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WP2’s long-awaited submission for the proposed ‘pyrolysis incinerator’ at Haybridge, Wells has now been approved by Somerset County Council.

Urgent Action Is Needed To Oppose This Plan

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WEPG's Concerns About WP2’s ‘Pyrolysis Incinerator’ at Haybridge - In Detail

Local residents of Haybridge, Wells and the surrounding area have expressed concerns about WP2’s proposed incinerator at Haybridge ever since the consultation process began just over a year ago. WEPG’s research into the proposal, to date, is detailed here and forms the basis of WEPG’s objections to the application.

Residents and Public Concern (SWLP: Strategic Environmental Assessment)

Planning procedure necessitates consultation with the public, and that social acceptability and social preferences for waste management are taken into account (Waste Strategy 2000).

The anxiety caused by the fact that risks to health, safety and adverse environmental impacts of this unproven process are poorly understood by science, and local economic consequences remain unknown, is a material issue of public concern. Lack of transparent evidence due to the unproven nature of the technology, and misleading information from the applicant  have contributed to public concern over this project (see 4, 5, 7).

The visual impact of the chimney stack, and potential odours, would serve as a constant reinforcer of the public concern of this facility should it be built. This may manifest itself a stress-related illness in residents.

WP2 billed this project  as ‘being a major step for Wells towards achieving self-sufficiency in both waste management and energy production’ (WP2’s Leafle to Haybridge Residents), but:

No local employment is safeguarded by building this facility, especially not at St. Cuthbert’s Mill, as WP2 stated in a public meeting (Wells Town Hall, 24 Feb 2005). It is unlikely that local employment will benefit from the build of the facility, as specialist skilled operators are required, and only two to three at a time, on a shift basis. Recycling always provides more job opportunities than incinerators!

Total CO2 emissions for the community of Wells could be doubled by this single facility (see 5).

Tourism and agricultural local economy will be damaged by a pyrolysis facility.

‘Recycle city is best in Britain’ proclaimed the front page Wells Journal headline (29 Sept 2005), and went on to say: ‘Wells has been so successful at gathering garden waste, putting aside plastic and saving scraps that it has one of the best recycling rates of any city in the country … with 55% of all the waste being picked up being recycled’. The community has committed itself fully to local waste management WITHOUT THE NEED for this pyrolysis incinerator. Somerset average is 27%, and Wells already exceeds 2005/6 40% targets!

The pyrolysis incinerator would adversely impact on the City of Wells bid for world heritage status (WJ, 27 Oct 2005). Potential tourism gains would be negated by an incinerator on the city boundary.

A handful of individuals would profit from a pyrolysis facility in Haybridge, at the expense of the economic welfare of a far greater number of people, in terms of safety, health and tourist business upon which the area is dependent.

Traffic Issues (SWLP: Policy W4)

Waste should be treated or disposed of in the region in which it is produced, in order to achieve government targets, but the proximity principle discussion in 3 shows that this is unlikely to be the case here. An extra9,000 HGV movements per year on narrow Haybridge roads: Glencot Road & Titlands Lane.

Wells is not centrally located within Somerset (see map below), and on the northern edge of the SW region, nor is it part of the strategic road transport network (darker roads on the map).

This facility is not needed to maintain the county contribution to regional self-sufficiency.

Sign at A371 turn into Titlands Lane: 'Unsuitable for heavy goods vehicles’

Glencot Lane is also too narrow over the railway bridge for HGVs & cars to pass.

The Proximity Principle (SWLP: Policy W2)

ALL industrial and commercial feedstock materials will have to be IMPORTED to the Haybridge site from other areas within and outside Somerset County. This unnecessary road transportation does not fulfil the terms of this principle that ‘waste should generally be disposed of as near to its place of origin as possible’. The 3 waste sources quoted by WP2 raise the following issues:

There is a clear shortfall of materials from WP2’s three stated sources, and all waste will have to be imported, some of it from outside Somerset. To the question ‘What will WP2 do if these sources fail to supply the required quantities?’ (WJ Article, 5 May 2005), they replied, ‘Should the need arise we do not envisage any difficulty in securing alternative sources ... to suit our needs from other locations in Somerset ...’. Mr J Gibson returns (WJ Letter, 19 May 2005): ‘Perhaps the most interesting point of all is that the WP2 responses actually give added weight to the [bigger environmental impact] by referring to ‘importing’ waste from further afield as necessary in order to ensure the long-term economic sustainability of this venture’. 

