Introduction

My name is John Austin. I am the Member of Parliament for Erith and Thamesmead. I live in Sutherland Road, Belvedere just off the southern end of Norman Road. Prior to my election to Parliament I worked in the borough for 21 years, mostly in the Erith, Belvedere and Thamesmead areas with an office in Erith and a project based in Thamesmead.

The Belvedere and Thamesmead area has a number of industrial processes which produce atmospheric pollution which is clearly hazardous to health and others which produce nuisance smells which it is argued are not health hazards but which certainly spoil the environment and enjoyment of the area.

There are a number of incineration processes in the area on both sides of the river which provides no barrier to atmospheric pollution. Indeed we also get emissions from major sources of pollution outside our area, such as the power station at Dartford.

The area is low lying land which in certain climatic conditions causes any pollution to hang over the area and not disperse. The area has high incidences of asthma and respiratory illness particularly among children. I cannot put it any more forcefully than the views expressed at the meeting at Lakeside by a 15 year old pupil from the Business Academy. I am sure the Inspector recalls Sandra McGough's comment that the new school had given young people a new future but she added a plea on behalf of young people "Why improve our brains and then spoil our health?"

I believe the record shows that there are health risks in the area. I also believe incineration carries increased health risks. I gave evidence at the previous Inquiry held at the St Joseph's Annexe of Bexley College on that issue, as did the then Director of Public Health, Dr Liz Dean. I believe that evidence is still relevant.

But the council has made a powerful case about perceived risk too. There is no doubt that perceived risk itself has an impact on people's health. And the Inspector can be in no doubt about local people's feelings on this issue. Children, in particular, are perceived to be at risk and morbidity records would suggest this is so. You have seen the level of anxiety and opposition that this application has generated. I put it to you that to ignore such public anxiety is to threaten the democratic process, and as the council says undermine the sense of well-being in the community.

I would also draw your attention to the report of the House of Commons Select Committee which said "There are…some truths which can be drawn from the debate over the health impacts of incineration. Firstly, that the health effects which result from an incinerator's emissions are not yet fully known. Secondly, that the regulation of incineration to date has been rather poor and that has resulted in poor practices developing in some incinerators." (Department of Environment Transport and Regional Affairs Committee, March 2001, report HC 39-I, Delivering Sustainable Waste Management, Vol 1 paragraphs 97/98)

There are also concerns about the visual impact which local residents have put forward which will affect not only those like me who live close to the site but also the folk who live on the hill. Their views should be taken into account also. And there is the question of its impact on regeneration.

In the 30 years from the sixties to the nineties, this part of London lost more jobs than any other part of the United Kingdom. When I was first elected to Parliament in 1992, one of the wards in my constituency had an adult male unemployment rate of 60%. We are now beginning to see a transformation with the development of the Thames Gateway.

I understand that one of the reasons for refusing the Hull application was the impact that it would have on regeneration of the River Hull Corridor and the city centre. The same argument can be used on the effect that an incinerator of this size would have on the regeneration of the Thames Gateway region. Government has identified this area as an area of huge development potential both for home building and for new cleaner industry such as the East Thamesmead business park. Argument from the community and which constituents relay is that the sheer size of the facility will have a negative impact on the area and reinforce a traditional view that this is the dumping ground of London. I believe the arrival of a massive municipal waste incinerator cheek by jowl with a Sewerage incinerator serving the whole of south London, opposite a sewerage incinerator serving north and east London would have an adverse effect on inward investment.

Hierarchy of waste management

In 1998 the London Planning Advisory Committee (LPAC), established following the abolition of the GLC, adopted a waste hierarchy as advocated by the EU, which puts recycling above energy recovery and seeks to take this priority seriously. They came to this view as the result of assessing both options from the viewpoint of planning for sustainability in London.

LPAC gave four reasons for their conclusion. Firstly, that recycling is environmentally preferable and represents the Best Practicable Environmental Option for London. They quoted in support a major US Environment Protection Agency study of 1997 on Greenhouse Gas Emissions which found that recycling was to be preferred over incineration for every individual material stream as well as mixed municipal solid waste (MSW). Secondly, they argued that recycling is economically preferable as it generates five times more (unsubsidised) jobs than incineration and provides major opportunities for new industries and the welfare to work programmes. Thirdly, they argued that recycling is socially preferable as it engages people in the problems of waste management at source in a way that incineration does not. Fourthly they argued that incineration would involve rising costs and liabilities, whereas recycling if properly carried out can reduce waste management costs.

I firmly believe that further large scale incineration capacity in London will undermine a recycling led strategy because there is an inherent conflict between high levels of incineration and recycling. Large scale incinerators such as the one planned require massive capital investment and shareholders will require a return on their capital, so the Incinerator would need to run at full capacity. LPAC pointed out that frequently the finance for incinerators is dependant on municipal contracts and guarantees. Often local authorities are locked into contracts with minimum tonnage requirements, which act as a disincentive to increased recycling in those boroughs. In some cases there is not only a minimum tonnage requirement but also a minimum calorific value requirement.

