The Public Inquiry is expected to last many months

Evidence from Mountfield Heritage Group was heard by the Inquiry from Wednesday 23rd to Friday 25th July 2003. (More evidence about Mountfield will be heard in September).

Why Mountfield is the wrong place for an incinerator

On the morning of Wednesday 23rd July 2003, Mountfield Heritage Group’s barrister, Tom Hill started by giving seven main reasons why Mountfield should never have been included in the Waste Local in the first place. 

1. It is an Area Of Outstanding Natural Beauty (AONB) and as such should only be considered as a suitable site if (a) it is of national importance or (b) no alternative site outside the AONB is available. Mountfield fails to meet either of these criteria as, according to Inquiry Background paper 7, only one Energy from Waste plant is needed to serve the whole of the plan area and this could be built at Newhaven. If a second site is needed then Pebsham, recommended by East Sussex County Council’s own officers, could be that site.

2. The impact of building an incinerator at Mountfield on the area of outstanding natural beauty would be severe and wide ranging as depicted in the photomontages produced by Nigel Marshall in his rebuttal proof, these show the impact of a 100 metre high chimney on various public view points eg Netherfield recreation ground.

3. Mountfield does not comply with the “proximity principle” (that waste should be dealt with as close as possible to where it is produced) because (according to the Inquiry Background paper 2) over 70% of the population live on the coastal strip.

4. It was chosen as a possible site on the basis that rail would be used to transport waste to the site. This relied on the potential use of the sidings owned by British Gypsum which may not be feasible.

5. If the waste is transported to the site by road there would be a severe impact on the highways at (a) the junction leaving the A2100, (b) the junction at Eatenden Lane and (c) an impact on local rural roads.

6. Other issues that have not been fully explored such as (a) British Gypsum's interests-do not want an Energy from Waste plant or Materials Recovery Facility (waste sorting plant) on their site as it would produce operational conflicts, (b) ecological issues-the site is surrounded by designated ancient woodland and nearby sites of national scientific interest, (c) the deep valley location of the site could lead to less efficient dispersion of any toxins emitted from an incinerator.

In conclusion, Tom Hill stated that the proposal that Mountfield should be a site for an Energy from Waste plant and Materials Recovery Facility is flawed as it fails to comply with a raft of national policies relating to waste management.

Evidence from Mountfield Heritage Group’s own witnesses was then heard and the Council’s witnesses were cross-examined.

Council tried to justify Mountfield decision after the event

It became clear that East Sussex County Council first decided to put an incinerator / waste processing plant Mountfield in the Waste Local Plan based on minimal evidence and much of the evidence was only obtained AFTER they had already decided on Mountfield. What they were supposed to do of course, was to evaluate the suitability of the site and THEN decide whether to put it into the plan. It came out strongly during the Mountfield Heritage Group’s evidence that the Council has been working rather hard to scrape up evidence and arguments to support the decision they have already made. In particular

Use of rail link will not be enforced

- The council say that one of the reasons for choosing Mountfield is that there is a rail link. They now admit that they will not be able to enforce that any of the waste will come in by rail – it could well be that it will all come by road. They did not evaluate the capacity of the railway or the siding, or the fact that the rail link is already heavily used; they did not consider the routes that would have to be used, they did not consider how the waste would get onto and off the railway. 

Cost of rail access not considered

- Council planners believe that the fact that using rail could well cost a lot more than bringing waste in by road is none of their business. During cross-examination the council’s own witness admitted that she is “no rail expert” and had taken a lot of her information from the Internet

Dangerous junction

- The route to the Mountfield site is over an accident black spot which is also very close to housing (Eatenden Lane). The council admits that this junction is “unsatisfactory”. The only detailed plan that they have come up with for improving this junction failed its safety audit because it could result in vehicles being trapped on the full-barrier automatic level crossing. 

Photomontage reveals impact of chimney

- The council’s own photomontage, which they hoped would show that the incinerator would be hidden among the trees, actually reveals that the 90 – 100 meter chimney would stick up well above the skyline and would be a blot on the landscape from all directions.

One sentence evaluation of Mountfield

- The council say that they evaluated the impact on the AONB (area of outstanding natural beauty) landscape BEFORE they decided to put Mountfield in the plan. They have now admitted, under cross-examination, that the entire evaluation of the landscape impact at Mountfield at this stage consisted of just one sentence in one document.

