Monday, 27 May 2013

[Reposted] London Borough of Brent responds to the Harlesden Incinerator - it doesn't like it!


SITE: Energy Recovery Centre, Channel Gate Road, Park Royal, NW10 6UQ

PROPOSAL: Construction of an energy recovery centre comprising a single purpose designed building to provide an advanced conversion technology facility and an anaerobic digestion facility with an integrated education/visitors centre and four 25-metre high flues; gas holder tank; emergency gas flare; electrical substation; two weigh bridges; wheel washing aparatus and a security house building.

Further to the consultation letter from Ealing Council regarding the Full Planning Application Ref. PP/2012/3267 at Channel Gate Road, Park Royal, Brent Council have the following comments:

On 23 October 2012, Ealing Council formally notified Brent that the applicant is seeking to increase the volume of waste the site processes from 148,000 tonnes per annum (tpa) to 195, 000 tpa, indicating that they are formally re-consulting on those proposed changes. For clarity, the comments below relate to the original proposal only, and Brent Council reserves the right to comment further.

1.    Brent recognise the need in the London Plan and strategic terms for well designed and located proposals to promote sustainable waste and recovery development. However, we  have significant concerns about the location of the development and the potential negative impacts of aspects of the proposal in terms of environmental and transport impact on Brent and it’s residents and the strategic policy context.

Strategic Policy Context
2.    The site is situated in the London Borough of Ealing across the West Coast Main Line from Brent so the planning application will be determined by the London Borough of Ealing. However, a material consideration in determining the application is the draft West London Waste Plan, Feb. 2011 (WLWP), jointly prepared on behalf of the six West London boroughs which comprise the West London Waste Authority which includes both Brent and Ealing.

3.    WLWP Policy 1 is concerned with the location of waste development. This states that “…Waste development on other sites not listed in Tables 4.1 and 4.2 may be permitted if the proposals comply with the other WLWP policies and the Borough’s Local Development Framework, and:
·         It can be demonstrated that the development is not suitable for any Sites listed in Tables 4.1 and 4.2; and
·         For some reason, identified Sites have not come forward and it can be demonstrated there is emerging shortfall in capacity…”

4.    The site of the proposal is not listed in tables 4.1 or in 4.2. Consequently, unless it can be demonstrated that other sites identified are not suitable then the application should be refused.  The Planning Statement submitted by the applicants affords the draft Waste Plan little weight.  However, the fact remains that what are considered to be better sites have been identified and the Plan has been through rigorous public consultation and has been amended accordingly, although yet to be adopted. Brent’s view is that the draft Plan is not at an early stage, as suggested, and has sufficient rigour to be considered as a significant material consideration and an appropriate guide for waste management development proposals and should not be undermined at this late stage. There is substantial opposition from local residents and others to this proposal whereas the sites identified in the draft waste plan have been subject to rigorous consultation, and a decision has been taken by all the boroughs involved, including Ealing to submit the Plan.

5.    The applicants also suggest that, in drawing up the WLWP, the freightliner site was not assessed properly as part of a  Stage 1 assessment and that if the assessment was undertaken now it could be identified as a shortlisted future waste management site.  This is an assertion that has not been tested and it is likely that, because of the proximity of residential properties and the nature of the vehicular access through the residential area, the site would still score poorly on the “proximity to residential areas” and “vehicle routing” criteria.

Environmental Implications
6.    The Council’s Environmental Health officers have examined and reviewed the statements submitted in support of the proposed development. The site is located on the south west border of Brent. The nearest residential properties within Brent are those based on Harley Road between 150-200m north/north west of the proposed facility, which is down wind of the site under prevailing weather conditions. As such the operation of the proposed facility is likely to have an impact on Brent residents in terms of air quality, odours, operational noise and site traffic.
Air Quality
7.    There are specific concerns with the modelling of the impact of both the stacks and the traffic on air quality in the local area along with more general concerns with the assumptions that are made in the assessements. In general the models fail to make use of localised data sets and instated use estimates which show current air quality levels to be better than the existing.

8.    The modelling in relation to the impact of Nitrogen Dioxide emissions from the stacks appears to be on a best-case scenario rather than the worst-case scenario that would normally be used. Brent does not accept that the air quality assessment has demonstrated that the processes will have an acceptable impact on the local environment for Brent residents particularly in relation to this pollutant.

9.    The model used to show the potential impact of projected traffic levels on air quality uses a very high adjustment factor which suggests that the model inputs maybe flawed. This fails to suitably demonstrate that projected traffic movements of HGV and refuse vehicles to and from the facility will not have a detrimental impact on local air quality.
10.  The main building containing the auto-claving, pyrolisis chambers and combustion tanks will only have an acceptable impact on odours if the measures for controlling the odours suggested in the assessement are implemented along with the appropriate contingency measures prior to the operation of any part of the process.

11.  However, the anaerobic digestion facility has not been sufficiently assessed within the odour control section and as such Brent’s environmental specialist is not convinced that the measures to control odours from this will be sufficient. We would, therefore, object to the proposal on the grounds that it has not been sufficiently demonstrated that the proposed development would have an acceptable impact on Brent residents in terms of odours emitted.
12.  In terms of noise impact Brent are concerned that the noise assessment does not provide adequate measures to guarantee that there will be no detrimental impact on Brent residents in the local area and particularly on Harley Road. The noise assessment suggests that an acceptable impact on Brent residents is feasible but does not guarantee it. An objection is therefore raised to the proposed energy recovery centre on the grounds that it has not been demonstrated that the proposal will have an acceptable impact in terms of noise and disturbance for Brent residents.

13.  Brent’s Highway Engineer is currently assessing the transport information on the proposed development. Further comment on this will be provided in due course.

14.  If Ealing go forward with presenting the proposal to the planning committee Brent will object strongly to the proposals until satsifactory information has been provided to enable an accurate assessment of the implications of the proposal on the Borough of Brent and its residents.

15.  As explained above, Ealing officers have formally notified Brent that the applicant is seeking to increase volume of waste the site processes from 148 000 tonnes per annum (tpa) to 195 000 tpa. The above comments relate to the original proposal. This amendment will significantly increase the potential impact on Brent residents. We would ask that an additional re-consultation exercise should be undertaken to notify all local residents of the changes and to allow for additional time to review and comment on the implications of the increase. 

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