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This article was downloaded by: [University of Tennessee, Knoxville]On: 13 September 2014, At: 18:53Publisher: RoutledgeInforma Ltd Registered in England and Wales Registered Number:1072954 Registered office: Mortimer House, 37-41 Mortimer Street,London W1T 3JH, UK
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Risk Communication and theWaste-to-energy IncineratorEnvironmental ImpactAssessment Process: AUK Case Study of PublicInvolvementChristopher SnaryPublished online: 03 Aug 2010.
To cite this article: Christopher Snary (2002) Risk Communication and the Waste-to-energy Incinerator Environmental Impact Assessment Process: A UK Case Studyof Public Involvement, Journal of Environmental Planning and Management, 45:2,267-283
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Journal of Environmental Planning and Management,45(2), 267–283, 2002
Risk Communication and the Waste-to-energyIncinerator Environmental Impact Assessment Process:A UK Case Study of Public Involvement
CHRISTOPHER SNARY
Department of Geography and Environment, London School of Economics and PoliticalScience, Houghton Street, London WC2A 2AE, UK. Email: [email protected]
(Received May 2001; revised September 2001)
ABSTRACT With a view to suggesting ways in which we might arrive at a more sociallyacceptable waste management facility siting process, this paper considers the effective-ness of a more innovative approach to risk communication for a planned municipalwaste-to-energy incinerator in Portsmouth, Hampshire, UK. The risk communicationprogramme involved a contact group process designed to enable key members of the localcommunity to participate in structured and informed discussions about the proposalbefore it was submitted as a planning application to the competent authority. The paperconcludes that the communication model was dominated by the �ndings of technicalassessments and that it provided only limited opportunities for interested stakeholders toparticipate fairly and competently in the development process.
Introduction
In the current waste strategy for England and Wales, Waste Strategy 2000(Department of the Environment, Transport and the Regions (DETR), 2000), thegovernment states that local authorities should look to implement an integratedwaste strategy based upon more sustainable methods of waste management,including waste-to-energy incineration. Michael Meacher, the Minister of theEnvironment in the UK, has previously stated that this will require the develop-ment of between 50 and 177 new municipal waste-to-energy incinerators in theUK over the next 10 years (Environmental Data Services, 1999). Problematically,these facilities are seldom popular with those who live near proposed sites and,consequently, gaining planning permission is often an extremely dif�cult pro-cess (Armour, 1992; Beder & Shortland, 1992; Petts, 1992; Petts & Eduljee, 1994;Wolsink, 1994; Gray, 1995; Rabl et al., 1995; Kuhn & Ballard, 1998).
Public opposition towards the siting of waste management facilities is regu-larly viewed, in particular by waste managers, as being based upon unjusti�edand irrational fears (Freudenburg & Pastor, 1992; Petts et al., 1996). In this view,the response of opponents is misguided and ill-informed in comparison with the�ndings of technical assessments of risk. However, numerous studies havedemonstrated that public concern is not irrational, but a complex and valid
0964-0568 Print/1360-0559 Online/02/020267-17 Ó 2002 University of Newcastle upon TyneDOI: 10.1080/0964056022011633 2
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response linked to a much wider range of considerations, such as the appropri-ateness of the waste management option, the trustworthiness of the wasteindustry and the perceived fairness of the decision-making process (Hirschhorn,1984; Portney, 1991; Kemp, 1992; Petts, 1992, 1995; Burningham, 2000).
The improved understanding of the nature of public opposition has resultedin calls for better risk communication throughout the waste management facilityplanning process (Institute of Waste Management (IWM), 1995; Energy Technol-ogy Support Unit (ETSU), 1996; Glasson et al., 1999; Petts, 1999). Arnstein (1969)used the analogy of a ladder to describe the different levels of communicationin land-use planning decisions. The bottom steps of the ladder representmanipulative public relations campaigns. These are persuasive tactics employedby a developer in order to get a proposal built. Next are the steps of informationprovision and consultation. Information provision allows interested members ofthe public to become knowledgeable about a proposal, and underpins all furtherpublic involvement. The �ow of information is ‘one-way’ and there is noprovision for responses to be taken into consideration. Consultation involvesinformation exchange between the proponent and the public in a ‘two-way’process. The public’s views are able to make a legitimate contribution to themaking of a decision, but only if they are deemed to be relevant by theauthorizing body. The top steps involve increasing degrees of participation. Atits extreme, participation requires the public to make the decisions.
