24 Jan Rivenhall Factsheet Permit Variation Consultation
What are we contacting you about?
In our last public briefing note (October 2018) we informed you that we had received an application from Gent Fairhead & Co. Ltd (‘the company’) requesting a variation to the company’s environmental permit for the Rivenhall Integrated Waste Management Facility (IWMF).
We can now advise that we have validated the application and can, therefore, provide you with further details on the company’s proposal together with how the public can make comments to us on the application.
What is the variation application for?
The company’s variation application seeks to change current permit conditions (and associated design and operational details) in order to allow a reduction in the height of the incinerator stack from 58 metres to 35 metres (above surrounding ground level).
The application also seeks to apply stricter limits on emissions of oxides of nitrogen (so-called NOx) compared to those stipulated in the current permit. The current permit sets a daily emission limit of 150 mg/m3 for NOx at the top of the stack whereas the variation application proposes a limit of 100 mg/m3.
The company’s application also seeks to change the primary means of controlling NOx emissions. At present, the permit requires the use of Selective Non-Catalytic Reduction (SNCR) for NOx abatement. The variation application proposes the use of an enhanced SNCR system. The application explains that the enhanced system will optimise the reaction between the ammonia dosing and NOx resulting in lower levels emitted from the plant in order to comply with the stricter limits.
The application includes a revised Air Dispersion Modelling Assessment which predicts the impact of stack emissions on local air quality. Our Air Quality Monitoring & Assessment Unit will be scrutinising this information as part of our technical determination of the application.
You may recall that we refused a permit application from the company in December 2016. That application included an incinerator design incorporating a 35-metre high stack (above surrounding ground level). The reason we refused the application was that we considered this design did not constitute ‘BestAvailable Techniques’ (BAT) as required by the relevant legislation to ensure that any impact on local air quality was minimised.
The permit we issued on 11 September 2017 requires a 58-metre high stack (above surrounding ground level).
When we issued the permit, we highlighted within our decision document that the facility would be unlikely to contribute to any breach of air quality standards and hence the risk to human health was considered insignificant. Even though the design was not considered BAT; we also reached the same conclusion for the company’s application for a 35 metre-high stack.
We will consider the company’s variation application against the new information supplied.
What happens now?
We will start the public consultation on the variation proposals and invite the public to make representations to us.
The statutory consultation period starts on 24 January 2019 and ends on 21 February 2019.
Please see the separate guidance we have provided concerning the scope of this consultation. Importantly, we can only consider those public representations that are within our legal remit for determining the variation application.
Should you have any comments or questions that relate specifically to planning issues for the IWMF, please contact Essex County Waste Planning Authority on 03330 139 808 or e-mail: mineralsandwasteDM@essex.gov.uk.
We understand the company has separately publicised a number of public exhibitions it is holding this month to explain the steps it is taking to align the current environmental permit and planning permission. Two of the exhibitions have already taken place, namely on the 14 January in Bradwell and 22 January at Silver End, with a third event as follows:
- Thursday 24 January 2019, between 4.00 pm and 9.00 pm at Coggeshall Village Hall.
Further details of the IWMF proposals, including permitting and planning information, are available on the developer’s website.
How do I make comments?
The public can provide consultation responses to us by any of the following:
Online at: https://consult.environment- agency.gov.uk/psc/co5-9df-gent-fairhead-co- limited/
By e-mail to: PSCpublicresponse@environment-agency.gov.uk
By post to: Environment Agency, Permitting & Support Centre, Land Team, Quadrant 2, 99 Parkway Avenue, Sheffield S9 4WF.
All the application details are available at the above website address. However, should you wish to view a hard copy of the permit application documents at our Feering office or wish to speak to one of our staff, please contact our Customers & Engagement Team in the first instance on 02030 255472 or by email: enquiries_eastanglia@environment- agency.gov.uk