Incinerator planning application objections – Part 2

Grounds for objections

Please note: there is a certain amount of overlap between the various headings

5. Environmental Impact

6. Community Involvement

7. Cost Effectiveness / Value for Taxpayers

8. Security Threat

9. Veolia's Safety Track Record

10. HCC Process and Flaws / Apparent Bias in Veolia's Planning Application

11. Impact on the Special Needs Children of Southfield School

12. Summary



5. Environmental Impact

5.1 Apart from the visual impact and pollution already covered, added HGV traffic will result in noise, dust and particulate pollution which will blight the lives of families particularly along A1001 South Way during the summer months when windows are open and people spend more time in their gardens.

5.2 It will also impact on ramblers, nature walkers, birdwatchers and even anglers who use the hillside around New Barnfield and its environs including Bunchleys Ponds – all of which are at risk from contamination.

5.3 Currently vehicle access by cars and LGVs is restricted to the north east section of the site so there will be an added impact on wildlife in the area as the plan envisages HGV traffic moving around the dome – bringing the fumes, noise and vibration closer to the park areas and surrounding countryside (and probably impinging on Southfields School).

5.4 Light pollution from the facility will interfere with views of the night sky (the University offers astronomy courses, and as New Barnfield is on high ground it offers a wider expanse of sky to observe).



6. Community Involvement

6.1 Veolia commitment to community involvement is debatable. The so-called Community Engagement Group (CEG) comprised only a small handful of residents. The meetings were run by a Veolia-paid contractor, Counter Context, who – like all the other ‘independent’ contractors employed by Veolia on this project – could hardly fail to realise that future employment with this major player is likely to be dependent on producing outcomes that favour Veolia’s interests.

6.2 It is significant that at the second meeting (17/08/11, Point 2) when WHBC Hatfield South councillor Kieran Thorpe had requested to send a representative as the meeting times coincided with WHBC meetings, the chair refused to allow it – an action that hardly seems compatible with a genuine desire to engage with the community.

6.3 It is also worth noting that according to Veolia’s Statement of Community Involvement (p.13) leaflets were only mailed to Hatfield households in the South and Central Wards (which just happen to have the four Labour WHBC councillors in the area illustrated – all the others being Conservative).

6.4 Veolia / Counter Context failed to inform the CEG members that they were planning to fly an inflatable at the New Barnfield site to get reference data of the visual impact (even though library staff have confirmed that they were notified the previous day).

6.5 Accurate recording and timely distribution of the minutes of the CEG meetings has been criticised by CEG members (19/10/11 formal protest lodged under Any Other Business). Significantly, this protest apparently had no effect as Veolia / Counter Context failed to circulate the minutes of the last scheduled meeting (09/11/11) in time for these to be included with their planning application (Community Involvement Statement). Or perhaps they were deliberately omitted.

6.6 Veolia / Counter Context was repeatedly asked (28/09/11, Point 2.3; 19/10/11, Point 3.1; 26/10/11 Point 2.1) for information on how long it would take to shut down the plant and cut off the flow of toxins once a problem had been detected. They repeatedly failed to supply this information, and at the 9/11/11 meeting, after being pressed, provided a less-than-satisfactory answer (Points 2.1.1 – 2.1.7).



7. Cost Effectiveness / Value for Taxpayers

7.1 Exorbitant cost of PFI funding –PFI funding which will be used by HCC to fund the incinerator has already been criticised as an expensive form of financing – an expense which will ultimately be borne by taxpayers, whether that be through higher income tax or VAT ie. direct or indirect taxation.

“Due to the financing costs involved, it said paying off a £1bn debt incurred through PFI cost the taxpayer equivalent to a direct government debt of £1.7bn."


7.2 Health costs – the incinerator poses a threat to health, and apart from the human suffering behind the statistics it also represents a potential burden on taxpayers and a strain on available medical resources. Not forgetting the cost to businesses in sick absence (whether direct or to look after an afflicted family member).

