Why is it bad?

The ‘mass burn’ energy-from-waste (EfW) incinerator proposal is seriously flawed in terms of its environmental, financial and democratic impact.  Here we explain why 65,500 people (92.7%) voted “no” in a referendum, and why this regionally controversial project is opposed across Norfolk.  Also see how Misleading Information from Norfolk County Council has been exposed.


In brief

  • EMISSIONS & HEALTH – respected scientific research shows increased poor health downwind
  • Government Agency concludes emissions are safe  - without conducting studies
  • HAZARDOUS WASTE CREATED – dioxins, arsenic, mercury, heavy metals released
  • COST of £500 million+ (more than double cost of some alternatives)
  • Worst alternative to landfill & SUPPRESSES RECYCLING
  • Damages tourism industry
  • BLIGHT – suppresses house prices
  • DAMAGE to fragile nature reserve
  • + 250,000 unnecessary HGV miles/year
  • Dioxins & toxic metals monitored less than 1% of the time


Emissions and Health

Scientific studies – more cancer & birth defects downwind:  The government’s Health Protection Agency (HPA) says well managed incinerators don’t have a significant effect on health. But in 2009 they admitted they hadn’t done any recent assessments. On the other hand recent studies in scientific journals do show increased cancer, and birth defects, amongst those living downwind of modern EU incinerators (Zambon et al 2007Cordier et al, 2010).  Local doctors objected to the planning application on health grounds.  Who do you trust?

Some scientific studies conclude there are no significant health impacts. Others conclude there are (Franchini et al, 2004, Raemdonck et al 2006). Many agree further research is needed before we can be certain whether or not incinerators effect health. The UK government’s official statements do not reflect this uncertainty.   One important scientific paper (Ranzi et al 2011) indicates how some studies may well be diluting the evidence by looking at health data upwind of incinerators.  When they checked the populations downwind they found an increased frequency of some cancers.  When they checked the wider area, including upwind, there wasn’t a statistically significant health effect – the previous evidence appears to be diluted.  Clearly, statistically identificable health impacts don’t occur upwind – so many studies that find no evidence of health effects are flawed.  We are concerned because King’s Lynn is downwind; including all 3 High Schools, and many of the primary schools.

Dangerous Particulates:  When waste is burnt it is broken down into a fine dust particles called ‘particulates’. These vary in size and include pollen-size (PM10), bacteria size (PM2.5) and virus-size (PM0.1) particles. Health affects include cancer, heart attacks and asthma.

Computer models used for planning applications show that incinerators contribute a small percentage of particulates to the atmosphere (by % weight).  Real world studies tell a different story. For example, a Swedish study shows the modern Boras incinerator is a major contributor of particulates.  The computer model also uses Marham’s weather data, not King’s Lynn’s, which is closer to the sea and therefore has a ‘microclimate’ that can concentrate pollutants.  Planning models also assess health impact based on  particle weight.  However, it is particle numbers, their surface area, and constituents that determine health effects.  NCC make reference to 8 tonnes of particulate emissions from a 230,000 tonne/pa incinerator.  This weight consists of an incredibly huge number of particulates, even though the annual emissions may seem small.

The emission of 8 tonnes of microscopic particles directly upwind of a major population centre will increase levels of PM2.5, whereas an EC Directive (para 11) requires their reduction. There is no getting away from this, and it calls into question NCC’s choice of location and technology.  Here’s what the Directive says;

“Fine particulate matter (PM2.5) is responsible for significant negative impacts on human health. Further, there is as yet no identifiable threshold below which PM2.5 would not pose a risk… “ 

Dioxins: Dioxins are one of the most cancer-promoting chemicals known to science. They accumulate in the human body where they break down very slowly.  The US Environmental Protection Agency shows 0.00006 grams of dioxin is a lethal dose for some mammal species (click here), and smaller doses have other health effects.  In 2008 Dundee’s incinerator released dioxins 100 times over the legal limit.  It wasn’t even fined.

We are concerned that similar incidents would go undetected in King’s Lynn.  The incinerator company proposes to monitor dioxin emissions only at the legal minimum of 32 hours each year, as required by the Waste Incineration Directive (Article 11 paragraphs 2c & 7).  Reputable peer-reviewed scientific studies have shown this greatly underestimates true levels of dioxin emissions (ENDS Report, ejnet).  It would be possible to monitor dioxin emissions far more frequently with AMESA monitoring equipment, but this is expensive, and the developer isn’t planning to use it.   Another study found that during incinerator start-up dioxin emissions can exceed the EU emissions limit by 1000 times (ejnet).

