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Secretary of State
Department for Business Enterprise and Regulatory Reform
On Shore Electricity Development V2121
I Victoria Street
London
SW1 HOET
FAO Mr Rod Pridham
Dear Sirs,
Proposed Combined
Heat and Power Facility, Runcorn, Cheshire
Planning
Application Number: 07/00068/ELC
I am writing to you
as leader of Halton Liberal Democrats concerning the proposal to
construct and operate an energy from waste combined heat and power
generating station with an approximate capacity of 360MW thermal and
up to 100MW of electrical power at Ineos Chlor Vinyls South Parade
Runcorn Cheshire.
I am
aware that Halton Borough Council wrote to you on 1st
August 2007 on this subject after the issue had been considered by
its Development Control Committee. Despite many local objections to
the proposal, the Council did not ask for a public inquiry. This
decision may or may not have been influenced by the claim at its
meeting that a public inquiry would cost Halton Council £1,000,000.
Halton
Liberal Democrat councillors did not form a party view prior to the
meeting of the Development Control Committee, as we know that a
party whip cannot apply to a regulatory committee. Some councilors
wrote to you independently. At our September meeting, I was asked to
send a letter to you on behalf of our local party asking for a
public inquiry into this proposal and explaining the reasons why it
should be held.
As the
Liberal Democrats have 15 councillors, an overall majority on the
Runcorn side of the Borough and also hold all the seats in the
Mersey and Heath wards, which would be most affected by this
proposal, we consider that our views must be taken seriously in a
democratic society.
We
share the concerns expressed by Halton Council in its letter to you
and agree that the Secretary of State should ‘be fully satisfied
that the proposal will not have any adverse effects on the health of
the Borough’s residents before authorising the proposal.’ The report
to the Development Control Committee drew attention to the
observations of the Director of Public Health and the request for
further information made in her report. Halton Council’s letter also
indicated that unless all of these matters are satisfactorily
addressed by the Secretary of State, the Council would wish to
object to the granting of permission. Whether or not there is a
public inquiry, the experts the Secretary of State has available
should be asked to thoroughly examine the concerns of local people,
health experts and Halton Council.
You will be aware
that there is an application for an energy from waste power plant at
Ince in Cheshire and that there are proposals for other similar
plants elsewhere in the North West. As each plant can cater for all
the residual waste in the North West, we believe that it is the duty
of the Government to look at each on its merits before making a
strategic decision. There is no requirement for an early decision,
as the decision must take account of the location and nature of
pre-treatment sites. To our knowledge planning permission has not
been granted for any pre-treatment site.
Ineos’ proposed
incinerator would be constructed close to a densely populated urban
area and even if much of the raw material in brought in by train,
its residual waste ash would be transported along congested sections
of expressway. These roads will not be relieved until there is a new
Mersey crossing which is expected to cost over £300 million and is
still at the consultation stage. We are particularly concerned that
this incinerator would have a detrimental effect on the health of
the people of Halton.
In our view, the
major health concerns relate to the following issues:
-
The high levels of pollution in Halton
which may be responsible for the fact that the Borough has the
highest cancer rate in England
-
The absence of information on the type
and location of any pre-treatment plants and how effectively they
can remove the hazardous substances which can result in hazardous
airborne pollution;
- The reliance on
the Environment Agency for ensuring compliance with emissions
regulations when it currently visits similar sites only twice a
year and gives notice of these visits;
- The
effectiveness of the 105m high chimney stack when it is adjacent
to a hill almost as high with prevailing winds in the direction of
the hill;
- The evidence
provided by Professor Dearden on higher infant mortality levels
downwind of current incinerators;
- The dangers
associated with loading and transporting hazardous ash from the
Weston point site across Runcorn for disposal in Randall’s Tip.
1. High levels of pollution
The
report published Halton and St Helen’s PCT on 4 June on the Runcorn
Energy from Waste Project states in Table 1 that smoking in Halton
is similar to the national average, and therefore smoking cannot be
responsible for the abnormally high levels of cancer.
The
report then goes on to say,
'The
Committee on Medical Effects of Air Pollutants conclude that clear
associations have been reported between both daily and long-term
average concentrations of air pollutants and effects on the
cardiovascular system, reflected by a variety of outcome measures
including risk of death and of hospital admissions. They recommend
that as these associations may be causal,
then
a precautionary approach should be adopted in future planning.
They could not be certain which
components of the ambient pollution mixture are responsible for
these effects but it is likely that fine particles play an
important part.'
Halton Council agrees
with the recommendations of this report and has asked for a Health
Impact Assessment to be commissioned.
2. Absence of
information on the type and location of any pre-treatment plants
Approval should not
be given for an incinerator until the location of the pre-treatment
plants and the nature of the products they produce from raw domestic
refuse is known. How will materials such as heavy metals, chlorine
products and persistent organic pollutants be destroyed or made
safe? Ineos cannot know whether they can meet the condition stated
in Halton Council Development Control Committee’s resolution,
section C, paragraph 1.
3. Reliance on
the Environment Agency
Residents will depend on the Environment Agency to ensure compliance
with current emission regulation standards. Unless the
site is
regularly monitored, residents will not have confidence in the
effectiveness of the Environment Agency as a regulator. Furthermore,
some experts believe that current regulations do not address the
problems associated with the smallest particles. The use of
continuous online monitoring equipment as described in Halton
Council Development Control Committee’s resolution, section C,
paragraphs 5, 6, 7 and 8 is needed, as is the facility for
unannounced monitoring visits.
4. 105m high chimney
stack
The proposed
105m high chimney stack is adjacent to a hill almost as high with
prevailing winds in the direction of the hill. I attach a letter
from a local resident, who has managed similar facilities for ICI.
He expresses his concern about the location of the plant. Many
people consider that it is only 5m higher than that proposed for the
Ince incinerator in order to comply with Liverpool Airport
requirements (maximum 106m).
5. Evidence provided by Professor Dearden
Professor Dearden
has provided information showing there are higher infant mortality
levels downwind of current incinerators. The NHS must have the
necessary data to check the veracity of this claim.
6. The dangers associated with loading,
transportation and disposal of hazardous ash
The process can
release hazardous material at each stage. Compliance with the
conditions in Halton Council Development Control Committee’s
resolution, section C, paragraphs 2, 3 and 4 is needed.
We are asking for a
public inquiry, but at the very least we consider that satisfactory
answers to all these health concerns are needed before approval is
given to this planning application.
Yours faithfully
Cllr Linda Redhead Leader of Halton Liberal Democrats
cc Halton Borough Council FAO Mr Phil Watts |