Evidence at the Inquiry

The following people gave evidence on behalf of East Sussex and Brighton & Hove councils:

· Mr Mark Lintell principal and chairman of Land Use Consultants – (Planning background)

· Mr Nigel Marshall principal landscape architect for transport and environment dept East Sussex County Council (Landscape)

· Mr Barry Stokes section manager transport dept East Sussex County Council (Road Transport)

· Mrs Elizabeth Thomas senior planning officer B&HCC (Rail transport)

· Dr Alex Tait county ecologist for East Sussex County Council (Ecology)

· Ms Claire Timms planner for East Sussex County Council - comparison of Pebsham vs Mountfield

· Barrister: Mr Tim Howard

The following people gave evidence for the Mountfield Heritage Group (MHG):

Mr Tim Allen highways engineer of Peter Brett Associates (Road and Rail
transport)

Mr Geoff Smith landscape and environmental planning consultant of Chris
Blandford Associates (overall planning background)

Mr Mark Holland principal landscape architect of Chris Blandford
Associates – (Landscape)

Barrister: Mr Tom Hill

Two waste sites or one?

After the barrister’s opening speech, Geoff Smith (Mountfield Heritage Group's planning consultant) presented a summary of evidence and was further questioned by Mr Howard on Mountfield Heritage Group’s membership and support and views on incineration. Evidence was presented that showed that Mountfield is not at the centre of gravity of waste arisings in the east of the county. There was further discussion of the Best Practical Environmental Option (BPEO) and how the WLP adheres to this; East Sussex County Council reiterated that they needed to provide two Energy from Waste sites, one in the west and one in the east of the county to prevent travel/environmental costs.

Landscape impact

On Wednesday afternoon, Mark Holland (Mountfield Heritage Group's landscape architect) presented a summary of his evidence that showed, in his opinion, the building of an incinerator and consequent 100m high chimney stack would have a far greater detrimental environmental impact on Mountfield and the surrounding countryside than would be the case for a similar structure in Pebsham. 

In addition, because of the remote location of Mountfield any electricity produced by an Energy from Waste plant may not be able to be used nearby but would require pylons or underground cables (which could harm nearby ancient woodland)to be built in order that it can be harnessed into the national grid. British Gypsum have not confirmed whether they would be able to use electricity produced by a nearby Energy from Waste plant.

Doubts about using rail to move waste

During Thursday’s session, Tim Allen (Mountfield Heritage Group's traffic expert) presented his evidence. This showed that, although there is capacity on the local highways to accommodate the extra traffic generated by a waste plant at Mountfield, there are serious concerns about the access to the mine both at the A2100 turning and the staggered junction at Eatenden Lane. 

He also raised serious doubts as to the feasibility of using rail as a means of transporting waste to and recyclables/incinerator fly ash etc from Mountfield. 

Mr Allen pointed out that the cost of transporting waste by rail over relatively short distances would be extremely high as dedicated rolling stock would need to be purchased. No assessment has been done on the feasibility of using any of the rail sidings available, for example, there may be no suitable lorry access and the sidings may be privately owned as is the Ore siding in Hastings. 

The rail network around Mountfield does not make it easy to be used to transport freight over short distances as there are missing loops at various key stations which means the trains have to make even longer journeys in order to turn round. 

Mr Allen said that East Sussex County Council had used Switzerland as an example of a system for transporting waste by rail. But what East Sussex had failed to point out, said Mr Allen, was that in Switzerland legislation had been introduced to reduce the number of lorries on the road. Hence, a charge per kilometre for lorry-carried freight is used to subsidise the railways to carry freight. As no such tax exists in the UK the systems cannot be compared. 

No data has been provided by East Sussex County Council on the capacity of the line during the day and the need to fit freight trains in around the busy time table of passenger trains. The inspector stated that perhaps some of the waste could go by road and some by rail. Tim Allen stated that this would further increase the cost.

Cars could be trapped on level crossing

Barry Stokes (East Sussex County Council's road traffic expert) presented the results of two traffic surveys undertaken this year on the roads around Mountfield and attempted to address the road safety issues associated with the access. 

None of Mr Stokes’ proposed schemes for the Eatenden Lane junction could be deemed to be at all safe, feasible or satisfactory, he said; the only one which had been fully evaluated had failed its safety audit because (among other reasons) of it could result in vehicles becoming stuck on the level crossing at Eatenden Lane in the path of an oncoming train. 

Waste lorries in Battle High Street and local roads?

The latest traffic survey revealed that an Energy from Waste at Mountfield would result in a 50% increase in the number of HGV movements to the mines. There was a lot of talk about lorry routing arrangements but he could not guarantee that any scheme would stop waste lorries from using the local minor roads or Battle High Street. 

