Policy WP10: Residual waste treatment facilities

We wish to register our grave concerns on the following two items contain in above plan.

Incineration. As West Norfolk residents we voted alongside 65,000 others to say no incineration in the previous Borough Council poll & find it totally unacceptable that this is now being reconsidered. The abortive costs associated with earlier application should bourn in mind.

Fracking. Report published today raises concerns regarding greenhouse gas emissions, ground water pollution, potential for fracking induced earthquakes & cost associated with land reinstatement & decommissioning. This should not be considered in an area identified for growth in West Norfolk.

Norfolk County Council Planning Department
To whom it may concern:
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.

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.

Fracking
Unnatural disturbance of the Earth's geological structure and plates is caused by fracking. Unknown effects could be disastrous and harmful for communities. It is irresponsible and dangerous for the current and future population. Fracking will contribute to climate change so goes against all policies to lessen effects of unnatural 'actions', eruptions and earth tremors.
Fracking already taking place in the Country has caused several tremors, causing fear, alarm and distress to residents. This is a material effect on human health and well-being.

Incineration
West Norfolk is responsible for more than a quarter of the County's emissions
(Lynn News page 12 - 9 August 2019.)

To allow, or even think of putting incineration into policies, is blatantly going against democracy of the last King's Lynn & West Norfolk Borough Poll where 65,000 people voted against incineration and NCC wasted millions of pounds on an abandoned project. Efforts should be put into alternative methods of waste reduction and disposal, or re-use schemes.

Questions asked by Norfolk County Councillor, Alexandra Kemp to NCC Cabinet.
Following £34 million lost from Council's budget, with the cancellation of the infamous South Lynn incinerator contract for Planning Failure in 2014, Council agreed a No-Incineration-in-Norfolk Policy, ("Appendix M").

West Norfolk is alarmed by the criteria-based Draft Waste Plan, which fails to state our No-Incineration Policy, instead permissively lists forms of incineration ( page 56), endangers West Winch Growth Area by permitting prospecting for fracking ( page 90), erroneously ignoring prospecting always causes earthquakes.

Can Cabinet amend the Plan to state " in West Norfolk, where 65,000 people voted against incineration in the Borough Poll, applications for incinerators will not be permitted"; and exclude fracking and prospecting for fracking?

West Winch Parish Council agrees with the County Councillor, Alexandra Kemp.

We do not need these policies which can cause more problems with emissions and climate change.

Policy WS07 Huge risks to human health and well-being and Air Quality page 17, para 5.18.

Page 26 Presumption in favour of sustainable development is likely to breach 7.1 (b) Communities health....
'Presumption in favour ...' should be removed.

Policy MW2 Development Management Criteria
'Unacceptable impact on (a) to (m).

Page 28 Pollution and Local Amenity Impacts
Para 8.9 there should be no impact on human health - densely populated area King's Lynn and proposed massive development at South East King's Lynn (SEKL).
Para 8.20 mentions Ancient Woodland - This must also apply to historical Grazing Commons, especially in West Winch and North Runcton.

Historical Environment
Para 8.28 - King's Lynn has ancient historical buildings. Harmful emissions and fracking would affect these valued buildings which attract visitors and tourists, contributing major finance to the area's economy.

West Winch and North Runcton have protected sites of local value -
Reference - page 20, West Winch and North Runcton Neighbourhood Plan (Planning material consideration)
Plus, 2 sites of Special Scientific Interest, and
3 County Wildlife Sites, including West Winch Common.

Page 32 - Land and Soil Resources
Para 8.31 Agricultural Land, which should include Grazing Common Land, must all be protected from contamination to protect our food chain for the future of the whole Country.

Page 34 Cumulative Impacts
It is imperative that cumulative impacts are taken into account as too often measurements are only taken close to the proposed development. Cumulative measurements impact on human health.

Page 46 '.... Not considered necessary to allocate any waste management sites in the Plan' - which means these sites can be developed anywhere on industrial sites etc and they could be near to densely populated areas.
This should be scrutinised more closely and incineration must be deleted.

Page 46 Policy WP1 Hazardous -----
Norfolk County Council needs to keep tight control over hazardous waste received from other Waste Planning Authorities.

