This planning application should still be refused, because:

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​​Emissions:

• HCC asked for Veolia to respond to the recently published World Health Organisations guidelines for air quality. Veolia's response only considers Particulate Matter (PM2.5) but the WHO guidelines refer to a range of pollutants. For example, Veolia has not responded to the WHO guidelines on NO2.

• The Environment Bill, when passed, will commit to two separate air quality targets: a “long-term” target, and a target for PM2.5. Veolia’s response does not consider the longer-term target. The long-term target is being set in recognition that there is no safe level of PM2.5, and that any reduction in emissions will have a positive effect on health.

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Landscape Impact:

• HCC’s landscape department, HCC’s own landscape consultants Indigo, CPRE, and independent landscape consultants commissioned by No Wey Incinerator, all believe the impact of Veolia's proposals on the rural landscape is unacceptable.

• The effectiveness of the proposed green wall is unproven, with comparisons made by Veolia with green walls in city centre locations, rather than in a rural location near Alton where HCC’s consultants state that the proposal ‘fails to mitigate the predicted Landscape and Visual effects.’

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Need for the Incinerator:

• According to the South East Waste Planning Advisory Group (SEWPAG), of which HCC is a member, if the national 65% recycling target by 2035 is met, there is already sufficient incinerator capacity built in the South East to meet residual waste needs.

• Furthermore, if any of the additional 1 million tonnes of incineration capacity which has either been consented or applied for comes on stream (which includes Alton), SEWPAG believe there is a risk that the 65% recycling target will not be met due to waste being incinerated instead.

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Climate Change:

• The Government's Committee for Climate Change believe that Energy from Waste incinerators in the UK are now emitting more CO2 than coal-fired power stations, and have said that carbon capture and storage should be fitted to incinerators from the late 2020s, as soon as this plant would come into service. Veolia has not provided evidence that carbon capture and storage is practicable and economic on this small isolated rural site.

Waste Heat Usage:

• Veolia has previously said a heat network will not be economically viable, and this has not changed. The inability to find heat customers is another demonstration of the inappropriateness of this remote location, at a time when the Government and the Committee for Climate Change are highlighting the need for incinerators to use heat as a high priority.

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Conflict of Interest:

• HCC has a close commercial relationship with, and is in the process of renegotiating waste contracts with Veolia. How can HCC ensure that this application is not only decided fairly, it is seen to be decided fairly, given this apparent significant conflict of interest?