In their WJ Article (3 Nov 2005), WP2 stated: ‘We believe that it is immoral in this day and age for anybody to want to export their waste problems to somebody else’s backyard ...’. Mr Underwood (Letter to WJ, 10 Nov 2005) was quick to reply: ‘WP2 said in last week’s Journal that is was ‘immoral’ to export waste to someone else’s backyard. Surely, at 50,000 tpa, they are doing just that to poor old Haybridge’.

The premise of the proximity principle in the Government's white paper, Waste Strategy 2000, is ‘to avoid passing the environmental and financial costs of waste management to communities that are not responsible for its generation’.

All waste will be IMPORTED. NO local Wells waste will be used!

Adverse Impact on Wildlife and Geology (SWLP: Policy W10, W11, W12)

These policies aim to protect International, National & Local conservation sites.

WP2’s assessments on wildlife are too localised to the site and incomplete. Little account has been taken of the wider impact that travelling emissions via land, water and air will have on neighbouring areas e.g. the site is a RIGs (Regionally Important Geological Site) and forms part of Wookey Station Site of Special Scientific Interest (SSSI); the protected River Axe runs through the site and could suffer contamination from surface run-off; Wookey Hole & Ebbor Gorge Special Areas of Conservation (SAC) and The Mendip Hills Aera of Outstanding Natural Beauty (AONB) are all within half a mile. 

Whilst all wildlife is essential to local ecology, particular species will be more affected than others. WP2 assure us that ‘badgers, bats, birds and otters will all be safeguarded within the scheme’. There are other high ranking and protected species that occupy the site (e.g. owls, buzzards and slow worms), whose survival would be made perilous by the activities of a pyrolysis incinerator facility. There is a recognised bioaccumulative effect of many of the emissions that will be released by this facility e.g. dioxins, PCBs, heavy metals, whose long-term effects cannot safely be accounted for in human or ecological terms.

Many plants, fungi and lichens found around the area, and especially in Ebbor Gorge SAC, would be adversely affected by releases of acidic gases (such as SO2, NOx & CO2) and heavy metals. Historic buildings , such as the limestone Wells Cathedral, can also suffer irreparable damage.

There are well-documented cases of incinerator pollutants, such as dioxins, accumulating in cow’s milk, and dangerously elevating human levels through its consumption (e.g. Seveso, in Italy, being the most famous). Somerset has a proud heritage of local food production,  which could potentially be contaminated by the pyrolysis incinerator emissions and hence enter the diets of the local community. This will have an adverse impact on the quality of locally grown produce and hence a direct economic impact on an established local economy.

Adverse Environmental Effects (SWLP: Policy W3, W7)

Incinerators of any kind, (and despite WP2’s contrary claims, this is an incinerator - see http://waste.eionet.eu.int/definitions/incineration  for a full discussion), are one of the most polluting technologies on the planet, producing thousands of chemical species about which little is known, and only a dozen are monitored and regulated (see 7).

The proposed technology will take inert (low toxicity) industrial, commercial and demolition waste and release large quantities of toxic chemical species (e.g. dioxins, PCBs, PAHs, SO2, NOx, VOCs, heavy metals) with known long-term cumulative and harmful effects to human health (e.g.birth defects, carcinogenesis, immunosuppression, kidney & CNS damage) and the environment (e.g. acid rain; greenhouse gases - CO2) to land, water and air.

Nearly 64,000 tpa CO2 will be released from incinerating 45,000 tpa waste in this facility; estimated as equivalent to twice Wells current CO2 production!

Since the larger proportion of feedstock will consist of plastics, derived from fossil fuels, plus the natural gas required to heat the pyrolysis chamber, there will be a major impact in terms of the Greenhouse Effect. This dependence on fossil fuels is unsustainable and the qualification of this technology for ‘renewables obligation certificates’ (ROCs) is severely limited by this dependence. There are no ROCs for the fossil fuel components of the feedstock. This facility is hardly a step towards renewable energy!

SWLP Policy on Incineration (SWLP: Policy W7)

WP2 propose to use UNPROVEN pyrolysis technology supplied by Graveson Energy Management (GEM). The Environment Agency have confirmed that GEM’s pilot facility, located in S. Wales, have only processed 27.5 tonnes of waste over 114 hours 35 mins operation between 18th Feb 2000-Sept 2001. These limited trails do not constitute ‘continuous operation’ and the EA view of this technology remains as unproven. All data supplied by WP2 in support of their application is derived from a GEM’s bench-top scale facility in Hampshire.

