Representation by Environment Agency (Environment Agency)
- Date submitted
- 14 November 2022
- Submitted by
- Other statutory consultees
Please find enclosed the Relevant Representation on behalf of the Environment Agency in relation to the above application for a Development Consent Order (DCO). The Environment Agency’s Role We are a statutory consultee on all applications for development consent orders. We have a responsibility for protecting and improving the environment, as well as contributing to sustainable development. We have three main roles: We are an environmental regulator – we take a risk-based approach and target our effort to maintain and improve environmental standards and to minimise unnecessary burdens on business. We issue a range of permits and consents. We are an environmental operator – we are a national organisation that operates locally. We work with people and communities across England to protect and improve the environment in an integrated way. We provide a vital incident response capability. We are an environmental advisor ¬– we compile and assess the best available evidence and use this to report on the state of the environment. We use our own monitoring information and that of others to inform this activity. We provide technical information and advice to national and local governments to support their roles in policy and decision-making. One of our specific functions is as a Flood Risk Management Authority. We have a general supervisory duty relating to specific flood risk management matters in respect of flood risk arising from Main Rivers or the sea. Relevant Representation Overview We do not have outstanding concerns to highlight within this Relevant Representation. We have reviewed the submitted documents and have provided below a summary of matters where we consider that further clarification is required to ensure that the proposal has no detrimental impact on the environment. These matters include flood risk, water management and environmental permitting. We reserve our right to add to or amend the matters set out in this Relevant Representation and will update the Examining Authority on any amendments to our position at the appropriate point during the examination of the DCO.Please do not hesitate to contact me if you require any further information. Yours sincerely, Miss Eleanor Stewart Sustainable Places - Planning Specialist Flood Risk We have reviewed Environmental Statement Chapter 12 Hydrology, including Appendix 12A: Flood Risk Assessment and the Outline Flood Emergency Plan (OFEP). We are satisfied that the submitted flood risk information is sufficient to provide the Examining Authority with the correct flood risk information to inform their decision making. We note that potential flood depths of between 0.1 and 0.6m are expected on the access road. The applicant should ensure that the appropriate emergency planners are aware of this matter, and that it is incorporated into the OFEP. Outline Water Management Plan We have reviewed the Outline Water Management Plan and advise that the use of hay bales as a pollution prevention measure can increase ammonia levels in a watercourse as they decompose. We suggest that the hay bales are replaced regularly, or an alternative solution is found. Environmental Permitting The Environment Agency acts as the Competent Authority and regulates relevant activities under the Environmental Permitting (England and Wales) Regulations 2016. The applicant has submitted a permit application, and assessment is underway. The following issues are considered under the permit application. Air Quality The air quality impact of the emissions from the proposed facility will be assessed in detail as part of the environmental permit determination but only for the operational phase of the project and not the construction phase. Combined Heat and Power Assessment The outcome of the assessment is noted. The action plan should be followed through to assess the feasibility and maximise the utilisation of surplus heat to local business. An assessment of the energy efficiency of the plant will be carried out as part of the permit determination. Visual Impact During periods of unfavourable meteorological conditions there will be visible steam plumes from both stacks. Steam plumes will increase the visual impact of the plant and may pass over the top of local receptors depending on the wind direction. Noise We would highlight the noise impact from the two ID fan cabins. These are situated at the front end of the plant and there is open ground in front of these over which the noise emitted will travel. The design incorporates enclosures around the ID fans and these should be of a type that can attenuate the noise effectively and reduce tonal aspects. We would also highlight the noise impact from the air-cooled condensers on receptors in the vicinity of these.