on-site gas compound for gas flaring. EcoIvy believes that given international, national and local concerns about climate change it is totally unacceptable to allow gas flaring at New England Quarry. If this scheme is to proceed, there must be plans put in place to use this gas as a resource to produce energy.

 

3.15 Odour Management Sprays

I find it surprising that if Viridor feel the risk of odour is so low they are also proposing to use masking and odour neutralising agents on the site. Pollution control experts I have consulted are concerned these agents may get into surface water and would like to know if they could have any detrimental effect on the environment, wildlife or River Yealm.

 

4.2.1 Subjective Odour Surveys

I was deeply concerned to read about the odour management inspections which use the so-called “sniff test”. Compliance with this type of monitoring will be highly subjective and open to wide interpretation and abuse. I am worried that the site manager will only be informed and the cause investigated if the odour has significant off site impact.

 

OT3 Surface Water Management Plan

 

Having reviewed this section EcoIvy remains unconvinced Viridor will be able to manage separation of rainfall and dirty water for the entire duration the landfill remains active.

 

3.2

The use of attenuation ponds provides a direct link to the Yealm. They are inadequately small buffers between the landfill drainage systems and the River. The ponds themselves are not sufficiently sealed to provide protection to the river if contaminated. The proposed monitoring system via visual checks is flawed and inadequate to ensure drainage is compliant with permitted standards.

 

EcoIvy requests that the Environment Agency asks Viridor to provide us with examples of what constitutes a non-immediate problem which results in a defect in the drainage system to be left unrepaired for up to 28 days.

Non Technical Summary

7.2Hydrogeological Risk Assessment February 2011

 

On reviewing the Hydrogeological Risk Assessment I – and experts who we have consulted - have grave concerns over contamination of the river Yealm.

 

EcoIvy have concerns about the compliance points for both hazardous substances and non-hazardous pollutants, for example one of theses is sited directly below the NEQ site and so allows for the immediate dilution in groundwater.

 

Viridor states that there may be other, physical receptors further away from these points, and that compliance with the regulations will ensure that other receptors are adequately protected. EcoIvy requests that the EA asks Viridor how this will be ensured.

 

It seems to us that the landfill leachate mitigation after construction mostly consists of infrequent monitoring and that using compliance points as a monitoring system is wholly inadequate and dangerous. The damage from hazardous leachate will already be done.

 

6.0

Viridor concludes in their application for an EA permit that the results of a risk assessment have established that the installation will potentially pose a hazard to ground and surface water quality. The company has said consequently arrangements must be made to collect contaminated leachate and any contaminated water that is generated by the site.

 

Viridor proposes that the installation will require a geological barrier and artificial sealing liner of sufficient thickness and attenuating properties to avoid the release of hazardous pollutants which

minimises the release of non-hazardous pollutants. Experts we have consulted argue that leachate is notoriously difficult to control in land-fill sites and constructing one that starts below the ground water level and progresses up through the strata to the surface is a deeply flawed solution.

 

Simply minimising the release of non-hazardous but not inert pollutants is also inadequate. DEFRA's 2011 Waste Hierarchy Evidence Summary states that eutrophication may be caused by leachate or effluent from the waste disposal system. This triggers excessive growth (and death) of plants and algae which can lead to decreased oxygen levels in water, creating conditions which cannot support diverse life. This means that there are real concerns about the river Yealm which is 50 meters from the NEQ landfill site. There is a risk of membrane rupture during construction and Viridor have concerns of rupture during waste deposition. This does not include the deterioration of the liner properties over time, something that the EA has admitted is a problem to EcoIvy in the past.

 

In addition to the main river, several tributaries are located within 1km of the site including a small stream which flows along the northern boundary, and a second stream which joins the Yealm from the east, approximately half way along the site boundary. The ground water is in hydraulic continuity with the river Yealm and there is a low ground water high river discharge rate, however ground water flow is towards the river Yealm from the landfill site.

 

There is a secondary aquifer on the landfill site and there are five groundwater extraction sites within 3km of the landfill site boundary.