“If the UK adopted the US Clean Air Act of 1997 we could easily reduce the annual NHS bill by £24 billion. The US saved $193 billion just from reduced hospital visits and days off work according to the White House Office of Management and Budget report which was featured in the Washington Post, 27 September 2003."


7.3 Incineration is highly unpopular – this means that there will inevitably be extra legal and administrative (and probably policing) costs. Already, Welwyn Hatfield Borough Council and Hatfield Town Council have pledged taxpayers’ funds to fight the proposals, which if it is decided to proceed will be defended by Hertfordshire County Council also using taxpayers’ funds.

7.4 If the Raike’s Lane or some other health study were to prove there were harmful health effects (whether due to the incinerator alone or its overall contribution to the cumulative effect in an area with already extremely high levels of traffic) then that opens a Pandora’s Box of potential litigation – and possibly corporate manslaughter charges against HCC and / or Veolia.

7.5 The planned incinerator has a much larger capacity than required and HCC is contractually required to supply a fixed volume of waste or pay a penalty. As amounts of packaging is being reduced, recycling levels increased (and could easily be increased further, for example: WHBC is one of only two areas in the East of England which do not recycle Tetrapaks / juice cartons); other local authorities develop / unveil their own waste disposal plants; and shrinking household incomes reduce consumption, there is a significant risk that there will be a shortfall. Indeed, it is likely that in a finite world with an expanding populace, that the sort of mineral rich waste produced will become a commodity in its own right.

16 December 2011 – South London Waste Partnership (includes London boroughs of Croydon, Kingston, Merton and Sutton) announced their preferred supplier for a 275,000 tonne capacity incinerator at Beddington Lane.


7.6 Veolia is also one of three bidders shortlisted by the North London Waste Authority (NLWA) to tender for its North London Fuel Use contract, and they are hoping to build a similar facility relatively close to Hatfield (which may impact on local air quality) at Fieldes Lock, Hoddesdon.


7.7 Impending EU action on UK Air Quality – this is particularly significant in light of the fact that it was a similar threat of fines for over-reliance on landfill, which led to the Landfill Tax Escalator – and the stampede to build waste disposal facilities by UK local authorities.

"In addition, the new EU air quality directive will force the UK to reduce nitrogen dioxide pollution on some of the capital's busiest streets by more than a third by the end of 2009, in order to move towards World Health Organisation guidelines. If air quality improvements are not achieved quickly, the UK could be taken to the European court. The court has powers to impose unlimited fines."


7.8 There is a very real danger that Southfield School will not be able to resume activities at New Barnfield (please see section 11), due to disturbance from incinerator operations – after construction has been completed. This suggests that the specially designed buildings will be wasted and further expense would be required to permanently rehouse this award winning school.



8. Security Threat

8.1 There does not appear to be any consideration given to the potential use of this facility as a weapon. It is located next to a densely populated residential area, and as can be seen from the New Barnfield hill at ground level there is a direct line of sight to Welwyn Garden City, Shenley, and St Albans (highly symbolic as a city and named after England’s first saint).

8.2 Contaminants / toxins and / or explosives / radioactive materials could be deliberately introduced into the waste stream.

8.3 The visitor centre makes reconnaissance easy and there are only a few people working at the site when it is operational, so it would be relatively easy to overpower them.

8.4 Even if it wasn’t possible to take control of the plant systems there will be several tonnes of combustible materials stored in the bunker. All that would be required would be to set fire to it, introduce toxic material and, if required, blow a hole in the roof. Consequently, depending on which way the wind was blowing at the time, terrorists could poison one or more towns and the surrounding farmland.

8.5 Less impactful would be a disgruntled employee or someone with a mental illness deliberately introducing something (like a gas cylinder wrapped in plastic) to cause an explosion to put the plant out of operation.



9. Veolia's Safety Track Record

9.1 The EA claims that there shouldn’t be any risk in modern well-run incinerators. However, this is contrary to Murphy’s Law. While Seveso, Bhopal, Chernybol and Fukushima have demonstrated things only need to go catastrophically wrong once – and none of these were deliberate sabotage or terrorism (while, in the 100th anniversary year of the sinking of the Titanic, we have another reminder of the failure of man and his machines with the sinking of the Costa Concordia).

