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
- 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.
- 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
- 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.