LPAC also argued that recycling offers a more immediate way of securing diversion from landfill pointing out that diversion on the Continent has in many places cut the amount of waste for disposal by 50% in 6-8 years which they quoted as the time it takes to plan, design, gain planning permission and build an incinerator.

Government guidelines

The government reiterated this hierarchy in the Prime Minister's Strategy Unit publication Waste Not, Want Not in November 2002 which stated that the first principle underpinning the government's waste strategy was that England needed to move up the waste hierarchy and that waste reduction, re-use, recycling and composting should take precedence over energy recovery.

The government's published Waste Strategy 2000 clearly states that energy recovery through the incineration of waste should be considered only after all options for minimisation and composting have been explored.

The Mayor of London has been given statutory responsibility for drawing up a waste strategy for London within the government's guidelines. Both the Mayor's Draft London Plan (June 2002) and the Mayor's Draft Municipal Waste Strategy (September 2002) promote an intensive recycling-led strategy. In order to comply with the spirit of these documents I would argue against any additional mass burn incineration capacity in London until other means of treatment have had time to develop. I share the view expressed by other witnesses that if we are to have incinerators they should have smaller capacities, 80,000-150,000 tonnes, which can deal with the residual waste of between 1-3 local boroughs conforming with the proximity principle.

Proximity principle

The proximity principle suggests that waste should be dealt with as close as possible to its source and encouraging communities to take responsibility for their own waste is a key part of the process of sustainable waste management. The Mayor's Draft Municipal Waste Strategy says that where possible waste should be dealt with within a borough boundary or waste disposal area boundary, or, where this is not possible, a site as reasonably close as possible.

Bexley has one of the best rates of recycling and composting in London and is now being asked to deal with the waste of authorities on the other side of London which have some of the worst recycling records. This cannot be consistent with the proximity principle and building a massive incinerator in Belvedere capable of burning all of west London's rubbish provides no incentive to those authorities to move up the waste hierarchy. If incineration is necessary to deal with residual waste small incinerators close to the source of waste generation may provide encouragement to recycle and compost, through encouraging local responsibility.

I understand that the applicants have argued that use of the river to transport waste is consistent with proximity principle because transportation by river is less damaging to the environment than transportation by road. But this misses out all the positive arguments for local responsibility. If a local solution is not possible, the use of more sustainable modes of transport might reduce the negative effects of long-distance options but it is hardly consistent with the proximity principle which the Western Riverside Waste Authority's own consultation document would seem to admit. They asked residents of the four boroughs, Hammersmith & Fulham, Kensington & Chelsea, Lambeth and Wandsworth for their preferred location for the incinerator. The options were:

1. "To conform best with the Proximity Principle, within the area of the Authority at Nine Elms, Battersea"
2. "Either of two potential sites in east London, with the waste transported by river"
3. "Nowhere"

In its own documents, the Western Riverside Waste Authority states quite categorically that a site within the area of the Authority conforms best with the Proximity Principle. And WRWA also admit that a site within the Authority exists.

But they have chosen to site their facility in Bexley. I would remind RRRL and point out to the Inspector that, in their consultation document, the Western Riverside Waste Authority stated "The best size for any incinerator would be one of the issues for the local planning authority". Bexley is the local planning authority for the chosen site. So what is the view of the planning authority which has one of the best rates of recycling and composting in London? It takes the view that incineration should only be used after all other options have been explored. The Council's view is that if we are to have incinerators, they should have smaller capacities, 80,000-150,000 tonnes, which can deal with the residual waste of between 1-3 local boroughs conforming with the proximity principle.

Indeed, Bexley gave planning permission in the 1990's for a small incinerator to deal with its own waste and in policy terms has stated that it would be happy for a small incinerator to be built to deal with Bexley's and 1 or 2 neighbouring boroughs waste.

WRWA will have a contract with the applicants for 30 years and even if those boroughs are not locked into minimum tonnage agreements and even if they are successful in getting their act together on re-use, recycling and composting, RRRL will still need to feed its hungry monster. WRWA say so in their consultation document. It says that Energy from Waste plants "require a guaranteed amount of waste each year to work properly and to pay for constructing them". So if the Western Riverside Authority does reduce its residual waste, where will the extra tonnage come from? Of course it will be imported from a wider catchment area – and possibly an area without easy access to the river so that waste will be transported long-distances by road, adding to environmental pollution.

We only need to look at Allington, with a capacity of 500, 000 tonnes per annum, as an example of an incinerator which was supposed to deal with regional self sufficiency. It can be seen from its size that it then becomes a magnet for boroughs from outside its region to export their waste.