No traffic surveys carried out before putting Mountfield in the plan

Tom Hill (Mountfield Heritage Group's barrister) noted that all the work done by Barry Stokes was done after the decision had been made to include Mountfield in the Waste Local Plan. No traffic surveys or schemes to improve the safety of the two dangerous junctions had been done previously, ie before the site-selection process. 

East Sussex had not even carried out traffic surveys or tried to come up with safety improvements even after receiving numerous objections on this point in response to the first draft of the Waste Local Plan.

“I’m not an expert on rail” says Council’s witness

Mrs Elizabeth Thomas (Railway expert for East Sussex County Council and B&HCC) presented her evidence for the use of the railway to transport waste to Mountfield. She admitted that she is a planner and is not an expert on railway usage. As the cross-questioning of her evidence by Tom Hill progressed it became obvious much of her evidence had been obtained from various web sites on the internet and was unsubstantiated, she had little knowledge of the rail capacity of the network around Mountfield and had used data from inappropriate locations to address the issues involved at Mountfield. 

Finally, Mrs Thomas admitted that it is not Waste Local Plan policy that the railway must be used for transportation of waste in the plan area and if Mountfield were to be used as an Energy from Waste site on the basis of road access the rail link (if any) would be an added bonus. 

Again, it was clear that investigations into the feasibility of using rail to move waste had been undertaken AFTER the decision to put Mountfield in the WLP had already been made.

330 foot chimney a “small incident on the horizon” claims County’s landscape expert

Nigel Marshall (East Sussex County Council landscape expert) presented his expert opinions on the possible environmental impacts of siting an incinerator, with a 100 metre high chimney stack, at Mountfield on the surrounding countryside. 

Mr Marshall started off by confirming that he has worked in the same role for East Sussex since 1978. 

Attendees at the Inquiry were able to see impressive photomontages of the chimney from various public viewpoints, showing the chimney sticking up way over the skyline. To some hilarity from the audience, Mr Marshall suggested that if built it would appear as a “small incident on the horizon”, no worse than some of the building conversions in the area! 

Once again, all the work presented was done AFTER to the inclusion of Mountfield in the WLP. 

Council’s landscape evaluation amounted to a single sentence

However, in 1998 Mr Marshall had been responsible for the one sentence in one document which defined the impact of a 90 – 100 metre chimney stack on the AONB around Mountfield. This one sentence seemed to be the only information about landscape impact that East Sussex County Council had available to them when they made their decision to include Mountfield as a possible incinerator site in the WLP.

Suitability only evaluated after the Waste Local Plan had been produced

On Friday, Mark Lintell (Planning expert for East Sussex County Council and Brighton and Hove County Council) presented his evidence as to why Mountfield is a suitable site for dealing with the waste of eastern part of the county. Again, he had first been asked to give his planning overview as to the suitability of Mountfield as a waste site in September 2002, after publication of both the 1st and 2nd Deposit Drafts of the Waste Local Plan

Hence, from the evidence presented to the Mountfield Heritage Group at this inquiry it appears that East Sussex County Council did not base their decision to include Mountfield as a possible site for an Energy from Waste in the WLP on accurate technical data received from their officers as (1) there is no assessment of landscape impacts documented, (2) no analysis of the feasibility of rail access and (3) no assessment of the access by road had been undertaken until recently.

The Inquiry continues

The Public Inquiry will continue until October 2003, and the Inspector is expected to take up to a year to produce his report.

The Mountfield Heritage Group is opposed to all incineration of waste anywhere. We believe that rather than focusing on incineration, there should be far greater attention paid to not generating waste in the first place, and to properly recycling waste that does arise, including 100% door-step collection.

The Public Inquiry, which is of course open to the public, is taking place at 

White Hart Hotel
55 High Street
Lewes
E Sussex    (Map)

The Inquiry opens at 10:00am each day but is not open every day.  

At the Public Inquiry, a government appointed inspector is examining all the objections made to the Plan during the two statutory stages.

The Public Inquiry is expected to take several months.  At the end of this stage the inspector will issue a report in which any modifications to the Plan that he considers necessary will be set out.

The Waste Local Plan still includes Mountfield as an area of search for an Incinerator and Waste Sorting Plant, despite the fact that this contravenes official Planning Guidelines.  The Mountfield Heritage Group will be mounting a strong attack on this part of the Plan at the Inquiry.