Policy WP10: Residual waste treatment facilities

Thermal treatment of waste by incineration and possibly power generation should not form part of waste management. It is a acknowledgement of failure to address a comprehensive system of waste reduction/reuse/recycling/composting/bio-digestion and lacks sustainability if the economics of having large plant requires numerous lorry movements including importation of waste from other sources. Incineration also produces air pollution allied with traffic movement when concerns over adverse health impacts are becoming much clearer. The incineration residue is also highly toxic requiring careful and expensive disposal.

Thermal treatment typically creates prodigious quantities of carbon dioxide and must be removed from the policy as it is incompatible with climate change and greenhouse gas minimisation commitments made in MW4. The UK already has sufficient thermal treatment capacity to meet its residual waste treatment needs; further capacity will harm recycling due to long-term and inflexible contracts required to make these facilities commercially viable. Norfolk has a disastrous history of failed waste incinerator bids that have cost the taxpayer tens of millions. Norfolk County Council has also made a commitment that no waste will be incinerated in the county.

Would you be kind enough to forward this email to whoever it may concern.

Clenchwarton Parish Council wish to register their objections to any Incineration or Fracking being included in Norfolk County Councils Mineral and Waste Plan.

Incineration and Fracking may be included in the Governments national policies however not all areas are as sensitive as the areas around THE WASH.

The Wash and it's environs have national and international protection.

The Wash is protected by an SSI, SPA and more importantly is also a RAMSAR site.

This area should be protected at all cost.

At the moment NCC has a 'No Incineration Policy'

Incineration and Fracking should be removed from the draft plan.

Over 65,000 people voted against incineration in West Norfolk.

I write in response to your consultation for Minerals & Waste, ending 30th October. I was one of the 65,000 people who voted no to incineration for Norfolk. I would not like incineration to be considered as an option for Norfolk's waste. Neither would I like fracking to go ahead in Norfolk. Many thanks.

As a resident of West Winch near King's Lynn I wish to point out that I don't see anywhere within your plan where it's stated that previously in excess of 65,000 local people who rejected the plans for an incineration facility being built locally for all the obvious reasons.

Please include this in your new proposals and take note that people still haven't changed their views on this!

I am lead to believe that there is still the push for 3,000 new homes in the West Winch Setchey corridor which is contentious due to the appalling lack of road/rail infrastructure that isn't in place prior to this possibly beginning.

To have the potential of fracking included near West Winch then seems ludicrous as across the USA Canada and recently parts of England this is known to cause earth tremors, why would you be pushing for new housing developments to then plague these with earth tremors and other known negative effects?

I am writing to register my dismay with this Council. May I respectfully ask what you don't understand about the two letters NO? 65000 West Norfolk Residents voted against incineration in West Norfolk. Norfolk County Council adopted a No incineration in Norfolk policy in December 2014 and yet nowhere is this stated in above mentioned plan. WHY NOT?
Also you are now proposing for fracking to go ahead in Norfolk. It is well known and documented that this is very controversial and known to have caused earth tremors and damage to surrounding property.
Do you think this would enhance the prospects for the housing development around the A10 corridor in West Winch? Who on earth would want to buy a property that stands a fair chance of being affected by fracking?
As regards above mentioned development in West Winch I understand that 350 houses have to be built before 1.1 million of funding will become available. So with other words we have to have gridlock before something can be done about it. Somehow that doesn't seem to be very sensible to me as it will also affect the businesses you are hoping to attract to West Norfolk.
I sincerely hope you will take the points the public is making to you into consideration in future decision making.

65000 West Norfolk residents voted NO to incineration in the Borough Council poll so the Plan must say incineration is unacceptable in West Norfolk.
The Plan must say fracking is unacceptable in West Norfolk, as it would affect the Wash, a protected area and West Winch Growth Area.

I note the incinerator and fracking is back on the counties waste plan.

