Stop Harpenden and Luton Incinerator Campaign response to Emsrayne Renewable Energy Ltd

Following the press release from Emsrayne questioning facts on the campaign web site we respond:‐

The Website facts are largely taken from National and attributed sources; with limited technical data being made available by Emsrayne we have been forced to use data from similar scale Incinerator projects in the UK. We will respond to the specific points raised on the LBEP web site.

LBEP, not SHLI, state they will be burning 500,000 tonnes of rubbish per year , if it is not dirty and smelly why is it transported in ‘sealed vehicles’ and why is it rubbish? RDF (refused derived fuel) is compressed and baled general refuse. LBEP also state ‘or similar non‐recyclable material’ this being loose un‐baled waste. LBEP give no control measures on the type of wastes burnt and say it will require“ odour control”.

Emsrayne claim burning waste is ‘not an incinerator’ but a “Combined Heat and Power Facility”. The heat and power are the by‐products (with no confirmed end user) of the incineration – which means the destruction of something by burning ‐ alongside 150,000 tonnes of landfill, 30,000 tonnes of highly toxic fly ash land fill, and 500,000 tonnes of CO2. An Incinerator is a more accurate description of the proposal.

We would suggest that the term Harpenden and Luton Incinerator for proposal being the 6th largest incinerator in the UK on a narrow strip of Green Belt land directly between the two largest towns being Luton and Harpenden is more accurate a description of the location and areas directly affected by this scheme than ‘Lea Bank’, The River Lea has two banks from its source in the Chiltern Hills to the Thames.

In response to the comments by Andy Brewer (Emsrayne Director), we believe that the facts on our website are correct and the vast majority have been un‐challenged by him. Emsrayne as a company currently operate two small solar farms and have no experience of running or developing anything like this proposal. In relation to the comment ‘opportunities it offers for renewable energy production’ we would quote :‐

The Environment, Transport and Regional Affairs Committee states: “We do not accept that energy from waste incineration is a renewable form of energy. Even if one considers that it meets the technical definition of renewable energy, it utterly fails to meet what might be called a ‘commonsense’ interpretation.”

According to the World Energy Council, an impartial network including government, research and industry practitioners, waste incineration generates over six times the amount of nitrous oxides compared to other energy from waste technologies, over ten times the amount of sulphur dioxides, and nearly three times the amount of particulate matter. Even compared to landfilling, incineration performs poorly on all counts.

‐ Source: World Energy Council Report ‐ World Energy Resources 2016‐ Waste to Energy

We look forward to Emsrayne providing accurate and detailed proposals that can be robustly and fairly interrogated before many millions of pounds are invested in this scheme with no clear public benefactors or benefits and many significant concerns.

Nick Martin – Vice Chair SHLI

Message from Bim Afolami

I am 100% determined to ensure than no incinerator is built so close to our beautiful constituency. Firstly, let me say the sheer amount of correspondence I have received regarding the incinerator has been truly astounding. I would like to thank everyone for contacting me and outlining their opposition on this matter.

I am completely in support of Stop Harpenden Luton Incinerator who have been brilliant in raising awareness and directing action against the proposal. I want you to know that I will pursue this matter to the highest level in government and ensure your views and concerns are listened to, heard and actioned upon.

Moving forward I will continue to liaise with all the parties involved. In early September, I will be leading a meeting with your local councillors, SHLI and Grant Schapps MP, who successfully led a campaign in 2015 to stop an incinerator being built in his Welwyn Hatfield constituency. Grant has offered to provide us with his advice so that we can better understand how to organise ourselves effectively on the next steps.

When the proposed application is put forward in September to Central Bedfordshire Local Council, I have complete confidence that our constituency will be ready to Stop The Incinerator.

Yours sincerely

Bim Afolami, MP for Hitchin and Harpenden

Opposition to incinerator….

“The prevailing winds are from the west which means most of the pollution will head straight for South and East Luton. We do not need more toxic Dioxins on top of the polluted air much of Luton already breaths.”

Liberal Democrat leader Cllr. David Franks.

Plans to build an incinerator to burn 500,000 tonnes of waste a year near the East Hyde sewage works have been slammed by Luton Liberal Democrats.

“There’s no way you can burn half a million tonnes of waste without throwing out tonnes of heavily polluted air”, says Liberal Democrat leader on Luton Council, David Franks. “The prevailing winds are from the west which means most of the pollution will head straight for South and East Luton. We do not need more toxic Dioxins on top of the polluted air much of Luton already breaths.”

