How to comment on the BXC planning application

REGISTER YOUR OPPOSITION by email: BXCapplication@barnet.gov.uk
(copying to: cllr.paul.lorber@brent.gov.uk) by Monday 5 January (at least b4 midnight on the day)!

(or by fax: see Barnet Council page: http://www.barnet.gov.uk/brent-cross-cricklewood-regeneration)

Give your postal address, and ask for an acknowledgement.

Please copy and paste into your email the following suggested text, and edit as you wish. It is based partly on Brent Friends of the Earth's which you may prefer, see: http://brentfoe.com/brent_cross.html. Sources and references appear below if you are interested.

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Dear Nicola Capelli

Re: Planning Application C17559/08 Brent Cross

I object to outline and full planning permission being given on the following grounds:

Climate Change and Transport

1. Development plans precede the passing of the new UK Climate Change Law to reduce CO2 emissions by 80% by 2050, and EU regulations to reduce emissions by 20% by 2020.

The application's Revised Environmental Statement Vol 1a itself concludes (part 19.9) that the plans will increase CO2 emissions, and noted the significance of the Climate Change Bill (that is now law).

With this in mind I want Barnet Council to SUPPORT the proposed Brent Cross Light Railway, which would benefit a wide area, as well as Brent Cross. We need an integrated transport plan fit for the 21st Century, that can get people out of some of the 29,000 extra daily vehicles that the existing plan predicts the new cityscape would attract. It would do much more to connect destinations than spending the same money on a new Brent X Thameslink station, which I believe would prompt Network Rail to close the existing Cricklewood Station, so increasing local deprivation.

Incinerator/CHP, the waste transfer site and waste

2. Full information has NOT been provided about the type of technology, capacity and emissions for the proposed incinerator/Combined Heat and Power plant. The application should NOT go through in outline and should NOT have gone to consultation without this detail, since the full environmental impact cannot be assessed without this.

3. Figures for WID-chasing waste must be provided! The Government says 80% of household waste can be recycled. Before any new Waste Incineration Directive (WID)- compliant plant is approved, first we must see the numbers to show there is more non-recyclable 'incinerator-chasing' waste in the North London Waste Authority area than the Edmonton plant will already be chasing for itself - shown separately from less problematic materials like untreated wood that don't require WID plant.

In view of the emitted dioxins, dioxin-like compounds and nano-particle types, incineration (as governed by WID) should occur downwind of population centres where possible.

4. In any plan for energy from waste (EfW), it must be specified that day to day responsibility for control of flue emissions, and sifting out potentially hazardous content from feed material, must be the sole preserve of Barnet Borough staff (including any staff waged indirectly via recruitment agencies but exclusively serving LBB) and not any contracted entity. This is the only realistic way to guard against 'meat factory' pressures for corner-cutting.

To rely on Environment Agency monitoring and policing is totally discredited, as the Greater London Authority itself noted in a press release: http://tinyurl.com/84puhc

5. Please impose a condition to forbid the burning of non-waste vegetable oil in the CHP plant! Liquid bioenergy from crops is WORSE than fossil fuel for CO2/equivalent emissions, as several recent authoritative studies have shown, and is a major current cause of hunger and deforestation. Alternatives are natural gas, biogas from the Greater London Authority biogas project, LPG, untreated wood and sustainable local plant cuttings.

6. Contractual and fiscal arrangements should be such as to discourage EfW from recyclable material to the extent, and in the event that, there is an effective market for recycling it. The Local Government Association recognizes the Waste Hierarchy which affirms that recycling is better where possible than energy recovery. It is evident from recent studies by Eunomia and for the GLA and WRAP that recycling, and using natural gas as a CHP fuel instead, is better in CO2 saving terms where materials can be recycled. The unit should default to using gas fuel if non-recyclable material becomes scarce. It should not 'lock in' future recyclable material to being incinerated.

Please kindly acknowledge receipt of this letter.

Yours

[Name]
[Address]

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Notes:

1. To read the Planning Application online, see http://www.brentcrosscricklewood.com/

For the Brent Railway proposal, and the threat to Cricklewood Station, see here: http://www.brentfoe.com/new_brent_x_leaflet_john_cox.pdf The Campaign for Better Transport was formerly known as Transport 2000.

2. Willesden & Brent Times, 22/12/08: "'Toxic dump' is 'not an incinerator'", http://tinyurl.com/9c5w4z or see http://www.brentfoe.com/w&b_times_18_dec_08_large.jpg. The planned plant will have a 140 ft chimney stack, this height is chosen to diffuse NO2 (nitrogen dioxide) emissions so that they only average a 2% addition to default levels in and around the development - see Environmental Statement Vol 1a in Planning Application at http://www.brentcrosscricklewood.com/.

3. According to UK Without Incineration Network, the incinerator planned will have 1/5 the capacity of the Edmonton plant: http://www.ukwin.org.uk/map/. Local government is under strong pressures to find alternatives to landfilling, further to the EU Directive that landfilling must be halved by 2013. Energy from waste with CHP heat utilisation is theoretically preferable to large plant incineration without heat capture, and especially to bonfires of man-made waste.

4. However the emissions from incineration (energy recovery that falls under the Waste Incineration Directive as this does) are distinctive and potentially significant - see http://www.ukwin.org.uk/?page_id=113#health

5. (i) The EU Joint Research Centre (JRC) (http://tinyurl.com/688cog, p10), warned (2008) that "if 2.4% of biodiesel comes directly or indirectly from palm oil grown on peatland, the GHG savings from EU biodiesel are cancelled out… unless there are large changes in the pattern of palm oil development, [an expected] 12% of the extra vegetable oil for biodiesel would come indirectly from palm oil on peat land (more than enough to negate the GHG savings from all EU biofuels)". The JRC is probably the most world's most cited scientific authority on biofuel GHG balances. (ii). P. Crutzen et al. found that if N2O emissions are properly factored in, vegetable oil biodiesel (very similar in CO2 life cycle to straight vegetable oil) from temperate feedstocks causes from as much as up to 70% more emissions than it saves, even without the indirect effects mentioned in 1. (iii) Zah et al. (study for the Swiss Government) found that if additional impacts in terms of biodiversity etc were added up, the costs of all first generation biofuels exceeded the benefits from replacing petroleum. Scharlemann and and Laurance (reviewing this) argue that this study itself did not account for the full indirect effects: http://tinyurl.com/5vkkl9 (iv) Joe Fargione, who led another influential study published 2008, commented: "From a climate change perspective, current biofuels are worse than fossil fuels". http://tinyurl.com/6z8yzk (v) The FAO has warned that the world hunger crisis could get progressively worse in future years, partly due to food-fuel diversion: see: http://tinyurl.com/8c65xy. The UN has also warned that millions of 'biofuel refugees' are likely to be created: http://tinyurl.com/7nlrjv. The orang-utan is threatened with extinction in Central Kalimantan (http://tinyurl.com/55q5af) while the Sumatran species is critically endangered, a key threat also being palm oil expansion (see (i)).

An exception applies to used cooking oil if it were otherwise being thrown away, but most substantial sources are already being put to use.

6. Gas-fired CHP (and direct gas central heating) outperform both CHP incineration and heat-only incineration for discharged CO2 emissions. See for example Eunomia report: http://tinyurl.com/99vmxp, figures 3. and 6, and GLA document, http://tinyurl.com/9baf6d.

These support the conclusion that it is preferable in CO2 terms to recycle material that can be recycled, and burn gas for energy instead. A study by WRAP (2008) found that the emissions savings from recycling paper and plastics even by shipping to China greatly exceed the extra transport emissions.