Although citizen control is an unlikely prospect in the context of the currentUK waste management system, the ladder makes the useful distinction betweeninformation, consultation and participation. It is generally agreed that all threetypes of communication are required throughout the waste-to-energy incineratorplanning process (ETSU, 1996; Petts et al., 1996). Concerns about health risksrequire comprehensive information on the emissions and a consultation processthrough which the public’s views can affect the decision-making process. Con-cerns about the ability of the waste industry and regulators to manage riskcompetently require participation in a process through which their concerns canbe openly addressed and conditions of competency discussed. Debate concern-ing fundamental policy issues and the legitimacy of the waste planning processrequires a public participation process through which a consensus may be built.This is often dif�cult at the site-speci�c stage because many of the policy andplan issues have already been decided. It is recommended, therefore, that thepublic are also involved at the plan-making stage of the waste incineratorplanning process (Petts, 1995). Models aimed at moving in the direction ofbuilding a consensus include: citizen advisory committees; citizen panels; andcitizen juries (see Renn et al., 1995).
Although a substantial body of risk communication guidance is now available(IWM, 1995; ETSU, 1996; Petts, 1999), relatively few evaluative studies ofrisk communication programmes for proposed UK waste management facilitieshave been undertaken (Petts et al., 1996). This may be due to a shortage ofmore imaginative communication programmes, which in turn is a re�ectionof both the reluctance of communicators to adopt such approaches until theyhave been seen to ‘work’, and the institutional constraints within whichcommunication often has to function. This paper evaluates a more inno-vative approach to risk communication for a municipal waste-to-energy inciner-ator environmental impact assessment (EIA) process in Portsmouth, Hampshire,UK.
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Figure 1. Communication and participation are central to an effective EIA process.
Risk Communication and the EIA Process
Before a waste-to-energy incinerator can be developed it requires prior planningpermission. When applying to the competent authority for planning permission,1
a waste-to-energy incinerator proponent is often required to undertake an EIA.2
The purpose of an EIA is to generate and make available information on thepotential environmental implications of a proposal and the measures for reduc-ing them. The EIA for the waste-to-energy incinerator proposal discussed withinthis paper was undertaken in accordance with the Town and Country Planning(Assessment of Environmental Effects) Regulations 1988 (DoE, 1988).3 The regu-lations require that interested stakeholders are informed and consulted about aproposed land use. The key source of environmental information that must bemade available to interested stakeholders is the environmental statement (ES),which contains the information produced by the EIA. The ES must be forwardedto a range of statutory consultees,4 and made available for public inspectionalong with any other documents relating to the development application. Interms of consultation, the statutory consultees and interested members of thepublic are able to make their views known about the application and the ES bymaking written representations to the competent authority, which in turn isrequired to consider the material nature of these representations when makinga decision.
As noted, the provision of information and consultation are important compo-nents of any risk communication process. Critically, however, these forms of riskcommunication restrict the scope, quality and role of wider technical andnon-technical information in the decision-making process. Faced with this prob-lem, a growing body of EIA literature and waste facility siting guidelines hasemphasized the importance of allowing interested stakeholders to participatethroughout the different stages of the EIA process (see Figure 1) (IWM, 1995;ETSU, 1996; Glasson et al., 1999; Petts, 1999).
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· Screening. In situations where the need for an EIA is not clear-cut, involvementof potentially affected stakeholders at the screening stage may improveunderstanding of the nature and signi�cance of impacts (EC, 1999). The publicmay also be involved in the selection of the environmental consultancy that isto undertake the EIA.
· Scoping. Participation at the scoping stage of an EIA enables the public tomake a contribution that is able to in�uence the scope of the EIA and thedesign of the project. It is undoubtedly easier to limit scoping to the statutoryconsultees; however, their views are not necessarily the same as those held bylocal interest groups and members of the public and, furthermore, scoping isaimed at identifying public concerns and values as well as likely signi�cantphysical impacts (Glasson et al., 1999; Petts, 1999). The opportunity for trueparticipation lessens after this stage because increasing amounts of time andresources become invested in a proposal, which means that a developer is lesslikely to agree to changes (Petts, 1999).
· Impact prediction and evaluation. Public involvement may contribute valuabletechnical and non-technical knowledge, and provide for a wider view on thesigni�cance of the predicted impacts and the need for mitigation measures(EC, 1999).
· Decision making. Public interests are represented in the planning process byelected members who are responsible for making decisions about the accept-ability of proposed land uses. The problem with the current system is thatthere is no requirement for decision makers to explain the reasoning behindtheir decision. The process might be made more transparent and accountableby requiring the production of a decision document that explains the basis ofa decision. The Environment Agency (EA) (1999) has recommended that sucha document should be produced for more contentious integrated pollutionprevention and control applications as part of its commitment to widerparticipation and greater transparency in environmental decision making.
