MMAG comments on Draft Waste Core Strategy

MMAG comments on the draft waste core strategy and it’s impact on Marston Moreteyne and the wider Marston Vale

July 6th 2010

Joint Minerals & Waste Planning Unit
Central Bedfordshire Council
PO Box 1395
MK42 5AN

Dear Sir

The Marston Moreteyne Action Group (MMAG) wish to comment on the draft Waste Core Strategy produced on behalf of Bedford Borough Council, Central Bedfordshire Council and Luton Borough Council and presently under public consultation from June 1st to July 12th. MMAG – a group of volunteers committed to sustainable development within and around Marston Moreteyne are head quartered, C/O The Retreat, Station Rd, Marston Moreteyne, Bedfordshire, MK43 0PU. (Further details about our organisation can be found at http://www.mmetag.com) We are currently campaigning against the Covanta proposal for an Energy from Waste Plant at Rookery Pit South.

As requested our response follows the order of the questions within the consultation paper. However can we register our unease at the short timescale for this consultation. Following a single advert in the local press, exhibitions were then held in Dunstable, June 8th, Elstow, June 16th and on June 24th in Stewartby. The consultation runs from June 1st and July 12th. This tight timescale MMAG believes is not conducive to meaningful consultation especially when the consultation specifically refers to the Covanta proposal and proposes Rookery Pit South should be designated as a strategic site – both highly contentious matters. These decisions will determine the shape and character of our environment for decades to come.

Q1 Do you agree or disagree with this Vision ?

MMAG disagrees with the Vision. The Vision still provides for an apportionment of wastes from London, a degree of landfilling – albeit highly limited (London waste) & for waste facilities being appropriately sited so as to be able to accommodate large numbers of traffic movements. MMAG does commend the statement that facilities should be located as close as possible to urban areas and yet no where in the consultation is it clear how Luton will share in providing these facilities ? MMAG appreciates the challenges to local authorities which waste presents: something has to be done with it. This Vision has been in development from 2007. Since then the economic recession and the election of a Coalition Government both challenge the growth predictions upon which projections are built and the planning frameworks which address them. The regional spatial strategies are to be abolished and there is to be a massive investment in anaerobic digestion: is the Vision relevant or indeed truly up to date ? The future in 2007 would have looked a lot rosier then than it does now.

Q2 Do you agree or disagree with these Core Strategy Objectives ?

The objectives of the Waste Core Strategy are to (1) Manage as much as possible of wastes arising from within the Plan area, and the agreed apportionment of London wastes; (2) Promote the reduction of waste arisings; (3) Move away from dependence upon landfilling ; (4) Provide greater capacity for the recovery of materials & energy; (5) Protect the biodiversity and landscape fabric of the Plan area; (6) Protect the safety of the road network in the Plan area; (7) Protect the cultural, social and environmental heritage of the Plan area.

MMAG disagree with these Core Objectives – they are not ambitious enough – they should seek to ensure the local authorities are exemplars in producing waste management solutions that challenge why so much waste is produced in the first place : the first rung on the waste hierarchy. MMAG believes local authorities should manage waste solely within their jurisdictions in accordance with the ‘proximity principle’ of waste management and cease any dependence from landfilling. The Core Objectives make no attempt to address climate change or measure the carbon footprint of this strategy if adopted. Residents of Central Bedfordshire may be surprised to see that they are to be volunteered as a waste dumping ground for Luton Borough.

Q3 Do you agree or disagree with the identification of Rookery Pit South, and Elstow Pit South as a Reserve site, for the land filling of Non-Hazardous Wastes ?

MMAG does not agree. There is much about this consultation which is self fulfilling – we have waste and a large hole in the ground in Rookery Pit South ; how can we design the criteria to ensure the only destination for the waste is Rookery Pit ? To do so would be at odds with Waste Core Objective (5) which seeks to protect the biodiversity and landscape fabric. The RSPB has noted the significant roosting/feeding movements of numerous species between the Pillange Lake, Marston Vale Millennium Country Park, Stewartby and Brogborough Lakes.. Rookery Pit South situated next to the Millennium Country Park is now an ecologically integrated and co-joined wild life site.

Q 4 The preferred Option for Waste Growth Scenarios during the plan period is the Low Growth Scenario. Do you agree or disagree with this ?

