Please e-mail your representation to:
Include your name and address
Quote the following reference and put in to subject line of e-mail: EPR/FP3335YU/A001 Draft Permit; Gent Fairhead; Rivenhall Airfield
Deadline is 18th July
Main suggested reasons for objecting to the draft Permit (please try to not use exactly the same words - and of course you can add your own reasons for objecting):
The draft Environmental Permit for the proposed Rivenhall Airfield waste site/incinerator is flawed.
When the Environment Agency (EA) refused the first Permit application, it stated that a stack height of a minimum of 70 m would be expected for a plant of this throughput size (595,000 tonnes of waste per annum).
In the Additional Information Response number 11, the applicants use a graph (figure 6) to compare the proposed Rivenhall plant stack height of 58 m above local ground level against 34 other plants, including 3 other plants which are "lowered".
All of the "lowered plants" have stacks higher than 58 m.
The only plant with a similar throughput to Rivenhall, and which is lowered, has a 70 m high stack.
The applicant's graph also shows that the usual stack height for incineration plants of the size proposed at Rivenhall is at least 90 m tall.
The Rivenhall Airfield incinerator would be one of the largest in England. It is unacceptable that the applicant's arguments about costs of a higher stack are apparently being allowed to influence the permit decision when human health is at stake. The applicants have themselves confirmed that a higher stack will expose local communities to lower concentrations of pollutants.
The EA in its draft decision document states that emissions "would not pose a significant risk to health" but also says that "the actual effect on health depends on the levels of the pollutants which people are exposed to ... the emissions from the facility have the potential to affect human health by ... affecting respiratory and cardiac health and ... causing a risk of cancer and other effects."
Given that the risks to health are real, there is no justification in allowing a 58 m stack, which is unusually low for an incinerator plant of this scale. The permit application should be refused on this basis.
There is also uncertainty over the use of the River Blackwater which is an important and fragile ecosystem and is also ready heavily used for abstraction and as a transport system for drinking water.
The applicants have told the EA that they do not intend to discharge to the river but have told Essex County Council that they DO intend to apply to discharge. It is unknown why the applicants told ECC this. It would not be acceptable for the developers to come back at a later stage and try to amend the permit to discharge - as they have indicated to the EA that they may do. For a plant of this size it is essential that there is certainty over environmental impacts before it is built.
The permit application should also be refused on this basis.
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