 

OT4 Waste List

 

In the waste list submitted by Viridor the list is a mix of categories. Although this waste is not classed as hazardous it is not inert waste either. This is unsuitable for landfill at a site as environmentally sensitive as NEQ. The options for waste management have been ranked in a waste hierarchy according to their approximate environmental benefit and dis-benefit in the revised Waste Framework Directive 2008.

 

Prevention

Preparing for reuse

Recycling

Other recovery

Disposal (landfill)

 

The UK needs to apply this hierarchy as a priority order in waste prevention and management legislation and policy. I have examined a few streams of waste destined to be dumped in the quarry and compared them to the recommendations from the DEFRA Waste Hierarchy evidence Summary 2011 below.

 

  • Food waste

 

Food waste should be diverted from landfill wherever possible. Food waste degrades to the potent greenhouse gas methane over a short space of time in landfill. Even where methane is captured for flaring or energy recovery, the overall impact is still extremely negative.

 

  • Conventional plastics

 

Conventional plastics will degrade very slowly, if at all, in landfill conditions. However, they are lost to the resource economy and take up landfill space. Overall, landfill remains the bottom of the waste hierarchy. Plastics which are designed to degrade may or may not breakdown in landfill

depending on their properties and the landfill conditions. There is a lack of research into this at present, but if the materials do decompose they are likely to lead to emissions of methane. Even if a proportion of this is captured much will also escape into the atmosphere.

 

  • Paper and card

 

Both these should be diverted from landfill wherever possible. As they degrade in landfill, they can emit methane. Even where some or most of these emissions are captured for flaring or energy recovery, the overall impact is still negative.

 

  • Metals

 

Metals may rust in landfill and break down, or may remain in situ. As there is no opportunity to recover value, landfill remains at the bottom of the waste hierarchy.

 

  • Glass

 

No energy can be recovered from waste glass. Some value may be recovered if the incinerator bottom ash can be used, for example in construction, but the benefits are negligible and Viridor has incinerator ash on the waste list for landfill anyway. As an inert material, glass does not degrade in landfill. However, it is lost to the resource economy and takes up landfill space.

 

  • Garden waste

 

Finally garden waste should be diverted from landfill wherever possible as it emits methane when it degrades. Even where some of this is captured for flaring or energy recovery, the overall impact is still negative.

 

The proposed landfill at NEQ will contribute to climate change caused by emissions of greenhouse gases including carbon dioxide, nitrous oxide and methane. Climate Change is an issue of global concern. In the UK, the Climate Change Act 2008 sets out an objective to reduce carbon dioxide emissions 80% by 2050 against a 1990 baseline.

 

Section 6 Operational Techniques overview

 

4.8.3 Noise

 

Noise pollution is inevitable in managing a landfill site, whether it is from the movement of HGVs, plant vehicle reversing bleepers or uploading and compaction of waste. Mitigation offered by the applicant is that these activities will happen at specific times. I fail to see how this will reduce the noise. Although Viridor suggest silencers may be fitted to some vehicles in accordance with manufacturers’ instructions, the company offers no solution to the huge amount of heavy goods vehicles that will be entering and leaving the landfill site.

 

4.8.4 Pests

 

It goes without saying that Birds, vermin and insects will be attracted to landfill site especially one in such a rural location. The mitigation offered by the applicant is that the tipping area for waste will be kept to a minimum, although once again mitigation plans seem to be inadequate.

 

4.8.5 Litter

 

I have concerns about litter from this landfill which is a threat to wildlife. Viridor assures us that it will cover light waste as soon as possible to reduce the risk of littering but shall only clear up litter from affected areas outside the site when practicable. Once again this is inadequate, given the sensitive nature of the local habitat.

 

Traffic

As Viridor did not win the bid for the South West Devon Waste Partnerships waste contract, it does not have the household waste to burn or landfill. Viridor cannot tell us where the 970,000 tonnes of waste for landfill will originate and be transported from. As a result their predictions of what the waste will consist of are inaccurate as they are pure speculation. This also has huge implications for traffic across the county and possibly further afield as waste may have to be imported. The Jacob's report for DEFRA 2010 shows as there is not enough commercial and industrial waste in Devon. The access through the village of Lee Mill is already under strain and cannot support further increases in traffic especially the vehicles needed to support a 970,000 tonne landfill.