Heavy Metal and Nitrous Oxide Emissions:  These include heavy metals such as lead, cadmium, mercury and arsenic, which the incinerator is legally allowed to emit.  The developer proposes to directly monitor these only for 32 hours each year. Additionally, emissions of nitrogen oxides (NOx) will be released.  King’s Lynn, immediately downwind, already suffers from nationally designated poor air quality due to NOx.

Greenhouse Gases:  Norfolk County Council says the incinerator will cut greenhouse emissions compared to landfill.  They have repeatedly claimed savings of 70,000 tonnes/pa of CO2, based on the incinerator operating in electricity-only mode.  However, there are incorrect assumptions in the Environmental Impact Assessment (EIA), and when corrected we get a very different result.  In brief, the incinerator will actually have a bigger carbon footprint than landfill if it produces just electricity, and it seems very likely it will also be worse than landfill even if it also exports steam.  If you want the detail please read on, otherwise skip the next paragraph.

What the EIA does is to work out the methane  emissions from an equivalent amount of waste going to landfill.  Methane is another greenhouse gas, and it’s global warming effect equivalent to carbon dioxide is calculated. This is then deducted from the incinerator’s own carbon footprint to give the incinerator’s carbon footprint as  compared to landfill.  However, the EIA states 50% of methane is lost from UK landfills, whereas the correct figure is really 25% according to DEFRA (see p23).  This has the effect of doubling landfill’s actual carbon footprint, and when deducting this from the incinerator, artifically reducing its own carbon footprint.  Don’t take our word for it; its all in Appendix B of the EIA’s Carbon Assessment, only they choose not to use these figures, despite DEFRA showing these are the figures that should be used.

The carbon assessment itself is flawed for other reasons.  At any rate, alternatives such as MBT with composting have a far lower carbon footprint.  This incinerator will emit over well over 200,000 tonnes/yr of CO2.

Why not write to Dr Palm?  If Palm Paper doesn’t buy the steam, the incinerator is far less viable. Please ask Dr Palm if he plans to support the people of King’s Lynn who welcomed him to their town; 65,500 of whom voted against this incinerator.  E-mail  enquiries@palmpaper.co.uk

Strict Regulation? – Think Again:  The Health Protection Agency says well-managed incinerators don’t have an impact on public health?  Doctors and scientists contest this claim.  And what if an incinerator is not well managed?  Accidents and breaches occur at many modern incineration plants.  In 2006-2007 English incinerators broke the law almost 1400 times.  The Environmental Agency can no more assure us of safe operation than the police can assure us of zero crime.   Recent breaches at modern incinerators include the Isle of Wight, Nottingham, Swansea, Stoke,  Wolverhampton, Birmingham, Bolton, Sheffield, Grimsby, TeesValley, Dundee, Dumfries, Swansea and Coventry.  For example, a Freedom of Information Act response shows the modern Dumfries ‘energy-from-waste plant’ has breached its permit for carbon monoxide, nitrous oxides, VOCs, and ammonia emissions; and also for non-reporting, late reporting, insufficient reporting and its failure to adequately control waste. It only started operation in October 2009, but the local press report 172 emission breaches in this short period.

Other Issues

Recycling Rates Suppressed:  The choice of a ‘mass burn’ incinerator conflicts with the waste hierarchy, which sets out the relative desirability of different waste options.  The House of Commons Environment Committee says, “Waste should only be used for energy recovery if it is not possible to re-use, recycle or compost it” (click here). However, this mass burn incinerator relies wholly on householders to remove recyclables; an inefficient process.  Using a front-end ‘dirty’ MRF (materials recycling facility), would greatly increase the proportion of waste that could be recycled; mechanically separating recyclable wastes that householders miss.  The incinerator lacks a MRF, and incinerates recyclable materials, including 40,000 tonnes of paper/year.

Norfolk has much potential for improving recycling/composting.  In 2009/10 it was just 43.5%; and NCC predict 47% in 2011/12 and 50% by 2018/19.  This is a convenient increase on the previous recent prediction of below 50%, which we pointed out breached recycling targets. The affect of the incinerator in suppressing recycling is clear if we look over the border.  Cambridegshire predicts; 50-55% recycling by 2015 and 55-60% by 2020 (Cambridgeshire Strategy p3). They selected an MBT recycling plant for their big waste infrastructure project, enabling them to follow the waste hierarchy by first maximising recycling.

The 170,000 tonnes/yr of waste destined for incineration is 43% of current municipal solid waste.  This means if the incinerator goes ahead Norfolk is unable to exceed 57% recycling.  In 2010/11 ten other councils were already exceeding this rate according to the waste industry’s journal Lets Recycle.com; e.g. Rochford at 66%.  NCC argues waste arisings will increase, however, the evidence contradicts this, with even recent historic data showing a decline in Norfolk’s waste.  Clearly, NCC have failed to select the most sustainable option, and with incineration’s thirst for waste better options such as recycling will now suffer.

Job Creation Opportunities Missed:  We’ve been told over and over again that this will create 40 full time jobs.  That’s 40 jobs for an estimated £500 million cost for the taxpayer, or £12,500,000 of our money spent for each job created.  That’s not efficient job creation.  Alternative recycling technologies create more jobs.

Hazardous Fly Ash Created: About 20% of what goes in the incinerator comes out as ash. Overall 5% is fly ash, classified as a ‘hazardous waste.’ Fly ash contains dioxins – one of the most cancer-promoting substances known to science. NCC claimed that the fly ash would be recycled, but documents show it will in fact go to landfill.  Photographs from one landfill site show it blowing into the air, and a scientific study has proven that its been deposited on nearby farmland.  The main way in which people are exposed to dioxins is via the food chain.

Increase in Heavy Traffic:  At least 900 extra heavy goods vehicles (HGV) movements will be made each week to serve the incinerator.  NCC denied this for a long time. A resident who attended a meeting in St Germans reports NCC said there would be only 9-10 extra HGV movements a day.  In April 2010 NCC told West Norfolk Borough Councillors it would be 25-30 a day (see page 1074 of the minutes). Eventually estimates crept slowly up as NCC was challenged. The real figure was calculated by an independent consultant, and is confirmed by the Planning Application.  It’s 168 additional HGVs per day, or 900 per week. This false claim is but the ‘tip of the iceberg’, yet Councillors have allowed such misinformation to continue.

The impact of such a sheer number of lorry movements in the area, in terms of congestion, road wear, noise and pollution will be considerable.  King’s Lynn is located at the far west of Norfolk.  If NCC had applied the ‘proximity principle’ and located the incinerator near to the County’s centre, 250,000 miles/yr of HGV movements would be avoided.

Financial Cost and PFI Funding:  The incinerator will cost Norfolk’s taxpayers £500 million pounds, not £169 million as frequently reported in the local press. The £169 million refers to a Private Finance Initiative (PFI) contribution from central government, a method notorious for causing over-spending. Under PFI, we (the taxpayer) do not own the asset (the incinerator), but instead we pay the contractor an annual charge for the use of the facility over the period of the contract. Once the contract has expired, ownership of the asset either remains with the contractor, or it is returned to the public sector, depending on the contract.* It should be noted that the annual charge is not fixed as it will rise along with inflation.  The actual cost is a closely guarded secret; the £500 million is the most recent figure we can access.

House Prices and Blight:  Incinerators blight towns. The Independent newspaper (28/12/10) reported house prices falling by 10%, but the main problem may also be an inability to sell. Another ‘hidden’ impact could be rising healthcare costs. We want a prosperous town. We don’t want our town to become a regional hub for dirty industry.

Threat to Nature Reserves:  The incinerator will increase nitrogen oxide pollution in the area. This type of air pollution is devastating to low nutrient ecosystems as it increases nitrate deposits in both water and soil. Roydon Common is one such ecosystem and is at extreme risk from this type of pollution. The Common represents the largest remaining area of heathland and valley mire in the county, and is of international importance.

Threat to Farming:  the long-term operation of a mass burn incinerator significantly risks loss of confidence in an area of national agricultural importance.  Mike to add an example

Visual Impact & Tourism:  The mass burn EfW incinerator will consist of a large building with a chimney stack 85 high. This will dominate the flat fenland landscape and is likely to be the first landmark visitors will see as they travel into the area by road and rail.  West Norfolk is an important area for tourism, with an historic town, Sandringham Estate, popular sandy beaches, and wetlands attracting bird-watchers. The physical eyesore of a giant chimney, combined with the knowledge that it is a waste incinerator could seriously affect visitor numbers, damaging the local economy.

Democracy – Referendum & ConsultationsIgnored :  Perhaps the most serious impact is upon democracy.  When Norfolk County Council ignored 65,500 votes they set a dangerous precedent.  The referendum followed consultations which showed virtually no support for mass burn EfW incineration.  DEFRA claimed the Future of Waste in Norfolk consultation showed support for the scheme, yet only 0.5% chose to express a preference for incineration, with recycling being the favorite option.  We would have provided a link, but NCC have removed the report form their website.

For a full explanation of the democratic impact, view the YouTube video on our Homepage or download the flier on the ‘How Can I Help?’  Also, why not help us by supporting the call-in.