9.2 Veolia’s track record is further cause for concern with 5 HSE prosecutions and 22 enforcement notices.

HSE’s prosecutions database


HSE’s enforcement notices database


9.3 NOT included in 9.2 are the six breaches of emissions limits for half an hour over two years across the six incinerators they operate which Veolia have admitted (CEG 9/11/11, Point 2.1.1) – none of which were investigated by the Environment Agency.

9.4 This high level of failure makes it not a question of whether there will be any leaks of toxins but of what toxins, for how long, in what concentrations and what will be the long term and cumulative effects (bearing in mind there are likely to more frequent ‘spikes’ ie. shorter releases).



10. HCC Process and Flaws / Apparent Bias in Veolia's Planning Application

10.1 HCC signed contract with Veolia before it had finalised its Waste Strategy.

10.2 28/04/11 HCC's Waste Management Cabinet Panel meeting

Page 33 (2Mb document) refers to alternative technologies. HCC claims they were 'technology neutral' however, by emphasizing the desire for a solution with a proven track record it skewed the selection in favour of incineration.


10.3 According to the HCC Waste Strategy consultation document:

2 Spatial Vision, Objectives and Strategic Issues;
2.3 Strategic Objectives
Table 3, Point 2 "To locate waste recycling, handling and reduction facilities as close as practicable to the origin of waste;"
Table 3, Point 4: "To facilitate a shift away from road transport to water and rail transport as the principal means of transporting waste;"


Hatfield is in the south of the county, further there is a much greater volume of industrial / commercial waste in Herts. Logically then, the facility should be located more centrally in the county. Additionally, while there are rail lines close by there is no cross-county line so it limited this option from the outset (but strengthened the case for picking New Barnfield). In fact, the final proposals do not appear to show any existing or future plans for transport of waste by rail. However, it does strengthen the case for arguing that HCC’s intentions from the outset have been to use the facility as an income generator by taking waste from London (which also explains the overcapacity at a time when recycling rates are increasing and there is decreased consumption). It raises intriguing questions over the legality of a local authority effectively entering the commercial waste disposal market in partnership with a private company. Especially, as it is likely to give Veolia a competitive advantage over other waste companies as apart from potentially shorter journey times to unload their collection vehicles they also would receive gate receipts and income from power generation (and possibly income from heat, as New Barnfield is designed as a Combined Heat and Power facility but it is not clear whether there are any customers).


24/12/09, the Environment Agency responding to HCC’s consultation said Harper Lane is unsuitable for a waste site as it is in a source protection 1 zone and they would object to any new waste development in that area (as a licencing body their opinions are critical).


So HCC’s decision to short-list New Barnfield and Harper Lane does not make any sense – unless they wanted to fix the outcome in favour of New Barnfield.

10.5 HCC’s process has been subject to an Independent Examination and the inspector is only due to report back on 31 March 2012, consequently there is a significant question mark over the process.
Apart from the issues with the CEG outlined in Section 6, there are other disturbing aspects to Veolia’s plans

10.6 Veolia’s traffic models were developed using two surveys – the first was held in June, and a second held in October – after it was pointed out that this was during the university summer holidays. However, the October survey was held after Hatfield House – a major tourist attraction and enhanced in 2011 by the addition of a rare breeds farm – had entered its closed season (although the farm and stable yard retail area remain open).This was pointed out at the CEG meeting on 9/11/11 (Point 4.2.9 – although this set of minutes was curiously not included in their Community Involvement Statement) Consequently, there is a serious question mark over the reliability of their models / forecasts.

10.7 Veolia’s Health Impact Assessment population profile (p.30) indicates that South Hatfield ward has a larger proportion of non-christians, non-working households, and a lower than the national average level of home ownership – a depiction which is perhaps calculated to favourably dispose Conservative-controlled local authorities to granting planning permission. However, it does not seem to have been made clear that there are a high number of student houses (usually buy-to-let HMOs) and the university’s own halls of residence. Education is a significant source of income for the UK and overseas students and parents (who have to pay three-times more than local students) may wonder whether a UH degree is worth the prospect of being poisoned.

