What will be the impact?
The estimated impacts of any development of the PW site – environmental and social – should, according to the existing planning guidance, have been assessed in the NLWP. Each impact should have been assessed separately. This was avoided by lumping all impacts together – another cause for serious questioning of the NLWP’s soundness.
In its Business Plan, the NLWA lists 17 priority objectives in order of importance, as determined by our councils. Here are a few results:
Minimising air quality impact – 17th out of 17
Minimising risk of noise and odour – 16th out of 17
Minimising local traffic impact – 15th out of 17
Impacts, and the measures to ‘mitigate’ them, are assessed as part of the process of the planning application itself, and can end up as a negotiation between the planning authority and the applicant after approval has been given in principle.
The effectiveness of ‘mitigation’ can, by definition, only be seen in retrospect.
Will there be odours?
Many of these plants have problems, which seem difficult to eradicate once they start. Are we saying that PW would definitely smell? We can’t say that; what we can say is that there is plainly a significant chance. One PWA member recently attended a seminar on air quality and happened to meet the consultant whose job it was to sort out a very persistent odour problem at an MBT. When asked whether his plan would work, he shrugged his shoulders and remarked that he was dealing with rubbish, and ‘rubbish smells’. For a more detailed account of odour problems at an MBT, please see our report on a visit to Farington near Preston.
To us, what is more important is that the NLWA cannot truthfully say that a PW plant would not smell.
Will there be increased congestion?
The NLWA argument re congestion is a) that there is so much traffic on the A406 that a bit more would make no difference, and b) that waste lorries would be on the roads anyway.
A neat NLWA graphic last year showed the peak traffic on the A406 to be for one hour in the morning and two hours in the evening, whereas the peak delivery time for waste would be between say 2pm and 4pm.
Our answer – plainly no-one from the NLWA has ever tried going east along the A406 from lunchtime onwards. Everyone who lives even in the distant vicinity knows what happens to local roads when the A406 is blocked(incidentally, the Mayor of London, when asked about the most congested parts of the Transport for London network, answered that the most congested stretch was Pinkham Way going east, and that the fourth most congested was the junction between the A406 and Colney Hatch Lane). In addition, it is not only the A406, but local roads which are the problem.
The NLWA’s peak delivery time coincides with school collection, which is also a busy period at the Colney Hatch Tesco’s. True, the lorries would be on the roads, but not all converging on one place, access to which, by LBH’s own admission, is poor.
What impact will there be on air quality?
The NLWA/NLWP position on air quality can be summarised in two ways:
As can be seen above, ‘minimising air quality impact’ came 17th out of 17 in their list of priorities.
The NLWA response to the NLWP EiP included the following comment about air quality: ‘PW is already in the vicinity of vehicle emissions from road traffic – particularly from adjacent A406’. It does not take long to fill in the missing phrase ‘..so some more won’t make any difference’. This, sadly but unsurprisingly, is also their attitude to traffic congestion.
The issue of air quality has been avoided. All the NLWA/NLWP member boroughs are Air Quality Management Areas, ie the air quality in all is poor. Their argument is that, because air quality is universally poor, it is not necessary to assess it around a particular site.
As those who know the area will be aware, the A406 is in a shallow valley as it passes the PW site. In some atmospheric conditions, what is known as ‘inversion layer’ can develop, which traps pollution near the ground.
A plant at PW is bound to increase diesel fumes; the WHO recently made a definitive link between diesel emissions and cancer.
Was nothing at all said about impacts and other points you've highlighted?
It was. Underpinning the NLWP is a Sustainability Appraisal(SA), written by the NLWP’s consultants, Mouchel. The aim of this document is to list the aims and options of the plan and to assess them against various important criteria, eg biodiversity, human health, etc etc. We list a few examples below(our emphasis).
One option for authorities was to choose ‘A centralized approach that relies on fewer but larger facilities’. The SA’s assessment of this option from the aspect of human health said the following:
‘Large centralized facilities are likely to result in nuisance to local residents eg from odour, dust, HGV movement, noise and emissions’
and from the aspect of biodiversity the following:
‘The environmental impacts associated with centralized facilities may lead to an increase in transport impacts, such as air quality and congestion’
and from the aspect of air quality:
‘this option has the potential to cause negative impacts as a result of emissions to the atmosphere from larger waste facilities’.
Another option was to ‘Prioritise sites at locations providing access just to main arterial roads’
The SA’s assessment in terms of air quality was:
‘Traffic related impacts on air quality would worsen in areas where they are already a local issue’(our emphasis). T
he SA’s comment about the traffic impacts is as follows:
‘Traffic impacts would be concentrated where they are already a local issue, compounding the existing associated problems, and causing detrimental impacts to human health’(our emphasis).
In addition, the SA called into question the accuracy of some of the data in the NLWP, summed up thus: “There are substantial inconsistencies in the waste data for North London. The data varies in origin, reliability and recentness”.
Comments were also made about the clarity of the policies of the 7 member councils: “For certain issues, different London Borough’s(sic) appear to have different priorities which are further complicated by unclear wording”,
“The seven issues raised in the Issues and Options report are discussed to different degrees within each Borough’s current UDP/LDF. This varies from a detailed discussion to a very limited indication or, in some cases, no mention of particular policies governing certain issues.”