· Implementation and review. Public involvement throughout the commissioningand post-development monitoring stages of the EIA process might take theform of a local liaison group, which provides key members of the localcommunity with information about the day-to-day operation of the facility,monitoring records and mechanisms for handling complaints (Petts, 1999).This will help to reassure interested stakeholders that a development is beingdesigned and operated as originally planned.
The Portsmouth Municipal Waste-to-energy Incinerator Planning Application
Hampshire Waste Services (HWS) is a member of the Onyx Aurora Group,which is a wholly owned subsidiary of the French company Vivendi. HWS hasa contract with Portsmouth City Council, Southampton City Council and Hamp-shire County Council to manage and dispose of all Hampshire’s householdwaste. In August 1998, HWS submitted an application to Portsmouth CityCouncil for the construction of a mass burn waste-to-energy incinerator. Theapplication was directed towards the incineration of 165 000 t of waste per yearcollected from south-east Hampshire and was designed to generate approxi-mately 14 MW of electricity per year. The application was for the site of the oldPortsmouth incinerator, which was closed in 1991, having failed to meet thelatest emissions standards.
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It is important to point out that this was the second planning application tobe submitted for a municipal waste-to-energy incinerator on the site of theredundant Portsmouth waste incinerator since 1991. The previous application,submitted in November 1991 by a different contractor, was for a plant designedto deal with 400 000 t of household waste—two-thirds of the household wastearising in the county. The application was met with considerable oppositionfrom both local residents and Portsmouth City Council. Objections centred on arange of issues: the health risk posed by the emissions; the visual impact; noiseimpacts; traf�c impacts; the size of the plant; and concerns that concentrating onincineration would be detrimental to the promotion of recycling and wasteminimization efforts (Read, 1997; Petts et al., 1996). In the end, HampshireCounty Council declined to support the application on the grounds that it wastoo large and not part of a more integrated waste management strategy (Read,1997).
Faced with the urgent task of �nding a solution to the waste managementproblem created by the failure of the 1991 Portsmouth application and theanticipated closure of a number of waste incinerators around Hampshire,Hampshire County Council set about developing a more integrated and publiclyacceptable household waste management strategy (see Petts, 1994, 1995). Thedevelopment of the strategy involved an innovative public involvement pro-gramme and provided the framework for private sector tender submissions fora long-term household waste contract. The successful contractor, HWS, wasappointed in 1995. HWS’s 1998 application for a 165 000 t per annum municipalwaste-to-energy incinerator in Portsmouth was a key element of the wastemanagement strategy for the south-east area of the county.
Moving Closer to Public Participation: The Contact Group Process
The closest that the Portsmouth EIA process came to a more participatory formof public involvement was a contact group process that had the potential toenable the public’s views to result in changes to the ES before its submission toPortsmouth City Council. Whilst the process cannot be termed a consensus-building model, it was a step in that direction and it is the �rst time that sucha model has been employed in the UK EIA process for a waste incinerator.
According to the agreed terms of reference, the contact group was designed to:(1) allow key members of the public to develop informed opinions about wasteissues and the proposal; and (2) assist HWS in ensuring that it understood andresponded to the views of the members of the local community (HWS, 1998).HWS (1998) said that it would give fair consideration to the opinions andcomments raised by the members of the group, and that it would review themin line with its objectives and technical constraints.
The following members of the public, 10 in total, were selected by HWS torepresent a range of key local interests in the contact group process: a represen-tative from the local school; the local Friends of the Earth representative; arepresentative from the Portsmouth Environmental Forum; and seven represen-tatives from the six neighbourhood forums (NBFs) in closest proximity to theproject site (Portsmouth is split up into NBFs, each of which is represented bya democratically elected chairperson who is charged with providing a moreactive link between the general public and the city council). The group memberswere encouraged to network with the local residents in their neighbourhood in
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Table 1. The timetable for the contact group meetings
Date Issue for discussion
29 June 1998 Introduction to group meetings9 July 1998 Energy recovery incinerators and environmental assessment
15 July 1998 Noise and traf�c assessments22 July 1998 Design of the plant, visual and ecological issues30 July 1998 Alternative sites and noise issues4 August 1998 Air quality issues and health risk assessment
order to ensure that a wide range of public views and questions were repre-sented by the contact group. An independent chairperson was appointed byHWS to ensure that all participants had an equal opportunity to contribute to themeetings and that issues were fairly addressed. It was made clear to theparticipants that membership of the contact group in no way implied supportfor the proposal.