Local residents demand not to be guinea pigs for potential health and environmental impacts of this commercially and technically unproven process - see 1.

Energy, in the form of heat or electricity for export, will not be recovered from the initial build due to its pilot status and the cost of connection to the National Grid. There is no suitable industrial customer or district heating scheme for heat export.

The location does not meet the needs of the proximity principle - see 3.

The proposal will give rise to significant adverse environmental impacts - see 4 & 5.

Adverse access and amenity impacts include: increased danger from 9,000 HGV journeys on narrow Haybridge lanes; 60 mph speed limit in Haybridge; health impacts to adults and children using the adjacent recreation area (football pitch); Mendip District Local Plan SN21: Protection of Former Railway Land and Corridors for Future Transport Use (e.g. pedestrian or cycle route) - as the Haybridge site is directly on the former railway between Wells and Cheddar, there would be a loss of access to the countryside, and loss of public amenity due to any diversion still being immediately adjacent to a substantial and polluting industrial development, there will be a permanent visual impact of chimney (35-40 m chimney stack).

Adverse effect upon the viability of existing recycling operations. WP2 have stated during public presentations (Wells Town Hall, 24 Feb 2005) and media interviews (BBC Points West, 16 Apr 2005) that L A Moore Ltd.’s current recycling of demolition materials into secondary aggregate by crushing would have to cease to site the pyrolysis facility. 

As it usually takes up to 25 years for the operators and investors of incinerators to gain a return on their investment, Wells would be committed to this method of disposal for this period. This would severely undermine the prospects of waste minimisation, as it may necessitate recyclable materials being used as feedstock, especially given the current success of the Somerset Waste Partnership - see 8.

 Typical Pyrolysis Plant

Note: GEM have no images as they have never built anything above pilot scale!

WP2 Site From Titlands Lane Bridge

The above photograph is taken from Titlands Lane bridge over the former Wells-Cheddar railway line, looking back to Wells, across WP2’s proposed pyrolysis facility site. The towers of Wells Cathedral are visible to the left of the crane. There will be a loss of character and visual amenity if the proposed facility is built, as this view would be obscured and the chimney stack would rise to the height of the crane in the skyline.

Regulation & Monitoring by EA (SWLP: Policy W3, W7)

WP2 state that adverse environmental effects will be mitigated by regulation from the Environment Agency by IPPC permitting, but to date their management of incinerator regulation is a matter of poor public record.

The Waste Incineration Directive (WID), which sets the limits for emissions to air from incinerators (and under which this pyrolysis facility would be regulated) is based on ‘what can be measured and what is technically achievable, rather than what is safe … This point was accepted by the Environment Agency [the regulatory authority]’ DETR Affairs Committee, March 2001, Report HC 39-I, Delivering Sustainable Waste Management, Vol 1. The same report also noted that ‘There are … some truths which can be drawn from the debate over the health impacts of incineration. Firstly, that the health effects which result from an incinerator’s emissions are not yet fully known. Secondly, that the regulation of incineration to date has been rather poor and that has resulted in poor practices developing in some incinerators’.

In their report Criminal Damage: A review of the performance of municipal waste incinerators in the UK, Greenpeace (2001) concluded: ‘Firstly, even though the parameters within which incinerators operate are based on what is technologically achievable and not on what is safe for human health, no incinerator actually operates within these limits. Secondly, the regulatory regime is clearly inadequate. The range of pollutants monitored is too narrow and the frequency of monitoring completely incapable of establishing a reasonable picture of what is entering the environment. The entire regulatory system is based on self-assessment and the penalties are virtually invisible. Of the 546 breaches of pollution limits in 1999 and 2000 there was only one prosecution for aerial pollution (Sheffield in 1999 – the City Council was fined £18,000). The conclusion to be drawn from this report is that incineration is an unreliable and dangerous technology incapable of being regulated with proper regard to human health and the environment’.

Proponents of incineration, in whatever form, would have us believe that regulatory authorities have moved on from these dark days, and that ‘new’ incineration technologies, such as pyrolysis and gasification, are a huge advance upon these pollution giants. However, the Environment Agency’s (2001) latest Review of BAT (Best Available Technology) for New Waste Incineration Issues: Part 1: Waste Pyrolysis & Gasification Activities states that ‘a key conclusion from this work is that, based on current evidence, waste pyrolysis and gasification plants have similar pollution potential to waste combustion plants ... and the achievable release levels should broadly be the same. Claims that pyrolysis and gasification processes are inherently less polluting than conventional waste combustion processes have not yet been substantiated’.

