T Jarman Further Comments: Ref Appeal by UBB REF.

APP/T1600/A/13/2200210, Invitation for Comment 20th Oct

1. I provided extensive evidence to the public inquiry. This evidence dealt with the design, sustainability and
performance of the planned incinerator with reference to current and emerging benchmark alternatives.
This evidence is public but is third party so for ease of reference I have attached the statement I submitted
at closing which summarises this input.
2. I have received a copy of your invitation for further comment on this appeal, in particular with reference to
The Secretary of States letter of 16th September and his new waste related planning policy and guidance.
Background and the Cory plans
3. At the core to the case argued for the planned UBB incinerator is that the only credible alternative is landfill.
This forms the basis of claims of need, economic and other benefits including CO2 emission reduction.
4. This case is clearly highly flawed, and fails to appreciate a key issue for sustainability, which is flexibility to
emerging science and technologies. The planned incinerator has a design lifetime of 30 years and beyond
and cost and CO2 savings versus landfill are quoted based on 25 years of operations. Yet it is abundantly
clear that waste should be treated as a resource within a sustainable local economic and environmental
structure. It is simply not credible, neither commercially as Corys and other plans show, nor from a WPA
perspective that waste would continue to be sent to landfill for this period.
5. The County Council through its planning committee has unanimously rejected the plans. Twice the full
Council has voted on motions to support that position. The Council has set up a committee, the Residual
Waste Working Group (RWWG) to propose alternatives should these be necessary. At a full Council meeting
in January 2014 (motion 694) the Council resolved c) Endorse the view of the Planning Committee given
on 21 March 2013 and instructs our Chief Executive as part of the inquiry process to write to the Secretary of
State for Communities and Local Government to strongly reiterate that view.
6. It is notable that at the inquiry and in subsequent press releases the Council has limited its objection to
grounds of visual and heritage impact, the lack of objection on technical or alternative grounds seems to be
linked to the constraints of a contract signed shortly before the planning decision.
7. The plans are for a project with a planned life of 30 years or more. Any assessment of need or benefit must
be done with an eye on alternatives that will be available over that timeframe. GCC planning policy
addresses sustainability and the impact on good design in a number of places, making is flexibility a key
driver.1
8. At the inquiry and in subsequent press releases the Council continues to argue a case compared to landfill,
yet it knows through its own Residual Waste Working Group that there are many alternatives that could and
would be delivered well before this. As a Gloucestershire and UK citizen I find this undermining of the
democratic process and refusal to progress alternatives effectively as disturbing, it seems a clear breach of
duties and improper that our public servants act in this way.
9. The Cory plans are just one of a number of third party plans to develop residual waste treatment facilities in
the County. They represent capacity for 70 ktpa of residual waste treatment, and the site has clear potential
to be expanded beyond this if required. This development is being driven by commercial need and
opportunity.
10. Plans for residual waste treatment have also been announced by ART GL using the Biocentre process,
potentially for a plant at an adjacent site at Javelin Park. These were briefly presented to the public inquiry,
again they show what would happen if the planned incinerator is not built, and may happen even if it is. The
Biocentre process is classed as a manufacturing process which requires B2 planning consent so falls under
the radar of the WPA. Evidence of this including consents in Birmingham and elsewhere was presented at
the inquiry.
11. I have presented to the Countys plan B committee looking at alternatives to the planned incinerator, the
RWWG. Their conclusions are not yet published, however it is clear that the plans discussed centre around
resource recovery and high grade recycling, with efficient energy recovery as part of an integrated solution
1

eg Waste Core Strategy Key driver 4 Changing technology as the WCS covers a 15 year period it is important to
build in appropriate flexibility

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T Jarman Further Comments: Ref Appeal by UBB REF. APP/T1600/A/13/2200210, Invitation for Comment 20th Oct

12.

13.

14.

15.