The public contact group met on a regular basis during the month leading upto the submission of the waste-to-energy incinerator planning application inAugust 1998. Meetings were held once a week on a weekday evening from7 p.m. to 9 p.m. At the meetings, the group members were given information ona range of issues by HWS and its consultants (see Table 1). There was also aclosing meeting to discuss the conclusions of the ES and the future roles of theparticipants in the planning application. During discussions, the participantshad the opportunity to make their views known by raising questions, concernsand suggestions. Answers to all questions were given on the day and then awritten copy of questions and answers was presented to each of the participantsat the next meeting.
Review Criteria
This paper’s examination of the contact group process is based upon a range ofprocess and outcome criteria. Process criteria relate to the degree to which riskcommunication enables interested stakeholders to participate fairly and com-petently in the EIA process. Outcome criteria relate to the extent to which riskcommunication has substantive bene�ts for the planning process, for examplewhether or not it is able to improve relations between local residents and thewaste incinerator proponent.
Process Criteria
The ideas of Habermas (1984) have been a major in�uence on the process criteriaemployed in this paper. Habermas’s (1984) thesis is based upon an examinationof reasoning; that is, the techniques and skills we use to make sense of the world.He identi�es reason as having three modes: instrumental–technical rationality;moral rationality; and emotive–aesthetic rationality (Webler, 1995; Healey, 1997).The �rst relates to naive positivist reasoning, the second to reason focusedaround values and ethics and the third to reason derived from emotive experi-ence. He has real concerns about the way in which the latter two non-technicalforms of rationality have been labelled as irrational and subjective, and does not
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believe that we can solve the questions being asked of us by reference to ascienti�c rationality alone. His solution is to develop the non-scienti�c rational-ities and invent a co-operative decision-making process in which all threerationalities have equal status and contribute to a socially constructed ration-ality. He refers to this as a communicative rationality (Habermas, 1984). Theco-operative process through which communicative rationality may be reachedis closely related to the structure of language, the principles of conversation anddiscourses that aspire to the ideal speech situation (Webler, 1995). McCarthy(1982) refers to the ideal speech situation as a form of interaction free from alldistorting in�uences.
Webler (1995) has built upon Habermas’s (1984) notion of the ideal speechsituation to identify fairness and competence as the two key process criteriaagainst which to evaluate models of public involvement. Fairness implies thateveryone should have an opportunity to be involved in a communicationprocess—to attend, initiate discussion, challenge and defend claims andin�uence the �nal decision—but that none of the participants should be allowedto dominate. Webler (1995, p. 65) de�nes competence as “the construction of thebest possible understandings and agreements given what is reasonably know-able to the participants”. In this sense, competence requires that the participantsare provided with the best available procedural tools and knowledge needed tomake the best possible decisions. Building upon Webler’s (1995) work, thefollowing process criteria have been employed in order to review the contactgroup process:
· the representativeness of the participants;· the effectiveness of the contact group model;· the compatibility of the process with the objectives of the participants.
Outcome Criteria
When considering outcome criteria it is important to ensure that short-termgoals do not obfuscate the long-term bene�ts that effective communication maybring to the siting process. A more immediate objective of a risk communicationprogramme might be to clarify stakeholder interests and perspectives. Even ifthis does not lead to the resolution of con�ict, it may bring viewpoints closertogether, increase trust between the stakeholder groups, improve the design ofa proposal and lead to a more informed and balanced decision-making process(Petts et al., 1996). This considered, the following set of less subject-centredoutcome criteria were employed in order to evaluate the contact group process(after Petts, 1995; Petts et al., 1996):
· the degree of knowledge achieved amongst the participants;· the impact of the contact group on the proposal;· the promotion of trust;· the resolution of con�ict.
Methodology
The examination of the Portsmouth contact group process draws upon a seriesof semi-structured interviews with the project manager from HWS, the indepen-dent chairperson and eight of the 10 contact group members (the representatives
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from the local school and one of the NBFs said that they were too busy to beinterviewed). The interviews were undertaken in person or by telephone inDecember 1998, approximately 5 months after the participants had been in-volved in the meetings. The delay did not seem to have an obvious effect on theability of the interviewees to recall and re�ect upon their experiences at themeetings, though interviews conducted nearer the meetings would have proba-bly bene�ted from more focused comment on the speci�c issues being dealtwith. As it was, the interviewees were clearly happier giving more generalre�ections on the contact group experience as a whole.