65,000 west Norfolk residents voted NO to incineration in the Borough Council poll so the plan must say incineration is unacceptable in West Norfolk.
The plan must say fracking is unacceptable in West Norfolk, as it would affect the Wash, a protected area and West Winch growth area

I would like to object to any form of incineration in the minerals and waste plan at The Willows Industrial Estate, King's Lynn.
65,000 West Norfolk residents, including myself, voted NO to incineration in the Borough Council poll so the plan must say incineration is unacceptable in West Norfolk.
The plan must say fracking is unacceptable in West Norfolk, as it would affect the Wash, a protected area and West Winch Growth Area.

Here are my comments on the minerals and waste plan as a resident of West Winch for the last 14 years:-

65,000 West Norfolk residents voted 'No' to incineration in the borough council poll so the plan must say incineration is unacceptable in west norfolk.

The plan must also say fracking is unacceptable in west norfolk, as it would affect the wash, a protected area and west winch growth area.

I am writing to say that I oppose both the Incinerator being built at the Willows site and Fracking at Setchey.

A vote was offered to the residents in King's Lynn and district area and the vote was a NO to the Incinerator. Unless this country no longer is a democratic society the NO vote means NO.

The Fracking that is being done up north has already caused minor earthquakes and has been stopped to assess the damage it may be causing. Do those people who live in the area of Setchey have to go through the same process?

I am against incineration and fracking in West Norfolk as it would affect the Wash
a protected area and the West Winch Growth Area

As a West Winch resident of more than 30 years - I was part of the 5 year campaign against the incineration plant proposal for the Willows Industrial Estate, which was quashed. I was therefore shocked to find that this had appeared again on the draft Waste plan.

65,000 West Norfolk residents voted NO to Incineration in the Borough Council Poll stating that Incineration was unacceptable in West Norfolk - therefore this must not happen.

Along with this and in light of all the data around how dangerous Fracking is we find that there is a proposal for this to be placed in Setchey - this again must not happen - Fracking is being stopped all over the country - if this is pursued it will be met will huge opposition from the residents of West Norfolk.

People are more important than money - something the planners do not seem to understand.

I would like to protest about West Norfolk being included in the County's waste plan and also about the possibility of Fracking taking place in our area. The vast majority of the people voted not to have an incinerator in the recent past so why include it again. Perhaps the County Council have got another £30 000 000 to spare in which case they can use it to finance a proper A10 bypass for this area.

I object to incineration and fracking being included in the waste plan. It is unacceptable for county council to say that they have to be in the plan as they are national policies. This makes a nonsense of the concept of a 'local' plan which should consider the views of the local community.
Fracking may work in the open spaces of the USA, but is totally unacceptable in heavily built up areas.
65,000 West Norfolk residents voted No to incineration in a previous borough council poll. Th county council's attempt to force incineration on us became hugely divisive, resulted in the loss of a conservative majority in county hall and an eventual loss to council tax payers in excess of 30 million pounds. Does the council really want to risk going through all this again?

There are two issues that I would like to comment on:

Norfolk has a no incineration policy following the abandonment of the proposed facility on the Willows site in Saddlebow in Kings Lynn. In a poll organised by the Borough Council 65000 people voted to say that they did not want this built. Therefore. to keep the option of incineration in the proposals is in violation of the Council's own policy.

Fracking should not be allowed anywhere near people's homes or near the Wash or any other protected areas. In addition it is a retrograde policy at a time when we should be putting every effort in producing our energy from sustainable and low carbon sources. Therefore, fracking along with incineration needs to be removed from the Draft Plans.

Five years ago 65,000 West Norfolk residents voted a resounding 'No' to an Incineration plant in the Borough Council poll so it follows that the proposed Plan now on the table must specify that any incineration in unacceptable in West Norfolk.
In addition, the Plan must state that fracking is unacceptable in West Norfolk as it would affect the Wash that is a 'protected area', as well as affect the West Winch Growth Area.
The collective voice of local residents must be respected when it relates what is happening in their locality. Local communities have a democratic right to be consulted prior to any Plans being considered and certainly before any start to be are implemented.

'65,000 West Norfolk people voted No to Incineration in the Borough Poll and so the draft Plan must Take out Incineration and say that Incineration would not be Acceptable in West Norfolk"
Thanks.