MMAG disagrees with this projection. The low growth scenario requires 7.2 million tonnes of void space for the landfilling of non-hazardous waste at 2027/2028 and coincidentally the consultation also estimates Rookery Pit South to have a potential capacity of 7-8 million cubic metres !

Q 5 Do you agree or disagree with our definition of a Strategic Site ?

MMAG does not since the plan is self fulfilling : ultimately the only site which meets the criteria of being essential to the achievements of the objectives is Rookery Pit South.

Q6 Concerning the Preferred Option for the Spatial Distribution of Strategic Recovery sites do you agree or disagree ?

MMAG disagrees as the preferred option is for a small number of principal sites located centrally and once it boils down to only Rookery Pit South and Elstow as meeting the criteria.

Q7 Do you agree with the sites we have identified as Strategic Sites ?

MMAG does not agree as the list is designed to ensure only Rookery Pit will emerge as the most suitable. The BEaR Project tendering process should be allowed to run its course and see what alternative proposals will be offered by the market – the Core Waste Strategy effectively rigs the market in favour of the Covanta proposal. It suggests to providers of a large facility that there is a large site readily available for use – Rookery Pit South !

Q8 Do you agree or disagree with Waste Core Policy 1 ?

MMAG disagrees that there should be future allowance for processing London waste.

Q9(a) Do you agree or disagree with Waste Core Policy 2 ?

MMAG agrees that landfilling of untreated municipal and commercial waste should be eliminated by 2021 and preferably long before.

Q9(b) Do you agree or disagree with Waste Core Policy 3 ?

MMAG believes that it is highly misleading to suggest that modern waste management facilities can be designed so as to be sympathetic to the area in which they are sited. To date consultation with Covanta have proven otherwise. Context and landscape are key. Rookery Pit South is a rural landscape and abuts a country park. There will be an immediate negative visual impact, loss of wildlife habitat in an area that has naturally regenerated over many years, predictably increased traffic levels with associated noise and dust pollution and an ugly building to boot. Waste plants are never attractive buildings and there is little real scope to alter the basic structure of the building because of the machinery within. They are essentially industrial structures more suited to an urban landscape.

Q10 Do you agree or disagree with Waste Core Policy 4 ?

MMAG agrees that there should be a rigorous enforcement regime although further clarification is required as to how legally binding arrangements are to be policed and enforced. In the event of infringements what would become of the delinquent waste – returned to its place of origin ?

Q11Do you agree or disagree with Waste Core Policy 5 ?

MMAG agrees that all new development should include sufficient waste storage and recovery facilities.

Q12 Do you agree or disagree with Waste Core Policy 6 ?

MMAG agrees that public safety must be paramount in the transportation of specialist waste and preferably dealt with at source.

Q13 Do you agree or disagree with Waste Core Policy 7 ?

MMAG agrees that consistent with the proximity principle non strategic sites should be distributed through localities with an emphasis on anaerobic digestion and that material recovery should be located in urban areas.

Q14 Do you agree or disagree with Waste Core Policy 8 ?

MMAG agrees that composting facilities should be situated where amenity impact is prevented.

Q15 Do you agree or disagree with Waste Core Policy 9 ?

MMAG agrees that waste should be freighted in accordance with Council requirements.

Q16 Do you agree or disagree with the identification of Rookery Pit South, and Elstow Pit South as a Reserve site, for the land filling of Non-Hazardous Wastes ?

MMAG does not agree for the same reasons as given in Q3.

Q17 The preferred Option for Waste Growth Scenarios during the plan period is the Low Growth Scenario. Do you agree or disagree with this ?

MMAG does not agree for the same reasons as given in Q4.

Q18 Do you agree or disagree with the above statements concerning actions to be taken ?

MMAG disagrees that this is a complete list of the possible contingencies. The suggestion that one contingency would a single large scale materials recovery facility and which would source the majority of its waste from outside the Plan area is code presumably for the Covanta proposal and totally unacceptable to residents. A further contingency would be the waste from the local authorities being transported out of the plan area to a more suitable site. A zero limit should be placed on receipt of waste beyond the Plan area. The people of Bedfordshire have done enough dealing with waste from elsewhere. Its surely someone else’s turn ?

Hugh Roberts

Chair

Marston Moreteyne Action Group (MMAG)

http://www.mmetag.com

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