All of the semi-structured interviews were approached with the aim ofexploring the set of pre-de�ned criteria, and also any further topics raised by theinterviewee that the researcher thought to be relevant. The interviews weretaped and transcribed in full. This enabled the written analysis to be supportedby relevant extracts from the interview.
Results
The Representativeness of the Participants (Process Criterion)
The members of the contact group were not intended to be representative of thelocal public. What HWS tried to do was to include the members of the localcommunity who were most likely to have a strong interest in the proposal. Evenso, it is likely that the members of the group adequately represented a range ofthe public’s views about the risks posed by the waste-to-energy incinerator.
The Effectiveness of the Contact Group Model (Process Criterion)
One of the biggest criticisms of the contact group meetings is that they were heldtoo late in the EIA process. The group was formed once the majority of the EIAhad been completed, so the opportunities for it to affect the de�nition, assess-ment and evaluation of the impacts were extremely limited. This was especiallytrue for the risks posed by the emissions, which were discussed in the very lastmeeting. Ideally, the contact group process should have been up and runningthroughout the scoping and impact prediction/evaluation stages of the EIAprocess. However, the scoping exercise was restricted to consultation with thelocal planning authority and the statutory consultees, and no public involvementwas allowed for at the impact prediction and evaluation stages. Other studieshave also reported very limited consultation with non-statutory consultees at thescoping stage (Pritchard et al., 1995; DoE, 1996). These omissions meant that theproponent had considerable opportunity to de�ne, assess and evaluate impactsin a way that supported a technical justi�cation of a scienti�cally de�ned risk.
When questioned further about the meetings, it was clear that the majority ofthe contact group members felt that the meetings were far from ideal. Moregeneral criticisms included the following.
· Three of the participants felt that meetings were trying to cover far too muchinformation in too short a period of time: “The developer should have startedearlier, because to try and get the message over on this very dif�cult topicdemands time” (contact group member A, personal communication 4 Decem-ber 1998).
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· One member felt the assessments were based too much upon desk studies andthat the consultants were not that familiar with the locality.
· Three members felt that the consultants did not always provide adequateanswers to questions.
· Three members said that all of the assessments should have been undertakenand presented by independent consultants.
· HWS’s project manager was critical of the process for taking a long time andbeing stressful to go through.
Key elements that bene�ted the contact group included: the clari�cation of thepurpose of the meetings at the beginning of the process; the small size of thegroup; and the employment of an independent chairperson to make sure that themeetings were not dominated by certain individuals.
The Compatibility of the Contact Group with the Objectives of the Participants (ProcessCriterion)
It has already been stated that the main aims of the contact group meetings wereto inform key members of the public about the proposal and to ensure that HWSfully understood the implications of the proposal for the local environment.Beyond these broad objectives, it would be naive to assume that HWS did notwant to build a more trusting relationship with the participants and reducepublic opposition to the proposal, and that the local residents did not want tostop the proposal. Consequently, there was always going to be some underlyingcon�ict and cynicism in a process that did not allow for a consensus to bereached on the more fundamental plan and policy issues attached to theproposal. However, all participants did formally agree with the objectives of thecontact group. Furthermore, one contact group member said that he felt that itwas a legitimate aim on the part of the developer to try and persuade the groupthat the proposal was acceptable, and another stated that the contact groupprovided more opportunities for him to in�uence the proposal than traditionalforms of public involvement would have done.
The Degree of Knowledge Achieved amongst the Participants (Outcome Criterion)
Almost all of the members, the developer included, said that they felt moreinformed about the issues relating to the proposal as a result of having attendedthe meetings: “What the meetings did do was to make sure that all the memberswere more informed about the proposal, and that their judgements were basedon detailed information” (contact group member I, personal communication 19December 1998). HWS’s project manager said that he was con�dent that theprocess had informed key members of the public better than the traditionalmethods of public involvement could ever have done.
The degree to which the process informed the participants about the healthrisks posed by the waste-to-energy incinerator emissions is less clear. One groupmember, a chemical engineer who deals with risk assessments in his job, feltthat, even though the health risk assessment (HRA) was presented in fairlystraightforward terms, many of the contact group members struggled with whatwas discussed, and another said:
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I am not a scientist and I found it very dif�cult to understand. I felt asthough they were trying to blind me with �gures and technical terms.The residents that I have spoken to who went to have a look at theenvironmental statement felt exactly the same; they didn’t really under-stand the assessment. (Contact group member D, personal communi-cation 13 December 1998)
This point is closely related to the timetable for the discussion of the issues. Themeetings would have enabled a greater degree of understanding if they hadallowed more time for the presentation and discussion of the risk posed by theemissions. However, even if more time had been allocated to the discussion ofthe air quality impact assessment and the HRA, it would have been unreason-able to have expected all of the members of the group to have fully understoodsuch technical assessments, and it seems clear that there will always be a needfor non-experts to take on a degree of trust in what is said by risk assessors.Trust might have been increased though the employment of an independentconsultant, or an independent third party to summarize and validate theinformation being presented.
