Home > Uncategorized > Ni4H Response to Environmental Permit Variation Application

No Incinerator 4 Horsham Community Group is very thankful to the many technical advisers and specialist consultants from across the UK, members of the public, local businesses and organisations, who assisted us in being able to compile and submit a very detailed response, from No Incinerator 4 Horsham Community Group to the Environmental Permit Variation Application by Britaniacrest Recycling Limited, EPR/CB3308TD/V002.

No Incinerator 4 Horsham Community Group

No Incinerator 4 Horsham Community Group (Ni4H) is a voluntary group formed in 2016, by local residents to raise awareness and campaign against the proposal for a large-scale incinerator in Horsham, to import waste from a wide area across the Southern Counties. The Group’s current focus is on the EA Permit Variation Application by Britaniacrest Recycling Ltd.

Ni4H took over from a previous campaign group called HALT in Horsham, which successfully fought a proposal for an incinerator in the early 2000s. As a result of that refusal of planning permission, West Sussex County Council (WSCC) made a significant investment in alternative waste management solutions and built a Mechanical & Biological Treatment facility (MBT) at the Brookhurst Wood site, next to the existing landfill which was due to close. The new facility provided West Sussex with significant additional waste processing capacity of over 310,000 tonnes per annum.

Ni4H gratefully acknowledges and thanks all those who have contributed to the campaign against plans to build an incinerator in Horsham, from those who supported HALT to those who have supported Ni4H through the different phases of the campaign including:

  • 6,769 signatures on Ni4H petitions
  • Delivering and displaying leaflets and posters
  • Campaigning in the streets
  • The local venues who supported our fundraising events, the quiz masters, rock and barn dance bands
  • Raffle and tombola prizes donated by individuals and businesses
  • Attending and speaking at meetings, planning meetings and the inquiry
  • Press and associated articles
  • Information gathering by many members of the public, local organisations, technical advisers and specialist consultants from across the UK
  • Fellow Community Groups across the country facing similar proposals and those who live or used to live near incinerators
  • UK Without Incineration Network
  • Local Parish Councils and Parish Councillors
  • Horsham District Council and Councillors
  • West Sussex County Council and Councillors
  • CPRE Sussex
  • XR Horsham
  • South East Climate Alliance
  • Sussex Green Living
  • Horsham MP, Jeremy Quin

Ni4H Response is Guided by  

  1. What the Environment Agency can and cannot take account of: https://consult.environment-agency.gov.uk/psc/rh12-4qd-britaniacrest-recycling-limited/
  2. Matters that UK Without Incineration Network (UKWIN) advises those responding to Environmental Permit applications to focus on: https://ukwin.org.uk/act-locally/#permitapplications       

Ni4H Non-Technical Summary


In the light of the many and varied comments, questions, ambiguities et al, Ni4H contends that an extremely detailed Schedule 5 needs to be developed and sent by the Environment Agency to the Applicant.

For example, the Environment Agency Notice of request for more information to Eco-Power Environmental Limited, Doncaster runs to 89 points. (Dated 15/04/2019 Application number EPR/EB3207LH/V005).

Ni4H contends that the current Environmental Permit must not be varied to allow the Applicant to operate an incinerator at the Wealden Works site.

“As we have reviewed and critiqued the material in the Environmental Permit Variation Application, given the complexity of the information it contains, we have been troubled that at this late stage in the consultation process there are still many errors, omissions and many referencing mistakes within this Application’s documentation that can easily misinform those wishing to comment or at worst put people off from commenting at all. Also we have identified the many places where there is still a lack of complete documentation.

The existence of these most basic of omissions and inaccuracies proscribe reasonable analysis of the Permit Variation Document, and that has led to a feeling from within our community that the consultation procedure is flawed and therefore does not give us the confidence that it should and that the public would expect.

Given the high ethical commitments set by the EA Chair and Chief Executive in The Environment Agency Strategy ‘Creating a better place Our ambition to 2020’ we hope the EA will live up to their corporate pledge and: ‘will go the extra mile for the people and places we serve’ by ensuring that this consultation reflects the high standards of governance expected of such a senior agency of government and put right the current deficiencies identified before any final decisions are taken.”

Peter Catchpole, Chairman
No Incinerator 4 Horsham Community Group