Herts. WithOut Waste (HertsWOW)

Recycling and composting not disposal


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PINS Report to Secretary of State

Posted by hertswow on October 2, 2018 at 4:20 AM Comments comments (0)

The Planning Inspectorate has announced that Inspector Jennifer Vyse's Report will be submitted to the Secretary of State on or before 4th February 2019.

However, we will not see it until the Secretary of State issues the Decision letter.

EA's Consultation on the draft Environmental Permit

Posted by hertswow on September 26, 2018 at 4:10 AM Comments comments (0)

We have made a submission to this Consultation, as follows.


We draw attention to matters within the scope of those identified in paragraph 4.1.4, Key Issues in the Determination, page 16: “… assessment of air quality, assessment of health effects, assessment of noise impacts, assessment of BAT and consideration of consultation responses, …”:

Temperature inversions: The CALPUFF software module is used for modelling in several case

studies. We raised queries about the potential for higher pollution levels.

Local emission sources: We noted these potentially expanding or new sources that should in our

view be taken into account in the assessment of cumulative impacts: Pharmaron UK Limited

and Woollensbrook Crematorium.

Water discharge: We noted the constraints on discharges of secondary treated domestic sewage

to water bodies, in this case to the River Lee, and asked for evidence of compliance by the


Long term emissions of oxides of nitrogen: We asked the EA to explain the relatively high

emissions estimated for the proposed facility at Rye House, Hoddesdon, in comparison with

other incinerator facilities.

Best Available Technicues for this installation: We enquired whether there are specific features (other than site-specific features) of the proposed installation in regard to BAT.

Period of abnormal operation: We raised queries about the way in which the end of the period of

abnormal operation would be determined.

Health impacts of emissions by industrial processes: We noted recently published research

findings and asked for the EA to suggest to HMG that it is time to review the current guidance.

Our detailed response is available on request and will be published shortly on the EA's new online consultation hub, Citizen Space: https://consult.environment-agency.gov.uk/psc/en11-0rf-veolia-es-hertfordshire/" target="_blank" rel="nofollow">link.


Responses are listed by response number. You can use the Search box to find a particularsubmission

Responses whose the senders have allowed to be published may still be redacted for personal identities.

Rattys Lane Planning Inquiry - hearings adjourned

Posted by hertswow on August 4, 2018 at 7:45 PM Comments comments (2)

The hearings of the Planning Inquiry for an incinerator plant for residual waset to be built in Hoddesdon were adjourned yesterday so that the Inspector can prepare her report to the Secretary of State. The hearings are "adjourned" rather than "ended" since it's possible that the Inspector will re-convene them on issues emerging or external matters arising. We do not have a view of what the Inspector will recommend nor what the Secretary of State will decide. However you are welcome to ask us about ehat took place from our point of view as a "Rule 6" party to the Inquiry.
For the Inquiry documents, see the Inquiry Library online here.

P.S. on 25th september 2018: We have been notified that the Public Inquiry hearings are now officially closed. The Inquiry goes on c/o the Inspector as she prepares her report for the Secretary of State to make a decision in due course.

BBC Radio 4 - Recycling - LGA, Veolia, BPF & Eunomia, 4 August 2018

Posted by hertswow on August 4, 2018 at 7:35 PM Comments comments (0)

A 10-minute item was broadcast in BBC 4's Today programme on 4th August 2018.

The item is now available for listening via the BBC's Radio iPlayer: https://deref-gmx.co.uk/mail/client/ULqOqbxIq6I/dereferrer/?redirectUrl=https://www.bbc.co.uk/programmes/b0bd6jj3" target="_blank" rel="nofollow">link

Below is a gist and timings. and timings. Please refer to the recording for the precise wording in context.


The Local Government Association

LGA - warning: "two thirds of food packaging can't be recycled and and have to be burned or sent for landfill. That's 350,000 tonnes a year"


Visit to Veolia's Recycling plant in South London

Richard Kirkman, Chief Technology & Innovation Officer

"just 25 people are on this shift"

"about 35,000 tonnes of black trays in the country but that's out of about 35 million tonnes of packaging waste."