The Impact of the Contact Group on the Proposal (Outcome Criterion)
When asked how the contact group meetings had affected HWS’s proposal,HWS’s project manager said that it had in�uenced the architecture, in particularthe colour of the buildings, and the traf�c assessment. One contact groupmember agreed that the process had resulted in signi�cant improvements in thetraf�c assessment; however, he remained sceptical, as did many of the othermembers of the group, as to how else the views of the contact group might haveaffected the development process.
The Promotion of Trust (Outcome Criterion)
The interviewed participants of the contact group process were also asked aboutthe extent to which they trusted HWS and its consultants (see Table 2). Four ofthe members of the contact group said that they had a low level of trust in HWSand its consultants. One of the participants related this to a view that there wasalways going to be an element of bias in what HWS said because its aim was togain planning permission. The other three members related their lack of trust toa feeling that they were only being told half of the information about the healthrisks: “I felt that they were untrustworthy and were only telling us what theythought we would want to hear” (contact group member D, personal communi-cation 13 December 1998).
The remaining four members of the contact group said that they had amoderate degree of trust in HWS. Two members related this to a feeling thatHWS’s project manager had been fair and open. The opinions of the remainingfour members differed over the trustworthiness of HWS’s consultants. Two ofthem said that they had a moderate degree of trust in HWS’s consultants,whereas the other two both said that they lacked trust in HWS’s consultants oncompetence grounds.
On the basis of the above responses, it not possible to determine whether ornot the contact group meetings resulted in a greater degree of trust in the
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Table 2. The levels of trust that the contact group members had in HWS and itsconsultants
Contact group Level of trust Level of trust inmember in HWS HWS’s consultants Reason
A Low Low HWS are biased because their aim is to getplanning permission
B Low Low The group was only being told halfthe information
C Low Low The group was only being told halfthe information
D Low Low The group was only being told halfthe information
E Moderate Low HWS was fair and open but its consultantslacked competence
F Moderate Very low —G Moderate Moderate HWS was fair and openH Moderate Moderate —
developer than other, less participative methods of communication would havedone. However, HWS’s project manager, who was also project manager for theSouth East London Combined Heat and Power application, Deptford, London,said that he was con�dent that the meetings had enabled him, and the otherrepresentatives of HWS, to build a more open and trusting relationship with thegroup members than more traditional methods of public involvement could everhave done.
The Resolution of Con�ict (Outcome Criterion)
As shown in Table 3, seven of the eight participants who were interviewed leftthe contact group meetings with relatively strong risk-related concerns about theproposal. Thus, although the contact group was able to better inform key localstakeholders about the risks posed by emissions, it was unable to convince thevast majority of the group that the risks were acceptable and that waste-to-en-ergy incineration was an appropriate waste management solution. Although theprocedural failings of the contact group are likely to have contributed towardsits inability to resolve con�ict, it is always going to be dif�cult for riskcommunication at the EIA stage to reach a consensus on the overall acceptabilityof a waste management facility proposal because issues fundamental to buildinga consensus, policy and plan issues, have already been decided at the develop-ment planning stage. The interesting thing about the Portsmouth application isthat it was born out of a county-wide waste strategy that involved an extremelycomprehensive and innovative risk communication programme, including aprocess designed to move in the direction of a consensus (see Petts (1994, 1995)for a full discussion of the risk communication undertaken at the strategic stage).However, despite its more participative nature, the strategic risk communicationprogramme seemed to have little real impact on the ability of the contact groupprocess to resolve con�ict. Possible reasons for this include the following.
· There was no obvious evidence as to how public involvement at the strategic
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Table 3. The overall views that the contact group members had of the proposal
Contact group View of themember proposal Reason
A Against · Health risks posed by emissions, in particular those resulting fromabnormal operating conditions
· Wrong waste management optionB Against · Health risks posed by emissions
· Traf�c impactsC Against · Health risks posed by emissions, in particular those resulting from
abnormal operating conditions and the incineration ofcontaminated waste
D Against · Health risks posed by emissions, in particular those resulting fromabnormal operating conditions
E Against · Health risks posed by emissions; the risks might be greater thancurrent knowledge suggests
· Proposal works against reduction, reuse and recycling· Portsmouth City Council needs to develop its own waste strategy
F Against · Health risk assessment is based upon too much guesswork· Wrong waste management option
G Against · Health risks posed by emissions, in particular those resulting fromabnormal operating conditions
H For · Waste-to-energy incineration is a suitable short-term solution tothe waste problem
· HWS is an open and responsible enough company to manage sucha facility
stage had affected Hampshire’s waste strategy and waste local plan, if at all(Petts, 1994).
