SUMMARY OF OBJECTIONS SUBMITTED TO THE NORTH LONDON WASTE PLAN (Proposed Submission Version May 2011) ON 8 JULY
‘The Plan’ is unsound because it is riddled with contradictions and confusion.
The Plan period is up to 2027 NOT to 2041. All the evidence covers the period up to 2017. There is no evidence for the claim that “in order to meet the longer term management of municipal waste until 2041 some larger sites are needed immediately and hence … two sites totalling 9.23 hectares are identified. If NLWA wish to plan for the period 2017 to 2041 they should produce a new plan for that period. Their own evidence suggests that “Further assessment of new and emerging technologies will need to be undertaken by the NLWA as they progress towards letting a new contract for waste management services from 2014.
The evidence does not support the need for this MBT plant, on the contrary, waste levels are falling. The evidence shows that existing, and already planned capacity, will far outstrip the amount needed until at least 2021. There has been a steady slowing of growth in municipal waste … and “the residual waste stream has actually fallen whilst extensive improvements in local recycling and composting services have occurred …” When the work is undertaken to analyse waste management needs beyond 2027, that will be the time to identify whether or not additional sites will be needed.
Errors of fact and methodology in the assessment and scoring of sites
- Pinkham Way should not have been included at all as it falls into the category of a site within an area in the show stopper category.
- Proximity to railheads and/or navigable waterway wrongly marked. It is not near either. Adding 3 instead of subtracting 3 gives an error of 6 points in favour of a site for a factor that ought to count against choosing that site.
- Air quality – not properly considered. If it were the score would not favour the proposed site. Adding to the existing problem in this area more than 1,000 trips per day by heavy vehicles is inconsiderate and dangerous
- Prevailing wind and topology not taken into account. Southgate Green at ground level is approximately 26m higher than the Pinkham Way site, and therefore only 9m below the top of the proposed chimney. Bedroom windows in Southgate Green would be perfectly aligned with the chimney emissions!
- Visual impact can not be mitigated. The height of the proposed building (23m) and chimney (35m) ensure that there is no form of mitigating measure that could prevent a significant negative visual impact on the surrounding residential areas. The evaluator multiplied 3 by 3 to score 9 turning a detriment into a bigger benefit. The correct score should have been minus 9, so the evaluator has introduced a substantial error in favour of the site.
- Site Access from Trunk Roads wrongly assessed. The maximum score of 5 ignores the road distance resulting from the markedly differing height of the site compared to the A406 roadway. There is no direct access from the A406. Vehicles arriving from the east must exit the A406 on the westbound slip road to the Colney Hatch Lane (B550) flyover, and cross four traffic lanes at the traffic signals to position themselves to turn right. Then turn right onto the Colney Hatch Lane and right again at a second set of traffic lights to get on to the eastbound slip road leading to the Friern Retail Park, turning right at the roundabout to access the road bridge (Pegasus Way) at the end of which is a second roundabout and access to the site. Distance from the A406 = 0.78 miles or 1.27k
- Vehicles exiting to the east must first take the westbound slip road (known as Orion Way) from the site to the Colney Hatch Lane flyover, and cross four traffic lanes of traffic at the traffic signals to position themselves to turn right. Then turn right onto the Colney Hatch Lane and right again at a second set of traffic lights to get on to the eastbound slip road leading to the A406 eastbound. Distance to the A406 = 0.7 miles or 1.22k
- Vehicles arriving from the west must exit the A406 on the eastbound slip road to the Colney Hatch Road flyover, cross the flyover at the traffic signals, on to the eastbound slip road leading to the Friern Retail Park, turning right at the roundabout to access the road bridge (Pegasus Way) at the end of which is a second roundabout and access to the site. Distance from the A406 = 0.85 miles or 1.38k
- Vehicles exiting to the west must take the westbound slip road from the site to the Colney Hatch Lane flyover, cross two traffic lanes to position themselves to cross the flyover at the traffic signals. Then on to the westbound slip road leading to the A406. Distance to the A406 = 0.75 miles or 1.27k
- Routing of vehicles to site scored a maximum of 5 by ignoring the impact on existing congestion on Colney Hatch Lane flyover which is already a notorious traffic congestion spot in the locality. Every trip to and from the site must use this bridge.
- Breakdown/Sustainability. The slip roads referred to above are 7 metres wide, comprising a single motor traffic lane and a cycle lane. Were a refuse truck to break down on one of these roads other traffic, especially other refuse trucks, would be unable to continue. With an average of 83 trips per hour (one every 45 seconds), the frequency and length of these vehicles would rapidly tailback to fill the slip roads, Pegasus Way Bridge, Colney Hatch Lane flyover and inner lanes of the A406, along with traffic using Tesco’s huge supermarket and petrol station etc. How long it would take to remove a broken vehicle. They may first need to clear the obstructing tailback by reversing all these cumbersome vehicles out. How many hours would it take to clear these tailbacks, what if an emergency vehicle (fire ambulance etc) needed to gain access to the site?
Conclusions on NLWP Proposed Submission May 2011
The Report is not soundly based; it is riddled with inconsistencies and is not based on proper evidence. It is not clear about the period it is planning for and the methodology used for scoring in the supporting London Waste Plan Technical Report May 2011 is wrong in its method and calculation. If the scoring had been applied correctly for all the headings associated with the Pinkham Way site the score would have been 59 and not the erroneous 102.
(A copy of Evelyn Ryan’s full statement can be supplied on request. A copy of the objection submitted by The Pinkham Way Alliance can be seen at http://www.pinkhamwayalliance.org/. See also The North London Waste Plan and the full set of supporting evidence on their website http://www.nlwp.net/