The Government has given clear guidance regarding issues of both proximity and the need to implement policies of recycling and composting before incineration through its decision in May 2002 regarding the extension of the incinerator at Edmonton in North London. The government's refusal was based around the effect that this extension would have had on recycling and composting levels in London, which policy dictates should be increased rather than encouraging incineration.

The Mayor also strongly opposed the Edmonton expansion on health grounds, and citing the fact that its expansion would crowd out recycling and would undermine his own waste strategy. It was felt that the Edmonton incinerator had enough capacity to cater for north London and should not be used to transport waste from elsewhere within London.

I share the council's view that incineration should only be used after all other options have been explored. That is also in accordance with government guidance and the Mayor's strategy. RRRL's proposal would therefore not appear to be a Best Practical Environmental Option as it would discourage levels of recycling or composting and appear to be more reliant on incineration.

The Mayor's strategy points out that there is already twice the national average of waste incineration in London. The Mayor wants to encourage an increase in waste minimisation and recycling, the development of new and emerging advanced conversion technologies for non-recyclable residual waste and new treatment methods such as Mechanical Biological Treatment.

It is widely accepted that in order to meet the government's targets only those items that cannot be reused, recycled or composted should be disposed of by way of landfill or thermal treatment. I accept the need to reduce reliance on landfill and to move towards a more sustainable approach to waste management. I do not rule out the use of thermal treatment. Municipal Solid Waste can be split into three fractions – a wet biodegradable fraction; a dry recyclable fraction and a thermally treatable fraction. A successful policy requires separation of these fractions. The wet biodegradable fraction should go to a biological treatment facility for either aerobic or anaerobic digestion. The resultant solids can in the main be used as a soil conditioner, subject to certain controls. Anaerobic digestion brings the added advantage of energy production.

Dry recyclables can include metals, glass, plastics, cardboard, textiles etc which should go to a materials recovery facility (MRF) or recyclables transfer station (RTS). There will be some residues which will need to be disposed of and added to the fraction for landfill or thermal treatment. A suitable thermal treatment process for treating this remaining fraction and residues should be small scale in order not to compete with the recovery of dry recyclables and the wet biodegradables and this fits in with government policy which requires that thermal treatment does not prevent recycling and recovery. The Mayor's Waste Strategy says that where waste cannot be re-used, recycled, or composted, pyrolysis and gasification should be used in preference to mass burn incineration. I do not have expertise in this area and I know that the applicants have argued against this approach on the grounds that there would be insufficient capacity and that there would be no advantage in environmental terms or in land required. I understand, however, that there are many small-scale conventional thermal treatment technologies operating successfully and economically at throughputs of less than 100,000 tonnes per annum in mainland Europe and an increasing number of advanced thermal technologies operating successfully on various waste types. The Compact Power Plant in Avonmouth would seem to provide evidence of this with a considerably reduced land-take and better results than conventional incineration in terms of emissions including dust/particulates, dioxins and furans, sulphur dioxide, oxides of nitrogen, carbon monoxide and heavy metals.

The building of a mass burn incinerator will make it extremely difficult for recycling to develop to its full potential and will be a disincentive to moving waste policy up the hierarchy of options. This would appear to have been a material reason in the refusal of the Edmonton application. It is a widely held view that re-use, recycling and composting will be compromised if this application succeeds.. There is an option available – a small incinerator in west London and investment in re-use, recycling and composting as advocated in the Mayor's Draft Waste Strategy. The Mayor has called for waste authorities to maximise the reduction, recycling and composting of municipal waste before considering energy recovery and for authorities in London to aim to meet the targets, specified in Waste Strategy 2000, for recovering value from 40 per cent of municipal waste by 2005, from 45 per cent by 2010, and from 67 per cent by 2015, by prioritising reduction, recycling and composting.

Conclusions

Whilst the proposed incinerator may meet emission control regulations, it should be seen in the context of the existing industrial processes in the area and the Inquiry should look at the cumulative effect of all consents.

I also want to draw attention to the position of two of the member authorities of the WRWA. Lambeth Council in a letter dated 3 October 2000 agrees that the size of the proposed incinerator would crowd out future recycling facilities. Lambeth also criticised the lack of consultation and failure to engage with local communities and declared its opposition to the proposal. Similarly, the Mayor of Hammersmith and Fulham write to the DTI asking for the application to be refused. And in a letter dated 27 September 2000 the DTI wrote to WRWA stating that "the size of the station does not adhere to the 'proximity principle' with the vast majority of waste requiring to be imported into the area".

This proposal, therefore, is opposed by two of the four authorities whose waste it would burn.

The proposal is contrary to government guidelines and the proximity principle.

The proposal is contrary to the Mayor of London's waste strategy and is opposed by the Mayor.

It is opposed by the Greater London Authority and the local planning authority. It is opposed by the local community and frankly, my constituents have had it up to here. We already have to cope with the whole of south London's sewage, we se no reason why we should have to have west London's rubbish as well. We are fed up being London's dust-bin.