“The only access to the proposed site is from Lower Harpenden Road and even if all of the waste was delivered on 40 tonne articulated lorries that would mean a minimum of 50 lorries into the site and 50 lorries out again every day. One hundred 40 tonne artics a day on Lower Harpenden Road does not sound to me like a good idea. Are the lorries coming away from the site going to be carrying the highly toxic ash the incinerator will produce?”

If the plan gets as far as a formal planning application it will have to be decided by Central Bedfordshire Council but Luton Council will be consulted and asked for its views. It is clear Liberal Democrat opposition councillors are pressing for a very strong objection.

David Franks.

Published and promoted by David Franks on behalf of Luton Liberal Democrats, both at 7 Honeygate, Luton LU2 7EP.


Two of our SHLI members (Rainey and Tim) attended the launch of a new report released today on incineration at the House of Lords.

The report states that harmful emissions from incinerators are going unreported. It reveals new research which highlights serious public health failings.

The new report reveals:

  • Incinerators exceed pollution reporting thresholds, but due to a loophole the public is not informed
  • Levels of emissions of harmful ‘particulate matter’ and NOx and the associated costs to society
  • A lack of regulation and official guidance ignored

Research by UKWIN (UK Without Incineration Network) has shown that waste incinerators are not reporting emissions of harmful particulates and the Government has failed to adequately regulate them.

The report, Waste Incineration and Particulate Pollution: A failure of Governance was launched on Tuesday 17 July in the House of Lords, with cross party support from MPs; John Grogan (Labour), Philip Davies (Conservative) and Liberal Democrat Peer, Lord Tyler.

The report reveals for the first time the levels of emissions of harmful particulate matter (PM) and Nitrous Oxide (NO) from incinerators across England.

It also shows that waste incinerators are regularly exceeding thresholds where they should be reporting emissions, but are failing to reveal their pollution level.

Incinerators release particulate matter (PM) into the air as part of the waste burning process.

The smallest particles, PM2.5 and smaller, are invisible and especially dangerous to health. Particulate matter (PM) and NO can aggravate breathing problems, heart and lung disease. PM and NOx are emitted by diesel cars, which the government is now working to phase out.

The report shows that the Particulate Matter (PM) released by incinerators in England in 2017 is equivalent to the PM emissions from more than a quarter of a million 40-tonne lorries travelling 75,000 miles a year, and the NOx emissions released by incinerators in England in 2017 are equivalent to around 80,000 lorries travelling 75,000 miles a year, using comparison figures from the Road Haulage Association and Transport for London,

Shlomo Dowen, National Coordinator of the UK Without Incineration Network, said: "For decades incinerators in England have been emitting significant quantities of pollution and greenhouse gasses. There is a substantial cost to society associated with these harmful emissions.

“This cost should be met by incinerator operators in line with the 'polluter pays' principle. Operators should also be required to be more transparent about their emissions and to do more to monitor and control the pollution they cause".

Philip Davies MP said: “Incinerators are being foisted on local communities right across the country and yet the damage that they cause to the local environment is not fully known. There really needs to be a suspension on new incinerators until there is better information available”

John Grogan MP said: “The case for a tax on waste incineration, to mirror the Landfill Tax, and for a moratorium on new incinerators is now very strong.”

Lord Tyler said: “Clean air is vital to health but the Government seems unconcerned about adequately monitoring the emissions from incinerators and has allowed this monitoring loop hole to go unchecked. We must tighten up monitoring procedures and fully investigate the impact before allowing any further incinerators to be built.”

The report calls for:

The development and implementation of accurate systems to measure the particulate matter that incinerators release, accompanied by proper enforcement

  • Stricter control of PM1 emissions
  • Incinerators to be taxed on their emissions
  • Moratorium on new incineration capacity in recognition of the issues identified in the report

Copies of the full report can be read here:

The Environment Agency (EA) says operators of incinerators must publish emission levels if the amount of PM10 and PM2.5 exceeds one tonne per year.

But DEFRA has admitted that there is no equipment available to continuously monitor PM10 or PM 2.5, making it impossible for an incinerator to accurately reveal its emissions of these particles.

The Environment Agency issues guidance for assessing PM10 and PM2.5 using an emissions factor (EF) based on the quantity of waste burnt. This factor should make it possible for incinerator operators to give an indication of tonnes of PM10, PM2.5 emitted.

However very few operators have followed this guidance, with only five reports of the levels of fine particulates in the last 19 years.

The  Emission Factor states that every tonne burnt will produce 0.022kg of PM10 and PM2.5

Using that factor, the report has reveals the levels of particulate emissions from 36 incinerators across England:

PM and NOx emissions based on EA Emissions Factors (2017)

1 2017 Incineration Inputs and Capacity (Environment Agency)

We will be updating this site regularly with news of the fight and more information and hard facts

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