Reprocessing plastic bottles into chips for milk bottles, plastic bags for bin liners

"Maybe 20% [of the extracted plastics] would difficult-to-recycle materials. It will be used for energy."

"Instead of burning oil, we can burn plastics."


Peter Fleming, spokesperson for the LGA

"black plastic makes the food look good"

"The British Plastics Federation ... says it would be delighted to work with local authorities."


Dr Dominic Hogg, Chairmen of Eunomia

"All of the cost at the moment is falling on local government."

"could the cost on manufacturers of packaging"

"There may be cost for standardising collections"

"£1 Bn per year ... fund by the producers" (of unrecyclable packaging)

single-layer polymer films would need to be thicker than multi-layer"

ends at 1:40:32

Available for download until 2nd September 2018

Revised National Planning Policy Framework (NPPF)

Posted by hertswow on August 4, 2018 at 10:25 AM Comments comments (0)

On 24th July 2018 the UK Government published a revised version of the central framework for land use planning in England, the Revised National Planning Policy Framework (NPPF). (source)

This is variously referred to as RNPPF, NPPF2 of NPPF 2018. Its policies have immediate effect for determining planning applications and appeals . However for plannning purposes, it is only relevant to plans submitted for examination after 24 January 2019.

Despite responses to a consultation earlier in 2018 across a wide range of matters, the Government chose to focus the changes on matters of Housing. That has given rise to a myth or misunderstanding that other areas of plan-making and site-specific decisions are not affected. However there are implications across several topical areas, notably the following:

Planners, analysts and legal advisers are studying the potential implications and the changes and clarifications of policy have yet to be tested in practice. The sources cited above are well-informed initial views and we can expect much further assessment in coming months. Several documents associated with the revised Framework were published at the same time and others are forthcoming.

Another handy commentary is provided by Lichfields,

VES Hoddesdon - Notice of Draft Environmental Permit

Posted by hertswow on August 2, 2018 at 5:25 PM Comments comments (0)


Notice - draft Environmental Permit: https://www.gov.uk/government/publications/en11-0rf-veolia-es-hertfordshire-limited-environmental-permit-draft-decision-advertisement/en11-0rf-veolia-es-hertfordshire-limited-environmental-permit-draft-decision-advertisement" target="_blank" rel="nofollow">link

EN11 0RF, Veolia ES Hertfordshire Limited: environmental permit draft decision advertisement

Published 2 August 2018

Applicant name: Veolia ES Hertfordshire Limited

Reference number: EPR/SP3038DY/A001

Brief description of activity: The incineration of non-hazardous waste in a waste incineration plant with a capacity exceeding 3 tonnes per hour.

Application type: Bespoke

Regulated facility location: Rye House Energy Recovery Facility, Rye House, Rattys Lane, Hoddesdon, Hertfordshire, EN11 0RF

Local authority: Broxbourne Borough Council

Information placed in Citizen Space for consultation:

Draft decision permit
Draft decision document

How to view the application

You can view the information at the Environment Agency register:

Environment Agency, Alchemy House, Bessember Road, Welwyn Garden City, Hertfordshire, AL7 1HE

How to comment on the application:

Online: view and comment on the proposed decision using Citizen Space

End date for representations: 30 August 2018.

Email: [email protected]

Or write to:

Environment Agency, Permitting and Support Centre, Land Team, Quadrant 2, 99 Parkway Avenue, Sheffield, S9 4WF

Herts CC / Veolia ES Planning Inquiry

Posted by hertswow on July 26, 2018 at 9:30 AM Comments comments (0)

The hearings of the Planning Inquiry for an incinerator plant at Hoddesdon to burn all of hertfordshire's residual waste have been extended by one day to conclude on Friday 3rd August 2018. Timetable: v.14

NOTES: The times given below take account of a programme update at end Thursday 26th July. Please check for any later verson of the timetable before you visit the venue* to attend any partiular session. Look out for start times varying, usually either 9:00 am or 9:30 am.

