This analysis was based on a small selection of the various documents in Veolia Environmental Services' planning application to build an industrial scale incinerator at New Barnfield. So there are probably further reasons for people to oppose it. However, this may serve as a useful guide for people who want to voice their concern.
Please note: objections need to reach the Planning Office at Hertfordshire County Council by 31 January 2012 at the latest.
Also, please use the HAI leaflet (link below) as a guide to the areas which the planning department is likely to be focussing on.
Objections can be sent by email to: email@example.com
Or mail to: New Barnfield Planning Team, Spatial and Land Use Planning, CHN216, County Hall, Pegs Lane, HERTFORD, SG13 8DN
Or respond online via through HCC's website (there is a link at the bottom of the page to an online form but you will be restricted to 3,900 characters): www.hertsdirect.org/services/envplan/plan/planningapps/nbplanapp/
Or handed in, by 27 January 2012, to the addresses given on the HAI leaflet (please click here for a link to the PDF document).
Some common abbreviations:
EA – Environment Agency
CHP – Combined Heat and Power
CRL – Central Resources Library
HCC – Hertfordshire County Council
HIA – Health Impact Assessment
HMOs – Houses in Multiple Occupation
HSE – Health and Safety Executive
HTC – Hatfield Town Council
VES – Veolia Environmental Services
WHBC – Welwyn Hatfield Borough Council
Please note: there is a certain amount of overlap between the various headings. Also, URLs to external websites will need to be copied and pasted into your browser address bar to access these pages.
1.1 This is an area which appears to have been largely glossed over – even though it is likely to have a devastating impact on Hatfield, which is already suffering the results of it being managed from Welwyn Garden City (a town it was artificially linked with in the 1970s).
1.2 Hatfield is a town of national and international historic importance – particularly in relation to its Elizabethan, Victorian and aviation connections (and was a key social centre in the 1930s), it’s within convenient commuting distance of London and Cambridge, and has excellent transport links.
1.3 The redevelopment of Hatfield town centre has been stalled for a decade. Even before the announcement of the incinerator and the current recession, the selected developers for the second scaled-back attempt, St Modwen, claimed that they were having difficulty in securing an anchor store that would enable them to sell enough retail / catering space and housing units to make the project viable. The presence of a large incinerator / waste park, especially with Britain’s worsening economic prospects, is likely to make this task next to impossible.
1.4 It is also likely to have an impact on the proposed High View (Hilltop) development in South Hatfield. WHBC have already linked this to progress on the Hatfield town centre redevelopment.
1.5 Hatfield badly needs to attract young professionals to secure its long term future and underpin its civic development. Exactly the sort of educated people who will NOT want to raise a family or work near an incinerator.
1.6 Hatfield has already seen a negative impact due to the incinerator proposals with the announced loss of the Central Resource Library. Given the cutbacks to the small town centre library in 2011, once it is closed Hatfield will have lost 75 per cent of its library access (including free wi-fi, study spaces, printers, photocopiers, and access to PCs). Hatfield is also home to the University of Hertfordshire, and has a very high number of Houses in Multiple Occupation (HMOs) – largely used by students and migrant workers (both groups that do use these facilities). Further details of the impact on library provision are listed in the CEG minutes (17/08/11 Point 3 – towards the end).
1.7 Impact on employment – in addition to the loss of civic facilities, according to HCC figures (FOI/FRS/08/11/3526), 72.11 Full Time Equivalent jobs (the senior librarian has indicated around 90 library staff are employed at this site) will go as result of shutting down the Central Resources Library and other services (excluding the Park Educational Support Centre). So there is already a net loss in employment (the incinerator will provide less than 60 full time jobs).
1.8 It is also debatable as to whether Mitsubishi Electric will stay on their offices across the road from the site – and whether anyone else other than a business connected with the waste industry will want to move in should they go (which would be an additional blight). Add in the likely loss of construction and full time retail / office / catering jobs from the town centre and High View redevelopments and it is clear that this project poses a disaster for Hatfield.
1.9 Veolia’s inclusion of a visitor centre in the incinerator as a community amenity appears to be little more than a move calculated to gain planning permission – its presence will not enhance Hatfield. It is extremely doubtful whether anyone moved to a residential area because it had an incinerator. Their own traffic figure projections cite only two vehicles a day (Transport Assessment, Table 3, p.23) – hardly a great draw. And this should be seen against the blight on the rest of the New Barnfield hillside and neighbouring residential area.
1.10 Veolia’s Volume II, Chapter 14 (Archaeology and Cultural Heritage), 14-39 suggests a potential threat to Hatfield House, which celebrated its 400th anniversary in 2011, and the Water Mill at Mill Green: “…there is potential for increased levels of emissions to contribute to the decay of historic fabric. For example, the prolonged exposure to weathering of certain building materials such as limestone and lime mortars can sometimes lead to the breakdown of historic fabric.”
