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Representation by Residents Against INcinerators (RAIN) (Residents Against INcinerators (RAIN))

Date submitted
8 September 2022
Submitted by
Members of the public/businesses

RAIN (Residents Against INcinerators) is a group of residents from Burton upon Stather, Flixborough, Amcotts and Dragonby who object to the proposed development and give their following concerns: 1. None of the residents of Dragonby, were provided with the public consultation pack in September 2021. Only a few residents of BUS were, despite being affected by this proposed development. They were unaware of the chance to consult the applicant. 2. The proposed full-time jobs created on completion mentions that some positions will be filled by local residents, but they may not have the skills required, so this will not be beneficial to the local working population. 3. Climate Central’s coastal risk screening tool consisting of Sea Level Rise and Coastal Flood maps predicts that by 2030, the proposed site will be below the annual flood level and if the water level rises by 1.0m then the proposed site could be flooded. This goes against the National Planning Policy Framework no.159. 4. The North Lincolnshire Council (NLC) Core Strategy 2011 CS19 only allows development on a flood risk site if it demonstrates wider sustainability benefits to the community, whilst National Planning Policy Framework 159 and National Policy Statements (NPS) for Energy EN-1 5.5.1 mention inappropriate development on a flood risk area should be avoided. The NPS Renewable Energy (EN-3) states the application must set out the development’s resilience to climate change. 5. NLC Core Strategy 2011 CS2 states that where large freight movements are involved the use of rail and water transport should be maximised. Since the proposed development states the use of rail and water transport the building of a new road should not be required. 6. Evidence suggests a long-standing noise issue with operations at the wharf and industrial estate, adjacent to the proposed development site, already exceeds the permitted base line figures. 7. The height of the chimney stack will affect the residents of BUS due to much of the village being approximately 65m above sea level. There are concerns about the impact this will have on the health and wellbeing of the residents. 8. The catchment area for the waste is nationwide so will severely affect the green credentials of the park and is at odds with the European Environment Agency’s Proximity Principle. NLC has contracts with local waste disposal companies so the proposed development will not be taking local waste. 9. The applicants 5.2 RDF Supply Assessment states that 760,000 tonnes per year of household and commercial waste will be processed each year, but there is no evidence that this amount of waste will be available. The supply assessment links Yorkshire & the Humber with the East Midlands which is irrelevant when the waste is not coming from local areas. It is unclear as to why this site has been chosen since the proposed development appears to be on an inappropriate site due to the distance the waste will be transported and the risk of flooding due to climate change.