LOCAL MP, Dr Andrew Morrison, has submitted his response to the Environment Agency’s consultation on Northacre Renewable Energy’s (NRE) Westbury incinerator application.
The Environment Agency (EA) has the regulatory power to provide NRE with a permit. Without this, the site would not be allowed to operate – even with planning permission from Wiltshire Council. It is understood that the application could be considered by Wiltshire Council next month.
The MP for South West Wiltshire wrote in his response to the EA, “I am strongly opposed to Northacre Renewable Energy Ltd’s proposed incinerator in Westbury in my constituency, an application of high public interest.
“The application aims to replace its extant permissions for gasification with old-style moving grate incineration, a completely different process, not a variation. The evidence submitted should reflect a new application, not an amendment. NRE plans to burn 50% more waste than the 2019 plant, with no more energy provided. This is inefficient and means that the 50% uplift in waste processing from the gasification plant is simple landfill in the sky – it releases all the carbon to the atmosphere with no energy benefit.
Human Health Risk Assessment figures
“The applicant’s Human Health Risk Assessment appears to have used an outdated form of weekly figures. Page 8 appears to use a Tolerable Daily Intake figure of 2 pg WHO-TEQ/kg bw/day. In 2018, the European Food Safety Authority (ESFA) set a new standard of 2 pg WHO-TEQ/kg bw/week (effectively just one seventh of the previous level).
“The intake of dioxins should be assessed against the new EFSA level. The EA has requested Fichtner (the same consultants used by the applicant in this proposal) re-visit these calculations.
False comparison
“Page 10 of the applicant’s Greenhouse Gas Assessment reads: ‘The full carbon assessment demonstrated that the Facility would result in a carbon saving of 57,844 tCO2e per annum when compared to the alternative scenario of disposing the waste in landfill.’
“However, comparison with landfill is not what the EA requires. Rather, it asks ‘whether the technology is the right one’ meaning comparison with more advantageous waste handling working upwards in the waste hierarchy, not down towards landfill.
“The applicant’s use of landfill as a comparator is invalid and non-compliant.
Measuring fine particulates
Part of the Agency remit, according to EA CEO is, ‘Whether emissions from the installation could cause harm to human health’ This brings into play the he precautionary principle. DEFRA notes that there is a danger to human health through exposure to airborne particulate (PM): ‘Exposure to airborne PM is associated with a range of adverse effects on human health including effects on the respiratory and cardiovascular systems, leading to hospital admissions and mortality. There is increasing evidence that fine (PM2.5) and ultrafine particulate matter (<100nm) plays a more significant role than previously thought, although as yet the precise toxicological mechanisms are not clearly understood.’ Indeed, deaths linked to air pollution in the UK are estimated to be as high as 36,000 a year, while current limits for particulate matter are two and a half times higher than the World Health Organization recommends.[1]
“In addressing this, the applicant states that: ‘Emissions from the Facility will be monitored and recorded continuously using a Continuous Emissions Monitoring System (CEMS)’ (Monitoring Methods, p.30). P.71, Monitoring Methods, reads: (NRE – the applicant – will) ‘Provide a written proposal to the EA, for carrying out tests to determine the size distribution of the particulate matter in the exhaust gas emissions to air, identifying the fractions in the PM10 and PM2.5 ranges from the Facility. The report will detail a timetable for undertaking the tests and producing a report on the results.’
“This is the only nod we find by the applicant to testing for PM10 and PM2.5 except to offer mitigation by asserting that ‘The single greatest source of PM2.5 is residential, commercial and public sector combustion (42%).’ (Dispersion Modelling, p.13). The Applicant cannot be allowed to get away with this. Given the EA’s ruling on Skelton Grange, Leeds (2020), in which ‘an improvement condition (IC2) has been included that will require a full analysis of particle size distribution in the flue gas, and hence determine the ratio of fine to coarse particles’, I am confident it will not.
Stack height
“The EA will want to examine carefully adequacy of the proposed stack and the distribution of the likely plume under various conditions. I have constituents worried that their homes are on a level with the stack and that they will be exposed to its effluent.
“It is not clear to me that the Applicant has evidenced fully its proposed stack height.
“Westbury’s recent history celebrates the pulling down of its cement works chimney (122m tall) – a blight and an eye sore for the community and tourists who enjoy the Salisbury Plain escarpment and particularly the White Horse scheduled ancient monument. Residents will not want to have seen the back of one industrial chimney only to find another in their midst. The Applicant does not appear to be alive to this. Its Stack Height Assessment (pp.37-38) takes just one page.
“The EA’s framework refers to ruling based on ‘The shape and use of the land around the site in terms of its potential impact, whether that impact is acceptable and what pollution control or abatement may be required.’ It is not clear from the application how the enjoinder has been reflected.
HGV movements, noise readings and pollution
“The applicant dismisses the potential for noise impacts on the local population. Table A2: Noise risk assessment and management plan (pp.8-9, Environment Risk Assessment) cites adverse impacts of machinery and the movement of vehicles would be ‘minimal’ and merely an ‘annoyance’.
“The EA states that it is within its remit to rule on ‘the impact of noise and odour from traffic on site.’
“The Applicant’s Noise and Vibration document refers to a ‘standalone document’, the ‘Transport Assessment’. Perhaps this gives details of HGV and other vehicle movements in and around the area, explaining the assumed readings and figures given in the Noise and Vibration document. However, in its absence (it is not published on the website as a submitted document, nor included within any other documents) it is impossible for any authority to rule on the impact of noise and odour from increased traffic.
“I request that the EA pay particular attention to the estimates of vehicular movements given by the Applicant, as it has previously provided inconsistent information on the number of HGV movements expected at the site. For example, on the Wiltshire Council planning page for the Applicant’s proposal, there is a Public Health England document, which cites a likely 78 HGV movements per day to be associated with the 243,000 tonnes per year site (an increase of 22, from 56, on the Applicant’s 2019 191,000 tonnes per year application).
“However, the Applicant’s submitted Transport Assessment (provided by IMA) gives a figure of 45 per day for the 2019 191,000 tonne per year application – and no figure for the 243,000 upgrade.
“We are left to speculate on whether the Applicant is making its calculations based on full loads. It seems unlikely that its lorries will all be full, meaning that there will be more vehicle trips to deliver the anticipated tonnage. 45 is therefore best case and almost certain to be significantly exceeded. For an estimate of the true number of heavy lorries than will shake my constituents’ Victorian terraced houses along the A350 in the middle of Westbury, we have a close approximation to the proposed plant in the 190,000 tonnes per year Javelin Park incinerator. Here, we find upwards of 208 HGV movements per day.
“The A350 in the centre of Westbury is an Air Quality Management Area due to the existing unacceptable level of air pollution. The Applicant asserts, the ‘primary source of pollutants in Westbury AQMA, and other AQMAs within Wiltshire, is vehicle emissions’ (p.23, Dispersion modelling assessment). It cannot have it both ways.
“Thank you for your consideration.”
[1] www.gov.uk/government/publications/nitrogen-dioxide-effects-on-mortality/associations-of-long-term-average-concentrations-of-nitrogen-dioxide-with-mortality-2018-comeap-summary