Page 48 Policy WP2 Distance
Distance of waste facilities needs to be considerably increased to safe levels for human health away from populated areas.

Incineration in Kings Lynn, in particular adjacent to West Winch, is unacceptable.
The main objections are increased traffic volume and air pollution created by traffic exhaust fumes.

Fracking has been found to create more problems than the sponsors forecast and is being abandoned nationwide. Tremors in the Wash would seriously affect the existing ecology.

Original response received 30.10 2019
Revised response received 18.12.2019

3. Implications for the Borough from sand and gravel and silica sand policies / areas
3.1 Tottenhill (Site 206 - West of Lynn Road) This is an extension of existing works. The Tottenhill sites would be worked sequentially to mitigate any cumulative impacts. Potentially acceptable subject to the requirements in the policy.

3.2 A site at East Winch (Site MIN06 Mill Drove, Middleton) is allocated for carstone extraction. Potentially acceptable subject to the requirements in the policy.

3.3 Silica sand - AoS's (E, F, J and I) and SIL01. The County Council concludes that Site SIL01 is suitable to allocate for silica sand extraction. Development will be subject to compliance with the relevant Minerals and Waste Local Plan Policies and Specific Site Allocation Policy SIL01. There are reasonable safeguards for the locality.

3.4 The AoS are the same as previously expressed in the Initial Consultation document. Silica sand is a nationally important industrial mineral, and as such, the County Council must make adequate provision for its extraction. However they are not able to find suitable sites for the quantity of sand required, especially having dropped a site at Shouldham / Marham. The AoS are large and the expectation is that a suitable location could be found within one of the areas. Without detailed further information or operator preferences, it is not possible to pinpoint a site and therefore assess the localised impacts. Whilst this may be unsatisfactory for local communities who fear the consequences of extraction, it does give a positive indication that the County Council is safeguarding land and narrowing down suitable sites. It would be unrealistic to seek to have no areas of search at all, and the Plan could be found 'unsound', which would not be of benefit to the area.

Policy MP13 Silica Sand Area of Search (AoS E - Shouldham Warren area) and Policy MP2 - Spatial Strategy for mineral extraction (including reference to Silica Sand Areas of Search, and buffer zones (clause e))
3.5 Policy MP13 provides a criterion based approach to potential development in Areas of Search, including Area E. The expectation is that various assessments about related impacts will be provided in support of any applications, covering matters such as archaeology, landscape etc. Heavy reliance is placed on the safeguards from supporting studies to achieve acceptable development.
The recent decision by Norfolk County Council (in respect of it's Environmental Policy - County Council 25 November) to support the planting of some 1 million trees over the next 5 years to mitigate for the effects of climate change suggests a significant policy shift in the important role that trees play in County Council operations. It is clear that much more attention needs to be given the retention of existing tree cover in any mineral extraction situation. Shouldham Warren is an extensive area of tree cover, with additional recreation opportunities. An elevated status needs to be given to this in the planning balance as to whether an Area of Search should be designated at Shouldham, the Borough Council view is that the County Council should remove the AoS for this reason.
Additionally, Policy MP2 provides a degree of protection for areas with defined characteristics. Clause a. refers to 'ancient' woodland. In view of the County Council decision referred to above, it would be appropriate to delete the word 'ancient', leaving an enhanced level of protection to woodland generally.
Conclusion on AoS E (Shouldham) - Taking into account the two proposed amendments to policies affecting the potential for extraction at Shouldham, and the significant additional constraints now evident, the AoS should be removed.
MP2 Clause e) - Whilst the hydrological catchment around Roydon Common and Dersingham Bog, is specifically mentioned in Policy MP2e for exclusion, the complex hydrology and geology of these extremely sensitive sites is not fully understood. These two habitats have been recognised through the Ramsar, SAC and SSSI designations as having protected status. The introduction of wider 1.5km buffer zones would better mitigate any risk.