*High Leigh Conference Centre, Lord St, Hoddesdon, Herts. EN11 8SG

The final expert witness session for the Applicant will take start on Friday 27th July from 9:00 am, when David W. Bridgwood will give  evidence on Planning Policy matters. Among the other Rule 6 objectors, HertsWOW will conduct a formal cross-examination on Tuesday 31st July. 

That will be followed by Round Table Sessions on Planning Obligations/Possible Conditions to cover the eventuality of planning permission being granted of Mr Bridgwood for the proposal.

The last two days, 2nd and 3rd August, will be taken up with Closing Submissions, including ours on the Thursday and the Applicant's and Herts. County Council's (as the Waste Planning Authority concerned) on the Friday.

Then the Inspector, Jennifer Vyse DIPTP MRTPI, will close the hearings in public so as to go ahead with producing her report of recommendations for the Secretary of State to decide upon in due course.

National Infrastructure Assessment

Posted by hertswow on July 10, 2018 at 3:35 AM Comments comments (1)

National Infrastructure Commission | National Infrastructure Assessment, July 2018

Quotes about renewable energy and waste reduction

"Cutting waste – that new national rules for what can and cannot be recycled be introduced, with restrictions on the hardest-to-recycle plastics, aimed at increasing rates and reducing the amount of plastics going to incinerators. This would also mean that all food waste is separated making it available to create biogas, so it can be used to heat people’s homes and potentially as a transport fuel."

“… Over the coming years, we’ll need to radically change where we get our energy from, with greater focus on renewable and low-carbon sources like wind and solar. The strides we’ve made in this field mean the UK gets nearly a third of its electricity this way, but we need to go even further. With falling renewables prices, this is an exciting opportunity. It must also lead to changes in how we heat our homes and businesses, an area where we still rely too heavily on fossil fuels.

This is essential to us meeting our legally-binding climate change targets, and so too is the need to get better at recycling our waste. We’re recommending changes that would restrict the use of PVC and polystyrene – the hardest-to-recycle plastics – in packaging. This would be backed up by a national recycling policy, so the same things are recycled regardless of where you are in the country, with a clear labelling scheme for packaging making it even easier for households and businesses to follow."


Blog: https://www.nic.org.uk/a-national-infrastructure-assessment-fit-for-the-future/

Report: https://www.nic.org.uk/publications/national-infrastructure-assessment-2018/

Chapter on 'Low cost, low carbon': https://www.nic.org.uk/assessment/national-infrastructure-assessment/low-cost-low-carbon/

Inforgraphics/text/download: https://www.nic.org.uk/wp-content/uploads/CCS001_CCS0618917350-001_NIC-NIA_Accessible.pdf#page=33


Foreword, pp.3-6:

"The recommendations set out a pathway for the UK’s economic infrastructure:


l half of the UK’s power provided by renewables by 2030

l three quarters of plastic packaging recycled by 2030



"...the recommendations will also improve our quality of life by reducing air pollution, protecting our homes from floods, and making cities better places to live. The cost of driving will fall substantially if people can switch to electric vehicles. And they will help the environment by reducing waste that ends up in our landfills, incinerators and oceans."

How has the Commission come to these conclusions? - p.7:

"The strategies have been developed considering the responses to the Commission’s consultation in Congestion, Capacity, Carbon: Priorities for national infrastructure, working closely with experts and other independent organisations, seeking diverse views across sectors and regions, asking the public for their views (via a social research programme), and through the Commission’s own internal analysis and modelling. More information and consultants’ reports can be found on the Commission’s website."

Overview - Low cost, low carbon - pp.9-10:

"In the waste sector, too, there are lower cost, lower carbon options especially for food waste and plastics. There is public support for greater recycling, but frustration with the complexity of the process.

It is cheaper to collect food waste separately and process it in anaerobic digesters, rather than send it to energy from waste plants (incinerators). Seventy nine per cent of people who do not currently use a food waste bin would be prepared to use one if it were provided by their local council. More plastics should be recycled, including by restricting the use of hard-to-recycle plastic packaging by 2025. Better packaging design, clearer labelling, fewer hard to recycle plastics, and tougher recycling targets (of 65 per cent of municipal waste and 75 per cent of plastic packaging by 2030) could all reduce residual waste and mitigate the need to build additional infrastructure."