I am writing to you to voice my concerns that incineration and fracking are in the county plan ,as you know incineration cost the county 40 million last time and the leader his job .
65,000 West Norfolk residents voted no incineration in Norfolk as the representative of these people you should be mindful of their wishes. fracking is also damaging to people's homes and this concerns me greatly as i live in West Winch. No incineration or fracking in Norfolk

County Councillor Response to Minerals and Waste Preferred Options Consultation
The Minerals and Waste Plan must state that 65,000 West Norfolk residents voted No to incineration in the Borough Poll and that Norfolk County Council has had a No Incineration in Norfolk Policy since Council's Motion of December 2014. People campaigned for 5 years to stop the incinerator in South Lynn and are outraged that incineration is still in the Plan.
The people's will must be respected.
The Plan must also state that fracking, and prospecting for fracking, will not be permitted in West Norfolk or around the Wash, as prospecting causes earthquakes and tremors. It is contradictory to say that prospecting for shale gas would only be allowed where there are no unacceptable environmental impacts. Around the UK prospectingalways causes unacceptable environmental impacts, and fracking notably caused a recent earthquake of 2.9 on the Richter scale at the UK's only active fracking site, in Blackpool, which saw its third record-breaking earthquake in under a week this August, breaking through a limit which made the government ban fracking for two years in 2011.

The National Planning Policy for Waste accepts that incineration can be excluded from a local plan at Page 6, where it says that "proposals such as incinerators that cut across up-to-date Local Plans reflecting the vision and aspiration of local communities can give rise to justifiable frustration".

The National Planning Policy for Waste says, at page 4, that there should be "early and meaningful engagement with local communities and plans shouldreflect a collective vision and agreed set of priorities, recognising that proposals for... incinerators can be controversial"

How can the Inspector not agree with these words of wisdom?

65,000 West Norfolk residents voted NO to incineration in a Borough Council poll, but once again Norfolk County wish to include incineration in their plan for West Norfolk. The Plan must make very clear that incineration is unacceptable in West Norfolk. The County Council must take into account the wishes of those 65,000 residents otherwise it is another nail in the coffin of democracy.

Fracking in West Norfolk should also be excluded from its Waste Plan as there is no evidence as yet that it is a safe method of extraction and could possibly cause damage to properties, not only in close proximity, but in a much wider area.

Fracking in West Norfolk is unacceptable as I believe it would cause damage to the Wash, a protected area, and detrimental to the West Winch Growth Area.

KLWIN
Kings Lynn Without Incineration (KLWIN) was formed as a broad-based organisation dedicated to the defeat of the Willows waste incineration plant proposal at Saddlebow Kings Lynn. Notwithstanding the victory over that scheme, KLWIN remains an active organisation to this day and retains its opposition to incineration at any location in Norfolk.
KLWIN wishes to express its opposition to the inclusion of incineration in the relevant residual waste sections of the Preferred Options Document. (W10,WP10). In acknowledgement of the human and other resources demands upon the Authority of taking the Minerals and Waste Plan to completion and approval KLWIN has chosen not to activate its membership base to inundate the consultation process with repetitive versions of our case. We hope that our case rests on its technical merits rather than in force of numbers.
Incineration
KLWIN takes incineration to include all processes, technologies, and plant designs which thermally 'treat' residual waste and require a stack for the discharge of some or all of the thermal treatment by-products. The term stack is used in the normal understanding of the word as being a structure raised above the level of the surroundings and intended to emit and disperse solids, vapours and gases (in this case some or all of the by-products of the thermal treatment of residual waste). KLWINs definition of incineration therefore includes processes which may be referred to by other names including but not restricted to gasification, pyrolysis, advanced thermal treatment, CHP etc.
The need for a stack is the defining feature of those approaches to residual waste treatment that KLWIN does not wish to see adopted in the M&W Plan.
KLWINs Objections
It should be noted that a full, referenced technical discourse on the dangers posed by thermal treatments of waste is not possible or appropriate in such a consultation opportunity. KLWIN has set out a few key issues to illustrate the rational of its objections to thermal treatment.
It is KLWINS position that any process of thermal waste treatment that employs a stack will be producing particulates especially pm 2.5s which are increasingly recognised as of clinical concern over a wide range of health issues which are almost daily attracting attention as being of public health concern. Currently vehicles and wood burning stoves are the pm 2.5 sources attracting the most attention.