The impact on the Southfield School, health, traffic / road safety, security, and the risks to taxpayers are covered below.
2.1 Air quality – there is now a substantial body of evidence that
particulate pollution (largely from traffic – whether uncombusted fuel
or ground off tyres and brake discs) is a danger to human health:
“Long-term exposure to air pollution may have contributed to all 15,800 deaths due to cardiovascular causes in London in 2009 (i.e. one in three of all deaths) at an average additional loss of life for each of these adults of some three years at typical ages (e.g. 15% below age 65) New scientific research indicates that children exposed to higher levels of traffic-related air pollution at school and home are at increased risk of developing asthma.”
Edinburgh University scientists found minuscule particles produced by burning diesel can increase the chance of blood clots forming in arteries...It was found that the particles, and not the gases, impaired the function of blood vessels...Professor Jeremy Pearson, associate medical director at the British Heart Foundation, said: "We've known for a long time that air pollution is a major heart health issue..."
According to Veolia’s Health Impact Assessment (p.57) measurements carried out at the de Havilland School between December 2010 and August 2011 showed higher than expected readings – it explains this as being due to weather conditions leading to a cap of still air which trapped the pollutants (p.58).
2.2 Hatfield is home to several major transport depots (Parcelforce, DHL, Ocado, CityLink, Yodel), and the Uno bus garage. In addition, Arla Foods has recently announced its intentions to build a food distribution centre in Hatfield (WHT 14/12/11 p.72). Plus, the Tesco depot (on the Welham Green side of Travellers Lane) is only accessible by road from Hatfield. These are in addition to the A1M which runs through the town via the tunnel. So there is the added threat to human health particularly from increased HGV traffic.
2.3 Veolia has conducted traffic surveys, but these will do not factor in the impact of developments which do not have planning permission so the impact of several major developments – like the proposed football grounds and stadium at Angerland Common (off Southway A1001); the planned increase in student accommodation at Bishops Rise (1,500 to 2,500); the High View redevelopment; or the impact of the development of the Veolia Water site on the same road – are not included. Further, there is a serious question as to their reliability due to the dates the traffic surveys were carried out (please see Point 10.7).
2.4 Then there’s the emissions from the incinerator itself – the
Environment Agency and Veolia are trying to maintain that there is no
problem with modern incinerators. It is interesting to note that when
incinerators were – as it is now acknowledged – releasing highly toxic
chemicals, like dioxins, there does not appear to have been any warning
given to the general public. Also, apparently the Environment Agency
considers breaches of safety limits to be inevitable, and is not
concerned by the occasional ‘spike’ (CEG 19/10/11, Point 7.7.1 and
7.7.2). As to the cumulative impact of these releases it is anyone’s
guess but it is probably safe to say that will NOT be beneficial.
2.5 It is worth remembering the decades it took to finally establish that smoking posed a danger to human health – even though there was no shortage of evidence. However, the true picture was blurred as a number of tobacco companies were later found guilty of suppressing evidence ie. in effect, some of the world’s most profitable businesses deliberately slowly murdered people for the sake of making more money.
2.6 There already are already reports of potentially adverse health impacts in other areas with incinerators:
"Chingford Green Ward has the second highest number of child deaths relative to its population in the whole of London, according to the most recent figures. Infant mortality rates are usually found in areas of high deprivation but Chingford Green Ward is the second richest part of the borough. The ward is close to Britain's largest incinerator in Edmonton and one researcher, Michael Ryan, says he has gathered evidence from across the country that areas situated where toxic emissions start to fall to the ground have a high rate of child deaths."
"Figures from the Office of National Statistics show a jump in infant deaths in Great Lever - where the Raikes Lane waste plant incinerator is based. The Royal Bolton Hospital is also on the edge of the ward boundary. The Health Protection Agency (HPA) does not believe incinerators cause “significant risk”, but is now looking to reassure the public with a special study."
2.7 According to Veolia’s Health Impact Assessment (p.58) measurement of ultrafine particles are not routinely made, and “concentrations rise by orders of magnitude in the immediate vicinity of strong sources, such as the A1(M) for example”.
2.8 The fact that the Health Protection Agency is carrying out a study suggests that there is a lack of definitive data. In any case, simple common sense suggests that it is sensible to err on the side of caution rather than risk poisoning a large number of people.
2.9 Apart from the A1M and local HGV traffic, air quality in Hatfield could potentially be affected by other existing and planned /proposed facilities, like Edmonton (London EcoWaste Park) and Fieldes Lane, Hoddesdon.
2.10 Hatfield South ward is, according to Veolia’s Health Impact Assessment (Point 4.2.7), “almost fifteen times more densely populated than the surrounding wards and the national average and six times more densely populated than Welwyn Hatfield Borough and Hertfordshire County.”
