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No Incinerator 4 Horsham Community Group represents local residents and we welcome your thoughts on this response from the Environment Agency, to the Letter of Concerns sent on 21 May 2021.

Letter of Concerns from Ni4H:

Please email your thoughts to:


From SSD Enquiries 28 May 2021

Thank you for your letter of 21 May 2021 about the environmental permit variation application to the Environment Agency, made by Britaniacrest Recycling Limited for their operation at Brookhurstwood near Horsham.

1.       Site of High Public Interest

This permit variation application is being treated as a Site of High Public Interest (SHPI).

2.       Documents

Before we accept (‘duly make’) an application, we ensure the essential documents have been enclosed and contain enough detail for us to begin its assessment (‘determination’). We may ask the applicant to provide additional information which would be posted online on ‘Citizen Space’.

Not all documents are not required for every type of permit application. For example, Climate Change Risk Assessments are not required for variation applications.

We have now uploaded the air quality modelling files and the H1 tool to Citizen Space. The Director’s details are required to be redacted and the redacted version has been uploaded to Citizen Space.

3.       Dated Documents

Application documents do not have to be dated from a specific period.

We do carry out sensitivity analysis (for example, on meteorological data) as part of determination and may request additional information. This could include confirming that older documents are still correct and valid.

4.       Advertising

This permit variation application has already been advertised in accordance with our guidance. Sign up to @EnvagencySE to receive a tweet reminder towards the end of the consultation period.

5.       Consultation Standard Document

Thank you for bringing this to our attention. We have updated the document on Citizen Space so that it now reads “We will look to make comments received publicly available at our Environment Agency public register”. A link to published responses will appear once a submission has been received where permission to share was granted.

6.       Public Events

We are not required to hold public events. We have to be careful with our limited resources. Any event would be limited to describing our role and the permitting process. This information is all available in our general GOV.UK pages or the Citizen Space consultation page. In any event, we would not comment on the adequacy of documents submitted or provide technical discussion.

7.       Viewing of Documents

We are following Government advice to manage the risks of Coronavirus to our organisation, to protect the health, safety and wellbeing of the public, our staff and sustain critical operations.

The documents are available on Citizen Space and, if required, access can be booked at local libraries where printing facilities are available at local libraries. We will update Citizen Space if a document is revised or added.

8.       Providing Comment

We are following our guidance and encouraging people to comment online through Citizen Space or to contact us using the email address provided. If any other problems are encountered please contact our Customer Contact Centre.

9.       Statutory Consultees

The organisations we are required to consult, by law, are Public Health England (PHE), Director of Public Health, Health and Safety Executive (HSE), local council (Horsham Borough Council) and the Food Standard Agency (FSA)

A briefing note was also prepared and emailed to a number of stakeholders in the area including the local MP, other local councils, ward councillors, environmental organisations and emergency services. This briefing note is available on the Citizen Space online consultation page.

10.   Community Liaison Group

Operators are sometimes required to set up Community liaison groups through planning permissions. We do not believe that a Group is required or has been set up.

11.   Duly Making

This permit variation application has been assessed as duly made.

12.   Consultation Extension

Consultations periods for permit variations are defined in law and usually run for 20 working days (4 weeks). We have extended the consultation on this variation to 6 weeks to allow people further time to submit comments.

Treating this permit variation application as a SHPI means that we will also consult on our draft permit (if we are minded to grant a variation), before making a final decision. This will allow people to check if the relevant information they have provided has been addressed and make further comment if they wish.

I trust this answers your questions.

Yours Faithfully

SSD Enquiries

Solent and South Downs Area
Environment Agency 

Guildbourne House, Chatsworth Road, Worthing, West Sussex, BN11 1LD


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