What is unique about thermal treatment however is that the pm 2.5s attract dangerous contaminants from the waste e.g. cadmium, arsenic, lead, dioxins, furans etc. The benchmark study of incineration particulates by London University intended by the Public Health England to provide reassurance to the public only studied the larger pm 10 particles which are medically of little concern. Assurances by operators and filter manufacturers regarding their efficiency for retaining pm 2.5s is based upon the mass of particulates captured not the numbers of particles. The results are therefore biased by the disproportionate capture rate of the much larger higher mass pm 10s!
Stacks also emit CO2 with its well-established capacity to contribute to global warming and the myriad problems associated with it and its risk to our legal and moral obligations to reduce such risks. Oxides of Nitrogen are invariably generated by combustion processes and figure repeatedly as key components in air quality control zone problems. The impact of these gases upon human health are well documented and are growing in the UK. While public health concerns do not carry much weight in planning decision making the Minerals and Waste Plan provides the opportunity to avoid these issues by omitting their causes at this formative stage. Residual waste thermal treatment plants are point sources of atmospheric pollution which impact downwind populations and environments. KLWIN does not think that any communities should be exposed to the unique, complex mixtures of dangerous gases, particles, compounds or elements they produce regardless of the efforts to filter or neutralise them.
These effects are not restricted to human residents, agricultural crops & livestock the vegetation and wildlife of our countryside and nature reserves are not immune from damage. Some of the contaminants are as dangerous as they are chemically stable. Dioxins have no safe minimum expose level for humans yet can remain and accumulate in the soil and living tissues for years.
Thermal treatments compete with recycling technologies for resources. Advocates of thermal treatments may claim it is only for waste that cannot be recycled but in practice recyclable materials are often subjected to thermal treatments. Long contracts linked to a minimum tonnage of waste for treatment is a typical scenario which can put pressure on parties to use recyclable materials to avoid contractual penalties.
Conclusion
KLWIN oppose the inclusion in the Minerals and Waste Preferred Options Document of any thermal residual waste treatment approaches that include a stack or stacks in the facilities design and operation. Such treatments pose unacceptable risks to human and environmental health and wellbeing and can compete with recycling.

Minerals and Waste Plan
Once again, the residents are being ignored by the Council They are wondering why an incinerator is back in the minerals plan.
In 2014 the locals protested loudly against the incinerator plan for South Lynn. Eventually, the plan was dropped. However, now it appears this may well be built after all. Do you not understand the people of Norfolk - the Council tax payers - disagree vehemently with this? Democratically, are not Councillors elected to carry out the wishes of the electorate? Obviously, they have forgotten the previous fight and the moans from your office relating to the money aspect.
We all fail to comprehend why an incinerator and fracking should be included in your minerals plan. Both would badly affect the whole area also cause further air pollution, damaging the health and welfare of everyone.
Parts of Norfolk will be destroyed and we rely on visitors and holidaymakers to help with the local economy. These people will not come as there will be no pretty scenery or beautiful buildings to see.
We feel these new proposals are unacceptable, damaging and ruinous to Norfolk

I am writing to you with reference to the attached copies of letters printed in the last two editions of "your local paper" relating to the above subject. These letters express the feelings of very many people in this area.
I have spent much time trawling through the Preferred Option Plan on the County Council website to no avail, and consequently I am writing to express my views on this subject and those of my wife, namely that there should be no incinerator or fracking in West Norfolk and that any mineral extraction should be conducted well away from houses, areas of proposed housing development, and places of natural beauty.
Furthermore, I feel that the on-line consultation process seems so complex and time consuming as to dissuade the general public form commenting on the proposals.

The minerals and waste plan must say that 65,000 West Norfolk residents voted No to incineration, in a Borough Council poll. Norfolk County Council has a no incineration in Norfolk policy. Incineration and fracking is UNACCEPTABLE in West Norfolk. I used to live in Blackpool. They have been fracking there and earthquakes of increasing size have occurred. Fracking has had to cease.
Will it take the toppling of the Tower to make authorities wake up and see sense? Don't play with our special environment.

