On 9 June 2021, No Incinerator 4 Horsham Community Group (Ni4H) sent a reply to the Environment Agency’s 28 May response to our Letter of Concerns, sent on behalf of local residents on 21 May. See previous posts for our letter and the response.
View the Ni4H reply here:
Many thanks to the experts and members of the public who contributed to this response, summarised as:
- Pleased to hear that this environmental permit variation application is being treated as a Site of High Public Interest.
- Seeking confirmation that the Environment Agency (EA) will be considering operator competence, as no evidence that the Directors have any expertise or training for making the transition from running a local skip and waste haulage business to: ‘Britaniacrest will ensure that under the operation and maintenance contract Britaniacrest retains control of the 3Rs Facility and it is operated to the exact instruction of Britaniacrest.’ (Source: Wealden Works 3Rs Permit Variation Application section 2.1.5.)
- A total of 39 missing documents, appendices, drawings and references so far identified, 32 of which are currently missing and so cannot be reviewed by consultees, stakeholders or the public.
- Britaniacrest Recycling Limited is a local family business; in good faith they paid huge sums of money to RPS, other consultants and the Environment Agency for their expertise in designing and applying for a permit to build and run this huge 230,000 tons per year incinerator in Horsham, yet many aspects are very worrying for local residents, and nothing is being done to address this.
- Some of the missing material has been expected up until now by the EA and published in proper time on Citizen Space, if such information is no longer required, it signals a genuinely concerning diminution in the scrutiny of the applicant’s application and suitability to operate a waste incinerator.
- Sensitivity analysis (for example, on meteorological data) reveals that the wind roses data is 10 years out of date and is not even local weather data, a point raised previously by Ni4H.
- The Local Area Potential Heat Users Report 2016 has not been updated.
- Risk assessments and other key documents are dated 2020, the March 2018 non-technical summary should have been updated.
- Consultation not widely advertised and no-one who lives near the site has received a letter from the EA.
- As public events cannot be held due to the pandemic, a consultation event could be livestreamed.
- Requested one printed set of all the documents be made available at Horsham Library, as the EA offices are not open to the public to view documents.
- Not allowing comments to be sent by post discriminates against those who posted handwritten comments at Planning and Inquiry stages and wish to send a handwritten response.
- Planning Consent Condition 10 Community Liaison Group (CLG) has been discharged by West Sussex County Council. The existing CLG are discussing this. Britaniacrest Recycling Ltd said they would keep the CLG updated regarding the EA permit variation application; they have not done so and have not published information about the Public Consultation on their website.
- The EA states that this permit variation application has been assessed as duly made, however with 32 of the documents missing and information so far identified still unavailable, it is not possible for consultees, stakeholders, the public, or the EA to properly review, report or comment on this application.
- Please pause and restart the 6-week consultation period from the date when access to all the documentation is clearly available to allow consultees, stakeholders and the public time to review these and submit comments.
- Ni4H are sorry to hear that the EA is suffering from staff shortages and Covid impacts, however, we still expect the EA to have an objective approach, demanding high standards from all applicants and their applications, and to offer the opportunities to objectors that are a legal requirement.
View the List of Missing Documents and Information:
EPR CB3308TD V002 HIGH PUBLIC INTEREST – Environmental Permit Consultation – Missing Documents revised 9.6.21Download
Copies were sent to our MP, Jeremy Quin, and we are very appreciative of ongoing support from Jeremy and his team.