3.6 Policy MP7 (relating to restoration and aftercare) suggests that preference will be given to enhancing biodiversity, green infrastructure, and high quality local landscapes. This approach is supported. Whilst not necessarily appropriate in all circumstances, tree planting on restored sites would be a useful additional boost to mitigate for climate change. It is proposed that an additional clause is added to this effect as a fifth bullet point in paragraph four to the policy.

4. Implications for the Borough from the NCC approach to proposed waste and other policies on 'energy minerals'.

4.1 NCC have reviewed the policies in the current plans and as with Minerals moved them on to an end date of 2036. One particular item is relevant to West Norfolk. This is the overall locational strategy for waste management facilities.
4.2 Main points:
* From Policy WP2 in the Preferred Options it would seem possible to locate waste management facilities away from the broad location that generated the waste. Thus necessitating potentially significant transport movements, and possibly generating resentment from recipient communities.
* Whilst not necessarily inappropriate for all types of waste where specialist facilities are needed, extremely careful thought should be given to general waste or significant quantities requiring movement.
* A better approach would seem to be one where the policy encouraged waste to be dealt with as near to the generating source as possible.
* It is suggested our original comments are still appropriate to make.
4.3 Incineration - For the avoidance of doubt, it would be helpful if the County Council could add text to explain the position whereby the County Council will not seek to procure incinerators within Norfolk.
The position of the Borough Council on incineration is clear from previous involvement in planning inquiries. A clear statement on the matter from the County Council in the Minerals and Waste Local Plan would avoid any uncertainty for residents.

4.4 Fracking - Reference could be made to latest Government announcements about the potential restrictions / banning on this subject.

We write to you on behalf of our client, Lichen Renewal, an independent UK company operating as an innovator in landfill site recovery and restoration.
Lichen Renewal (LR) has patented a holistic approach to capture Greenhouse Gases released from former landfill sites by capping them, using the harnessed gas to dry green waste, which is then used to generate renewable energy for either local users or to be transmitted via the National Grid.
Enclosed alongside this letter is an informative brochure about LR and the offer they can give to assisting in reducing greenhouse gas emissions.
In regard to the the emerging Norfolk County Council Minerals and Waste Local Plan Review consultation, which this letter relates, the effort to consolidate three separate documents into one cohesive and comprehensive Waste Management Local Plan is to be commended, and LR are in general support of the Plan, the policies within it, and the overall Vision.
A consistent target within the plan is 'to move waste up the waste management hierarchy to minimise the need for landfill.' (p90-100), which LR greatly support as an initiative to reduce waste, and to limit the impact of waste on the environment.
Policy WP10 (Residual Waste Treatment Facilities) is broadly supportive of facilities that meet the criteria of other plan policies. It states 'Facilities that include thermal treatment of waste must provide for the recovery of energy and, where practicable, heat; and the use of combined heat and power will be encouraged'. The endorsement for the generation of heat and power from waste is positive, and a factor which LR's technology can deliver.
Additionally, the plan states in the introductory text that "The Plan will provide an approach that ensures suitable areas for sustainable waste management facilities are identified and that there is a flexible approach to waste technologies so that innovation within the market is encouraged, while still providing appropriate safeguards". This forward-thinking initiative encourages new technologies to come forward in order to further move waste up the waste management hierarchy in previously unforeseen ways.
In line with the target 'to move waste up the waste management hierarchy to minimise the need for landfill', mentioned several times in the Implementation, Monitoring and Review table (p90-100), LR could offer a solution to move existing landfill sites from 'disposal' to 'other recovery'. According to the Waste Management Capacity Study (2017), there are two permitted landfill sites in Norfolk with 5.09m tonnes of void space, both of which have been mothballed. We think that one (or perhaps both) of these sites could be an opportunity for our technology, and would like to investigate this further with you.
With this in mind, we would like to propose a meeting with the Council, to explain the processes of a Lichen Renewal facility and to discuss the possibility of a waste management project in Norfolk to positively harness the greenhouse gases released from a former landfill site within the County.
We look forward to formal confirmation that these comments have been received and processed. We also look forward to the opportunity to comment on the further phases of consultation on this plan. If you have any questions or queries regarding the points raised in this letter, please do not hesitate to be in touch with me, or my colleagues at your earliest convenience.