There is no reassurance in the powers of the regulatory authority for incinerators and this creates genuine public concern of material planning consideration, especially if the integrity of the applicant can be proven to be questionable.

Whilst we appreciate the EA has a tough job to do, with limited resources, we are concerned that there are no guarantees of protection from the adverse impacts of this incinerator, especially since breaches of regulation are self-reported by the operator (WP2)!

Locally Trapped Emissions Demonstrate The 'Basin Effect' of The Mendip Hills

The above is a photograph montage looking from Wells towards Haybridge on a cold November morning in 2005. The emissions from St.Cuthbert’s Paper Mill are drifting with the South-Westerly breeze in the direction of the Blue School in Wells. Note the ‘layering’ effect of the emissions cloud, demonstrating the impact of the basin effect of The Mendip Hills (visible in the background) in trapping emissions locally and preventing their dispersion. 

WP2’s pyrolysis facility would have a far greater emissions output in quantity and toxicity than the Paper Mill, and employ a lot less people.

Energy efficiency is increased, and environmental impact is reduced, the higher the method of waste management used in this conceptual hierarchy.

• WP2’s waste sources will not conform to the waste hierarchy unless they are truly residual i.e left after re-use, recycling and composting processes. Whilst this may be true of feedstock from Southwood Waste Management Ltd., this will not be true of wastes from St. Cuthbert’s Paper Mill. Combustible demolition waste supplied by L A Moore Ltd. will not be subject to RECYCLING as they are not a waste transfer station, like Southwood, and so do not possess the license, facilities or even space for this processing.

• St. Cuthbert’s Paper Mill have stated in a letter to WEPG, that their sources of waste include: ‘process waste; packaging waste; and off-spec products’. Some of this material is appropriate for RE-USE, RECYCLING or even COMPOSTING, and hence incinerating it would not be the most environmentally or energy efficient means of disposal.

• WP2 have proposed the initial build of a pilot plant. Past evidence shows that energy recovery as heat and electricity is non-viable in this phase, and so this facility will be classified as a means of DISPOSAL, like landfill. Importing waste to this facility will not move it up the hierarchy!

Best Practicable Environmental Option – BPEO (SWLP: Policy W1)

WP2 must demonstrate that their ‘pyrolysis incineration’ process is the best environmental, community and financial option for dealing with the specified waste. WEPG say it is not:

WP2 cannot guarantee the best practice application of the waste hierarchy to the waste stream prior to incineration i.e. recyclable materials will be incinerated - see 8.

This is disposal, as it will not move waste up the hierarchy due to no energy being recovered as heat or electricity for export (see 6 & 8). It will create more toxic waste for disposal & extra transport pollution.

It will adversely impact on local community through 9,000 extra HGV’s pollution and road danger; massive and tangible public concern for health and safety; poorer local air quality issues; no local benefit to Wells waste management (as it is not suitable for domestic waste); adverse impact on established local (tourist based) economy e.g. campsites, caravan parks, ‘fresh country air’, adverse visual amenity;  no local jobs; energy will be sold nationally not locally!

BPEO demands ‘systematic consultative procedure’ to establish best option for specified waste. WP2 have not considered other options and locations systematically.

Unsustainable option in this northern regional and county location - as waste minimisation processes are enhanced,  waste will have to be imported ever greater distances from southern areas. Unsustainable technology is heavily reliant on non-renewable waste e.g. plastics, and natural gas for pyrolysis chamber.

Of Waste-to-Energy technologies available to WP2, Graveson Energy Management (GEM) is not the BPEO due to its unproven technological, environmental and commercial record (see 6) e.g. Mass Burn incineration (boiler transfer: 25% Energy Conversion to Electricity)  = 1 tonne CO2/tonne waste (tCO2/tw); Compact Power Coupled Pyrolysis & Gasification (boiler transfer: 25% ECE)  = 0.737 tCO2/tw; GEM Pyrolysis & Syngas Engine Combustion (theoretical: 17-28% ECE)  = 1.42 tCO2/tw. GEM’s energy conversion is theoretical: GEM have never demonstrated electricity generation, and the Environment Agency consider syngas combustion engines to be ‘at the development stage’. GEM process demands higher calorific value material, for a similar electrical conversion efficiency, but poorer pollution profile.

WP2’s facility will not be a Combined Heat & Power (CHP) plant as advised in Waste Strategy 2000. A Recycling (MBT) & CHP plant is proposed by SW Regional Development Agency for the Moorlands Site, Street. This is BPEO over WP2’s plant for all requirements.