· A general consensus was never reached on the role of waste-to-energyincineration in the waste strategy (Petts, 1994).
· The only member of the contact group to have also been involved in theconsensus-building process at the strategic stage had serious concerns aboutthe authenticity of the strategic public involvement programme. He felt thathe had been selected to be involved in the strategic risk communicationprocess because he had supported the 1991 Portsmouth waste incineratorproposal on the grounds that it produced electricity. He was critical thatHampshire County Council had not really been interested in the views of themembers of the strategic risk communication process and that there had beena degree of deception as to the extent to which their views would be taken intoaccount
· All but one of the remaining contact group members had legitimacy concernsabout the strategic public involvement programme, saying that they had beenunaware of it before joining the contact group:
One of the big criticisms of the history of this is that people don’tseem to be aware of the consultation that was carried out at thestrategic level. Whether this is because people are not interested orwhether it was done in such a way so that those people who reallywere interested did not get the chance to hear about it, I’m not sure.(Contact group member A, personal communication 6 December1998).
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Summary
The impact of the contact group process may be summarized as:
· providing key members of the public with detailed information about theproposal;
· allowing key members of the public to in�uence the proposal, albeit to arather limited extent;
· improving HWS’s relationship with key members of the public;· sending a signal out to the greater local public that HWS was actively
involving key public representatives.
The contact group was adversely affected by the following.
· The contact group process started too late in the EIA process to allow itsmembers to affect the de�nition, assessment and evaluation of environmentalimpacts. Earlier involvement would have helped to reduce the inevitablecynicism that will always underlie a public involvement process employedwithin the context of the con�ict-ingrained waste management facility sitingprocess
· The process was too intensive to enable debate about and understanding of allthe relevant issues.
· The process did not provide an adequate assessment of the risk posed byemissions released under abnormal operating conditions.
· The assessments were not undertaken and presented by independent consul-tants.
· The process was not preceded by a strategic risk communication programmethat provided evidence as to how public involvement had in�uenced Hamp-shire’s waste strategy and waste local plan.
· The only member of the contact group to have also been involved at thestrategic level had concerns about the authenticity of the strategic risk com-munication programme.
· The majority of the contact group were unaware of the strategic risk com-munication programme prior to joining the group.
Further Developments
In January 2000, Portsmouth City Council’s planning committee decided torefuse planning permission for the Portsmouth waste-to-energy incineratorproposal. The grounds for refusal included the risk posed by emissions tohuman health: “The City Council as Local Planning Authority is not satis�edthat the emissions to air from the proposed waste incinerator would not be a riskto human health” (Portsmouth City Council, 2000). These concerns existeddespite the proposal having already been granted an integrated pollution controlauthorization by the EA. A council of�cer said that there was little doubt that thedecision was based upon the considerable amount of local opposition towardsthe proposal (personal communication 16 August 2000). HWS appealed againstthe decision and a public inquiry was held in September 2000. The Secretary ofState granted planning permission for the facility in October 2001, 3 years afterthe submission of the initial planning application and 7 years after the start ofthe strategic risk communication programme.
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Figure 2. The waste management facility siting cycle.
Conclusions
Risk communication in the Portsmouth contact group process was far removedfrom the ideal envisaged by Habermas (1984), being more about the provisionof information and consultation than about participation. Its most signi�cantfailing was that it did not allow its members to in�uence the scope of the EIA.This meant that HWS and its consultants had considerable opportunity toimpose what Habermas (1984) refers to as an instrumental–technical rationalityon the decision-making process. In this sense, they were able to focus the contactgroup meetings on the technical information issues with which they felt mostcomfortable. This criticism is not to suggest that it would be practical for futurecontact group processes to enter a debate about the relevance of a full range ofrationalities and issues. The EIA process is concerned with project issues, notwider policy and plan concerns, and, without wanting to suggest radical andthus unlikely changes to the planning system, these wider issues need to beaddressed by implementing more participatory processes in relation to:
· the discussion of perceived societal waste management needs prior to thedevelopment of speci�c technologies for managing waste;
· the development of the UK waste management strategy;· the development of local-level waste strategies and plans.
