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I believe that this proposed development would have a massively damaging visual impact upon
the Vale, and all of the famed views across it, not just that from Haresfield Beacon.
I argue that such a development should only be permitted
if it can be demonstrated that there is an overwhelming need for it, and that no better
alternative solution exists. ----------------------------------------------------------
I first came to the Vale in 1947, and have been resident here for most of my life. I
once walked the Vale escarpments with my granddad. Nowadays
I walk them with my grandchildren. I feel passionately that the Vale has a beauty of
its own, irrespective of its proximity to the AONB. I
believe that that beauty is worthy of protection, and that it should be accessible to future
generations. To those who know it, the Vale is special, even if it does not enjoy special
designation, and, as I see it, this issue is about the Vale. It certainly deserves better
custodianship than it has recently received, at least as far as GCC is concerned. Anyone
who has walked its edges will know it as an undulating
riverine plain, surrounded by rolling hills and
escarpments, with the River Severn snaking up its centre. Nowhere will you find it angular
or harsh, yet the proposed incinerator design
is just that, - geometric, brutish, and of a scale that is
completely out of proportion with its surroundings. I did hear the UBB architect explain at one
of their presentations that he had tried to reflect the pattern that the field outlines
make within the Vale, which viewed from above do form
an angular grid-like pattern. Grids were then quite
the rage in contemporary art, so I can understand his approach -- and I accept that it does
mean that this proposal will probably look really
great from a satellite. But from the ground, or even
the escarpments? No, - it would appear totally incongruous. It could never sit comfortably
in this particular landscape, and its sheer mass
would ensure that it would not only be the view
from Haresfield Beacon that would be affected. It would dwarf Gloucester Cathedral, and
would stand out when seen from Frocester Hill. Cam Long Down, Uleybury, May Hill,......from
wherever folk go for the views, even as far as the Malverns. It would have an adverse
impact upon the whole of the Berkeley and Severn
Vale. I accept that need can sometimes override
concerns such as the preservation of the character of a particular landscape. After all, this
site was first developed in 1939, and commissioned that
November, as RAF Haresfield, but I understand that events just then probably did satisfy
the criterion of overwhelming need.
Today, the proponents of this scheme within the County Council are arguing that the harm
that this proposal will do to the landscape is
justified by our need for an incinerator. But is this
reasonable? What is this need? We do need to move away from landfill, but incineration
is not the only alternative. South Gloucestershire,
as part of the "West of England Waste Partnership", use a system which would, compared
to this incinerator: 1. Be very much cheaper, both to set up and
to operate. 2. Allow efficient second-chance recycling.
3. Be accommodated within a structure that would not breach the current 15ยท7m height
restriction, so be relatively easily concealed within the Vale.
4. Be modular, and therefore flexible and able to adapt to technological advances.
5. Produce energy in a form that actually can be efficiently utilised.
6. Operate without emitting toxic nanoparticles into our atmosphere in anything like the
quantity that would be produced by this mass-burn incinerator, and without the problem of
disposing of huge quantities of highly toxic flue ash.
7. Only require a ten year contract to be viable, as opposed to a minimum twenty five
year commitment for this incinerator.
If an alternative is available with so many advantages, why do we need an incinerator?
What single advantage does this incinerator have
that makes it a desirable option? What benefit would it confer that justifies such damage
to the landscape, and the huge extra cost to the
county's ratepayers? Why is it better than the South Gloucestershire option?
I have asked this so many times that I have lost count. I have never once had a direct
answer. I always hear that someone else has said that
incinerators are a great idea, but never get the
reason why. I have attended as much of this Inquiry as I have been able to, in the hope
of an answer to this question, but still haven't
got one. Johnny Ball was then endorsing this scheme
in their promotional material -- he has taken an
active interest in the waste debate, and has supported incineration in the area where he
is resident, where they wish to be rid of an
offensive landfill site-- so I wrote to him. I received a
very prompt and full reply, broadly in favour of incineration, but including this caveat:
"Now I do not have the details of the proposed EfW
plant, but just as with Avonmouth, surely it will
reclaim and recycle all metals, hard and heavy plastics and bottles, prior to incineration?
If this is not the plan, then it falls short
of European requirements anyway and you would be
right to oppose it." That did seem clear. Mr Ball had cut to the
chase. This incinerator is old technology. It will
simply put the black bags into the burner, and hope to recover some material from the
bottom ash. It will have scant control over what
goes into the fire, will certainly burn recyclates, and
will not even attempt to recover strategic material such as rare earth metals. It is
obsolete. It is obsolete today, and, with better options
immediately available, I believe that it would be
unconscionable for this county to commit to it for the next quarter of a century.
--------------------------------------------- Regarding, Mr Ball's letter, it should be
noted that most of the figures he quotes, particularly
regarding the Avonmouth plant, are wildly inaccurate. Oddly they are the same as those
that Mr Waddington had been using. In June 2012
New Earth Solutions wrote to Mr Waddington requesting that he stop spreading such inaccurate
information, and issue a retraction when practicable. He did neither. I would love
to know where he got this "information" from, and
who gave similar figures to Mr Ball. ----------------------------------------------
I have also been asked, as I have a clinical background, to say something about health
risks. I haven't heard all of the previous evidence,
but I did catch one cross-examination which seemed
to conclude with the agreement that incinerators were "safe", and that there only existed the
"perception" of risk as a problem requiring attention. I have to take issue with this.
Technically one can never prove that such a system is
safe. No accumulated number of instances of harm
not being suffered will prove safety, whereas it only takes a single instance of harm being
suffered to prove danger. I have seen all sides of this conundrum. I have tried to fight
vaccine hysteria, and many times lost that argument,
even though all of the solid evidence favoured the
vaccine. Once I spent hours in laboratories, and handled asbestos with complete abandon.
We knew it was inert and totally safe. Drugs that I used on a daily basis, believing them
to be "safe" on the available evidence, suddenly
proved dangerous and were abruptly withdrawn. In
the case of this incinerator, we do know that the intention is to site it upwind of the
principal population centres in the county, and we do
know that its stack emissions will contain nanoparticles that are highly toxic. We know
that there is no way to monitor or control the
very smallest particles, the ones that are most likely to cause long-term problems. We
also know that the effects of such exposure might
only appear after a very long interval. There exist "acceptable limits" within which such
facilities are currently allowed to function, but this is
a necessary pragmatic approach. We do not actually know with certainty what constitutes
safe practice in the long term. The evidence is
simply not available, and might not be so for another
fifty years or more. Right now UBB cannot prove that such an incinerator will not cause
harm, and its opponents cannot prove that it will.
I do not believe that in this situation we can write
off the concerns of those who are alarmed by the risk. In time, they might still be
proved to be correct. That being the case, we do have to
ask why this county council is so determined to
commission a facility that will expose its population to such emissions, when a cheaper
alternative exists which will achieve similar landfill diversion, but with added advantages
that include a vastly lower level of exposure to
such potentially damaging emissions.