I was dismayed and horrified to learn that the County Council has put incineration for Norfolk back into the minerals and waste plan and also to permit prospecting for fracking.
Both these considerations must on no account be allowed to go ahead and I am writing to express my disapproval. The very idea of fracking, so close to the wash & very near places of growth areas, is an abomination after evidence of problems in the north of the country.
I recall vividly the many weeks of special inquiry held in King's Lynn about 5 or 6 years ago, so many meetings of which I attended. The outcome, which you seem to be ignoring, ensured that a no incineration policy in Norfolk was declared and the Willows site for waste incineration was cancelled.

To whom it might concern in the Norfolk county Council.
What are you thinking about for people living in the West Winch to start again with the worry of having another thought about incineration and fracking, WE DO NOT want either, how can you when you are planning 4000 houses in West Winch & North Runton expect people to buy these houses with such views, you only have to ask people in areas where fracking has been started & the earth tremors have appeared.
We have lived in West Winch for 48 years, very happy in the village, how do you expect families to think about moving to live in West Winch with all this hanging over their heads, we as an owner would never be able to sell our house nobody would want to buy it. I bet if a few Norfolk County councillors lived in West Winch the result would be different. We are both not in agreement with any of the TWO PLANS.
We Will fight and fight until people see sense.

Over 65,000 residents have already voted NO to incineration of waste in West Norfolk. The mineral and waste plan consultation must say that incineration of waste in West Norfolk and also any attempt at "Fracking" is not acceptable as it will affect the "Wash", an already protected area and West Winch Growth Area.

For the attention of Planning Services Dept, Norfolk County Council

65,000 West Norfolk residents voted NO to Incineration in the Borough Council poll so the Plan MUST say incineration is UNACCEPTABLE in West Norfolk.

The Plan MUST say Fracking is UNACCEPTABLE in West Norfolk as it would affect the Wash, a protected area and West Winch Growth Area.

I vote NO (again) to Incineration and vote ABSOLUTELY NO to fracking!!!!!!!

Firstly; the Sand, Gravel, Carstone and Silica sand tonnage you require, all traded on the international minerals market, you do not have to have applications for mineral developments within Norfolk which has an unknown "total" cost. You can buy forward on futures markets to meet the demand you need. Developing Middle Eastern countries have abundance of sand and other minerals, economically they find buying from Australia a leading mineral exporter and other countries, far more cost effective also more environmentally friendly.
Secondly; to even contemplate extraction near Fritton is surprising, with too many issues. How are you going to remove the minerals? By road? One way road through St Olaves , main road to Gr Yarmouth , Fritton unsuitable for heavy trucks (warning sign for trucks having to move over to centre and beyond in road ). By boat? Which will destroy all the Holiday business from St Olaves, Somerleyton and beyond to Oulton Broad.
The gravel beds you plan to remove, filter the underground water through to the local river system and Fritton Lake. Removing the filter bed will have catastrophic impact on the whole water system polluting the river system and Fritton Lake. Somerleyton Estate is investing millions of pounds to generate tourism and upgrade the holiday offer in the area, increasing employment plus a vast range of other benefits. Not only Somerleyton, many other local enterprises have invested in the future of the area, you will jeopardise all investment and question the success of all local business .
I note your title is not only minerals, waste as well, are you planning to dig a big hole and then fill with waste? Making a triangle from Haddiscoe , Bradwell , Oulton Board a NO GO AREA for over 10 years, and have all the residents (there will be no tourists) having to put up with the smell of waste for years to come.
Johnson Matthey (British Company) leading the world in technology on removing pollutants from burning fossil fuels, there's an opportunity for Norfolk Council to lead in Climate Change by investing in a power station burning waste, dramatically reducing emissions ( buried rotting waste is a time bomb for climate change).
It's easy to call the concerned NIMBY's when Development, can Destruct Environment, Against The Habitat, DEATH.
Your "Preferred Option" should be to purchase the minerals on the open market at best price secure supplies on forward purchase. Waste look at the best way on cost and on Climate Change, looking into Eco generation plant that burns waste in an effective low carbon system, with removal of toxins with Johnson Matthey technology. Make Norfolk a leader in Climate Change, by pioneering waste management to electric generation.