 

Waste Local Plan

Viridor's proposals for the NEQ site violate Devon County Councils Waste Local Plan 2006 SH17. Under considerations for the site, the plan states their should be no further encroachment into the flood plain and any proposed extensions should be away from the watercourse.



Environmental Impact and other concerns

I am concerned that the revised plans have widened and lengthened the access road to the NEQ site and it would encroach further into ancient woodland. This obviously cannot just be replaced.

The plans to drain the quarry void will destroy foraging sites for twelve species of bat.

The NEQ site to the river Yealm provides a wildlife corridor for recently returned breeding otters and many threatened birds. This will be destroyed or at the very least put at risk. I feel the proposed nature conservation mitigation is completely insufficient.

Devon County Council has just had further environmental information given to them, I would like the Environment Agency to ensure that they pass this additional information onto EcoIvy.

The New England Quarry has many characteristics that make it a unique and valuable wildlife area. The north eastern corner of the site and much of the woodland to the north, south and east has been designated as Mackarell Parks, Southwood Woods and Strashleigh Ham County Wildlife Sites (CWS) for the presence of ancient woodland. The north western corner of the site has also been designated as New England Fields County Wildlife Site for the presence of marshy grassland habitats.

 

Much of the quarry void has also been designated as a Regionally Important Geological and

Geomorphological Site (RIGS) due to the presence of gabbro intrusions into Middle Devonian slate. Several other non-statutory wildlife sites are present within 2km of the site boundary, these are predominately ancient woodland and neutral grassland sites.

 

The Dartmoor National Park is located approximately 3.6km to the northeast of the proposed

landfill and the South Devon Area of Outstanding Natural Beauty (AONB) is located approximately 2.3km to the south.

 

In summary New England Quarry is the totally wrong choice of site for a nearly one million tonne waste landfill for so many reasons. The Environment Agency has a unique opportunity to protect this delicate ecosystem and that of the river Yealm.

 

Finally we have the technology to vastly increase recycling rates so much of the material that Viridor proposes to land-fill could be reused or recycled.

 

Yours sincerely,

 

Charlotte Mills

 

On behalf of EcoIvy and the residents of Ivybridge.

 

 

Last Updated on Wednesday, 29 June 2011 22:04
 
Friends of the Earth NEQ Landfill Objection - Link PDF Print E-mail
Written by Chris Mills   
Wednesday, 22 June 2011 23:15

Kate Wilson on behalf of Friends of the Earth (South Hams) has written a comprehensive letter of objection to the Environment Agency. This is in response to Viridor's application for an environmental permit to use New England Quarry, close to Lee Mill and Ivybridge, as a 970 000 tonne land fill site. Click HERE to link to the letter in full.

 

Last Updated on Thursday, 23 June 2011 23:13
 
New England Quarry Objections PDF Print E-mail
Written by Chris Mills   
Friday, 08 April 2011 22:39

 

Hi All

We still need your help to object to Viridor's plans

Despite Viridor not gaining the contract from the local Waste Partnership, the company is pressing ahead with plans for an incinerator at New England Quarry.

However, there were so many complaints and objections to its original plans that Viridor has had to submit revised plans.

The Council has now put these revised plans out to public consultation.

We have until the 11 April 2011 to submit objections.

Responding to planning applications is complicated and Viridor's is no exception. Kate Wilson from Friends of the Earth South Hams has written a very comprehensive response to Viridor's planning application revisions. Click HERE to see Kate's response.

If you want to respond to the revised application but have not had the opportunity, you could support the Friends of the Earth response.

All you have to do is give your name, address, the application number DCC/2975/2010 and maybe a sentence or two about your concerns and how difficult it is to respond to such complicated plans. Then state you would like to support the Friends of the Earth objection letter.

Email objections to planning permission to: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Post them to: Mrs S Penaluna, Planning Officer, Devon County Council, ABG Lucombe House, County Hall, Exeter, EX2 4QW

Its important to remember all previous objections still stand but only objections to the revised plans should be commented on this time.

Please feel free to contact me with any queries.

Best of luck,  Charlotte

 

Last Updated on Thursday, 23 June 2011 23:16
 
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