G) National and Local Waste policy issues – IMPORTANT as contravenes many policies

***Use your OWN words – do not copy ours – or your planning objection may not count***

1. Does not tie in with Government policy to achieve 65% recycling target across UK by 2030 as it is statistically proven that waste incineration discourages recycling efforts. Contravenes Dorset Council declaration of a Climate and Ecological Emergency and draft CEE Strategy and Action Plan. https://ukwin.org.uk/oppose-incineration/#recycling
2. Does not tie in with Government policy to reduce waste generation ‘upstream’ as, in order to operate economically, incinerator would continue to demand 202,000 tonnes of waste for burning until after 2050. Inconsistent with Dorset Council declaration of a Climate and Ecological Emergency
3. Does not comply with Dorset waste policy of applying Proximity Principle of locating waste incineration facility near to source of fuel (currently nearest being near Wimborne): Waste Plan 2019 3.16. PfP’s Supporting Statement section 8.7 gives a 3-hour drive time radius for transport of the fuel by road.  Examples of locations an approximate 3-hour drive from Portland Port are: St Austells, Gloucester, Oxford, Hammersmith and Worthing – these locations could not be said to be local in any sense of that word. Similarly, at 8.6 to 8.9, Powerfuel say they will not accept any condition restricting the geographical source of the RDF.  Therefore, they are saying they want to be able to source it from anywhere in the world.
4. Counter to encouragement in National Planning Policy for Waste of co-location of waste management facilities: NPPW; WP 2019 9.15
5. Does not comply with Dorset waste policy of locating incineration facility near to a facility for treating the ash generated: WP 2019 9.20
6. Does not comply with Dorset waste policy re NO adverse effects on internationally protected sites: Waste Plan 2019 9.31, Policy 6f; NPPF 174, 175, 176, Portland Neighbourhood Plan Port/EN0, Port/EN2, Port/BE6
7. Does not comply with Dorset waste policy that waste incineration development should be at one of the allocated sites: “Proposals will be expected to come forward on these sites in accordance with Policy 3. Proposals for unallocated sites will need to demonstrate that Allocated Sites are not available in accordance with Policy 4”. Eco Sustainable Solutions have announced their intention to submit a planning application for the Parley site which IS one of the allocated sites.  That incinerator would be less than a third of the size and would still be larger than necessary for the burning of RDF generated from Dorset Council residual waste.  Unlike Powerfuel which is a specially created company for the purposes of this planning application, Eco Sustainable Solutions are established in the waste management industry and have established contracts with Dorset Council. IF Dorset Council decide that a waste incinerator in DC is really needed, despite the available capacity at the Bridgwater incinerator, the ESS application is more compliant in many ways with the Waste Plan 2019 and so should be given preference.
8. This is a case where the consequences of the development either singly or in combination add up to such a severe impact that development is considered inappropriate (Waste Plan 2019 3.21)
9. Very unlikely to comply with national and local guidance that new waste incineration facilities should be able to supply a district heat network. Powerfuel have not specified an actual customer for district heat.  They use the words ‘potential’ or ‘expected’ which might give the impression of an agreement where in fact none exists.  They mention the prisons.  But the heat would have to be ducted underground to the prisons and it is hard to conceive of any viable route which would not cross protected areas (SSSIs etc).  The location of the site adjacent to a steep hill with cliffs also makes ducting of heat pipes unviable.  District Heating is one of the pillars on which PfP try to argue that their plant would be carbon neutral.
10. Counter to policy that management of RDF should seek to reduce impacts associated with transportation and support the supply of electricity and heat locally and that the most sustainable location for final management of the RDF/SRF should be selected, having considered options for its management and having regard to the proximity principle. (Waste Plan 2019 9.11, 9.21) NB PfP state that a main driver for their application is supply of shore power, Supp St 8.25; and at ES NTS 20 they state that up to 15 megawatts of electricity (out of a total of 15.2 MW available) would be made available to moored ships. Thus, this electricity would often not be available to the national grid, as was originally claimed.  At ES NTS 20 PfP admit that there is no customer for heat and recognise the practical problem over providing heat from the site, see G9.