We said we would look through the enormous documents for you. We’ve done it and it doesn’t make good reading. We have been asked to comment in the light of the new National Planning Policy Framework (NPPF). If you have already objected, or even if you haven’t, it’s important that you follow it up with a further comment on the latest documents. Here are some guidelines. There are many more points but this list should help you. Please use your own words.
You should send your objection to firstname.lastname@example.org with a copy to Shaun.Robson@northyorks.gov.uk.
The planning reference is NY/2011/0328/ENV.
The NPPF changes the context of the AWRP planning application. The NPPF is intended to allow planning to “include, people and communities” and make it less remote from ordinary people like ourselves. It deplores decisions taken by “remote bodies”.
This challenges NYCC’s presumption that it should decide the AWRP application. We think it should either be decided locally by Harrogate Borough Council or, failing that, at a Public Inquiry where local views can be fully aired.
“At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development.” – meeting the needs of the present without compromising the ability of future generations to meet their own needs.”
Crucially, AWRP does not meet sustainability criteria. The 25 year contract will fundamentally compromise the ability of future generations to meet their needs and lead to the destruction of valuable resources that could have been reused or recycled so virgin resources would have to be exploited. The incinerator dominates the facility in cost and treatment volumes and, once built, cannot be reduced in size. Its high cost forces the operator to run it at full capacity even where there is no need within the county to do so.
The NPPF identifies “three dimensions to sustainable development: economic, social and environmental. Use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy” The proposed AWRP would do none of these things.
The scheme relies on significant Trade Waste being collected by Local Authorities in the County. This is outside the original purpose of the scheme and is anti-competitive; it will put existing local businesses out of business, in favour of a Spanish-owned multi-national. This is not sustainable economically.
NYCC (and hence future generations of its residents) would be committed to the costs of decommissioning the plant and re-instatement of the site. These costs are not known, another nail in the coffin of the idea that this scheme represents Value for Money.
The NPPF states “Sustainable means ensuring that better lives for ourselves don’t mean worse lives for future generations.” This scheme doesn’t even ensure better lives for ourselves because of: excessive cost; inferior recycling capability; increased greenhouse gas generation from increased waste transport distances and waste disposal; serious and unavoidable damage to the local landscape, and; increased risk of pollution from the incineration element. All of these unnecessary outcomes would be worse for future generations.
Locking Out Better Options
The NPPF states “We must respond to the changes that new technologies offer us.” This application fails this test because the proposed technology is out of date and does not offer the best solution to maximising recycling or good value for money. It also locks us out of exploiting newer, cheaper and cleaner options for a generation.
The NPPF states that all developments which generate significant amounts of movement should be required to provide a Travel Plan. AWRP will result in a significant increase in the distances waste will be transported and an increase in vehicle movements on the dangerous A59/A168 junction yet the planning application does not include a Transport Statement. The AWRP fails to provide such a plan and therefore cannot be approved.
The NPPF states that Minerals are essential to support sustainable economic growth and our quality of life. Mineral Extraction is an important contributor to the NYCC rural economy and reinstatement requires landfill. AWRP and NYCC have not quantified the impact of trying to eliminate landfill on this important rural North Yorkshire industry.
NYCC has ample scope for landfill and modern landfill strategies coupled with enhanced recycling and recovery provides a viable alternative, both in the short-term and in the long-term. Don’t let AWRP kill off this opportunity.
The majority (about £1 million) of the proposed mitigation will be spent on features and buildings which are not accessible to the majority of the population of North Yorkshire.
The remainder of the proposals are simply an unachievable wish list. They are unachievable because AWRP do not own the land on which they would like mitigation to take place – e.g. they are suggesting banks of trees to obscure the view of the incinerator. Even when fully grown, these trees would not be big enough to hide the development.
The projections of waste volumes that were used to justify the original plan for an incinerator have changed dramatically. Now NYCC say there is a need to incinerate a lot of trade waste to bolster the supply for the incinerator.
This country is already nearing overcapacity for incinerators. Too many incinerators will be competing for too little waste. That means the price will drop. That will blow the financial projections apart. It’s just not needed.
Last Call for the Bike Ride
If you’d like to join our group of cyclists on Saturday September 8th you’ll have a great day out and raise funds for the campaign. Whixley to Filey Sponsored Bike Ride – 57 miles, start at Whixley church 8.30am. There will be a support vehicle. Back roads all the way. If you can’t get sponsorship, please give a donation of £25.