Improving the links between risk communication at these stages and the EIAprocess is one way of addressing the scoping limitations of the contact groupprocess. As Figure 2 illustrates, the stages are best conceptualized as part of acycle because this will enable the critical evaluation of previous siting attemptsto impact upon decisions taken in relation to the development of future wastemanagement technologies and strategies. The Portsmouth proposal suggests thatone of the main challenges facing the communicative cycle will be raising
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awareness at local levels that waste management issues are being fairly andcompetently addressed at the more strategic levels.
Policy and plan limitations aside, participation at the scoping stage of thePortsmouth EIA process would have enabled problem areas to be addressedmuch earlier, for example the need for independent assessors to consider the riskposed by emissions released under accident scenarios, and would have servedto increase the perceived authenticity of the public involvement model.
There is little doubt that the long-term future of more participative models ofpublic involvement in the EIA process will be determined by their ability toresult in substantive bene�ts for the waste industry and regulatory authorities,in particular whether or not they are able to better inform key local stakeholders,build trust and reduce con�ict. The Portsmouth contact group process wasde�nitely a better way of informing key local stakeholders than more traditionalforms of communication, and the manager of HWS felt that it improved hisrelationship with the members of the group. However, one thing that it did notachieve was a consensus on the acceptability of the proposal. It is possible torelate this to the range of procedural failings identi�ed throughout this paper,but it seems unlikely that even the most innovative risk communication pro-gramme would have reached a consensus on the acceptability of the proposedwaste-to-energy incinerator. If we consider the entrenched nature of the publicopposition towards the proposal alongside Beck’s (1992) thesis that society as awhole lacks trust in the regulatory process, scienti�c experts and industry, moreparticipative processes are unlikely to be wholly effective until we have a historyof their implementation and have thus reduced the inevitable public cynicismthat will always surround their employment in high-con�ict areas. Then, andonly then, may we begin to re�ect upon whether or not effective risk communi-cation is truly able to build trust in the waste industry and regulatory authori-ties, and reach something close to a consensus. With local opposition groupsbecoming ever more adept at �ghting applications, this raises serious questionsabout the UK planning system’s ability to provide the infrastructure necessaryto implement the current waste strategy.
Acknowledgements
The examination of the Portsmouth contact group process was part of a widerstudy into the effectiveness of risk assessment and communication in the UKwaste-to-energy incinerator siting process. The author would like to thankElizabeth Wilson, Joe Weston, Graham Wood, Jake Piper and John Glasson fortheir support throughout the duration of this study. The author would also liketo thank the two referees for their helpful comments on several aspects of thispaper.
Notes
1. With the exception of waste-to-energy incinerators that are designed to generate more than 50MW of electricity, planning applications for waste incinerators are determined by local planningauthorities. Applications for waste-to-energy incinerators that are intended to generate morethan 50 MW of electricity are determined by the Secretary of State for the Department of Tradeand Industry (DTI) under the Electricity and Pipeline Works (Assessment of EnvironmentalEffects) Regulations 1990 (DTI, 1990). These regulations are not considered by this paper because
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the case study under discussion is for a waste-to-energy incinerator designed to produce 14 MWof electricity .
2. The Town and Country Planning (Assessment of Environmental Effects) Regulations 1988require a developer to undertake EIA for two broad categories of projects, set out in Schedules1 and 2 (Department of the Environment (DoE), 1988). These relate to Annexes I and II ofEuropean Commission (EC) Directive 85/337 (Council of the European Communities, 1985),excluding those projects that do not require planning permission. Waste incinerators areconsidered as Schedule 1 projects if they are to dispose of toxic or hazardous wastes, and asSchedule 2 projects if they are to dispose of controlled wastes. The Town and Country Planning(Environmental Impact Assessment) Regulations 1999 (DETR, 1999) amend these criteria byconsidering non-hazardous waste incinerators as Schedule 1 projects if their capacity exceeds 100t per day.
3. It should be noted that the Town and Country Planning (Assessment of Environmental Effects)Regulations 1988 (DoE, 1988) have now been superseded by the Town and Country Planning(Environmental Impact Assessment) Regulations 1999 (DETR, 1999). Their implementation hasresulted in no signi�cant alterations to the statutory provision for risk communication in the EIAprocess.
4. Any principal council for the area in which the land is situated, if not the local planningauthority; the Countryside Agency; English Nature; and the Environment Agency (EA) if theproposal is likely to have signi�cant waste or pollution effects.
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