10.8 It is also worth remembering that the 2011 census data has yet to be released and since the last in 2001 there has been a considerable amount of new and brownfield development in Hatfield, coupled with a growth in HMOs so it is questionable as to the accuracy of the population data used (the use of 11-years-old data is acknowledged in the Health Impact Assessment – p.3, Point 0.4.1).

10.9 The Barton Willmore study (CEG meeting minutes 08/09/11 Appendix 2) shows a variety of views of the New Barnfield area taken on a very overcast day, as a result the colours are muted and it looks very drab and dreary so the area’s natural beauty does not come across – which may be as coincidental as the joint HCC-Veolia press release announcing that New Barnfield had been picked being released on the day before the Royal Wedding. Images showing the area in a much better light can be found on this site – click here for a link.

10.10 According to the Health Impact Assessment, Point 4.9.5 Infant Mortality (p.36): “From 1999-2000 Welwyn Hatfield (5.39 per 1,000) had a higher rate of infant mortality compared to the national average (5.65 per 1,000)”. This is mathematical nonsense, which suggests that the figures are incorrect / transposed. This begs the question: how accurate are the other figures in Veolia’s planning application?



11. Impact on the Special Needs Children of Southfield School

11.1 Probably the most disturbing part of the New Barnfield incinerator saga is the impact on the children of the award winning Southfield School.

11.2 Southfield School is a relatively new facility (around 15-years old) specifically designed and dedicated to catering for special needs children, and is located next to the New Barnfield site.

11.3 HCC is planning on temporarily (allegedly) moving this specialist school to a site between Woods Avenue and Old Rectory Drive at a cost of several million pounds (at a time when services like library provision are being cut because of a shortage of funds), which they have acknowledged is poor value for taxpayers.

16/05/11 Hertfordshire County Council's Education and Skills Cabinet meeting minutes: “6.1 The current estimate of costs is a top limit of £3.9m, with a residual value of £1.0m after the proposed three year occupation. This represents poor value for money for a temporary relocation of a school. It is only being considered in the context of the bigger financial risk of preventing the granting of planning permission for the waste facility.”


11.4 Worst still it involves disruption to these extremely sensitive youngsters who will have the distraction of having to adapt to totally new surroundings. And this is not likely to be the only move.
Veolia’s Health Impact Assessment (p.4-5): “Once the Project is operational the changes in environment in particular the slight increases in noise and traffic could potentially still have a negative impact on the health of children especially those with sensory processing disorders”.

11.5 As HGVs will be routed around the dome they will be travelling much closer to the school than currently, consequently the increase in noise and vibration is likely to be more than just ‘slight’.

11.6 HCC cannot be seriously considering moving sensitive and vulnerable children back next to an industrial incinerator, which apart from the traffic and operational noise and disturbance, the EA openly admits inevitably releases toxic materials (CEG 19/10/11, Point 7.7.1 and 7.7.2).

While p.7 of Health Impact Assessment suggests their own doubts as to whether the move is a temporary measure: “If Southfield School does return to the original site.”

11.7 As it is operated by HCC, the school staff are in an invidious situation as they cannot fail to be aware that openly opposing the clear aims of their employer could have an adverse impact on their careers.

11.8 It appears that HCC has been less than honest with parents and the local populace and poses questions as to what else are they being less than frank about.

11.9 Indeed, a move to introduce the term waste parks into their Waste Core Strategy may well be a sign that other waste processing facilities are likely to be introduced in this area. The slides of the presentation for the CEG visit to Marchwood include an artist’s impression of the dome surrounded by a green landscape – while a later slide has a photograph that shows a large power substation has been built by it. So the reality is today the area looks nothing like the artist’s impression.



12. Summary

It is the respondent’s opinion that this is an ill-conceived, poorly thought out and morally reprehensible scheme by local authorities that will condemn a historic town for at least a generation, and poses substantial risks to taxpayers and the wider UK national interest. It should not be granted planning permission.

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