January 23, 2020

EA objection letters

Letter 1

PSC-EP Team, Quadrant 2,

99 Parkway Ave,

Sheffield, S9 4WF

 

By email to: pscpublicresponse@environment-agency.gov.uk

 

Re Application ref no: EA/EPR/FP3335YU/V002

I would like to object to the ​proposed Environmental Permit for the Rivenhall Integrated Waste Management Facility​ on the following basis:

During the public consultation in January 2019 the EA was clear that a 58M stack was required to provide the Best Available Technology. This was based on the requirements of the Industrial Emissions Directive (IED),  which considered the technology and overall emissions to determine the stack height required to meet the IED.  

In your ‘Minded to Permit’ documentation, you now appear to have reversed this approach trading technical measures (i.e stack height), with equivalent levels of environmental protection by simply lowering these levels to suit the stack height of 35m permitted by the planning authorities.

This revised approach is constrained, flawed, and therefore inconsistent and ‘unsound’. It now allows the stack height to determine the levels of environmental protection rather than the IED, and favors the applicant over the environment.

In addition, the reference facilities cited in the EA documentation are all almost half the size of the Rivenhall incinerator at around 300,000 TPA, the Rivenhall incinerator has a capacity for 595,000 TPA. The lower capacity ‘reference facilities’ are meeting the emissions targets with taller stacks.

I object to this permit to operate the Rivenhall incinerator, given the ability of the proposed technology to meet the Industrial Emissions Directive with a 35m high stack is theoretical and unproven. Secondly, because the comparisons with the referenced facilities cited in the EA documentation are not justified.

The EA has my permission for this response to be published. 

Yours sincerely,

Address:

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Letter 2

PSC-EP Team, Quadrant 2,

99 Parkway Ave,

Sheffield, S9 4WF

 

By email to: pscpublicresponse@environment-agency.gov.uk

 

Re Application ref no: EA/EPR/FP3335YU/V002

I would like to object to the ​proposed Environmental Permit for the Rivenhall Integrated Waste Management Facility​ and question the Environment Agency’s stance over the now imperative issue of Climate Change and Carbon dioxide.

Paragraph 3 of the EA’s  ‘Consultation on our decision document’ says: “We consider that, if we grant the Variation it will ensure that the operation of the Installation complies with all relevant legal requirements and that a high level of protection will be delivered for the environment and human health.”

In paragraph 5 it then refers to the “proposed changes to the regulated activity can present different types of risk to the environment, these include point source releases to air and global warming potential. All these factors are discussed in this and other sections of this document.”

A careful search of the documentation relating to this application reveals NO references regarding the impact of this facility on global warming and climate change.  The EA must make public its findings around this  globally important issue. The EA states that a permit would only be granted if a high level of protection be delivered for the environment, and you also say that the application could pose a risk to the environment in terms of global warming. Given that the facility will add approx. 625,000 tonnes of Carbon dioxide into the atmosphere each year I suggest that this facility will have a negative impact on global warming. In addition, given that ECC said in 2019 when refusing the planning application for a taller stack on the grounds that another incinerator in Essex was not needed (See below for full text) then the possibility that the Environment Agency might grant a permit on the basis that a ‘high level of protection will be delivered for the environment’ is preposterous.

8. RECOMMENDED That planning permission be refused for ESS/36/17/BTE & ESS/37/17/BTE for the following reasons: “3. It has not been demonstrated that there is a need for the waste treatment capacity of the IWMF, in Essex and Southend-on-Sea, beyond those shortfalls identified in Policy 1 of the Waste Local Plan and as such would be, likely to give rise to waste not being managed in accordance with the principles of the Waste Hierarchy, of achieving net self-sufficiency for waste management in Essex and Southend-on-Sea and the Proximity Principle, contrary to the NPPW and would undermine the strategic objectives of the Essex and Southend Waste Local Plan 2017.

The Environment Agency should make public its findings on the impact of CO2 on global warming from this facility, and not discount the CO2 and air pollution from the 400 daily truck movements to deliver the waste. The Environment Agency should then ensure there is enough time for public scrutiny as part of a transparent and comprehensive public consultation process.