16.

for Gloucestershire. These proposals include full technical assessment to show how around 50% of waste
currently in the residual waste stream would be automatically recycled with good design of a suitable sorting
facility. This would immediately increasing Gloucestershire recycling rates from the current c50% to 75%. In
addition energy recovery from the proportion not recycled would be in excess of 60%, rather than the
planned incinerators 20%.
Stroud DC (SDC) and other WCAs are in a process of considering their next collection contracts. I have been
in discussion with SDC about an integrated waste resource recovery, recycling and refining process (R4C)
based on established and conventional processes. Such a plan would recycle or use elsewhere between 75%
and 94% of all waste collected, leaving very little to be sent to an incinerator once built. Ironically although
this would save an enormous amount in landfill tax or gate fees to an incinerator, this benefit is not seen
directly by the WCA. This makes progress on a far more economic and sustainable solution for
Gloucestershire or the districts difficult while the incinerator is being progressed.
The contract between UBB and GCC allows for an alternative project to be considered should planning
consent not be granted. This includes technical alternatives, presumably alternative forms of EfW
incorporating waste pre-treatment and enhanced energy recovery in a much smaller building. I presented an
outline for such a scheme in my third party submission to the inquiry. I have had discussions with UBB and
GCC about investigating these alternatives and been told that this would be done when and if planning is
rejected.
All of the alternative plans above for waste management in Gloucestershire, including the Cory plans, are
difficult to progress (although not impossible) while uncertainty over the proposed incinerator continues. Far
from encouraging a good waste solution in the County, the proposed incinerator is holding back the
development of far more sustainable alternatives.
The planned incinerator burns all material received which includes a large amount of plastic. Plastics are of
course a fossil fuel, and burning these inefficiently (c20% energy recovery for the incinerator) is
environmentally ludicrous. To present this as renewable energy as the applicant does is outrageous to thus
of us who cares about our planet. Over 62% of all useful power produced by the planned incinerator comes
from the burning of these plastics.2
The environmental footprint of the planned incinerator measured by WRATE is far worse than many
alternatives as presented to the inquiry. Development of this incinerator would lock us into a solution at the
peak of cost, which barely steps onto the first rung of the waste hierarchy (recovery) with a c20% efficiency,
when far than this, typically >60% is achieved by many other modern facilities.

New Planning Policy Guidance Waste. Updated 16.10.14

17. This new planning policy guidance on waste makes clear the importance of sustainability and details a
requirement to prepare a sustainability appraisal for local plans. According to evidence presented to the
inquiry by myself and others the proposed facility would score badly on the following criteria in particular.
Sustainability principles should surely encourage us to have an eye on what such an appraisal of the
proposed incinerator would yield. (italics below are abbreviated headings from that guidance)
a. Sustainable use of resources: It is essential that materials are recovered from the waste stream prior
to incineration. Incineration degrades and destroys material such as aluminium, precocious metals
present in WEE and plastics. See also point 18
b. Climate change: This is best assessed using the WRATE tool. As presented at the inquiry, GCC and
others have conducted WRATE assessments for a range of alternative waste treatment solutions for
Gloucestershire and these were presented to the inquiry. These show that the planned incinerator,
while being slightly better than landfill, performs far worse than EfW with effective heat recovery,
and far worse than solutions with pre-sorting / treatment of waste prior to efficient energy recovery.
For example the highest performing solutions such as MBHT as presented to the inquiry remove

See my closing statement to the inquiry, January 2014. Also attached with this note.

