Personal reflections after the Kingmoor Park/Fortums EfW planning meeting
The final decision of the planning committee meeting was 10 councillors in favour of the scheme, 2 against the scheme and 1 member abstaining.
The meeting consisted of a presentation of the proposed planning application by one of the county planners followed by the objectors speaking in turn.
My feeling was that all those who spoke, spoke well.
With hindsight I felt that I struck the wrong note really and put the councillors backs up.
2 or three spoke about how diligent and independent they were. I do not doubt their diligence but the truth is that they were never going to go against the advice of the County planning officers who had recommended that approval be given.
In the end would not have made any difference how many spoke nor how well.
Having chosen CA31 in the county plan as the recommended site for an EfW plant they were never going to reject this scheme unless the planners could be caught in a clear planning blunder.
The real problem with the planning system is that none of us were aware that this important decision was being made. We were never informed of this decision or its relevance to us.
I felt that the ‘public consultation’ and the ‘opportunity to raise objections’ are really a total farce and a completely pointless waste of time for all who were involved.
The truth is that on a project of this scale with a large corporation behind it the councillors were never going to go against the advice of their own planning advisors unless there was an obvious planning blunder by the planners.
All our arguments had been ruled out by the narrowness of the permitted grounds to object. You need to be an expert planner to find one of these and it is pointless objecting without one.
I note the following points in respect of Donalds answer:
- wrt TRACK RECORD OF ERF FACILITIES IN UK / EXEMPLAR PLANTS – Donald confirms that there are no working plants using this technology anywhere in the UK.
- wrt Verus Energy track record – Donald says nothing at all in his letter and this was my main concern. Fortum have some experience with the UK framework but most of their experience is in Finland and eastern Europe.
- wrt STATUS OF THE LOCAL PLAN & SITE ALLOCATION DOCUMENT – It turns out that the consultation period for the site allocation part of the local plan came to an end a few days after the first public meeting (the initial drop in meeting held in the main Kingmoor CBC room [which is now being turned into a classroom to allow further expansion of the Junior School!]) I had no idea after attending the drop in meeting of the significance of that deadline! The relevant department refused our request to extend that consultation deadline in view of its significance just now becoming apparent to Lowry Hill residents.The responses regarding the allocation of the site from the County Council are here. How many of the Lowry Hill Residents were aware of the significance of the CA31 site allocation prior to the Special General Meeting? Very few indeed.
- wrt THE ENVIRONMENTAL PERMIT LIMITS & EMERGENCIES – This all sounds wonderful in theory…but the actual practice turns out rather differently as the situation with the Dumfries incinerator makes clear.
- wrt “Green Energy production” many would dispute that WfE plants produce ‘green’ energy. They produce a huge amount of CO2.
Following my return from holiday I discovered that a planning notice had been fixed to our nearest lamp post… presumably a few days prior to the objection deadline.
I have also received a response from Donald Wilkins the Principal Planner for the proposed EfW plant.
His letter is available here:
This is the wording of the objection of the LHRA to the planned Waste for Energy plant.
We would like to raise an objection to the application PL\1572\05 (1/16/9005) on the following grounds:
Compliance with the Local Plan (i.e. Local Planning Policy)
The current site is identified as the preferred location in the 2012 Site Allocations Policies and Proposals Map due to governments new development plan system this plan has been abandoned and there seems to be a vacuum with regards to detailed County planning
Design out of keeping with the character of the area.
Despite the fact that the proposed location is in an industrial estate the types of development on the estate are mainly warehousing, showrooms and office accommodation. This would be the first major combustion type of process in the estate and it is adjacent to a local nature reserve and close to a residential area with a junior and primary school.
Dominant and oppressive environment created by the proposal.
This development includes very large structures which will have a huge impact on the outlook from the elevated areas of Lowry Hill Road and some locations around the Kingmoor Nature Reserve.
Excessive noise, dust, smell or nuisance.
The plan is to service this incinerator with 100 HGV deliveries per day. Each of these deliveries will require the reversing of the HGV into the reception hall with accompanying reversing beeps. We are concerned that this will cause significant disturbance and distress especially when this occurs during the night, over weekends and during holiday periods.
We are also concerned that the distance from the nearest residential accommodation (730m) means that the noise of the waste treatment and the generator will cause disturbance especially during the night.
We are concerned that this type of technology (untested in the UK) will inevitably result in frequent shutdowns for maintenance or breakdown. We are concerned that at these times there will be a build up of smelly waste waiting to be incinerated (as occurred at the Dumfries EfW plan) and that this will increase flies and rodents in the area.
Impact upon Conservation areas.
The development is very close (perhaps 300-400m) to the Kingmoor Nature Reserve, a highly valued area for dog walkers and family walks. We are concerned that the outlook and perceived safety concerns will affect the value of this reserve.
Its position in respect of Government Planning Policy.
There is considerable concern from the residents that while the pollution levels proposed may be lower than the pollution arising from Kingmoor Road, there is a EfW facility near Dumfries that has repeatedly failed to keep to the required emissions standards. It has proved difficult to do anything about this problem within a reasonable timeframe.