The owner and operator of this facility will make money; the people, the environment, and the government will pick up the bill for mitigation of the environmental impact. You, the Environment Agency, are already making decisions about which communities will be sacrificed to the sea as sea levels rise. In accordance with your remit (“We work to create better places for people and wildlife, and support sustainable development”), be part of the solution not part of the problem.

The EA has my permission for this response to be published.

 

Yours sincerely,

Address:

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Letter 3

PSC-EP Team, Quadrant 2,

99 Parkway Ave,

Sheffield, S9 4WF

 

By email to: pscpublicresponse@environment-agency.gov.uk

 

Re Application ref no: EA/EPR/FP3335YU/V002

I would like to object to the ​proposed variation of the Environmental Permit for the Rivenhall Integrated Waste Management Facility​ and raise the following unanswered questions:

The consultation day at Rivenhall marked the start of the short, 4-week consultation period on the decision that has now been ‘made’ by the Environment Agency (EA) to grant the above variation on the Environmental Permit.

I would like to point out to the EA that their consultation timing has been anything but perfect. The 10th of January being the first Friday after most people return to work and children go back to school after the Christmas break. The timing (2pm to 7pm), therefore prevented most people who had children at school or commuted longer distances to work from attending the consultation and required others to change plans in order to attend. The EA chose only to consult at one location, Rivenhall and not at the other directly impacted communities of Feering, Kelvedon, Coggeshall and Bradwell. Indeed, given the distance that the plume will spread the case can also be made for Tiptree, Earls Colne, Marks Tey, Stisted, Braintree, Witham and so on to have been included. One might even think the EA was trying to minimise its exposure to consultation. Following a previous consultation, a representative of the EA had admitted that two drop-in events had perhaps not been sufficient, so to reduce it by half to just one, even they must acknowledge is barely an appropriate consultation. Finally, the EA documents that support their decision where not published until the 9th of January, the day before the public consultation, therefore giving inadequate time for the public to review them and come to the public consultation with informed questions about the EA’s decision.

At the consultation, the information was poorly set out and not in a language that a lay person could understand. Many of the EA and applicant representatives were also unable to answer questions posed by the public. I therefore ask the following and submit that the EA must answer in full the following before any permit is granted:

  1. Why have you changed your mind from the original 35m stack refusal?
  2. What’s the difference between this and the 58m stack as they are using the same technology?
  3. Why are you reviewing this in a different way? Previously you used ‘Best Available Technology’ (BAT), but now it is considered sufficient to use an ‘equivalent emissions’ approach. Whilst this may appear to address the emissions levels it does not and cannot meet the dispersion requirements provided by a higher stack.
  4. Can you confirm the number of houses that will be powered by this facility, their location and how the energy generated will be connected to the grid?
  5. What is the water requirement for this new technology?
  6. Which standards are you using given the up to-date knowledge on small particles, ultrafine particles, air quality etc? I note that the World Heath Organisation (WHO) is about to release new guidelines which includes incinerators and PM’s. Why did the EA not wait for these guidelines so you could be fully informed, after all the application was submitted to the EA in October 2018 so it has already been 15 months?
  7. Who is monitoring the emissions; are you marking your own homework?
  8. Are you aware that that the applicant’s partner, Indaver topped the EPA’s 2014 list of emissions offenders list? Indaver’s Meath incinerator rated the highest emissions of any EPA licensed facility in 2014 with 19 breaches; the EA should be aware of the track record of the companies to whom they are granting permits and take this into consideration.
  9. What will be the CO2 loading from this facility on the area?
  10. Why are you allowing this in the face of the current climate change and the necessity to severely cut, if not cease all CO2 emissions as a matter of urgency?
  11. Why are you allowing this in the face of the known impacts of air pollution on health? Colchester Borough Council has this month (Jan 2020) launched a survey to help improve air quality in the district. Next door the EA has decided to worsen Braintree Districts and Colchester District’s air quality with this decision. If you are unsure about the impacts of air pollution on health, then please consult BDC’s survey and please be informed that incinerators produce the same chemicals and micro particles as diesel engines.

The EA has my permission for this response to be published.

 

Yours sincerely,

Address: