Environment Agency Consultation

This is the last chance to stop the incinerator!
Prevent decades of deadly toxic emissions, smells from waste, 70 HGVs a day, light and noise pollution – tell the Environment agency today!

Here’s all the information you need to submit your concerns & objections in relation to the planned Marley waste incinerator to the Environment Agency. There’s also some ideas below to copy and paste to use in your submission.
Link here: https://bit.ly/2zrZm5Y – section 4 is the main part. Don’t forget to your email address so you receive confirmation.
Alternatively you can email: pscpublicresponse@environment-agency.gov.uk – Add EPR/ZP3537AT into the email subject field.
Please share this post to as many people, pages and groups as you can and please spread the word offline too – friends, schools, businesses, pubs, community centres, etc!
Most of all, please submit your objections and questions to the EA. Every person in your household, business, etc can submit, so let’s make it as many as possible. The more submissions the EA receive, the better.
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IDEAS: Here’s some ideas for your submission based on our main concerns. Feel free to copy and paste and add to them:

Things that are fruitless to mention:

  • Questions over statements
  • Whether incineration should be allowed or not as a matter of principle
  • The impact of noise and odour from traffic travelling to and from the site (onsite!)
  • Personal health effects i.e. Grandchild’s asthma
  • The EA will not test the noise levels of a site before construction.

Endless Energy’s documents are all there on the EA consultation website:
https://consult.environment-agency.gov.uk/psc/bd21-4lw-endless-energy-limited
Some of them are very technical but we mustn’t be put off. Sometimes the simplest questions are the best.
If you have time to scan through the EE documents you will find plenty of implausible and contradictory statements. The more we can challenge the better!
Here’s some information we hope you will find useful  and some questions you could ask in relation:

Pollution
You could refer to the document ‘Operating Techniques’ sections 5 – 8, (describing in great detail each stage of the incineration process).

Questions

  • How proven is the technology described ‘Operating Techniques’ sections 5 – 8?
    Are there other plants built to this design operating in the UK?
    What is their track record with regards to breakdowns, safety, efficiency in terms of the amount of electricity produced for the waste consumed?
  • Is a 60m chimney stack the optimum height for the dispersal of emissions? What height should be applicable for BAT?”
  • Or ask about the filter bags designed to catch the really dangerous pollutants in the chimney stack. It’s mentioned that any splits/damage to the bags will be swiftly repaired.
  • At similar plants how often are the bags damaged/split and how long does is typically take to repair?
  • Does the incinerator have to shut down while the repair is made?
  • Does it happen often in other incinerators using this design?
  • Is it ever possible for the pollutants which are supposed to be captured by the bags, to escape into the atmosphere is a bag is damaged/split?
  • Another question about the filters is to ask what they DON’T capture:
  • What pollutants are NOT captured by the bag filters?”
  • 5 and PM10 are known to be hazardous to human health, are these fully captured? If not, how much escapes?
  • Are all of the dioxins and furans captured which are created by burning plastics? If not, which ones are not and at what levels?

Noise
There will be no ‘baseline’ noise testing, (i.e. monitoring the noise levels around the site and across the valley prior to the site being built or operational).

  • How will you, the EA determine what is additional noise (from the plant) if you have no baseline?
  • How much noise is deemed to be a nuisance to the local population?
  • What evidence can you give to demonstrate that the operating volumes and HGV movements on site will not constitute a nuisance to the many sensitive receptors within half a km given that conversation can be heard through the ‘acoustic fence’ which surrounds the site?
  • How will any complaints about noise be handled?
  • What is the EA’s role in the process for handling noise complaints?
  • Have any sites ever had action taken against them as a result of noise issues?
  • If yes, can you please list which sites and what action was taken?

Odour
As there is no ‘baseline’ testing, f there was an issue with odour it would be on us to prove that the odour is coming from the incinerator and not the sewage works or somewhere else.
EE’s application contains an extensive list covering a broad range of waste materials that they can burn within their permit application, including, but not limited to:

  • ‘Wastes from the preparation and processing of meat, fish and other foods of animal origin’
  • ‘Wastes from human or animal healthcare and / or related research’
  • ‘Wastes from natal care, diagnosis, treatment or prevention of disease in humans,
  • ‘Wastes from research, diagnosis, treatment or prevention of disease involving animals

Questions

  • What procedures are EE are putting in place to ensure that there is no backlog of waste and in particular, any waste that would be particularly pungent?
  • This is a site with restricted access, due to the road and railway. Can you provide evidence of how EE operations will cause no backlog of waste and that they have the right capacity of indoor storage and adequate systems to prevent odours escaping?
  • What are the proportions of waste streams that EE propose to burn? e. municipal/ commercial/ medical?

Impact on Ecological Sites/ Water courses

  • A project to reintroduce Salmon into the River Aire is supported by the EA
  • This project to improve coarse fish populations and engage people with the River Aire has secured £800,000 from the National Lottery.
  • The Environment Agency and the Aire Rivers Trust have worked together to get Stage 1 funding from the Heritage Lottery Fund (HLF) to progress their £1.6m Developing the Natural Aire (DNAire) project.

Questions

 

  • Given the EA are actively supporting the bid for reintroducing Salmon into the River Aire, how might the surface run off affect the chances of success?
  • What are the levels of pollutants in the river currently and how will this be impacted with the surface water runoff from the incinerator site? How will this be actively monitored?
  • Ilkley Moor is a Site of Special Scientific Interest. Modelling shows that if the chimney stack was higher than the approved (in planning) height of 60m, then this could cause further acidification to Ilkley Moor. Can EE provide the full stack height assessment graphs to a stack height higher than 60m to show that EE are indeed using Best Available Technique (BAT)?

The Applicant

Questions

  • EE are a shell company that seemingly have no provenance in the waste industry. How does the EA ensure that EE are competent without a track record in the industry?
  • Have all interested parties relevant to the application been vetted for criminal records to the satisfaction of the EA? Can you show how this was achieved?

Location/ Sensitive Receptors
In the ‘Site Condition Report’, paragraphs 4.1.1, 4.1.2, 7.1.1 describe what ‘Sensitive Receptors’ surround the site. The EE in their application have failed to highlight or even mention to the EA the vast number of sensitive receptors surrounding the site and the receptors the receptors they have used are incorrect. There is no mention of the care home, the nursery school, or the hundreds of homes within half a mile of the site.

Questions

  • Given that the sensitive receptor map is out of date and inaccurate and does not mention , the care home, the nursery school, or the hundreds of homes within half a mile of the site, will EE be required to resubmit accurate and up to date information and mapping? If not, why not?
  • How many incinerator permits have been issued in areas that are densely populated within a steep sided valley and how many have been turned down and for what reasons?
  • The EE in their application have failed to highlight or even mention to the EA the vast number of sensitive receptors surrounding the site and the receptors the receptors they have used are incorrect. With that said, will EE be required to resubmit an accurate and up to date map? If not, why not?
  • How many incinerator permits have been issued in areas that are densely populated within a steep sided valley and how many have been turned down and for what reasons?
  • In some contentious permit applications, the developer will often go the extra mile to prove their modelling is ‘worse case’ scenario. EE have only modelled using one piece of software. To be able to determine whether the data is indeed ‘worse case scenario’ will the EA request that the EE model using different software? If not, why not?

Monitoring of Emissions
We are aware that an operator needs to ‘self-report’ when they are in breach of emission limits.

Questions

  • What are the specific maximum fines that the EA have issued in relation to multiple breaches for incinerator sites?
  • What are the range of sanctions that have actually been implemented on operators who breach the conditions of their permit?

Is there an actual need for another incinerator?
Baroness Jones, the Green party peer, said:
“There is a logic to generating energy from the waste that we cannot recycle or reuse, but it is meant to be the last resort option. What we have created instead is a market-driven system of incinerators which constantly need to be fed.”

Questions

  • Can the EA demonstrate that there is a need for this incinerator?
  • How will the EA ensure recyclable waste is not burned in this incinerator?

Accident risks
The site is close to a major road, railway, high pressure gas mains, river, schools, houses, business, sports facilities and a nursing home. There are many potentials for a major incident. We need to ask how well-prepared EE are for any such event.
You could open the ‘Fire Prevention Plan‘ document. “. Ask for details of how, in reality, they would do this.

Questions

  • What will happen if there is a major accident on site?
  • In para 8.3.2 of the ‘Firee Prevention document’ states “local residents and businesses will be kept informed of the size of the fire and potential airborne products….and of any toxic gas releases and be advised to keep doors and windows closed.” How will this managed?
  • Is there enough water on site in the event of a major fire?
  • How will the local population be prepared for a major incident at the site given its close proximity to housing, schools, nursing homes etc?

Other issues to consider

  • Best Available Technique
  • Regulations
  • Residues – bottom ash and the toxic filter bags
  • The consultation process itself
  • Whether the EA has a proven track record of effectively monitoring these plants and it’s ability to put in place ‘punitive’ measures for offences.