WRAP EfW guidelines indicate that these facilities should not be located near residential areas, school or local nature reserves.
The proposed facility is very close to Kingmoor nature reserve, Kingmoor Junior School and the Lowry Hill residential estate.
Visual or Landscape Impact
The image on the planning proposal (KNG-017cG Visuals A3.indd) gives some indication of the significant visual impact to Lowry Hill residents. This impact will be even greater at some of the entrances to and exits from the Kingmoor Nature Reserve.
This objection was supported overwhelmingly at a Special General Meeting of the Lowry Hill Residents Association on 3rd July after a presentation and opportunity for questions from representatives of the developers.
Over 85 residents were present at the meeting.
Representatives of the Association would like to be present at the planning meeting to further explain our objections to this proposal.
We have also asked Councillor Gareth Ellis to ask for a representative of the Minerals and waste planning policy team to attend a further meeting of the Association to answer questions regarding the allocation of CA31 for a WfE facility.
On behalf of the Lowry Hill Residents Association
A view of the proposed facility from Lowry Hill Road from the planning proposal.
The image on the planning proposal (KNG-017cG Visuals A3.indd)
How to object to the propsoal…
This document was given out at the meeting explaining how to object to the plan to build this facility.
Special General Meeting (SGM)
There was an excellent turn out for the SGM on the 3rd July.
The developers had put on a second ‘drop in’ session running from 5pm to 8pm in the main hall at Kingmoor Junior School. However it was the SGM that attracted the residents with at least 87 people being present in the crowded hall.
Tim Jervis from Verus Energy gave a short presentation describing the process that is planned for the Energy from Waste facility.
From about 8.30pm until 9.45pm there was a deluge of excellent questions from the residents of the estate.
The appetite of residents to get answers to their questions did not seem to be flagging even when the meeting had to be closed as the hall was not booked beyond 10pm.
- There was real frustration and consternation that the Cumbria County council together with the City council had allocated this site as its only preferred site for an incinerator. This is a huge facility using a technique that has no working track record in the UK at all. It is a development that is being proposed by developers who have no track record of operating this kind of plant in the UK. There are no exemplar plants in the UK to which we can be pointed providing reassurance that this technology works efficiently and safely. Despite this a site has been chosen as a test site for this technology which is just over 700 metres away from from a large residential area and a junior and infant school.
The local plan which identifies this site as the preferred site has not been adopted as the official policy of the Cumbria County Council. One of the planning considerations which we are encouraged to use as a means of generating valid objections is the local plan. It turns out that there is not properly approved and adopted plan for us to refer to.
Would it not be wise to shelve such a massive development and drastic change to the Counties waste management system until a proper plan has been officially adopted?
In the ‘site consideration’ document there is only one site that has been considered for an EfW facility… this seems rather odd to me! It appears as if at a very early stage in the planning this site was chosen and very little consideration was given to any alternatives.
- There was concern that the creation of these EfW facilities creates a system with a need for more waste rather than providing strong incentives to reduce the creation of non-recyclable waste.
- A further meeting was requested with representatives from Carlise and Cumbria County councils to explain which this site has been chosen and why there does not appear to have been much consideration of any other alternatives.
- There was real concern expressed regarding the possibility of toxic waste being released from the chimney of the plant. The development team sought to reassure residents that the emissions would always be kept at safe levels. There would be sampling of the supply streams of waste to see whether they contained materials that could produce undesirable. However its seems unlikely that the sampling regime could prevent at least some contamination from a rogue supplier during the process of investigation. What would be the consequences of a waste load contaminated with asbestos for example?
- No doubt the planning and consideration for safety is of the highest order and that in normal working conditions there is a real expectation that the fumes will be safe. However, what happens when things go wrong? How long does the operation continue despite unsafe emissions? How strongly and rapidly can the site operation be stopped if the emissions turn out to be not as safe as anticipated? No doubt at the planning stages for the Dumfries EfW facility there were assurances given that all the emisions were going to be completely safe. Practice is often very different from theory. In these situations there are huge financial and practical pressures to keep such a facility working.
- There was real concern that there would be noise which would disturb residents. There is a large amount of machinery that will be in continuous operation. There are also a large number of HGVs entering and leaving the site each day. The reversing beeps of lorries can carry a long way and be very disturbing.
- What plans are in place if there has to be a lengthy shut down? What will have to the backlog of waste?
3rd July UPDATE
This is the leaflet describing how to object in person to the planning development.
A leaflet describing best practice regarding the development and siting of EfW plants:
22nd June UPDATE
The planning proposal for this development has now been submitted.
The details are available here:
The (very large number of!!) documents associated with this application are available from this page:
To submit an objection you can either email your objection to firstname.lastname@example.org quoting the planning reference number: PL\1572\05 (1/16/9005)
or you can use the form available here:
We have a SPECIAL GENERAL MEETING arranged for 4th July 8.15pm
We are planning to distribute this background sheet to all houses on the estate:
10th June UPDATE
Update on the Energy from Waste Facility
600m 730metres (corrected 4th July) from Lowry Hill.
Plans have now been submitted for consideration for this facility.
The developers have agreed to attend a public meeting which is being arranged for concerned residents.
We will be delivering a leaflet to all residents about this meeting as soon as we can.
A non-technical summary of the plan is linked to below:
The complete plans should be available from this link within a few days:
On 28th April the News and Star had an article about a proposed new waste processing facility planned for a site not far from the Lowry Hill estate.
During the week of the 1st May residents in most of the estate received a letter which is available below.
A map showing the areas that received the notice.
The letter received by most residents.
I was contacted by Stephenson Halliday Ltd, who are responsible for this public consultation exercise prior to the submission of a formal planning application.
Lowry Hill Residents Association
Further to our telephone conversation earlier today, I am writing to provide you with further information about the proposed Kingmoor ERF and the public consultation exercise we are currently undertaking.
We published a public notice within the Cumberland News on the 22nd April and we have also sent a press release to a number of media outlets including the News and Star, The Cumberland News and BBC Cumbria. As you may have noted, an article was published in the News & Start yestarday with regards to the proposal.
I have attached an information leaflet which has been sent to local residents and businesses within 1km of the site this week. The letters and information leaflet are being delivered today. I have also attached a distribution map which illustrates which properties are being contacted. As you will note, we have extended the consultation further than 1km into the residential areas of Cargo and Kingmoor.
Letters have also been sent to Local Councillors, Mr Stevenson MP, the Kingmoor Parish Council and the Kingmoor Junior and Infant Schools.
We are holding a public event on May 4th between 4pm and 8pm at the Kingmoor CBC, and people are invited to drop in to view our exhibition boards and speak to a member of the project team.
I have also attached a location plan which clearly shows and location and extent of the site.
If you have any questions regarding the development or the public consultation process, please contact me on the details below.
Tel: 0141 204 7900
Dir: 0141 204 7903
Mob: 07833 256728
7th Floor Atlantic House
45 Hope Street
Glasgow G2 6AE
As part of this public consultation there is a meeting at the Kingmoor Business centre on Wednesday 4th May from 4pm until 8pm. All the residents on the estate are welcome to visit to this drop in session.
One concerned resident put the following questions to Donald Wilkins:
- I understand that Shank’s site at Hespin Wood processes about 75,000 tonnes of waste pa and that their Barrow site processes the same amount. How does this Kingmoor site fit into Cumbria CC’s current plans?
European and national policies require the amounts of waste going to landfill to be progressively reduced. Waste should be driven up the waste hierarchy. The first step in the waste hierarchy is to minimise the amount of waste that is produced in the first place, followed by increasing the rates of re-use, recycling, composting and recovery of value from waste.
The two Mechanical Biological Treatment (MBT) plants at Hespin Wood near Carlisle and Sowerby Woods Business Park in Barrow do indeed have operating capacities of 75,000 tonnes per annum each. These sites accept ‘Local Authority Collected Waste’ (LACW) which is primarily the wastes collected from households. The MBT plants process this material to form products know as ‘refuse derived fuel’ (RDF) and ‘solid recovered fuel’ (SRF). These products are potentially part of the feed stock of the proposed Kingmoor Energy Recovery Facility. In addition, the Kingmoor ERF will assist in meeting the capacity gap for the management of commercial and industrial waste arising within the County.
The Kingmoor ERF would therefore fit into the evolving network of waste management facilities in Cumbria, ensuring waste generated in Cumbria can be managed locally.
- I understand that Cumbria produces about 250,000 tonnes of waste pa – is the new site to import waste from elsewhere?
LACW arisings within Cumbria are in the region of 250,000 tonnes. In addition to this however, businesses and industry generate waste. The Commercial and Industrial (C&I) waste arisings within Cumbria are estimated to be in the region of 680,000 tonnes per annum.
The aim will be to attract sufficient wastes from within Cumbria. It may be that there will be wastes from other administrative areas which could be managed more sustainably by this facility than by other management options involving long vehicle trips but these have not been identified as yet.
- If so how? To me that looks like 40 lorries per day.
We estimate that approximately 50 HGV’s would visit the site on a daily basis. This would cover both waste coming into the site and recyclates and other wastes leaving the site. The vast majority of HGV’s would travel either along the M6, exiting at Junction 44, then to the site via the Kingsway (A689), or HGV’s would travel to the site via the Carlisle Northern Distributor Road (A689) from the south west. These routes have been designed and engineered to accommodate high volumes of traffic of this character.
- What’s wrong with siting this plant on contaminated land at Hespin Wood or on the old Carlisle Power Station (NY 386566), both near major electricity sub stations?
Planning Policy directs energy recovery facilities to industrial landuses. This site has been identified as a preferred site for a waste management facility, including thermal treatment within the Cumbria Minerals and Waste Local Plan, and is the reason why it is has been selected for this proposal.