2.11 According to a report in the Sunday Times (22.04.12, p.6) researchers from the Royal London Hospital (led by Professor of Paediatric Respiration and Environmental Medicine Jonathan Grigg) particulate pollution (particularly from traffic – especially diesel fumes) damages the health of children by stunting lung growth and function. This research is part of a larger study into air pollution under Dr Frank Kelly, Professor of Environmental Health at King's College, London.
3.1 Hatfield already has increasingly congested roads with a high volume of HGV traffic thanks to the large number of logistics and distribution companies located here (Point 2.2). Add in expected growth in local traffic due to the planned expansion of student places at Bishops Rise (and the development of High View and the Veolia Water site on the same road) and plans to build a football stadium at Angerland Common and there is a danger of increasing congestion leading to gridlock (more traffic jams / slower moving traffic will have a direct impact on air quality).
3.2 According to Veolia’s Health Impact Assessment (p.36) there is already a higher than the national average number of road traffic accidents.
3.3 Thanks to the university there are a high number of young, inexperienced drivers resident in south Hatfield, and there have already been a number of accidents at the roundabout near New Barnfield . The situation is further compounded with the UH Park and Ride located on the A1001 South Way and slower moving funeral corteges travelling to the cemetery adjoining it.
3.4 The New Barnfield segment of Travellers Lane already sees a high volume of HGV traffic due to the Tesco Distribution Centre. While vehicle access ends at that point there is a popular foot and cycle path linking Hatfield with Welham Green, whose users will be threatened/intimidated by the HGV traffic – particularly as currently it does not cross their path (apart from a few deliveries to the CRL and Southfield School).
3.5 There appears to be no consideration of seasonality in Veolia’s Transport Assessment. As people in the area saw in December 2011 there was a marked increase in the number of HGV moving in and out of the Tesco Distribution Centre – a period which would also be accompanied by a marked increase in waste generation (something that would be repeated at Easter and other retail peaks).
3.6 HCC is planning on temporarily (allegedly) moving Southfield School to a site in between Woods Avenue and Old Rectory Drive (please see 11.3) solely in order to move the sensitive special needs children away during the construction of the incinerator. This will lead to further congestion during the school run as there are already a number of schools in this area: St Philip Howard Catholic Primary School, Bishop’s Hatfield Girls’ School, Oak View Primary & Nursery School on Woods Avenue; De Havilland Primary School (and De Havilland Children's Centre)on Travellers Lane; Onslow St Audreys School on Old Rectory Drive; and a new Free School being built on Briars Lane. Additionally, it is very close to Hatfield town centre.
3.7 Please refer Point 10.6 regarding flaws with the data used for their traffic model.
4.1 The visual impact is far greater than the Veolia planning application suggests. Also, on the day that they flew the inflatable to obtain readings there was a strong, gusting wind which noticeably pulled the cable from the upright and thereby reduced the height of the streamers. Plus, there was a smog which reduced overall visibility, particularly in the morning.
4.2 Artist illustrations used by Veolia generally show the incinerator when there is leaf cover. Its visual impact will be far greater after leaf fall. And particularly in low temperature / light conditions when the exhaust plume will be far more visible.
4.3 Further, there does not appear to be any mention / indication about aircraft warning lights (apart from a brief comment in the HIA, which referred to them as “assumed”). Given that the facility is on high ground on / close to the approaches to Panshanger and Luton airports it would seem odd if these were not required.
4.4 The Veolia Planning Application includes a view taken near the road bridge crossing the railway tracks at Welham Green. However, the view at the summit of this humpback bridge is far more revealing than the angle they have shown (indeed, with the leaf fall it is now possible to see the existing chimney at the New Barnfield site).
4.5 There do not appear to be any views from the railway lines itself ie. the views that rail passengers will see (which will influence opinions of Welham Green / Hatfield).
4.6 The incinerator will be visible from and have a negative impact on key heritage assets, like Grade One listed Hatfield House and Gobions Folly Arch (it is also bound to be visible from St Albans Cathedral). In addition to the inevitable periodic breaches of emissions limits, the fumes from the increased HGV traffic pose a threat to flora and fauna in Hatfield Park and other nearby nature sites (including an SSSI).
4.7 Dutch Elm Disease (caused by two species of the Ophiostoma fungi) has already wiped out the UK Elm population and the now acknowledged out-of-control outbreak of Ash Dieback (caused by the fungus Chalara fraxinea) are evidence that tree cover can be lost in a short space of time and given that all major UK native tree species are facing a variety of threats cannot be counted upon to screen the incinerator. Indeed, if anything, the impending loss of Ash trees means it is likely to become visible from even more areas.