November 4, 2017


What will the impact be?

River Blackwater

Gent Fairhead has a licence from the EA to abstract water from the River Blackwater.

Abstracting water

The licence states:

  • The maximum quantity of water to be abstracted is not to exceed:
    • 360 m3/hr;
    • 8,640 m3/day; and
    • 250,000 m3/yr.
  • No abstraction is permitted when the flow in the River Blackwater (as gauged by the Agency) at Appleford Bridge gauging station (NGR TL 845 158) is equal or less than 1,309l/sec (1.309 m3s-1);

PAIN says:

  • The abstraction license, the volume abstraction rates (hourly, and daily limits) as based on the applicant’s abstraction license will only permit 28 days of abstraction per year if used full time. This leaves 337 per year where no water may be abstracted.
  • Analysis of the documentation indicates a significant imbalance in the figures presented by Gent Fairhead with regards to the water stored on site (approx. 200 days) and the plants overall usage, evaporation and leakage
  • The rainfall calculation assumes it rains every day. Local, recent, met office rainfall data for this area indicates it rains for only 112 days per year (greater than 1mm). This significantly limits the applicant’s predicted overland run off of rainwater to top up the lagoon. The water calculation rates and predicted water usage put forward by Gent Fairhead must be questioned
  • The River Blackwater is only above the prescribed minimum flow rate for 10% of the year as shown in the Appleford data below. The availability of water during this time is not constant. The table indicates that the availability does not match the above abstraction 28-day limit: there are not 28 days during the 10% period above the 1,309 / 1 flow rates. Instead of linking the water levels to a particular gate (gates which can be used to alter levels based on demand), it should be linked to the weather so it reflects the levels of the river as a whole

Discharging water

The licence states:

“The option to apply for a discharge licence always exists and is currently being considered and designed by GFC based on its discussions with the EA and the E&SW. In due course an abstraction and discharge licence application will be made to the EA, and will be subject to their detailed assessment and ultimate approval.”

PAIN says:

Discharge of water from the plant back into the river risks polluting the water and raising river temperature harming wildlife. The EA should never permit them to do this.


There are valid and serious concerns regarding the impact that the incinerator will have on the health of people in the surrounding areas.


The Royal College of Physicians published a report in 2016 (Every breath we take: the lifelong impact of air pollution), in which it states that small particles (such as those that will be released by the IWMF) can cause Dementia, Parkinson, cancers and have a damaging effect on people with respiratory diseases.

It also adds that some of these effects are “well recognised”, but air pollution may be associated with a wider range of health conditions such as diabetes and neurological disease, and could also lead to low birth weights and pre-term birth. It argues that “more research is needed to characterise the impacts, but there is no doubt that the health effects of air pollution are significant.”

Health Impact Assessment

The NPPF establishes that “health” impacts are a material consideration in planning decisions. Paragraph 120 states:

“To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the effects from pollution, should be taken into account. Where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner”.

On this basis, the Environmental Statement does not include any assessment of the impact of the development on health. We would submit that the Council request the developer to produce a Health Impact Statement relating to the proposed increase in height the stack and the variation of conditions. It will not be acceptable for the applicant to refer to the EA Permit clearance as this is a planning matter for the County Council and must form part of the planning applications.

Schools within a 25 mile radius of the incinerator

Annual look at the incinerator plume with a map of schools in the local area


Originally the IWMF was going to process waste through a variety of means - now it is mostly going to burn waste.


“With more facilities still in the construction pipeline, the report forecasts that the UK’s supply of treatment capacity will exceed the available quantity of residual waste in 2020/21. Were all facilities to operate at full capacity, together they would limit the UK’s recycling rate to no more than 63%.”

Eunomia, Residual Waste Infrastructure Review: 12th Issue August 2017