Waste and the Wembley Plan - some reservations

As residents of Ealing and Brent in the area around Willesden Junction station fight a planning application for a 'waste to energy' incinerator on the Freightliners Depot site, readers may be interested in Brent Campaign Against Climate Change's submission on the Wembley Plan. This includes references to waste processing. Wembley was of course the site of the 'Wembley Stink' during the Olympics when the stench from rotting organic waste at the Seneca Materials Recycling Facility became a national issue.

Since this response was submitted the Brent Executive have agreed plans for the purchase of a site for a new waste management depot in Brent as part of the four-borough contracts for waste management, recycling, street sweeping and parks maintenance. £6m has been allocated and one wonders if the site will be in the Wembley Plan area.

Brent Campaign Against Climate Change – submission on Wembley Plan

We have limited our comments to the most relevant aspects of the Plan. Omission of comment on other areas neither indicates agreement, nor disagreement, with those proposals.

VISION OBJECTIVES (p13)

• To preserve open spaces for recreation and biodiversity and create new and enhanced open spaces to address deficiencies where possible, but particularly to meet the needs of additional population commensurate with current levels of provision. AGREED
• To increase the amount of public open space (at least 2.4ha within Wembley) and the amount of land with enhanced ecological value. AGREED
• To enhance green and blue infrastructure by tree planting, returning rivers to their more natural courses and mitigating the pollution effects of development. AGREED
• To achieve sustainable development, mitigate & adapt to climate change. AGREED
• To reduce energy demand from current building regulation standards and achieve exemplar low carbon schemes and combined heat and power plants. RESERVATIONS SEE BELOW
• To create a well-connected and accessible location where sustainable modes of travel are prioritised and modal share of car trips to Wembley is reduced from 37% towards 25%. AGREED AS A START BUT NEED TIMELINES FOR MORE AMBITIOUS TARGET
• To promote access by public transport, bicycle or on foot and reduce car parking standards because of Wembley’s relative accessibility AGREED

Wembley Area Action Plan - Preferred Options 13

Business Industry and Waste

1. We are in favour of strict controls on waste management and processing sites in the entire area, rather than the limited area proposed. We would also favour relocation where that is possible. The events over the summer regarding the Seneca MRF and the ‘Wembley stink’ should serve as a warning for the future.  The Neasden/Wembley area already suffers from severe air pollution problems with school pupils particularly at risk because of the impact of air pollution on their smaller lungs. Chalkhill Primary, St Margaret Clitherow Primary, Northview Primary, Oakington Manor Primary and the proposed new Wembley Stadium Primary in Fulton Road are all in the vicinity. Older people also suffer disproportionately from respiratory problems.

2. We propose the creation of a Green Enterprise zone in the area with a concerted effort by Brent Council, in conjunction with the College of North West London, to bring green training, apprenticeship and jobs into the area. At present aside from the building jobs associated with regeneration there is an over dependence on the creation of jobs in retail and leisure. Green jobs would make a significant contribution to the upskilling of the Brent labour force.

Response to Climate Change

1. We welcome the inclusion of a response to Climate Change in the report and note this statement from the Wembley Plan:

10.6 Climate change will have a significant impact on the economic, social and environmental well being of Wembley. Hotter summers will have a bigger impact in Wembley because of the predominance of concrete and buildings. Heat waves will mean more people are likely to suffer from illnesses and could also lead to damage to roads, railways and buildings. Heavy thunderstorms and intense winter downpours will become more common, and will lead to flash flooding where the drainage system cannot cope with the increased rainfall. It is therefore crucial that future development in Wembley addresses these impacts and limits its contribution to climate change by minimising carbon emissions.

10.7 Specific issues for Wembley include the legacy of industrial use in the area which led to a lack of green and ‘cool’ spaces. Much of Wembley is deficient in open space and there are few mature trees. Land adjacent to the Wealdstone Brook is most at risk of flooding, although much of Wembley is also prone to surface water flooding. In addition, the majority of the sewer network in the Wembley area is undersized.

2.       We welcome the recognition of the importance of this issue and that fact that it is being addressed in detail by the Council. We welcome the proposals on naturalising of the Wealdstone Brook, flood plain storage, tree planting, green roofs and creation of new parks are all welcomed as  responses to this situation.

Climate Change Mitigation

1.       Under this heading the Council make a number of proposals for Decentralised  (CHP) Combined Heat and Power facilities and for Energy from Waste over which we have reservations.

2.       The  reservations below regarding CHP are pertinent: and should inform the Council’s plans: (From  www.arthurshumway.smith.com)

 "Combined Heat and Power" (CHP) or "cogeneration" systems for producing both heat and electric power are generally mature and really can reduce emissions of CO2 compared to other fossil-fuel technologies. But there are two problems with typical discussion of CHP:

(1) Fossil-fuel-based CHP cannot be a long-term solution on climate or energy because they still burn fossil fuels, and therefore still emit a lot of CO2. Reducing that by 20% or even 50% is not enough; we need to take steps that over the next 30-40 years will bring fossil CO2 emissions close to 0.

(2) Efficiency claims for CHP systems are frequently greatly overstated. Heat is lower-quality energy than electricity, and only at high temperatures does it become close to comparable. Efficiency claims for CHP systems that use high-temperature heat are not so far off, but CHP systems that make use of low-temperature waste heat have much lower thermodynamic efficiencies than usually claimed.

The inflated efficiency claims often lead to assertions that CHP is the "largest" or one of the largest potential solutions. But the number of applications that require high-temperature heat where CHP efficiency really is quite high are limited. And the modest efficiency gains with low-temperature waste heat use, which could be much more widely applied, don't lead to very much improvement in overall energy use. The combining of heat and power production in CHP systems can reduce our fossil CO2 emissions by a few percent, but much more than that is needed in coming decades.

3. The Wembley  Plan (WEM 33) supports Energy from Waste and again we have reservations.

3.i The first issue is that the emphasis should be on the reduction of waste at source in manufacturing,  then re-use and recycling. There is a danger that in using residual waste as fuel in order to reduce landfill, the incentive to reduce waste is removed. Furthermore, dependence on waste as fuel to generate heat and power, can lead to the need to import fuel in order to keep the processes going. The NABU Study (2010) in Germany illustrates this:

The study shows that in 2010, somewhat less domestic waste will be produced in Germany than at present.. This is due to a decline in the population and a slight increase in recycling. Overcapacities with incinerators are already occurring. This applies to combustible material used in energy from waste plants as well as conventional incineration   

At this point in time, 2 million   more tonnes  of waste are imported into Germany than exported. This is equivalent to a goods train 1000 km in length. Germany is therefore a net importer of waste

We would not want Brent to become an importer of waste in order to fuel our EfW plants.

3.ii  Secondly, the Plan states ‘There are a number of new and emerging technologies that are able to produce energy from waste without direct combustion’ . Our reservation on this is that in some technologies the initial stages do not involve combustion but further stages involve, for example, gases being burned off..  We cannot pretend to be expert on these issues but urge that complete transparency, independent expert advice (rather than assurances from the companies involved) and public debate must take place before any such technologies are employed.

3.ii In investigating the detrimental impact on human health the Council must take into account the concerns that exist over nanoparticles  produced in the incineration process and the emerging science discipline of nanopathology that studies the impact of such particles on the human body.

Food Growing

1.       We welcome the proposal to include food growing areas in new development (WEM 38) and the use of temporary vacant spaces. However we do not agree to the claim that restricted space means that such spaces cannot be provided in any new schools in the area. Raised beds do not take up much space and there are many imaginative solutions involving containers, window boxes, growing walls etc that could be incorporated into new build. In addition the growing spaces in existing schools in the area show what can be done. Provision of demonstration food growing areas in newly created parks would be useful as well as support for finding food growing spaces alongside the Chiltern/Metropolitan and Jubilee  railway lines.

2.       Food growing in schools raises awareness of the children about the impact of climate change and encourages healthy eating and a long term interest in gardening. It links with the curriculum and awards such as Healthy School and Eco School. The Council should be vigorously supporting it and making every effort to find food growing space for children.

3.    The Metropolitan Housing Trust is already working on these issues on the Chalkhill Estate with residents and are seeking additional growing spaces on the estate Involvement of other housing providers should be sought.