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T Jarman Further Comments: Ref Appeal by UBB REF. APP/T1600/A/13/2200210, Invitation for Comment 20th Oct
500kg of CO2 from the atmosphere for every 1000kg of waste processed. By comparison the
planned incinerator is a net emitter of CO2. Technically there are two reasons for this poor
performance of the planned incinerator. Firstly the burning of plastics which should be recycled
before incineration, secondly the location of the planed incinerator which means that heat produced
by the process is wasted, with only 20% of the energy in the waste being recovered.
c. Landscape: Please dont forever blight our beautiful County!
d. Quality of surroundings (improving the quality of where people live) : Please!
e. Public involvement (participation): The Gloucestershire public together with their elected officials
have become very involved in this proposal. 4,355 people wrote to object to the original application,
30 people spoke at the planning inquiry including parish, district and County Councillors, and two
MPs. The Planning Committee heard local representations and unanimously rejected this proposal.
Following the 2013 local elections the Council has twice voted to endorse and support this planning
decision and has set up a committee to investigate alternatives. I would like to think that
sustainability principles do not only encourage the participation of local people, but also encourages
responsiveness to their position. It would hugely undermining of the principles of local democracy,
public inquiry and sustainability if this level of public rejection was ignored by the planning process.
Please dont allow a monster building stuck on the edge of our area of outstanding natural beauty to
forever remind us that what we think doesnt matter.
f. Sustainable economic growth: The alternative plans being discussed by GCCs Residual Waste
Working Group and Stroud District Council would harness waste as a resource, stimulating the local
economy. Plans have been discussed that have a processing cost of 50 per tonne (compared to
c100 for the incinerator or landfill) itself clearly economically far more sustainable. An example of
how alternative waste treatment could be used to support sustainable economic growth: Dairy
Crest just 8km from Javelin Park, but too far to ship heat - is a large user of heat and power
(>10MW) and would upgrade their current boilers to accept a high grade fuel produced from an
MBHT type process. This would drive down local costs, drive up competiveness and drive growth.
This kind of project becomes possible if you have not destroyed all of the value in waste in an
incinerator being open to these developments is an important component of sustainability.
g. Waste Hierarchy: I presented to the inquiry detailed analysis showing 47% of material in
Gloucestershires current residual waste stream can be economically recycled prior to any
incineration. Full WRATE assessments and policy guidelines including those emerging from the
Waste Regulations Act 2011, make it clear that it is not just steps on the hierarchy that matter, but
the best environmental outcome. The planned incinerator claims recycling for material to be used as
the lowest form of road aggregate, even (incredibly) that made from incinerated precious metals
present in WEEE in residual waste. Clearly it would be far superior to separate out this material prior
to incineration. The incinerator can just claim to be recovery because it achieves c20% efficiency. Yet
clearly a recovery process that achieves >60 efficiency (as a number do) is far superior. For these
reasons the planned incinerator would score very poorly.
18. As I am sure the Secretary of State is aware the Environment, Food and Rural Affairs Committee issued their
report on Waste management in England on the 21st October 2014. This makes a number of important
points about how waste should be managed, in particular emphasising that Valuing waste as a resource is
increasingly important for the economy and environment (conclusion 1) . Paragraph two of the press
release issued at the time was:
MPs also call on Government to ensure that only genuinely residual waste is sent to energy-from-waste
plants and to do more to encourage the use of heat outputs from such facilities to improve the overall energy
efficiency of this waste management method. (my emphasis)
19. These are important conclusions which reflect the change in understanding and capability that has occurred
for EfW plants since the Gloucestershire project was first conceived. The planned UBB incinerator fails to
meet these requirements and as such cannot be a sustainable way to treat waste. In particular:
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T Jarman Further Comments: Ref Appeal by UBB REF. APP/T1600/A/13/2200210, Invitation for Comment 20th Oct
a. The waste to be burnt by the incinerator is not genuinely residual and could be simply processed to
extract valuable further recyclates. In particular the majority of useful energy produced is from the
burning of plastics which should be recycled3. Sorting prior to incineration to achieve Second
Chance Recycling is essential in a modern waste management system.
b. Javelin Park is 8km away from a large heat user Dairy Crest but this is too great a distance to
transport the heat. There are no identified users for the heat produced. It is suggested that the
planning process should reject proposals that to not demonstrate effective use of heat.
20. In summary I would ask the Secretary of State to reject the proposal and urge all parties to pursue
alternatives which will deliver higher levels of recycling, higher grade recycling of material and increased
levels of renewable energy production from the material which cannot be economically recycled.

Tom Jarman. Selsley, Stroud, Gloucestershire 29.10.14

PS I did not receive a direct invitation to comment on the letter of 16th September, however I was made aware.
Tony Field and Brian Stopp were invited to comment on both letters and have asked that I reflect their input in my
comments above.

See submissions by Tjarman to the planning inquiry and for example WRAP final report on Domestic Mixed Plastics
Packaging and Waste Management Options June 2008

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