Chapter 2 - Low cost, low carbon - pp.31-50:


England needs to do as well as Wales – a world leader – at recycling"

"Higher recycling, especially of plastics, could: - £6.2 billion from 2020 to 2050

- Avoid the need to build 20 additional incinerators

- Reduce greenhouse gas emissions"

p.34: "Reducing the waste sent to energy from waste plants (incinerators) by recycling more plastic and converting more food waste into biogas can also help reduce overall emissions."

pp.34-35: "The successful delivery of a low cost, low carbon energy and waste system requires:


- encouraging more recycling, and less waste incineration."

pp45-50: Incinerating less, recycling more

Low cost, low carbon waste is also necessary and achievable in the near term. The Commission’s remit on waste covers England only, where waste generation is expected to rise as the population grows. Energy from waste plants (incinerators) facilitated the move away from landfill, and make sense when the alternative is energy from fossil fuels. They incinerate ‘black bag’ waste and other wastes that cannot be recycled, producing electricity and providing heat where there is a source of demand nearby.

However, lower cost, lower carbon options exist for some types of waste, in particular food waste and plastics. In these areas, England should not settle for the minimum standards set out in EU legislation but should seek to be amongst the best performers, learning from the example set by Wales.



Annex D: Recommendations, pp.155-6:


The Commission recommends that government should set a target for recycling 65 per cent of municipal waste and 75 per cent of plastic packaging by 2030. Government should set individual targets for all local authorities and provide financial support for transitional costs. The government should establish:

l Separate food waste collection for households and businesses (to enable production of biogas) by 2025.

l Clear two symbol labelling (recyclable or not recyclable) across the UK by 2022.

l A consistent national standard of recycling for households and businesses by 2025.

l Restrictions on the use of hard-to-recycle plastic packaging (PVC and polystyrene) by 2025.

l Incentives to reduce packaging and for product design that is more easily recyclable by 2022.

l A common data reporting framework for businesses handling commercial and industrial waste by the end of 2019, ideally through voluntary reporting but if necessary by legislation.


Chiltern Green Energy Park

Posted by hertswow on June 16, 2018 at 5:15 PM Comments comments (3)

This is a new proposal for a merchant facility including a waste incinerator to burn refuse derived fuel (RDF) at Chiltern Green, New Mill End, Bedfordshire between Luton and Hertfordshire's western border.

Emsrayne Renewable Energy Ltd: "... a Central Bedfordshire company specialising in providing green energy solutions for the local community and beyond. With two successful solar farms, and plans to expand into other forms of environmentally friendly energy, ..."*


Planning application: "Emsrayne Renewable Energy Ltd are planning to submit a proposal to Central Bedfordshire to build a state of the art energy park at New Mill End. The facility will process around 500,000 tonnes of waste per year, generating up to 49MW of power - enough to supply over 60,000 homes. It will also generate heat which will be supplied to local farms, businesses and homes."


About Chiltern Green Energy Park: "Emsrayne Renewable Energy Ltd are planning to submit a proposal to Central Bedfordshire to build a state of the art energy park at New Mill End. The facility will generate up to 49MW of power and heat for local homes and businesses as well as supplying the National Grid."

Web site: cgep.uk/

Location: Wikipedia: "New Mill End is a hamlet located in Bedfordshire, England, close to county border with Hertfordshire. It is in the civil parish of Hyde, Bedfordshire"

*Caddington is also close to Luton, but a few miles westwards.

Request: If you live in that area and have any local information or concerns, please contact us a.s.a.p.

China's waste import ban

Posted by hertswow on June 4, 2018 at 2:15 AM Comments comments (0)

The Environment Agency’s Assessment of the China Waste Import Ban and the resultant local issues

"China has recently introduced a ban and restrictions on the import of foreign waste for recycling. The measures have been introduced in a bid to improve their poor local environment in a campaign against what China calls 'foreign garbage. ..."

Available to download: